Category: Uncategorized

Cal OSHA Covid Prevention Plan Now Available

In response to the recent emergency Cal OSHA standards published on November 30, 2020, I have prepared a draft Covid Prevention Plan which can be downloaded here:

I have written the program to reflect the operating procedures that I’ve observed during client visits.  These are the standard things that most Counties have already dictated.  Please review the entire document and make changes where appropriate to ensure that it accurately reflects what YOUR facility is currently doing, i.e., do not commit yourself to anything that you are not actually doing.


Jonas Aras
ManPower Compliance Services

Cal/OSHA’s New COVID-19 Regulations

California’s Occupational Safety and Health Standards Board unanimously approved emergency temporary standards for workplace coronavirus disease 2019 (COVID-19) exposures. The board now will submit the rule text to the state Office of Administrative Law. If approved by the Office of Administrative Law in the next 10 calendar days, the emergency standards will be in effect immediately and remain in effect for 180 days. The standards board may twice readopt temporary standards for 1 additional 90-day period each .

The California Division of Occupational Safety and Health (Cal/OSHA) will enforce the standards.

Employers must have a written COVID-19 prevention plan under the emergency rules to address issues, including:

Communicating information to employees about COVID-19 symptoms and illnesses, prevention, and testing and establishing a system for employees to report exposures without fear of retaliation;

Identifying and evaluating COVID-19 exposure hazards and identifying workplace conditions and practices that could result in potential exposure;

Procedures for screening employees for symptoms;

Procedures for responding to and investigating cases in the workplace, responding immediately to potential exposures by following steps to determine who may have been exposed, providing notice within 1 business day about potential exposures, and offering testing to workers who may have been exposed;

Correcting COVID-19 hazards, especially following a workplace outbreak, including correcting unsafe conditions and work practices, as well as providing effective training and instruction;

Physical distancing and implementing procedures to ensure workers stay at least 6 feet apart from other people if possible;

Providing face coverings and ensuring they are worn;

Adopting site-specific strategies such as changes to the workplace and work schedules and providing personal protective equipment to reduce exposure to the virus;

Maintaining records of positive COVID-19 cases and illnesses and making the COVID-19 prevention plan available to employees and their representatives;

Removing exposed workers and COVID-19-positive workers from the workplace, with measures to protect pay and benefits;

Establishing criteria for employees to return to work after recovering from COVID-19;

Establishing requirements for testing and notifying public health departments of workplace outbreaks—3 or more cases in a workplace in a 14-day period—and major outbreaks, which are 20 or more cases within a 30-day period; and

Establishing and maintaining infection prevention practices in employer-provided housing and transportation to and from work.

The text of the regulations can be found here:

More information to follow as it becomes available.


Jonas Aras


ManPower Compliance Services


Coronavirus Update – May 11, 2020

DISCLAIMER:  Information regarding COVID-19 is dynamic and constantly evolving.  The information provided here is a brief guidance for employers and employees to undertake in order to protect themselves in the workplace. There is no warranty implied or expressed regarding the completeness or accuracy of information presented here.  The information provided here is not complete and/or exhaustive.

The guidance from the California Department of Public Health (CDPH) and Cal OSHA published May 7, 2020 ( ) indicated that employers should have a worksite-specific COVID-19 Prevention Plan. The documents that have already been published and used by County of Los Angeles Public Health and Ventura County appear to specifically meet CDPH/Cal OSHA specifications. Thus far, Santa Barbara County and Riverside County do not appear to have similar documents. In the absence of specific guidance from other Counties, the Los Angeles County document appears to be a good model to use.



The CDPH/Cal OSHA guidance document also states that the Covid-19 Prevention Plan should include employee training. To that end, I have added an attendance roster to the OSHA “10 Steps” poster which can be used to satisfy the training element.


CDC general information:

Stop the spread of germs poster:

CDC Factsheet:

CDC Handwashing guidelines:

List of EPA Discenfectants-

CDC cleaning-disinfection guidelines

CDC Glove removal poster:

OSHA Laws for respirator Appendix D:

How to Properly Put on and Take Off Disposable Respirator Poster (CDC, Niosh):

Federal EPA e-Manifest

e-Manifest was launched nationwide on June 30, 2018.  As no hauler currently has an end-to-end electronic manifesting system that interfaces with the EPA, the current paper-based system will persist for the short-term.  However, TSDFs (treatment, storage and disposal facilities) must now submit manifests electronically to the EPA at a cost of $4 – $20 per manifest. This cost will be passed on to generators either by increased hauling fees or by itemizing the fee out separately.

Generators who wish to review the manifests that are uploaded by their TSDF can register for a free EPA e-Manifest account at, but there is no requirement to do so at this time.  The EPA’s goal is to completely eliminate the use of paper manifests within five years and it will undoubtedly take some time before this new process is smoothed-out.

Upcoming Changes to Proposition 65 Warning Signs

California’s Office of Environmental Health Hazard Assessment has adopted a change of the required verbiage for The Proposition 65 warning signs that will go into effect August 30, 2018. The California New Car Dealer Association has the new signs and stickers available to its members through Reynolds and Reynolds at 800-559-3676.

The new verbiage can be found here:

As Proposition 65 is a matter of ongoing case law, Manpower Compliance Services cannot offer legal advice. Any questions regarding this matter would be best handled by qualified legal counsel. However, MCS will make every effort to provide access to the best published information on this subject as it becomes available.

California Lead Acid Battery Fee Account Registration

Facilities can now register online for a California Lead Acid Battery Fee account with the California State Board of Equalization here:

Be sure to read the other sections of their website (Overview, Dealers/Retailers, Industry Topics, Resources) for additional information or contact your ManPower Compliance Services representative at 877-626-7697.

California Battery Fee

Beginning on April 1, 2017 a mandatory $1 California Battery Fee must be collected for lead acid battery purchases, similar to the current fee for tires. The text of the law can be read here:

The fee must be listed as a separate line item on the invoice as “California Battery Fee”. If a person purchases more than one lead-acid battery in a single transaction, and is therefore imposed more than one California lead-acid battery fee in that transaction, the dealer is not required to individually list on the invoice each California lead-acid battery fee imposed, but may instead condense the fees to a single-line item. Also, dealers are not to accept more than six batteries per customer per day.

Note that there is no charge for warranty batteries or replaced batteries under a service agreement. Facilities will have to register with the State BOE and remit fees to the state after completing appropriate forms (forms not yet available). The facility will be able to retain 1.5% of the fee as reimbursement for any costs associated with the collection of the fee and the dealer will remit the remainder to the State Board of Equalization (state board) for deposit into the Lead-Acid Battery Cleanup Fund. On and after April 1, 2022, the amount of the fee will increase to two dollars.

Dealers can continue to charge their normal core credit fee if the core is not provided at the time of battery purchase. Customer must bring the core to the dealer within 45 days of the new battery purchase to claim the deposit paid at the time of the battery purchase. The refundable deposit must be indicated on the invoice as a separate line item and not included with any other fees or charges. After 45 days, if no core is returned, the dealer can keep the core credit minus the sales tax remitted.

A written notice is to be included for batteries sold OR included on the invoice as follows:

“This dealer is required by law to charge a non-refundable deposit of a $1.00 California Battery Fee and a refundable deposit for each lead-acid battery purchased. A credit for the refundable deposit will be issued if a used lead-acid battery is returned at the time of purchase or returned within 45 days of the new battery purchase along with the receipt”. A PDF version of this sign is available here:

First Aid vs. Not First Aid

First Aid

Completing and Posting the OSHA Log 300

Everything is REPORTABLE, but NOT all incidents are recordable.

With limited expectations, every employer in the state (including state and local public agencies), must complete the Log and Summary of Occupational Injuries and Illnesses, also known as the OSHA Log 300 (Title 8, California Code of Regulations §14301. Below are guidelines for determining the recordability of an injury or illness on OSHA Log 300.

Recordable (i.e., NOT First Aid) vs. Non Recordable (i.e., “First Aid”)

If injury or illness involves:

If injury or illness involves:

  • Loss of consciousness (regardless of medical/first aid treatment).

  • Restriction of work or motion (regardless of medical/first aid treatment). (caveat – see below).

  • Transfer to another job (regardless of medical first aid treatment).

  • Antiseptics applied on second or subsequent visit to a doctor or nurse.

  • Burns of second or third degree.

  • Compresses, hot or cold, on second or subsequent visit to a doctor or nurse.

  • Cutting away dead skin (surgical debridement).

  • Diathermy treatment (during second or subsequent visit).

  • Foreign bodies, removal if embedded in eye.

  • Foreign bodies, if removal from wound requires a physician because of depth of embedment, size or shape of object(s) or location of wound.

  • Infection, treatment for.

  • Use of prescription medications, (except for a single dose administered on first visit).

  • Soaking, hot or cold, on second or subsequent visit.

  • Sutures (stitches). Dermabond.

  • Whirlpool treatment (during second or subsequent visit).

  • X-ray which is positive.

  • Admission to a hospital for treatment or prolonged observation.

  • Rigid splint.

  • Termination of employment (regardless of medical first aid treatment).

  • Observation of injury on second or subsequent visit to a doctor or nurse.

  • Antiseptics, application of, on first visit to a doctor or nurse.

  • Bandaging on any visit to a doctor or nurse.

  • Burns of first degree.

  • Compresses, hot or cold, on first visit to a doctor or nurse only.

  • Elastic bandage, use of, on first visit, to a doctor or nurse only.

  • Foreign bodies, not embedded, irrigation of eye for removal.

  • Foreign bodies, removal from wound by tweezers or other simple techniques.

  • Non-prescription medications or doses of prescription medication on first visit for diagnostic treatment.

  • Ointments applied to abrasions to prevent drying or cracking.

  • Tetanus shots, initial or boosters alone.

  • Hospitalization for observation only (no treatment other than first aid).

  • Soaking therapy on initial visit or removal of bandages by soaking.

  • Whirlpool therapy on first visit.

  • Heat therapy on first visit.

  • Steri-strips.

  • X-ray which is negative.

  • Non-rigid splint.

2017 Compliance Roundup

Most ManPower Compliance Services clients have been using the electronic OSHA 300 injury log form at The email following this one will contain an attachment that has all the recordable injuries that occurred in 2016. If the form is inaccurate you can respond via email or FAX (626-602-9209). Note that first aid claims are not included on the form. For additional guidance on first aid vs. not-first aid claims more information is available here:

Note that most dealerships are not required to submit these forms electronically. The exceptions are dealerships that have more than 249 employees or those who have been specifically identified as High Hazard Employers.

The new California law allows for communication if the cell phone is mounted or affixed to a window, console or dashboard in a way that the view of the road is not hindered; and the driver must be able to activate or deactivate the feature or function of device with a single swipe or tap of the finger.

The prohibition on smoking applies to all enclosed places of employment that are structural parts of the building(s) including covered parking lots, lobbies, lounges, waiting areas, elevators, stairwells and restrooms. E-Cigarettes are included in the new prohibition. MCS recommends that you review your current policies on smoking in the workplace and update as appropriate.
If you need a W-9 form for ManPower Compliance Services, please respond to this email and I will email you a completed form. MCS recommends that you update any company policies to reflect the new change.

Wishing all of you a healthy and safe 2017.

ManPower Compliance Services, LLC

556 S. Fair Oaks Ave.

Pasadena, CA 91105


Used Oil Filters Made Easy

There has been a lot of recent activity on the subject of managing used
oil filters and some conflicting notions on how to manage them properly.

Firstly, there has been NO CHANGE in the California Code of Regulations
regarding the disposal of filters.  The DTSC Regulatory Assistance Guide
Document on managing used oil filters is easy to comprehend and can be
found here:
  However, enforcement of the law HAS CHANGED.

Used automotive filters that do not have a metal housing MUST be managed
separately from filters that do have metal housings. This is because
filters with metal housings are managed under a scrap metal exemption in
the hazardous waste regulations, so non-metal filters are clearly a
separate waste stream.

Metal used oil filters “must be drained of all free-flowing oil or fuel
before they are placed in storage containers. The term “free-flowing”
means a continuous stream of used oil from the filter when it is turned
over. Used oil that flows drop-by-drop is not considered to be
free-flowing.”  Again, this is not anything new.  This has been the rule
since the early 1990s.

Depending upon which smelting facility your hauler uses, some haulers
are making their clients crush or puncture their metal filters or pay a
higher price to have them managed as “hazardous”.  This is not due to a
change in regulatory requirements.   Rather, it is because their
smelting facility is unable to process filters that have even small
amounts of residual oil within the housing.

Other haulers use smelting facilities that are able to process the
filters without the generator crushing or puncturing them.  The usual
draining is all that is required.

For those clients that generate a significant volume of non-metal
filters and incur higher disposal costs, MCS will be adjusting the
Hazardous Waste Recovery Fee to reflect the price increase.

Hopefully that clears up the confusion.  Please feel free to contact me
if you have any further questions.


Jonas Aras
ManPower Compliance Services