Recordkeeping – Construction
Recordkeeping is probably one of the easier parts of the OSHA Silica Standard in which to comply. At first glance, this one seems simple. Keep everything. In actuality, that’s really the best thing to do – keep everything.
What Records Must I Keep?
The OSHA Silica Standard only requires you to keep three things:
- Air monitoring data
- Objective data used to determine potential exposure
- Medical surveillance records
What Additional Records Should I Keep?
In addition to the required records, you would also want to keep records pertaining to:
- Employee training attendance, including quizzes.
- Site inspections by the competent person.
- Corrective actions made by the competent person.
- Safety Data Sheets on all silica-containing materials.
- Manufacturer’s instructions (user’s manuals) for all tools used around silica.
How Long Should I Keep These Records?
Records retention for the mandatory records is spelled out in the OSHA Medical Records Standard (29 CFR 1910.1020). This OSHA standard basically says that the employer must keep all medical records for the duration of employment, plus an additional 30 years. There is an exception for employees who worked less than one year, but basically medical records must be kept for 30 years.
Can I Keep These Records Electronically?
Yes. Records can be kept electronically just as long as they are accessible.
Maintain a good Silica Plan with all records from all projects in the one plan. This will make compliance and verification of compliance much easier in the event of an audit.
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