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Office of Security, Safety and Risk Management

Chemical Hygiene Plan

E. Records and Recordkeeping
Follow the procedures described in this section when performing laboratory work with greater than 10 mg of any carcinogen, reproductive toxin, substance that has a high degree of acute toxicity, or a chemical whose toxic properties are unknown.


1. A detailed written report form should be completed for each accident or exposure incident and retained in file. OSHA form 200 should be used to record lost workdays that may occur as a result of accident or chemical exposure.


2. Inventory and usage records for high risk substances should be kept including the amounts of these materials on hand, amounts used, and the names of the workers involved.


3. Medical records should be retained by the institution in accordance with the requirements of state and federal regulations.


4. A collection of Material Safety Data Sheets (MSDS) should be maintained in one or more locations and made accessible to all employees who require them. Documents relating to the distribution and maintenance of these materials should also be retained.


5. Documents relating to the safety training of employees should be kept.


6. Records of air concentration monitoring results, exposure assessments, medical consultations, and examinations must be maintained for at least 30 years and must be made accessible to employees or their representatives.


7. Major safety suggestions from employees should be kept. A suggestion that is unusable today might be useful tomorrow. Even when a suggestion is clearly nonworkable, it should be taken seriously, examined and recorded.


8. Near miss reports. Employees who participate in or witness events that could have caused harm, but fortunately did not, should prepare reports of the incidents. These reports are used to develop changes in procedures that will prevent a future more serious occurrence.


9. Repair and maintenance records for control systems. These are useful as they suggest corrective actions and indicate that equipment was or was not well maintained and kept in working condition.


10. Complaints from employees. It is useful to keep a record of all complaints, investigations, and outcomes. Even when not justified, especially when a complaint correctly or incorrectly involves defects in and difficulties with operating equipment, the record may prove to be invaluable if that equipment develops a defect or malfunction at a later date.


11.

The EPA and other Federal and state agencies have special recordkeeping requirements. For example: Recordkeeping of allegations and the reporting of suspect hazards from the adverse effects of chemical exposure are required under Sections 8(c) and 8(e) of the Toxic Substances Control Act; see 40 CFR 716 and 717.