Reporting deadlines: Hennepin County businesses are up first
We’ve hit the end of Daylight Savings Time (for now) and the fourth quarter of the year, which means annual reporting is coming up. It is time to make sure your records are in order.
Check the information below. Some environmental reporting only happens every five years – and those are coming up now. Hazardous waste minimal quantity generators need to report this year. Stormwater no exposure exclusions need to be renewed.
Sometime shortly after November 1, Hennepin County should start sending out notices about hazardous waste management plans, which will be due by December 15. Note the following deadlines, through April 1, for OSHA recordkeeping, hazardous waste generators and air quality permit holders.
If our contract with you includes assistance with reporting, Solana has already reached out or will be contacting you soon to set up appointments.
For companies outside the Twin Cities metro area, hazardous waste reports are not due until Aug 1, but it is a good idea to gather your information early in the year. You can submit as early as April.
*If you have an air quality permit B, C or D, you may be eligible to void your permit. We can explain that to you; just give us a call.
If you voided your air permit, you must still maintain records of paint purchases, so continue to ask your jobber for an annual VOC report.
If you are subject to industrial stormwater (including filing the no-exposure exclusion): the MPCA is making changes to the general permit so no one can start renewing yet.
If you are a CHESS maintenance client, we will be contacting you to set up a time to help complete your recordkeeping. If you are not a maintenance client and would like assistance, please contact Solana at 651‑842‑9215 or sgarbow@chess-safety.com.
Stormwater No Exposure Exclusion
Businesses in certain industries are required to have industrial stormwater permits, unless they have no exposure (nothing is exposed to possible rainwater, snow or other ways to have water run off). To maintain a no exposure exclusion, there must not be any raw materials, waste, or products stored outdoors where it is exposed to the elements.
Dumpsters must be closed and not have open plugs
Materials such as metal that can corrode, used appliances, etc. cannot be stored outdoors
Loading and unloading of materials must be indoors or sheltered
No uncovered scrap metal outside
Leaks and spills must be controlled and cleaned up immediately
For more information, please see the MPCA industrial stormwater site.
OSHA Updates
OSHA 300 Log Updates
The OSHA 300A Summary allows you to report the average number of full-time employees. However, if you have 20 or more employees at any time during the year, the OSHA 300A must be submitted to federal OSHA’s Injury Tracking Application (ITA). If you have 100 or more employees, additional information on the injuries is required.
For municipalities: Election judges, part-time and seasonal employees must be included in your employee count.
Employment poster updates
A couple of employment posters have been updated and are available on the MN Department of Labor and Industry website here.
- Minimum wage rates: new rates go into effect Jan 1, 2025
- Employer sponsored meetings or communication was updated in October 2024
Employment posters must be available to all workers, even if you have remote and on-site workers. Hard copies should always be posted in a place where employees are likely to see them. For remote workers, you can provide them electronically as long as employees have easy access to them. If you have a shared drive that is accessible to all remote workers, you could have the posters there.
Minnesota OSHA penalties went up
MNOSHA published their new maximum ($161,323) and minimum ($16,131) penalties as of October 1. There are still credits available for small businesses, good faith effort and no prior history of a specific citation. We have definitely seen OSHA being more active and penalty amounts being higher. We have also seen companies receive no citations or penalties totaling less than $1000.
If you need to have an AWAIR program, you need a safety committee – even if you have only a handful of employees. If you don’t have a safety committee and have an OSHA inspection, you will not get the full good faith effort credit. The rules don’t tell you how often the committee has to meet. It must be no more than 50% management, needs to do or delegate workplace inspections, ask for input from employees, review injury incidents, and review and recommend safety programs and records.
A reminder if you do have an OSHA inspection: OSHA has the right to inspect. You can deny entry – but they’ll come back with a warrant. Life’s easier if you let them in.
Are you too small to have an inspection? Some companies with ten or fewer employees will not be visited by OSHA safety inspectors, but could have health inspections, complaint inspections, or inspections after serious injuries. Whether you’re exempt from routine safety inspection depends on your industry. Check with us if you want to know more (but keep in mind: even if you’re small, you need to protect your employees. Following OSHA standards gives you a good start on doing so).
That’s a powered industrial truck??
The ANSI standard (B56.1-1969, reference in the OSHA standard) defines a “powered industrial truck” as a “mobile, power-driven vehicle used to carry, push, pull, lift, stack, or tier material.”
According to a September 2023 letter of interpretation OSHA considers golf cart and light utility vehicles (like the Toro Workman) as falling under the Powered Industrial Truck standard. Employees must have classroom training, hands on training and a driving evaluation. The standard also covers modifications to equipment (don’t make any unless you have the manufacturer’s approval), battery charging or fueling precautions, operations, and maintenance.
Want to know more about confined spaces?
Janet recently presented a webinar on confined spaces, sponsored by Industrial Safety & Hygiene News. It’s now available on-demand. You need to register, but there’s no cost for it.
This and That
Holiday gift idea
Back in April 2024 there was a news article and video about bystanders trying to help a motorist out of a burning car on I-94 in St Paul. Because of the guardrail, they could not get the car doors open. A MNDOT Highway Helper was able to break the door window using a tool called resqMe®. This tool has a seatbelt cutter and window breaker on it. I saw this and spoke to resqme® folks at a safety conference. I now carry the tool in my car. It makes a great, inexpensive gift and I hope you never have to use it.
First Aid-CPR-AED Training
If you need first aid, CPR and/or AED training, Mary Dipping is a certified instructor through the Red Cross.