10 Oct Safety Update: 6 Tips for Smart Safety Recordkeeping

Source: Safety Daily Advisor

 Enforcement and Inspection

Find it hard to keep up with all of OSHA’s record-keeping requirements? Here’s some advice from safety expert Chip Darius and attorney and safety professional Adele Abrams who offer six simple tips for smart safety record-keeping.

1. File employee training records by date and topic.In an effort to keep employee records organized, most supervisors put employee training records in the employee files. According to Darius, this is wrong.If an OSHA inspector were to request to see all training records, he would ask for records by date and topic. If you have to search through all employee files for this information, it could be quite time consuming.In an effort to speed things along, a busy supervisor could give the OSHA inspector full access to employee files to find the training records on his or her own.But this would definitely be a bad move. As Darius points out, this could open you up to invasion of privacy issues. That’s why he recommends never giving an inspector access to your employees’ personnel files for the purpose of providing documentation of training. 
2. Log your training attendance.Abrams recommends keeping a log of attendance at your training sessions. This would be helpful during an investigation of an incident involving an employee who may not be able to testify for his own training record. If you have a record of who attended the training session with that employee, then you can find out from the other attendees what you need to know about the session.For example, if your company was being investigated for a fatality and you needed to know exactly what was covered in a particular training session, you could reference the attendance log and find another employee to fill you in on any undocumented details. 
3. Be careful about hazard assessment documentation.Conducting hazard assessments for self-audits is a responsible practice that can benefit you in several ways during an OSHA inspection. However, be very clear about what you are recording. Darius and Abrams say that OSHA requires two things: a hazard assessment and the hazard assessment certification. Do not disclose anything that is not mandatory such as notes or opinions.The safety experts also recommend that if you document a hazard in the assessment, you’d better be sure to 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. 
4. Know the records that you don’t have to produce for an inspection.Abrams says there are a few documents that you do not have to produce for an OSHA inspector. They are: 
   • Safety and health audits
   • Self-inspection checklists
   • Informal notes by supervisors
   • Memoranda
   • Corporate safety policy 
5. Get proof (politely, of course!). If you are asked for a record to be produced, Abrams says to politely ask the inspector to show you in the CFR where it states that it is mandatory. If the inspector cannot produce the proof that you need to show him the records, it is your right to respectfully decline disclosure.There’s no need for overachieving here. Abrams says that if it is not required by law, don’t show the inspector. You never know what kind of can of worms you may open up—even with the best intentions. 
6. Keep documentation of discipline. Keep any and all records of disciplinary action taken against workers who do not follow appropriate safety practices. You want OSHA to know that you enforce the rules at your facility.