Chemicals

Toxic and Hazardous Substances Records Checkup

One of the most tedious aspects of an environment, health, and safety (EHS) manager’s job is to keep track of a host of records. Don’t get caught without the necessary records in the event of an Occupational Safety and Health Administration (OSHA) or Environmental Protection Agency (EPA) inspection.

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.


Join us on Thursday, January 21, for our in-depth webinar, Hazard Recognition and Control: How to Effectively Identify Potential Occupational Risks for Injury Prevention


Chemical or Substance

Required Records

Record Retention Period

Acrylonitrile

Objective data supporting exempted operations

Duration of employer’s reliance on the data

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Exposure monitoring and medical surveillance

Duration of employment plus 20 years or for 40 years, whichever is longer

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

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

Records of all measurements taken to monitor employee exposure

30 years

Objective data supporting exempted operations

For the duration of the employer’s reliance on the data

Medical surveillance

30 years

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Training records

1 year beyond the last date of employment of that employee

1,3-Butadiene

Objective data supporting exempted operations

Duration of employer’s reliance on the data

Exposure measurements

30 years

Respirator fit test

Until the next fit test

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Medical screening and surveillance

Duration of employment plus 30 years

Benzene

Exposure measurements

30 years

Medical surveillance

Duration of employment plus 30 years

Written compliance program

No specified retention period

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Bloodborne pathogens

Exposure control plan

Update annually

Medical record for each employee with exposure

Duration of employment plus 30 years

Training records

3 years

Sharps injury log

5 years following end of calendar year covered

Cadmium

Exposure measurements

30 years

Medical surveillance

Duration of employment plus 30 years

Written compliance program, updated annually

No specified retention period

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

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

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Chromium (VI)

Air monitoring data, historical monitoring data, exposure records, objective data, and medical surveillance

30 years

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period


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Chemical or Substance
(Continued)

Required Records
(Continued)

Record Retention Period
(Continued)

Coke oven emissions

Exposure measurements and medical surveillance

Duration of employment plus 20 years, or for 40 years, whichever is longer

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Cotton dust

Exposure measurements

20 years

Medical surveillance

20 years

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

1,2-dibromo-3-chloropropane

Exposure monitoring
Medical surveillance

40 years or duration of employment plus 20 years, whichever is longer

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Ethylene oxide

Negative initial determination of exposure

Duration of employer’s reliance on the data

Exposure measurements

30 years

Medical surveillance

Duration of employment plus 30 years

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Formaldehyde

Exposure measurements and exposure determinations

30 years

Medical surveillance

30 years

Respirator fit testing

Until replaced by a more recent record

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Inorganic arsenic

Exposure monitoring and medical surveillance

Duration of employment plus 20 years, or for 40 years, whichever is longer

Written compliance program, updated annually

No specified retention period

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Ionizing radiation

Records of the radiation exposure of all employees for whom personnel monitoring is required

No specified retention period

Records of exposure to employees in restricted areas

No specified retention period

Lead

Records of all measurements taken to monitor employee exposure

40 years or for the duration of employment plus 20 years, whichever is longer

Medical surveillance

40 years or for the duration of employment plus 20 years, whichever is longer

Records of employees removed from current exposure to lead

Duration of employment

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Methylenedianiline

Monitoring and objective data for exempt employers

Duration of employer’s reliance on the data

Exposure measurements and medical surveillance

30 years

Medical removal

Duration of employment plus 30 years

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Methylene chloride

Objective data supporting exempted operations

Duration of employer’s reliance on the data

Exposure measurements

30 years

Medical surveillance

Duration of employment plus 30 years

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period

Vinyl chloride

Monitoring and measuring

30 years

Medical surveillance

Duration of employment plus 20 years, or for 30 years, whichever is longer

Written compliance program, updated annually

No specified retention period

Respiratory protection program (see 29 CFR 1910.134(c))

No specified retention period