Maximum penalties for OSHA violations are set to increase for the first time since 1990 as part of overall federal penalty adjustments mandated by Congress last year. The increases cover penalty adjustments for several DOL agencies, including OSHA, MSHA and the Wage and Hour Division.
OSHA's new penalty levels will take effect after August 1st, when the maximum penalty for serious violations will rise from $7,000 to $12,471. The maximum penalty for willful or repeated violations will increase from $70,000 to $124,709. Any citations issued by OSHA after August 1st will be subject to the new penalties if the related violations occurred after November 2, 2015.
State programs such as MIOSHA will be required to adjust their penalty levels accordingly. You can read the full article and see more details on penalty categories here.
For example, a clear colorless jar or beaker should be used to collect storm water samples – every time. Something else to consider is making sure there is consistent lighting and a white backdrop is available when making your observations. When you keep your apparatus consistent from sample to sample and from sample event to sample event, then it will be easier to demonstrate that your samples have been evaluated in the same way every time.
Maintaining consistency in using your sample collection procedure is also very important. For example, if a specific sample location requires you to lower a glass jar using a strap or rope down to the water to collect a sample, then put a description of that activity, including the specific jar and specific strap used, in the procedure. Don’t let sampling staff figure it out for themselves. Each sampler should follow the same procedure using the same apparatus - every time.
Include safety considerations for the various sample points in your procedure as well. Some locations may be slippery when wet or have some traffic issues to contend with. Some locations may be hard to climb down to. Others may have thick vegetation that needs to be cleared during certain times of the year before a sample can be collected. Ask your maintenance or grounds keeping staff to help make each sample location accessible and safe. Consider installing wooden or cement platforms and railings to help your staff stay safe and make it easier to collect samples.
Annual Employee Training
We always want annual training to be interesting so that employees will get something out of it. With that in mind, training content will depend greatly on the knowledge level of your current staff involved in storm water compliance. You can make the annual storm water training more interesting and productive by discussing topics like:
Getting input on these topics from the SWPPP staff provides them an opportunity to become engaged in the program evaluation and improvement process, and we know that compliance programs have better longevity when workers are engaged in the program. Getting feedback from SWPPP staff also provides insights and opportunities for improvement that the Certified Operator can explore during the comprehensive site inspections.
If you have any questions, call us today!