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One of the first things inspectors will ask for is records of compliance. Good recordkeeping indicates to them good housekeeping practices. Conversely, poor recordkeeping tells the inspectors that you are not quite keeping up to speed, and that will likely cause them to dig deeper for other possible problems. The Advisor will provide you with records “checkups” on a regular basis. Today we will help you determine if you have all the necessary records for OSHA’s general industry requirements for certain toxic and hazardous substances.
HazCom Plus Some
In addition to the requirement under the Hazard Communication (HazCom) Standard to keep safety data sheets (SDSs) for chemicals as long as the chemical is used at your facility, OSHA also has recordkeeping requirements for specific chemicals and hazardous substances.
Records Checkup
If your workers manage or otherwise handle any of the following toxic or hazardous substances, make sure you are keeping the required records for the required amount of time.
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Chemical or Substance |
Required Records |
Record Retention Period |
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Acrylonitrile |
Objective data supporting exempted operations |
Duration of employer’s reliance on the data |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Exposure monitoring and medical surveillance |
Duration of employment plus 20 years or for 40 years, whichever is longer |
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Anhydrous Ammonia |
Document related to the testing of equipment by a professional engineer or someone who has specialized training or experience |
No specified retention period |
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Asbestos |
Building and facility owners must maintain records of all information concerning the presence, location, and quantity of asbestos-containing material. |
Duration of ownership and transfer to subsequent owners |
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Records of all measurements taken to monitor employee exposure |
30 years |
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Objective data supporting exempted operations |
For the duration of the employer’s reliance on the data |
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Medical surveillance |
30 years |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Training records |
1 year beyond the last date of employment of that employee |
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1,3-Butadiene |
Objective data supporting exempted operations |
Duration of employer’s reliance on the data |
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Exposure measurements |
30 years |
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Respirator fit test |
Until the next fit test |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Medical screening and surveillance |
Duration of employment plus 30 years |
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Benzene |
Exposure measurements |
30 years |
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Medical surveillance |
Duration of employment plus 30 years |
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Written compliance program |
No specified retention period |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Bloodborne pathogens |
Exposure control plan |
Update annually |
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Medical record for each employee with exposure |
Duration of employment plus 30 years |
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Training records |
3 years |
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Sharps injury log |
5 years following end of calendar year covered |
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Cadmium |
Exposure measurements |
30 years |
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Medical surveillance |
Duration of employment plus 30 years |
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Written compliance program, updated annually |
No specified retention period |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Carcinogens (13)—4-Nitrobiphenyl; alpha-Naphthylamino; Methyl chloromethyl ether; 3,’-Dichlorobenzidine; bis-Chloromethyl ether; beta-Naphthylamino; Benzidine; 4-Aminodiphenyl; Ethyleneimine; beta-Propiolactone; 2-Acetylaminofluorene; 4-Dimethylaminoasobenzene; N-Nitrosodimethylamine |
Medical examinations |
Duration of employment |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Chromium (VI) |
Air monitoring data, historical monitoring data, exposure records, objective data, and medical surveillance |
30 years |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Chemical or Substance |
Required Records |
Record Retention Period |
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Coke oven emissions |
Exposure measurements and medical surveillance |
Duration of employment plus 20 years, or for 40 years, whichever is longer |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Cotton dust |
Exposure measurements |
20 years |
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Medical surveillance |
20 years |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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1,2-dibromo-3-chloropropane |
Exposure monitoring |
40 years or duration of employment plus 20 years, whichever is longer |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Ethylene oxide |
Negative initial determination of exposure |
Duration of employer’s reliance on the data |
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Exposure measurements |
30 years |
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Medical surveillance |
Duration of employment plus 30 years |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Formaldehyde |
Exposure measurements and exposure determinations |
30 years |
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Medical surveillance |
30 years |
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Respirator fit testing |
Until replaced by a more recent record |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Inorganic arsenic |
Exposure monitoring and medical surveillance |
Duration of employment plus 20 years, or for 40 years, whichever is longer |
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Written compliance program, updated annually |
No specified retention period |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Ionizing radiation |
Records of the radiation exposure of all employees for whom personnel monitoring is required |
No specified retention period |
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Records of exposure to employees in restricted areas |
No specified retention period |
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Lead |
Records of all measurements taken to monitor employee exposure |
40 years or for the duration of employment plus 20 years, whichever is longer |
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Medical surveillance |
40 years or for the duration of employment plus 20 years, whichever is longer |
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Records of employees removed from current exposure to lead |
Duration of employment |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Methylenedianiline |
Monitoring and objective data for exempt employers |
Duration of employer’s reliance on the data |
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Exposure measurements and medical surveillance |
30 years |
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Medical removal |
Duration of employment plus 30 years |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Methylene chloride |
Objective data supporting exempted operations |
Duration of employer’s reliance on the data |
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Exposure measurements |
30 years |
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Medical surveillance |
Duration of employment plus 30 years |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |
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Vinyl chloride |
Monitoring and measuring |
30 years |
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Medical surveillance |
Duration of employment plus 20 years, or for 30 years, whichever is longer |
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Written compliance program, updated annually |
No specified retention period |
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Respiratory protection program (see 29 CFR 1910.134(c)) |
No specified retention period |