Enforcement and Inspection

Some Dos and Don’ts of EHS Recordkeeping

Dos

DO talk to your legal counsel before destroying any records. Although federal and state law may require record retention for only a specific period (usually 3 to 5 years), DO talk to your legal counsel before destroying any records. For example, environmental experts advise that biennial reports be kept indefinitely as these reports provide vital information about a facility’s operational and environmental compliance.

If you document a hazard in a hazard assessment DO correct the hazard. If you have no plans of correcting hazards that you find, don’t do them at all–it will hurt you in the end to have a known hazard that is uncorrected. OSHA considers this a willful violation.

Don’ts

If an inspector asks to see documentation of training, DON‘T give them full access to employee files to find the training records on their own. This opens you up to invasion of privacy issues. Keep training records in a separate place other than employee personnel files and show the inspector only those files. Employee training records should be maintained and are subject to inspection for up to 3 years.

When keeping your records, DON‘T disclose things in them that are not mandatory like notes and opinions. Only give them what what’s required.

DON’T be an overachiever. When it comes to records, if it is not required by law, don’t show your inspector. You never know what kind of can of worms you may open up-even with the best intentions.