A crucial part of any environmental health and safety (EHS) program involves accurate record keeping and reporting. Many records are internal and do not always require reports to be submitted externally to the authority having jurisdiction (AHJ). The AHJ will expect to find those records readily available upon written request or during a site visit.
Some agencies require their own forms for record keeping and may provide samples. However, equivalent information may be maintained on forms other than the ones the agency generates. For example, workers’ compensation insurance forms will satisfy many of OSHA’s requirements.
Many of the regulatory agencies also have “non-enforcement divisions” designed to assist businesses in, among other things, establishing and maintaining appropriate records for their particular operations. The services offered by these agencies are typically geared toward smaller businesses and are provided free of charge. (Larger businesses will often have an environmental health and safety specialist on staff.) These non-enforcement divisions maintain their advocacy and public acceptance by not reporting to the enforcement division.
However, the agency providing consultancy services may refer violations to the enforcement division if the hazards remain unabated by the offender. In reality, this rarely happens because ideally a company using the consultant service intends to comply with the regulations.
Many companies are reluctant to use these agency resources and rely on third-party consultants. Insurance companies are a useful resource and are often complementary, as well. Regardless of which outside source of information is used, the owner and manager are ultimately responsible for compliance.
Document Destruction Guidelines
The maintenance and retention of records occupies considerable regulatory language and is, of course, a fundamental management responsibility for ensuring compliance with EHS laws. Aside from general EHS record and reporting obligations, OSHA has specific requirements that apply to records of medical surveillance, exposure monitoring, inspections, and other activities and incidents relevant to occupational safety and health, and for the reporting of certain information to employees, as well as to OSHA.
Every workplace manager has to deal with the storage, handling, and destruction of records, whether paper or electronic. Usually key departments such as libraries, legal offices, and safety or environmental units have records retention policies or guidelines to comply with external requirements. Most organizations have extensive records policies and schedules, but managers may be required to establish and maintain storage areas or vaults and/or shredding equipment. The workplace rule is that all retention regulations of the relevant agency must be met, and that records beyond the necessary or useful life should be appropriately destroyed.
With electronic data storage (whether on a computer or via the Cloud, a way to store data over the Internet on servers provided by Internet service providers or specialist companies), it is imperative to assure document integrity and backup. Technology is rapidly advancing in both higher quality and lower cost. Some larger companies may seek the use of enterprise content management, while others may rely on relatively simple and readily available tools.
Low-cost, all-in-one printers (with scanner and fax capabilities) offer advanced software tools to create searchable static document images. Electronic storage has the added advantage of reducing paper files and saving the file storage systems and space required to maintain paper documents.
Most agencies are likely aware of many methods to manipulate records and will likely want to see a policy on maintaining electronic record integrity. Altering or falsifying records is a criminal offense. Therefore the manager needs to:
- Minimize the risk of unauthorized alteration or erasure of the records
- Allow only authorized personnel access to the records in the system
- Allow only authorized personnel to perform administrative functions, such as creating or deleting directories, altering the parameters of metadata fields, and assigning access rights
The system must allow for records to be backed up to protect against information loss and be able to:
- Be backed up on a regular basis to safeguard against the loss of information due to equipment malfunctions or human error
- Provide for recovery of the records that have been copied during the backup
- Allow duplicate copies of permanent or unscheduled records to be maintained in storage areas separate from the location of the records that have been copied
Guidelines for Maintaining Written Logs
Manually maintained logbooks and checklists are being replaced by electronics, but are still viable forms of maintaining working documents for the foreseeable future. For example, inspection lists of equipment rooms or fire extinguishers are often posted on-site and with entries over time. They may be simply filed for a period of time, then destroyed or scanned to be archived. There are several guidelines to follow for these types of records:
- Use pen, preferably black or dark blue, as these colors photocopy or scan the best.
- Do not use pencil; graphite will fade in time.
- Simply line through mistakes and initial to avoid giving the impression records were changed or something is being hidden.
- Do not skip lines or leave blanks; it is preferred to enter “N/A” for “not applicable.”
- Date entries in the month/day/year format to assure chronological sequences.
- Do not leave pages blank unless you mark the page as “intentionally blank”; “remainder of this page is blank” denotes the end of the entries on a partially blank page.
This article is adapted from BOMI International’s course Environmental Health and Safety Issues, part of the RPA and FMA designation programs. More information regarding this course or the new High-Performance certificate courses is available by calling 1-800-235-2664. Visit BOMI International’s website, www.bomi.org.