One of the essential risk-management components that’s often missing from self-storage operations is a formal safety program. In many cases, staff lack safety training and equipment, or the facility fails to have the proper compliance documentation. This is dangerous because if an employee or tenant has an onsite accident, the owner and/or management company can be held liable for damages. They might also be subjected to a not-so-friendly visit from the Occupational Safety and Health Administration (OSHA).
OSHA will inspect your business if it hears about unsafe work conditions or there’s a serious injury or death at the property. Their representative will evaluate all safety-related training programs and memos, Material Safety Data Sheets (MSDS), and right-to-know documentation. They’ll also want to see any safety equipment and chemicals kept on site, including how they’re stored and labeled.
Depending on the severity of the incident that triggered the OSHA visit and the nature of any infractions uncovered during the inspection, fines may be levied—and they can be hefty. Factored into the equation will be whether a violation is the result of willfulness, ignorance of requirements, or a lack of training, safety equipment and proper documentation. Believe me, this is no laughing matter! Fines can range from thousands to hundreds of thousands of dollars.
The good news is, unless there’s been a death or serious injury, OSHA often allows a business to quickly correct any issues it uncovers and will subsequently lower the initial fine. Still, it’s better to avoid getting in trouble in the first place. Following are some ways to keep your self-storage site safe and stay out of hot water with the regulatory agency.
A First-Hand Example
Before we dig deeper into self-storage safety and OSHA compliance, let me share a personal experience from early in my career. I was working as a building supervisor when one of my maintenance workers was accidentally sprayed with a chemical solution by a pest-control vendor. The employee had a severe reaction and had to go to the hospital.
We received a visit from OSHA, which learned we didn’t have an MSDS on hand for the chemical used, even though we had formally requested one from the vendor. Once this slight glitch was discovered, they used a fine-tooth comb to find everything we were doing incorrectly. The resulting fine was massive, just short of six figures. Fortunately, we were given a timeline to get the safety violations fixed, which would reduce the fine to less than $10,000.
The good news is the injured employee was released from the hospital right away, with no lingering issues after treatment. Still, this incident was a wakeup call to everyone in the company. Once we fixed our errors, OSHA revisited the building at our request, and we passed with flying colors. In fact, the business had almost no claims going forward, and it implemented a safety program that earned it lower insurance premiums. The important thing to know here is that once you’re visited by OSHA, you’re on their radar, and you won’t receive the benefit of the doubt if there are any further incidents.
If you use an employee-leasing company to staff your self-storage operation, there’s a good chance it has a team who can consult with you on safety matters and help you take steps toward compliance. They may even offer webinars that document staff participation and completion, which can prevent your employees from claiming they received no training. This can be crucial to softening fines and penalties if OSHA ever knocks on your door.
Your business-insurance provider may also offer safety training for your team, as it has a vested interest in not paying out for incidents that could easily have been prevented. This training should occur at least quarterly or as required by your state or insurance company.
In addition, there are safety-supply companies in just about every city that can be of assistance. They can provide informational posters and other materials on how to read MSDS, handle chemicals, maintain safety equipment and more. They can even guide you through the requirements for assembling an employee right-to-know manual, which should describe how to handle and prepare chemicals on site.
Finally, there are third-party companies that specialize in business-safety issues. Your self-storage operation can hire one to conduct a thorough site evaluation.
Putting these types of safeguards in place not only helps prevent injuries, they show OSHA that you’re being proactive and diligent in trying to avert accidents. If you’re an independent self-storage owner, this is a must to help protect against disasters and avoid large fines that may not be covered under your insurance policy. If you contract with a third-party management company, it’s your duty as well as your provider’s to ensure safety precautions are in place, or you could both face penalties.
To ensure you have all your ducks in a row, I strongly recommend hiring a safety trainer or consultant. To find a qualified provider in your area, get recommendations from any of the resources mentioned above.
Items to Keep on Site
If your self-storage facility has proper safety procedures in place, congratulations! If not, your operation could be a ticking time bomb. At a minimum, your site should be equipped with the following:
- MSDS and knowledge for all chemicals stored at the property, including how they work and for what purpose they’re used
- Safety cabinets for chemicals and a breakdown of what can be stored together
- Instructions for labeling all chemical containers and how to note reactions
- Guidelines for handling unlabeled containers, including proper disposal
- First-aid kit
- Safety equipment, including directions for how and when to use it
- Operations safety manual
- Right-to-know document for employees
All employees should have their own eye and ear protection, chemical-resistant gloves, and respirators with cartridges that protect against chemical exposure. (Before buying respirators, make sure each employee can wear one without breathing distress.) When turnover occurs, buy fresh gear for new employees rather than recycle. Though these items are an expense, they’re far cheaper than the fines and penalties you’ll pay if your self-storage operation faces an accident or injury.
Have a dedicated eye-wash station in case of emergency. Put it outside or wherever employees are most likely to be exposed to chemicals. Supervisors should examine all safety equipment, including the eye-wash station, during each visit.
Finally, create a safety manual and issue a copy to every self-storage employee. In many cases, you can get one from your employment or management company if you work with one. Every team member needs to sign a document stating that they’ve read the manual, acknowledging that they’ve been informed of all safety requirements and guidelines of the business.
It’s imperative that every one of your self-storage employees receives training to address safety requirements, protocols and equipment. This includes how to handle chemicals.
When purchasing chemicals, always choose less hazardous options and buy them in small amounts. Make sure every substance you keep on site is clearly labeled. Never leave unlabeled liquids or solids laying around. Everyone should know what’s inside a container. If they don’t, they should dispose of it at an approved hazardous-waste drop-off facility. Never dump or pour unknown substances down the drain or in the toilet!
If a chemical is put into a container other than the one in which it came, it must be labeled. The rule of thumb is to put only enough of a chemical into the container for a single use. This avoids you having an unlabeled container on a shelf that could create an accident or be discovered during an OSHA inspection.
Also, never put a substance into a container that’s been previously used for a different chemical purpose. For example, don’t pour a pest-control liquid into a bottle that used to hold weed-killer. It could cause an unknown release of gas, or an explosion or burns. Though rare, these incidents can harm or kill people.
Any container that’s been used to hold a chemical should be cleaned thoroughly according to the MSDS. When in doubt about a container, dispose of it properly.
Finally, make sure everyone on your self-storage team knows first-aid procedures as well as how to find and read MSDS on chemicals and hazards. Though sweeping out an empty self-storage unit may seem elementary, staff should always be on the lookout for potential risk. A tenant might leave behind an unknown substance that could be dangerous. When encountering something like this, it’s wise for staff to wear gloves, eye protection and a respirator.
Always make safety the No. 1 priority in your self-storage operation. Not only will it protect your employees and tenants, it’ll keep the dreaded OSHA from knocking on your door. When you know you’ve done all you can to prevent accidents, you’ll sleep a little easier.
Andrew Kelly Jr. is principal of Sierra Self Storage Consulting LLC, which was founded in 2004 to help new and existing facility operators enhance their return on investment. The company offers brokerage and due-diligence services, consulting for new development, facility audits, owner and staff training, and property management. For more information, call 520.323.6169.