APPENDIX A: Records and record keeping
This section reviews the value of documenting an employer's compliance with
the Laboratory Standard which is required by 29 CFR 1910.20. This information is general; it does not include the details necessary for compliance.
- The Laboratory Standard requires that records of air concentration
monitoring results, Exposure Assessments, Medical Consultations and
Examinations be maintained for at
least 30 years and that they be accessible to employees or their representatives.
- It is desirable to develop a system that retains documents related to distribution and maintenance of Material Safety Data Sheets, to the safety training of employees and to significant employee suggestions for many years, perhaps for the lifetime of the institution. For example, although not required by any regulation at this time, some employers use "MSDS Sign-off" records; for each hazardous chemical used or handled by employees, each employee certifies by dated signature that he or she has read that MSDS and understands the content.
- Specific records may be required in the event of lost work time resulting from an exposure or accident on the job. Use OSHA Form 200 to record lost workdays that occur. Contact your local OSHA office for details.
- In addition to required records, it is often desirable to keep records developed internally that document employee exposure complaints and suspected exposures regardless of the outcome of an Exposure Assessment. Other incidents also might be documented for future reference. Examples include:
- Major Safety Suggestions from Employees - To improve laboratory safety, keep these records. An unusable suggestion today might be useful tomorrow. Even when a suggestion is clearly non-workable, it should be taken seriously, examined, and a record kept.
- Near Miss Reports - Employees who participate in or witness events that could have but fortunately did not cause harm prepare reports of the incidents. These reports are used to develop changes in procedures that will prevent a future more serious occurrence. The CHSC will decide whether an incidentis a near miss for purposes of record keeping.
- Repair and Maintenance Records for Control Systems - These are useful; they suggest corrective actions and indicate that equipment was or was not well maintained and kept in working condition.
- Complaints from Employees - It is useful to keep a record of all complaints, investigations, and outcomes. Even when not justified, and especially when a complaint correctly or incorrectly involves defects in and difficulties with operating equipment, the record may prove to be invaluable if that equipment develops a defect or malfunction at a later date.
- The EPA and other Federal and State agencies have special record keeping
requirements. For example: Record keeping of allegations and the reporting of suspect hazards from the adverse effects of chemical exposure are required under Sections 8(c) and 8(e) of the Toxic Substances Control Act; see 40 CFR 716 and 717.