Thank you!
We offer a sincere thank you to all of our clients. We are very fortunate to work with great employees and employers. May 2026 be a year of health and prosperity for all.
January Reporting Month
We will be busy in January with annual reporting – OSHA 300 logs are due for nearly everyone and hazardous waste reporting is due for companies in Ramsey, Dakota, Scott, Carver, Anoka and Washington counties.
The OSHA 300 log of injuries and illnesses in the workplace is required for all Minnesota companies that have had more than ten employees at any time during the year. Companies with more than 20 employees must submit their report to federal OSHA.
- Seasonal and part-time employees must be counted. For cities, that means including election judges and paid on-call firefighters.
- Even if you had no recordable injuries, you still have to keep the log. We recommend you note “no injuries” on the OSHA 300 and still complete and post the OSHA 300A Summary.
- If you have over 100 employees and had recordable injuries, additional reporting is required. For more information, see MNOSHA Compliance or contact us.
- Your OSHA 300A summary needs to be certified (signed) by a “company executive.” That can be an owner, an officer of the corporation, or the highest ranking official working at the establishment. For cities, it should usually be the city manager or city administrator. The reason: OSHA wants to put responsibility for an accurate log on the top people.
Some deadline reminders:
| When | What | Who’s Affected |
| Jan. 31 | Hazardous waste management annual report and license renewal for all metro counties, except Hennepin County (they were due in December) | LQG, SQG, VSQG hazardous waste generators |
| Jan. 31 | Industrial wastewater discharge reports due | Those holding MCES wastewater permits |
| Jan. 31 | OSHA 300A log summary should be completed and signed. | Employers with 10 or more employees at any time during the year |
| Feb. 1 | Post your OSHA 300A log summary until April 30. | |
| Mar. 1 | Tier II reports due` | Companies that have more than threshold amounts of specific chemicals |
| Mar. 2 | OSHA 300A must be submitted electronically to osha.gov | In MN, any company with 20 or more employees at any time during the year. If you have more than 100 employees, additional information about injuries will need to be submitted. |
| Apr. 1 | Air permit (VOC) reports due | Air Quality Permit C and Permit D holders. |
Environmental Updates
Hazardous waste updates
Have you switched to LED lights yet? As of January 1, 2026, most mercury-containing (fluorescent) bulbs will no longer be sold in Minnesota. Sodium and metal halide lamps and some specialty lamps will still be allowed. While LEDs should last a lot longer than fluorescent or incandescent lamps, we have seen companies starting to accumulate used LED bulbs. Because LEDs have circuit boards, they must be managed as electronic waste. Similar to fluorescent bulbs, they cannot go in ordinary trash. They have to be disposed of with a company that will recycle them.
Managing electronic waste
A few notes about e-waste: Electronic waste includes computers, monitors, LEDs, keyboards, cell phones, cameras, USB plugs, and anything else that has a circuit board. Because these contain metals such as lead, e-waste cannot go into the trash. E-waste does not count towards your hazardous waste generator size, but you are supposed to ship the majority of your e-waste for recycling every year. Keep a record of how much you recycle.
If you want more information, see the MPCA fact sheet on Managing Electronic Wastes.
Industrial stormwater updates
There aren’t any. As of the date we drafted this newsletter (Dec 29), the “e-Services application service for the 2025 permit is not yet available.” If you have the no-exposure exclusion, your exclusion is extended until the new permit accepts applications. You’ll have to reapply at that time. The MPCA is hoping to open this in Q1 or Q2 2026.
OSHA Updates
A few quick updates from the December OSHA Advisory Council:
- Federal OSHA is adopting new penalty credits. Minnesota OSHA is not adopting this; they are staying with their current system, which offers up to a 90% credit based on company size, inspection history and good faith effort. Minnesota OSHA’s penalties overall are about half the national average.
- MNOSHA continues to work with the MN Department of Health on a lead standard. The proposed draft standard is available online here.
- MNOSHA has released their most frequently cited standards for 2025 (Oct 2024-Sept 2025). For general industry, hazard communication and employee right-to-know top the list (as usual), followed by lockout/tagout, safety committees and carbon monoxide monitoring. Fall protection, scaffolding and haz comm top the list for construction industry.
OSHA doesn’t certify
If someone claims OSHA certification, they are not being accurate. OSHA does not certify. For example, Carol is an OSHA-authorized instructor for the 10- and 30- hour OSHA classes for general industry. Although she is a Certified Safety Professional (CSP) and OSHA-authorized instructor, she is not certified by OSHA. There is no such thing as OSHA certified personnel or equipment.
Carol’s Certified Safety Professional designation comes from the Board of Certified Safety Professionals. Their procedure for certifying has itself been certified by an independent auditor as meeting an international (ISO) consensus standard. OSHA doesn’t do the certifying.
OSHA requires a lot of equipment to be listed or approved by a Nationally Recognized Testing Laboratory (such as UL, Underwriters Laboratory). Some standards incorporate consensus standards such as ANSI or NFPA standards, and OSHA often favors compliance with those consensus standards (but once a consensus standard is written into OSHA rules, that version becomes enforceable law, even when the consensus standard is updated). Respirators have to be certified by NIOSH, a federal agency. But none of that makes equipment or certification programs “OSHA-certified.”
This article from the American Society of Safety Professionals goes into more depth explaining the differences.
Updated minimum wage, Paid Leave posters available (from MNDLI)
Minnesota requires some specific employment posters, all of which are free to download here. Two posters were recently updated or recently became available: the minimum-wage poster; and the Paid Leave poster. Posters are available in multiple languages.
Where to find us
Carol and Solana will be at the American Society of Safety Professionals Northwest Chapter Professional Development Conference (ASSP Northwest PDC) on Feb 17. Carol and Solana have been helping with the planning. Carol is currently the President of the Northwest Chapter. You do not have to be a member to attend, exhibit or sponsor the PDC. For more information, click this link