Contractors doing business in Minneapolis should be aware that the City will be conducting on-site “reviews” of the general contractor for City projects. Don’t get fooled that this is a friendly visit just because you are called in advance to schedule a time to meet. This “review” is an audit or investigation or whatever you want to call it. It is the City’s way to determine whether you are in compliance with your contract. A violation is a violation. Be sure you have the proper postings, records, and are paying the appropriate prevailing wages. Keep in mind that just because the City’s contractor compliance officers are knocking politely, doesn’t mean they don’t communicate with MnOSHA and other agencies. Be sure your job site is in compliance with not only City regulations and ordinances, but state and federal as well. Here is the notice that I received from the City on June 21, 2016:
“Contract Compliance Officers (CCOs) will be conducting onsite reviews on construction projects. Developers and Contractors can expect that a CCO will schedule the onsite with the general contractor in advance. During the review, the CCO will tour the job trailer and job site looking for relevant postings (i.e. wage decision and City’s Non-Discrimination Notice). Then the CCO will interview employees and subcontractors. Specifically, the CCO will be reviewing whether:
- Women and minority businesses are providing a commercially useful function.
- Female and minority workers are being utilized and are not experiencing any discriminatory treatment.
- Employees are being paid prevailing wage
- Apprentices working on site are utilized within ratio and paid according to their pay scale.
The review will vary in length depending on the size of the project and number of employees interviewed. Afterward, the CCO will produce and share an onsite report with the project contacts. Then the CCO will work with the general contractor and/or developer to remedy any noncompliance issues. Any questions regarding upcoming onsites can be directed to the CCO assigned to the project or via email at email@example.com.”
Note, even the City has acknowledged that you may be found in noncompliance as a result of the “review” – and if that is the case, you will need to “remedy” the “issue”. This is simply a workplace investigation without a complaint, in order to determine whether you are in compliance with the terms of the contract with the City. Contractors are highly encouraged to review your practices now and get into compliance if you are not already!