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While Injury and illness records need only be posted in the workplace from Feb. 1 until April 30, the recordkeeping is ongoing. Not only must injuries and illnesses be logged again this year and compiled in 2014, other safety and health events and activities must be recorded and maintained. Almost all of these other records fall into two basic categories: training and inspection.
The main purpose of keeping training records is to prove that you are training your employees and to show what information you have provided to them. The purpose of inspection records, whether job site hazards or equipment, is much the same. You need to prove the inspection was completed, show that safety issues have been addressed and keep track of upcoming inspections.
Before getting into the details, it should be noted not all records are truly mandatory. A distinction needs to be made between records kept because an Occupational Safety and Health Administration (OSHA) regulation specifically dictates it and records kept to satisfy an implied requirement. For example, fall protection training or crane inspection records are mandatory. In the case of fall protection, OSHA states: “The employer shall verify compliance with paragraph (a) of this section by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer.” For cranes, the regulation states: “The following information must be documented and maintained by the employer that conducts the inspection: A) the items checked and the results of the inspection. B) The name and signature of the person who conducted the inspection and the date.”
Training records required by OSHA’s Hazard Communication standard (HazCom) is implied but not mandatory. HazCom states, “Employers shall provide employees with effective information and training on hazardous chemicals.” Nowhere does it require sessions to be documented. The language is performance-based. Verification by a compliance officer, in the absence of records, falls to the results of employee interviews about whether training occurred.
Then why keep these records? Well, you may need to prove that a specific training or inspection has occurred. While it increases the amount of records you must store, in the event of an accident or OSHA visit, it will help prove you took action to prevent injury or fatality.
Regardless of whether it is mandatory, training documentation should include dates, a summary/outline of the content covered in the training methods, names and qualifications of the trainers, and attendance records for each session conducted. Attendance records should include the participant’s name, department, the topic covered and course date.
The length of time that training records must be kept varies. To be safe, 30 years is a reasonable mark. OSHA requires medical exposure records, such as material safety data sheets (now safety data sheets), to be kept for this period. Therefore, it’s logical that associated HazCom training records would be re-tained for the same period.
Inspections can vary widely in scope. The action can be as simple as inspecting a ladder or a power drill before using it or as in-depth as checking out a crane or motor vehicle. Inspection records should include the following:
• What is being inspected
• The date the inspection was completed
• The inspector’s name and any applicable credentials
• Reason for the inspection—e.g., annual inspection or to follow up on a reported problem
• Inspection results
Performing an inspection can be overwhelming. Checklists are useful to ensure all items are addressed. They can be used as part of the record to prove that the inspection has been completed and can show exactly what was inspected.
Frequency varies depending on the type of inspection being conducted; some are annual (motor vehicle inspections), some are before each shift (safety net systems and scaffolding) and some are required after an incident involving a piece of equipment (personal fall arrest systems). Another variable is the length of time that inspection and maintenance records must be kept. Records for portable fire extinguishers must be kept for one year after the last entry or the life of the shell, whichever is shorter.
The number of records is just as varied as the specifics (e.g., retention period and elements) associated with the record. The suggestions offered here provide a broad base to ensure the record is sufficient. However, the best way to comply is to check the specific standard in question.