Surprise! Don’t get caught without the necessary records in the event of a surprise EPA or state agency inspection. Here are some tips for getting and keeping your records organized.
Employee training records should be filed by date and topic. In an effort to keep employee records organized, most supervisors put employee training records in the employee files. This is wrong because if an inspector requests to see all training records, he’s going to ask for records by date and topic. If you have to search through all employee files for this information, it could be quite time consuming.
Keep and maintain employee training records for 3 years.
Use a log to keep track of attendance. This would be helpful during an investigation of an incident involving an employee who may not be able to testify for his own training record. If you have a record of who attended the training session with that employee, you can find out from the other attendees what you need to know about the session. For example, if your company was being investigated for a fatality and you needed to know exactly what was covered in a particular training session, you could reference the attendance log and find another employee to fill you in on any undocumented details.
A note about hazard assessment documentation. Conducting hazard assessments for self-audits is a responsible practice that can benefit you in several ways during an OSHA inspection. However, be very clear about what you are recording. OSHA requires two things: a hazard assessment and the hazard assessment certification. But do not disclose anything that is not mandatory such as notes or opinions.
Get proof-politely, of course! If you are asked for a record to be produced, just politely ask the inspector to show you in the CFR where it states that it is mandatory. If the inspector cannot produce the proof that you need to show him the records, it is your right to respectfully decline disclosure.
Keep records of discipline. Keep any and all records of disciplinary action taken against workers who do not follow appropriate safety practices. This way OSHA will know that you enforce the rules at your facility.