Safety Recordkeeping: Set the Record Straight; Understanding the Ins and Outs of Cal/OSHA s Recordkeeping Rules

Transcription

1 S P E C I A L R E P O R T Safety Recordkeeping: Set the Record Straight; Understanding the Ins and Outs of Cal/OSHA s Recordkeeping Rules Nobody likes to shuffle papers. But the fact is, the paperwork that relates to your safety program is critical both to your compliance efforts and to documenting the program s intensity and effectiveness. Cal/OSHA inspectors know this; that s why the first thing they ll ask to see when they walk onto your site is your paperwork. If an inspector showed up at your door today and asked for your training records, injury and illness records, written Injury and Illness Prevention Program (IIPP), hazard assessments, and inspection records, could you produce them? If you can t show your records in a timely fashion, the state Division of Occupational Safety and Health (DOSH) will cite you. Recordkeeping violations, by themselves, may not be serious but without appropriate documentation, you may find yourself subjected to serious citations in other areas. For example, if you can t furnish your training records and written operating procedures, you could be slapped with a serious citation for not training workers in proper operating procedures. Being able to produce the C O N T E N T S Injury and Illness Prevention Program Records...1 All That Paper!...3 Log of Work-Related Injuries and Illnesses (Form 300)...4 Exempt from Recordkeeping Is Not Exempt from Reporting...4 Posting the Annual Summary...5 Employee Exposure and Medical Records...7 Keeping Workers in the Loop...8 Conclusion...8 records in a timely fashion could save you from the citation. This Special Report clearly lays out which records you must keep, the information you need to include in them, and the circumstances under which you must make them available. We ve broken down the information into three sections: 1. Injury and Illness Prevention Program Records 2. Log of Work-Related Injuries and Illnesses (Form 300) 3. Employee Exposure and Medical Records INJURY AND ILLNESS PREVENTION PROGRAM RECORDS In California, all employers are required to create and maintain an IIPP by General Industry Safety Orders Section 3203 (which is incorporated by reference into the Construction Safety Orders). Under your IIPP, you must create and keep: the written IIPP itself hazard analyses conducted under the IIPP inspection records (for both your own site inspections and equipment inspections) written safe work practices training records Tips for Your Written IIPP If your organization is inspected, the DOSH inspector will ask for a copy of your IIPP. The inspector will also ask to see any records required by the IIPP that are necessary to document your compliance with Cal/OSHA standards and with policies and procedures your own IIPP sets out. For example, if your IIPP says employees won t begin work until they have received a basic safety orientation, the DOSH representative may ask to see training records showing that your workers received this orientation _0808_SR

2 It s important to keep your IIPP up to date. A common mistake employers make is not keeping their responsible person designations current. A DOSH inspector who finds that the person listed in your IIPP as responsible for maintaining your plan left the company three years ago will cast a jaundiced eye on all of your IIPP recordkeeping. So set aside time annually to review your IIPP and make sure you ve updated: Your responsible person designations. Check to be certain that none of the designated individuals have been promoted to other positions or other divisions, left the company, or even moved to new quarters with new contact information. The system described in the plan for ensuring that employees comply with safe and healthy work practices. For example, if you have implemented a safety incentive program, make sure your IIPP reflects this. Or, if your training or disciplinary procedures have changed, make sure the IIPP includes the current procedures. Your system for communicating safety and health to employees. If you ve switched to a new labeling system, added multilingual materials to your training, instituted daily safety meetings, or made other substantial changes to the methods described in your plan, revise the IIPP to reflect this. Your procedures for identifying and evaluating workplace hazards. New management systems or inspection protocols must be added to your IIPP. Your accident investigation procedures. If you conducted an investigation in the past year, include all information you gathered, making sure to describe procedures and what you learned through that process. Your methods and procedures for correcting unsafe and unhealthy workplace conditions. Have you devised new work orders that allow maintenance requests to be prioritized with regard to concern for safety? Put this in your IIPP. Your documentation, by maintaining records of all other activities covered under your IIPP through the past year. Make sure you keep these documents organized. Tips for Keeping Hazard Analysis Records Cal/OSHA s IIPP standard requires you to identify the hazards in your workplace. Your initial hazard analysis conducted as part of the process of putting your IIPP in place, which should have been done either when the IIPP standard took effect in 1991 or when you began operating your business should be kept with your IIPP. The analysis must be conducted by a qualified person someone qualified to identify and evaluate workplace hazards because of his or her education and/or experience so be sure that your records identify the person who conducts the analysis. Examine your facility for compliance with Cal/OSHA standards and for hazards associated with equipment, chemicals, and work practices. Follow-up assessments should be conducted whenever your process changes in a significant way and can be limited to the area of change. For example, if you change the inputs to a process, conduct a fresh hazard analysis of that process and account for the new inputs. If you add new equipment, add a hazard analysis for the new equipment to your records. Note in your hazard analyses which records you looked at and where these records can be found. To make sure you don t miss anything, as part of your initial and follow-up hazard analysis you should collect and examine: accident, injury, or illness data workers compensation data employee turnover and absenteeism rates written materials, including company policy statements, safety programs, work rules, safety rules, and work practices and procedures training records written programs Employer Resource Institute products are designed to help California employers keep up to date on the latest developments in the constantly changing field of employment law and employee relations. Readers comments and suggestions are always welcome. 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3 Tips for Keeping Site Inspection Records Scheduled site inspections are a required part of your IIPP to identify hazards and ensure compliance with safety regulations and your work rules. These inspections are separate from daily or preshift checks that supervisors or operators conduct; they should be comprehensive inspections conducted by a qualified person. The Cal/OSHA standard does not specify the frequency of these inspections, and courts have ruled that a qualified person or site inspector doesn t need to be at a worksite at all times. However, inspections must be conducted often enough to show that you are practicing due diligence in identifying workplace hazards. You should determine how frequently to conduct these inspections based on: Your operations and the magnitude of any given hazard. More hazardous operations should be inspected more often. Your employees proficiency. If your workforce is at higher risk of injury and illness, you need to schedule more frequent inspections. For example, you would need to do this if you have a very young workforce or a large percentage of immigrant workers. Changes in equipment or work processes. Managing change is an important safety consideration; stepped-up inspections are in order after any significant changes. History of workplace injuries and illnesses. Operations, shifts, or groups of workers with higher rates of incidents or near misses warrant more frequent inspections. Your site inspection records should include: the name(s) of the person(s) conducting the inspection the unsafe conditions and work practices identified any actions taken to correct the unsafe conditions and work practices Save these records for at least one year. But if you have fewer than 10 workers, you must keep the inspection records only until the hazard is corrected. Tips for Keeping Equipment Inspection Records Some equipment, like cranes and fire extinguishers, must be inspected periodically in accordance with consensus standards, manufacturers recommendations, or state rules. Keep records of these inspections so you can produce them if needed. To facilitate recordkeeping: Provide workers and supervisors with simple checklists for daily inspections to create an ALL THAT PAPER! Between your IIPP records, your injury and illness records, and your employee exposure and medical records, you can feel swamped in a sea of paper. However, under the federal Government Paperwork Elimination Act, you can keep those records electronically and eliminate some of that paper. instant record. Make sure that workers complete each form with the date and time or shift, and the worker s name. These records can be kept with the equipment they pertain to or in a central location and checked by the competent person the individual who meets the requirements of the applicable standard during weekly walk-throughs. Some standards require records to be maintained for a specific time period. One year is common and appropriate for most purposes, but make sure you don t have to keep certain records longer. Aerial lift inspection records, for example, must be kept for three years. Tips for Keeping Written Safe Work Practices Safe work practices should be developed for each job task in your workplace. This can be an overwhelming project, so start with the most hazardous job tasks areas such as lockout/tagout, confined space entry, and fall protection. When you develop work practices, get specific: Make sure practices cover equipment, tools, and chemicals. Include required personal protective equipment and safe use instructions for it. If guarding is required, spell out when and under what circumstances it may be removed or bypassed. If task ventilation is provided, include instructions for its use, inspection, and maintenance. Cover any applicable emergency procedures. Require the use of appropriate tools. Tips for Keeping Employee Training Records Make sure your training records will stand up to DOSH scrutiny by following these guidelines: Every time you provide training under your IIPP, keep a record that includes the name (or other identifier, such as ID number) of each employee who received the training, the date the training took place, the type of training, and the name(s) of the trainer(s). 3

4 Hold onto your training records for at least one year. However, you may wish to retain your training records for longer than one year under certain circumstances. For example, training conducted under your IIPP may also be necessary under another hazard-specific standard (such as powered industrial truck training or hazardous chemical training) that requires records to be maintained for a longer period of time. Also, in the event of an inspection or incident, your training records may become vital evidence for your defense. Note that you can give a worker who leaves before the year is out his or her own training record and save yourself the trouble of keeping it for the rest of the year. Special provisions apply to small employers and construction employers: If you have fewer than 10 employees, you can simply keep a training log for each employee. The log should list instructions given to the employee when hired and when assigned to new duties that pertain to the job s unique hazards. If you re a construction employer licensed under Chapter 9 of Division 3 of the California Business and Professions Code, you do not have to keep your own records if workers have employee training records provided by a DOSHapproved training program. LOG OF WORK-RELATED INJURIES AND ILLNESSES (FORM 300) Unless you are exempt (see below), you re required to maintain a log of work-related injuries and illnesses under the rules of the state Division of Labor Statistics and Research, found in Title 8, Section If you re inspected, a DOSH inspector will typically ask to see your Form 300, the Log of Work- Related Injuries and Illnesses, during the inspection s opening conference. The inspector may also request your Form 301 records (detailed reports of workrelated injuries and illnesses) or your Form 300A, the Annual Summary of Work-Related Injuries and Illnesses. You must keep your Form 300 and 300A (the log and summary) for five years following the year to which they pertain. Are You Exempt? You are exempt from Cal/OSHA injury and illness recordkeeping not necessarily from all Cal/OSHA recordkeeping if you: Are a small employer. If you had 10 or fewer employees at all times during the previous calendar year, you re exempt. Conversely, if at any point during the previous year you had more 4 EXEMPT FROM RECORDKEEPING IS NOT EXEMPT FROM REPORTING Some California employers are not required to keep records of work-related injuries and illnesses, but all California employers are subject to Cal/OSHA reporting requirements. All employers in the state must report each work-related serious injury, serious illness, or fatality to DOSH no more than eight hours after the employer learns of the incident, even at night, on weekends, or on holidays. Serious illnesses or injuries are those that 1) require inpatient hospitalization for more than 24 hours for other than medical observation, or 2) involve the loss of a body part or a serious degree of permanent disfigurement. Employers that don t report a serious injury or illness to DOSH within the required time frame can face a $5,000 penalty on top of any other penalties assessed after a post-accident workplace investigation. When a worker is seriously injured or becomes seriously ill in your workplace, make sure to call DOSH at your nearest Cal/OSHA Enforcement Unit District Office. You can find the phone number for your nearest office at DoshZipSearch.html; just enter your facility s ZIP code or city. than 10 employees, you are not exempt under the small-employer provision. You have to count all employees in your organization, including temporary employees you supervise on a day-today basis. Are within an exempt Standard Industrial Classification (SIC) code. Certain retail, service, finance, insurance, and real estate employers don t have to keep injury and illness records, regardless of how many employees they had during the previous year. Examples include, but aren t limited to, hardware stores, meat and fish markets, dairy product stores, used car dealers, beauty shops, museums and art galleries, advertising services, computer and data processing services, offices and clinics of medical doctors, medical laboratories, child day care services, retail bakeries, liquor stores, and credit reporting and collection services. This exemption may apply to an entire company or to only certain locations within the company. However, even if you are in a partially exempt SIC code, you may still have to keep records if Cal/OSHA or the U.S. Bureau of Labor Statistics asks you to do so. You can find a complete list of partially exempt SIC codes at

5 Complying with Form 300 Requirements You have seven calendar days from an event that results in an injury or illness or from the time you receive information about a work-related illness not connected to any specific event (such as occupational lung disease) to determine whether it s recordable and note it on your Form 300. If the case is recordable, put it on your Form 300, and decide which detailed incident report form you will complete. You may opt to use Cal/OSHA s own Form 301, Injury and Illness Incident Report, or an equivalent form. Some workers compensation or other reports may be acceptable if they capture the same information. You have to record on your Form 300 any injury or illness that: Is work-related. DOSH presumes that any injury or illness that occurs in the work environment is work-related, but the rule (Section 14300) defines a work-related injury and illness as: 1) one that is caused by an event or exposure in the work environment; 2) one in which a work event or exposure contributed to the condition (for example, work exposures may contribute to ergonomic injuries even if they are not the sole cause); or 3) one in which a preexisting injury or illness was significantly aggravated by a work event or exposure. Is a new case. A work-related injury or illness is a new case, rather than a continuation of an existing case, if the employee has not previously experienced a recorded injury or illness of the same type that affects the same body part, or if the employee completely recovered from a previous recorded injury or illness of the same type that affected the same body part. For example, each occupational asthma attack is a new case. Meets the general or specific criteria for recordability. In general, an occupational injury or illness is recordable if it involves death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. Significant injuries and illnesses diagnosed by a doctor or other licensed healthcare professional are also recordable, even if they don t result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness. In addition, a few specific injuries and illnesses are recordable by definition rather than by criteria; all of these are discussed below. To determine whether an injury or illness meets the general criteria, it helps to be familiar with a few definitions: Days away from work. The day a worker is injured doesn t count, even if he or she has to be placed on 5 POSTING THE ANNUAL SUMMARY From February 1 through April 30 each year, you have to post the Cal/OSHA Form 300A, Annual Summary of Work-Related Injuries and Illnesses that occurred during the previous calendar year. You must post this form even if you had no recordable injuries or illnesses in the previous calendar year; if that is the case, just put zeros in the total lines. If you are exempt from Form 300 recordkeeping, you are also exempt from the posting requirement. restricted duty, sent home for the day, or given medical care beyond first aid. (This makes an injury recordable, but if the worker returns to work the next day, you don t have to count days away from work.) For example, you decide to send a worker who has gotten a little too much sun home for the rest of the afternoon; if he comes back to work the next day, he did not have any days away from work. Begin counting lost workdays on the first day after the event itself, and count every day that the employee would be unable to work even weekends, holidays, and a worker s scheduled days off. Enter the number of calendar days (not scheduled workdays) the employee is away from work in the appropriate space on your Form 300. If a worker is going to be out for an extended period, estimate the number of days the worker will miss on your Form 300 and update the form with the correct count once the worker returns to the job up to a maximum of 180 days. After a worker has missed 180 calendar days, you can put 180 on your Form 300 and stop counting. You can also stop counting if a worker leaves your employment. Restricted work or transfer to another job. A worker is restricted when, because of a work-related injury or illness, the individual cannot perform one or more of the routine functions of the job or cannot work the full workday that he or she would otherwise have been scheduled to work. (Routine functions are job tasks the worker performs at least once a week.) A worker is also considered to be on restricted duty when a physician or other licensed healthcare professional recommends that the employee not perform one or more of the routine functions of his or her job or not work the full workday that the individual would otherwise have been scheduled to work. As with days away from work, although you have to record the injury or illness, you do not have to start counting restricted workdays until the day after the event. Medical treatment beyond first aid. This criterion is both important and confusing. A worker has not

6 received treatment beyond first aid if he or she has: been sent to a physician or other healthcare provider for observation or counseling received diagnostic tests or procedures, such as X-rays, blood tests, or prescription medications for diagnostic purposes (eye drops to dilate the eyes, for example) DOSH has defined first aid to include specific types of injury treatment; no other treatment or intervention counts as first aid. Treatment for an injury is first aid only if it involves: Using a nonprescription medication or using any medication at nonprescription strength. For example, if a worker takes one 200 mg ibuprofen tablet (a common over-the-counter painkiller), the medication is used at nonprescription strength. However, ibuprofen is also available at prescription strengths of 800 mg or more; a worker who decides to take four 200 mg ibuprofen tablets (800 mg) is considered to have taken a prescription-strength dose of ibuprofen, and the injury becomes recordable. Likewise, if a physician recommends that the worker take four 200 mg tablets of ibuprofen, the injury is considered recordable because the healthcare professional s recommendation was for treatment with prescription-strength medication. Administering tetanus shots. All other immunizations and vaccinations administered after an injury or exposure incident, including rabies and hepatitis B vaccinations, are considered medical treatment. Cleaning, flushing, or soaking wounds on the skin surface as well as removing foreign bodies from the eye using only irrigation or a cotton swab. Putting a self-adhesive bandage, gauze pad, or butterfly bandage on a wound. Sutures, staples, and all other wound closures are considered medical treatment. Applying hot pads or ice packs. Using nonrigid means of support for strains, sprains, and similar minor injuries elastic bandages and wraps fall into this category. Finger guards are also considered first aid. Anything else with rigid stays or other means to completely immobilize a body part is considered medical treatment beyond first aid. Temporarily immobilizing a worker. Splints, slings, neck collars, backboards, or similar devices applied to an injury only while an injured worker is being transported are considered first aid. Drilling a fingernail or toenail to relieve pressure 6 or draining fluid from a blister. Applying an eye patch. Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means. Massaging. But physical therapy and chiropractic treatment are considered medical treatment. Drinking fluids for relief of heat stress. Loss of consciousness. Any time a worker loses consciousness on the job even for just an instant it s a recordable injury or illness event. The amount of time the worker spends unconscious does not affect the injury s recordability. Significant diagnosed injury or illness. Some workrelated injuries or illnesses must be recorded even if the worker does not lose consciousness, require treatment beyond first aid, miss days of work, require job restrictions or transfer, or die. These include but are not limited to cancer, chronic irreversible disease, fractured or cracked bones, and perforated eardrums. Record these injuries or illnesses on the day a physician or other licensed healthcare professional diagnoses them. Other recordable injuries and illnesses. A few other conditions are recordable if they are work-related. These include: all needlestick or sharps injuries when the needle or sharp is contaminated with another person s blood, potentially infectious tissues, or fluids any case requiring an employee to be medically removed under the requirements of a Cal/OSHA health standard tuberculosis infection, diagnosed based on a positive skin test or by a physician or other licensed healthcare professional after exposure to a known case of active tuberculosis occupational hearing loss, diagnosed when an employee s hearing test (by an audiogram) reveals 1) that the employee has experienced a Standard Threshold Shift (STS) in hearing in one or both ears (averaged at 2000, 3000, and 4000 Hz), and 2) the employee s total hearing level is 25 decibels or more above audiometric zero (also averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS Completing the Form 300A Annual Summary To complete your annual summary, total each column on your Form 300 and transfer each number to the appropriate line on Form 300A. Put zeroes in any blank for which it is appropriate. Fill in the establishment information, including the calendar year covered, company name, establishment name, establish-

7 ment address, annual average number of employees covered by Form 300, and total hours worked by all employees covered by Form 300. To figure total hours worked, include hours worked by all employees, including hourly, part-time, and seasonal workers; salaried employees; and workers supervised on a day-to-day basis by your establishment (for example, temp workers). Exclude vacation, sick leave, holidays, and any nonwork time, regardless of whether employees are paid for those hours. If you track only hours paid and your records include vacation time, sick leave, or other nonwork time, or if you have workers who are not paid by the hour, make your best estimate. Form 300A must be reviewed for accuracy and certified signed by a company executive. A company executive is an owner of the company (for partnerships and sole proprietorships); an officer of the corporation; the highest ranking company official working at the establishment; or the supervisor of the highest ranking company official working at the establishment. In many cases, this person will not be the environmental, health, and safety manager. For More Information You can download Form 300, 301, and 300A from DOSH s website, PubOrder.asp. Scroll down to Recordkeeping for the links. Cal/OSHA s Consultation Service maintains an interactive website ( on how to comply with injury and illness recordkeeping requirements. EMPLOYEE EXPOSURE AND MEDICAL RECORDS As if recording all work-related injuries and illnesses and keeping records of all your inspections and training sessions weren t enough, you must also maintain records of any employee exposures to toxic substances or harmful physical agents as well as any medical monitoring records, exposure assessments, and exposure analyses that are generated because of employee exposure to these hazards. The rule, found in General Industry Safety Orders Section 3204, requires you to retain those records for a certain period of time and make them available to employees and certain others. Maintaining Worker Exposure Records Section 3204 doesn t cover all exposures to anything that can harm employees. It covers a worker s exposure to toxic substances, including chemicals or biological agents, and harmful physical agents, such as radiation, noise, ergonomic exposures, or temperature extremes. (Yes, you have to keep records when workers are exposed to potentially dangerous heat conditions.) These records must be retained for 30 years, reflecting that it can take that long for disease to appear. Exposure records you must keep include: Material safety data sheets (MSDSs). This requirement sometimes proves a sticking point for employers that would like to purge their records of MSDSs for chemicals no longer present in the work environment. Under the rule, after a substance is no longer used or stored, only the chemical s identity and a record of where and when it was used (not the entire MSDS) must be kept. Environmental monitoring or measurement. For example, if you record the outdoor temperature and humidity as part of your heat illness prevention program, conduct personal exposure monitoring to assess a worker s hazardous chemical exposure, test for asbestos or mold in the workplace, record the readings from a carbon dioxide or chlorine monitor in the workplace, or conduct a job hazard assessment for ergonomic stressors, those records fall under this standard and must be kept. Any analysis of the monitoring results is also covered. Biological monitoring results. These results include blood or urine testing or any other biological monitoring to measure a worker s exposure to workplace chemicals, but do not include results that assess an employee s use of alcohol or drugs. Other records. If you have no MSDSs or environmental or biological records of workplace exposures, you must maintain some written record of toxic substances or harmful physical agents in the workplace. Record what each substance is and when and where it is used. Maintaining Worker Medical Records You don t have to keep all of a worker s medical records under Section 3204, just the ones created by doctors, nurses, technicians, or other healthcare personnel (such as dentists or therapists) that apply either to your health and safety program (such as the record of an employee s medical assessment before being fitted with a respirator) or to occupational injuries and illnesses. Employee medical records must be kept for the duration of a worker s employment, plus 30 years, unless another applicable standard requires a different length of time. You don t have to keep the 7

8 KEEPING WORKERS IN THE LOOP Your workers have a right to know which exposure and medical records you keep that pertain to them and how to obtain those records. Verbally inform new hires about where exposure and medical records are kept, who is responsible for providing access to the records, where a copy of the Cal/OSHA standard can be found, and his or her right to access these records. You can also hang the poster available from DOSH ( Access_En.pdf) in your workplace to inform workers of their rights under Section records of an employee who stays on for less than a year if you provide them to the employee when he or she leaves the job. Records that fall under the standard s retention and accessibility requirements include: medical and employment questionnaires or histories the results of work-related medical exams and lab tests, including preemployment, preassignment, and periodic exams; and X-rays and range of motion or other tests taken to establish a baseline or detect occupational illness medical opinions, diagnoses, progress notes, and recommendations descriptions of treatments and medications employee medical complaints You don t have to keep actual physical specimens (such as urine samples), health insurance claims records, records of voluntary employee assistance programs (as long as these are separately maintained and not personally accessible to the employer), or records created as evidence for use in a lawsuit. You don t need to retain first-aid records that apply to nonrecordable injuries. Under equal employment opportunity and healthcare privacy laws, employers are not entitled to some categories of medical information about employees. For example, the new federal Genetic Information Nondiscrimination Act prohibits private employers with 15 or more employees and public employers from requesting, requiring, or purchasing genetic information except under specific exceptions about an employee or an employee s family member. Making Employee Exposure and Medical Records Available Generally, you have 15 days to make this information available to someone who has a right to request it. That includes employees, former employees, their representatives, and DOSH representatives. Employees, former employees, or their representatives may request the employees own exposure and medical records by providing the worker s name, dates of employment, and the location(s) where the employee has worked. If you don t have records on the worker who made the request, you should provide exposure and medical records for another worker whose exposure would have been similar but with personally identifiable information removed. If a records request made by a collective bargaining agent does not include written permission from the workers they pertain to, you must protect the privacy of individual workers whose records are released. To do this, remove any personally identifying information, such as name; Social Security number; payroll number; height, weight, gender, or age; and employment dates from the record(s). If a record contains trade secret information, such as a manufacturing process or the percentage of a chemical substance in a mixture, you can remove that information from the record before you make it available. If you withhold a toxic chemical s identity, you must tell the requestor that you have withheld this information and be able to support your claim that it is a trade secret. You must still give all other information on the chemical s properties and effects, and you must provide the chemical s identity immediately to a treating physician or nurse in an emergency situation without requiring a confidentiality agreement. You can make a record available either by providing a copy of the record at no cost; providing the opportunity to make a copy of the record at no cost; or providing the record itself, on loan to the employee, for long enough that the employee can make a copy. You can charge a minimal search and copying fee for additional copies. A record that includes an original X-ray must be provided for on-site examination or temporary loan. CONCLUSION Keeping records can be time-consuming, confusing, and frustrating but it s also vital. Well-organized and well-maintained records can help you identify and correct small problems before they become big ones, defend your company against violations, avoid citations, and demonstrate to your bosses and to the workers you re trying to protect that you re getting the job done. So don t let recordkeeping get you down; get on top of the paperwork and rest easy. 8