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Environmental Health and Safety Checklist for Minnesota Printers
The following list of compliance areas includes federal, state, county and
sometimes local requirements. This list is provided as a tool to assist Minnesota
companies identify environmental, health and safety requirements. It does not
provide detailed information on specific requirements.
Environmental Requirements
Hazardous Waste
Solid Waste
Wastewater
Stormwater
Air Emissions
Storage of Hazardous Material or Fuel in Tanks
Storage of Hazardous Material/Waste in Drums
Hazardous Material/Waste Transportation
Community Right-to-Know Requirements
Other Environmental Requirements
Health and Safety Requirements
AWAIR
Right-to-Know
General OSHA Requirements
Other OSHA Requirements
Environmental Requirements
For the first six sections, contact the Minnesota Pollution Control Agency
(MPCA) at 651/296-6300 or 800/657-3864 or the MPCA's Customer Assistance Center
at 651/297-2274. For further details, visit the MPCA Web site.
For hazardous waste in the Twin Cites, contact your county's environmental
health department.
For wastewater discharges in the metro area, contact Metropolitan Council
Environmental Services (MCES) at 651/602-4703.
1. Hazardous Waste
- Has an evaluation been completed to determine if your company generates
hazardous waste?
- If your company generates hazardous waste, have you notified the Minnesota
Pollution Control Agency (MPCA) or your metro area county?
- If your company generates hazardous waste, are the following items addressed?
- Proper storage and labeling of containers and container inspections if required.
- Reporting annually to state or county regulatory agencies.
- Correct procedures for tracking and reporting each hazardous waste stream.
- Proper recycling and disposal for each hazardous waste stream.
- Training, as required by size of generator and employee job description.
- Contingency plans, if required as a large quantity generator.
- Emergency planning requirements.
- Emergency equipment for spills, leaks or fire.
- Maintenance of required records.
- Determination of correct U.S. Department of Transportation (DOT) shipping
name and hazard class before shipment.
2. Solid Waste
- Some waste that is not hazardous by evaluation, such as ink, may not be
acceptable to the facility receiving your trash. Have you notified your solid
waste hauler about such waste? It may need to be managed separately as industrial
waste.
3. Wastewater
- Have you identified all wastewater discharges (routine and infrequent) and
where they go? Do not forget cooling water.
- Have you determined whether these industrial wastewater discharges require
reporting or permitting? Contact your city's treatment plant, the (MCES) or
the MPCA.
- Does any of the wastewater from your printing or photoprocessing go to a
septic tank? This waste should be routed to a holding tank instead to prevent
it from going into the groundwater. Have you filed information with the MPCA
and the U.S. Environmental Protection Agency (EPA) on this wastewater? If
not, call 612/282-6246 and request a Class V inventory form.
- Does any part of your wastewater go to surface water such as lakes and streams?
If so, do you have a permit for this?
4. Storm Water
- Have you determined if your company needs a storm water permit? If you have
hazardous materials or waste stored outside and unprotected from snow or rain
water, you may need to apply for a general storm water permit. You may also
need a permit if you don't have a procedure for containing accidental spills
from loading dock accidents or yard activities like maintenance. For more
details, visit The MPCA Stormwater Program Web site.
5. Air Emissions
- Has your company determined whether your air emissions require a state permit?
If your only source of air emissions is from volatile organic compounds (VOCs)
and your company uses less than 200 gallons of VOCs a year, you do not need
an air quality permit. Records to document that you use less than 200 gallon
of VOCs yearly are required. For more information, visit MPCA's Facts about Air Quality Rules Affecting Print Shops.
- Are procedures in place to assure that monitoring and reporting complies
with existing state air quality permits?
If your business has less than 100 employees, call the MPCA's Small Business
Assistance Program (SBAP) at 651/282-6143 or 800/657-3938 for assistance with
your air emission questions.
6. Storage of Hazardous Materials or Fuel in Tanks
- Do you store more than 110 gallons of hazardous substance, motor fuel, or
other material that has the potential to cause pollution in an aboveground
tank? If so, is the tank registered with the MPCA? Are secondary containment
specifications in place (if required)? For complete information on requirements
for aboveground tanks in Minnesota, go to the MPCA's Aboveground Storage Tank Systems.
- Do you store heating oil in an aboveground or underground
tank with more than 1,100 gallon capacity? If so, is the tank registered with
the MPCA?
- Do you store fuel or a hazardous substance in an underground tank
with a capacity over 110 gallons? If so, is the tank registered with the MPCA?
For complete information on requirements for underground tanks in Minnesota,
go to the MPCA's Underground Storage Tank (UST) Systems.
NOTE: Installation, repair and removal of registered underground tanks
must be done by a certified tank installer.
- Do your fuel and hazardous substance storage tanks comply with your local
fire marshal requirements?
In any of the previous sections, see Environmental Guide for
Small Businesses in Minnesota.
7. Storage of Hazardous Materials or Wastes in
Drums
- Has your company worked with your fire department to assure that storage
requirements are met?
- Has your company stored its hazardous waste in drums that meet USDOT packaging
standards for hazard class or division for a specific waste?
- Has your company provided information to local authorities on the location
and quantities of hazardous materials on-site in case of a fire or explosion?
- Are the necessary precautions in place if incompatible materials are stored
together?
- Are all hazardous materials or waste properly labeled?
8. Hazardous Materials or Hazardous Waste Transportation
- Does your company ship hazardous materials or waste? If so, have you covered
training requirements for employees who package or prepare hazardous waste
or materials for transport?
- Does the training include information about labeling, marking for transport
and correctly filling-out shipping papers?
- Do supervisors of these employees receive the required training?
- Does your company have a file for each employee involved; certifying that
the training has been completed?
- Is the transporter registered as a hazardous waste (HW) or hazardous material
(HM) transporter with MnDOT and or the USDOT?
- Is your company required to be registered and pay fees as a HM Shipper with
USDOT and MnDOT? This is required:
1. If your company has waste, ink or solvent for example, which is pumped
into a bulk transport vehicle equal or greater than 3,500 gallons for shipment.
2. If you ship at one time in a transport vehicle required to be placarded,
generally more than 1,000 pounds of HM (i.e., flammable solvent waste) in
drums or containers in non-bulk packaging with a capacity of 119 gallons or
less.
For more details contact MnDOT at 651/405-6060 or see the Minnesota Department of Public Safety Web site.
9. Emergency Planning and Community Right-to-Know Act
- Does your company store more than threshold quantities of any of the 360
chemicals listed as extremely hazardous under Section 302 of the Act? Printers
engaged in the most common printing activities do not have chemicals on this
list.
- Does your company store more than 10,000 pounds (approximately 20 drums)
of a material or product required by the Occupational Safety and Health Administration
(OSHA) to have a Material Safety Data Sheet (MSDS). If so, reporting to the
Minnesota Emergency Planning and Community Right-to-Know Act (EPCRA) Program
and your local fire department is required under Section 311 and 312 of the
Act?
- Does your company have toxic release inventory (TRI) reporting requirements?
Reporting is required if your company has more than 10 full-time employees
and uses more than 10,000 pounds of any toxic chemical listed in Section 313
of the Act. Examples of toxic chemicals that some printers must report include:
trimethyl benzene, methanol, dichloromethane, nitric acid, xylene, glycol
ethers, barium or copper compounds.
For more details contact the EPCRA Program at 651/201-7417 or see the EPCRA Program Web site.
Other Environmental Requirements that May Apply
Minnesota Toxic Pollution Prevention Act
- If your company has TRI reporting requirements (see above), have you developed
a pollution prevention (P2) plan? Does your company submit annual progress
reports to the EPCRA Program?
For more details, contact the EPCRA Program at 651/201-7417.
Toxics in Packaging (CONEG Legislation)
- Does your company print packaging materials? If so, have you assured that
the metals (lead, cadmium, mercury or hexavalent chromium) are not part of
the formulations used for producing the packaging materials? This requirement
is in Minnesota Statute 115A.965.
For more details, contact John Ikeda at MPCA, 651/296-7294.
Listed Metals in Specified Products
- Has your company checked the composition of your inks for the metals (lead,
cadmium, mercury, or hexavalent chromium) listed in Minnesota statute 115A.9651.
The statute prohibits: a.) Any parts per million (ppm) intentionally introduced,
or b.) An incidental presence at greater than 100 ppm.
For more details, contact John Hensel at MPCA, 651/296-7213.
Spill Reporting
- Does your company know that spills and releases in Minnesota usually require
reporting to the State Duty Officer? Have you established additional spill
reporting requirements that may be necessary for your company? The phone number
for the Minnesota Duty Officer is 651/649-5451 or 800/422-0798.
For more details, contact the EPCRA Program, 651/201-7417.
Health and Safety Requirements
Contact the Minnesota Department of Occupational Safety and Health, Labor
and Industry Division (MNOSHA) at 651/296-2116 or 877/470-6742, or MNOSHA Workplace
Safety Consultation at 651/297-2393, Minnesota Department of Labor & Industry.
A Workplace Accident and Injury Reduction program (AWAIR)
Does your company include the following in your written program?
- Names of people responsible for implementing, maintaining, and enforcing the
program.
- Methods used to identify, analyze and control hazards.
- A list of safety rules that all employees must follow.
- An enforcement system for safe work practices and rules.
- Methods of communicating hazard information to employees.
- Procedures for investigation and corrective action following a workplace accident.
SIC Code 2759 (commercial printing) is currently required to have an AWAIR
program in place. The list of SIC codes is updated every two years (next in
2002) and will likely reflect changes in SIC codes for which AWAIR programs
are required.
Right-to-Know (Hazard Communication Standard)
Does your Right-to-Know written program include the following:
- Inventory of all the hazardous substances in the workplace and MSDS for
each?
- An inventory of physical agents such as noise and non-ionizing radiation
to which employees may be exposed (such as the light used for curing ultraviolet
ink or coatings)?
- An awareness level training of possible infectious agents if first aid
is being performed?
- Annual training of employees exposed routinely to hazardous substances
or harmful physical agents and maintenance of training records?
- A system of maintaining written information such as MSDS and a written Right-to-Know
program with access for all employees?
- Procedures for maintaining a labeling system?
- Additional training required if your inks contain lead or cadmium-based
pigments?
General OSHA Requirements
Does your company have in place a program to meet standards for:
- Lockout/tagout including a written program for the control of hazardous
energy whenever machines and equipment undergo service or maintenance?
- Employee training, annual inspection of lockout use, and maintaining training
records?
- Electrical wiring safety and required grounding?
- Machine guarding which includes equipment guards for moving portions of
machines or emergency shut-off mechanisms?
- Housekeeping and emergency exits?
- Confined space entry (if tanks or enclosed areas are entered)?
- Dispensing and storage of flammable and combustible liquids and gases?
- A personal protection program which evaluates the hazards of all activities
and provides necessary protection equipment (such as gloves, goggles and eye
wash stations)?
- A hearing conservation program?
- Addressing ergonomic symptoms of employees?
- General safety, housekeeping
and ventilation?
- Fire safety including appropriate equipment and communication
tools?
- An emergency response plan including exit routes, accounting for all employees
and who is in charge in the event of an emergency?
- The OSHA log of accidents and injuries, with the previous year's summary
posted every February?
Other OSHA Requirements
- Do you operate propane or gasoline-powered forklifts indoors? If so, is
the required carbon monoxide monitoring done? Are the forklift operators receiving
proper training? Are other safety requirements associated with their use in
place?
- Do you use respirators? If so, you must have a partial or complete respiratory
protection program in place?
- Do you use cranes or hoists? If so, are requirements for training and inspection
in place?
More Information
MnTAP has a variety of technical assistance services available to help Minnesota
companies reduce and manage their industrial waste. If you would like assistance,
call 612.624.1300 or 800.247.0015 from greater Minnesota.
This checklist has been updated by MnTAP. MPCA, Minnesota OSHA and other state
agencies provided review. Update - January 2001
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