An employee exposure record is a record of what toxic substances or harmful physical agents workers were exposed to: workplace monitoring, biological monitoring of absorption, material safety data sheets or, failing those, a chemical inventory, as defined in 29 CFR 1910.1020(c)(5). The term comes from that US federal OSHA standard. Where the employee medical record documents a worker’s health status, the exposure record documents the hazard.
What counts as an exposure record
The standard defines four kinds of information (§1910.1020(c)(5)):
- Environmental (workplace) monitoring of a toxic substance or harmful physical agent, including personal, area, grab, wipe or other sampling, with the methods, calculations and background data needed to interpret the results.
- Biological monitoring results that directly assess absorption by body systems, such as the level of a chemical in blood, urine, breath, hair or fingernails. Results that assess the biological effect of a substance, or a worker’s use of alcohol or drugs, are not included.
- Material safety data sheets indicating that a material may pose a hazard to human health.
- A chemical inventory or other record, in the absence of the above, showing the identity of a toxic substance or harmful physical agent and where and when it was used.
“Toxic substance or harmful physical agent” covers chemical substances, biological agents and physical stresses such as noise, heat, cold, vibration and radiation that meet the criteria in §1910.1020(c)(13). “Exposure” includes past and potential exposure (§1910.1020(c)(8)).
How long to keep it
Unless a specific OSHA standard sets a different period, each employee exposure record must be kept for at least 30 years (§1910.1020(d)(1)(ii)), with three exceptions:
- Background data such as laboratory reports and worksheets: one year, as long as the sampling results, sampling plan, analytical methods and a summary of other background data are kept for at least 30 years.
- Material safety data sheets and inventory records: no specified period, as long as some record of the substance’s identity, where it was used and when is kept for at least 30 years.
- Biological monitoring results designated as exposure records by a specific OSHA standard: as that standard requires.
Other countries’ rules are compared in how long to keep occupational health records.
Who can see it
On request, employers must give each employee and designated representative access to exposure records relevant to the employee (§1910.1020(e)(2)(i)(A)). Where no record measures that worker’s own exposure, relevant records include those of other employees with past or present job duties or working conditions related or similar to the worker’s, to the extent needed to reasonably indicate the worker’s exposure (§1910.1020(e)(2)(i)(A)(2)). In practice, organizing exposure data by similar exposure group makes those records easier to find. A recognized or certified collective bargaining agent is treated automatically as a designated representative for exposure records, without written authorization (§1910.1020(c)(3)). Employers must also give OSHA representatives prompt access on request (§1910.1020(e)(3)(i)).
Exposure and medical records answer different questions about the same worker, and both are kept for decades. MyC’s occupational health platform keeps exposure and medical records for decades after a worker leaves.
Related terms
- Employee medical record: Employee medical record, under OSHA 29 CFR 1910.1020, means a record of an employee's health status made or kept by a physician, nurse or health care staff.
- Similar exposure group (SEG): A similar exposure group (SEG) is a group of workers expected to share the same exposure profile, used to plan monitoring and read surveillance results.
- Health surveillance: Health surveillance is a program of repeated health assessments for workers still exposed to a hazard after controls, to identify ill health caused by work.
- Medical surveillance: Medical surveillance is the program of medical exams and tests that specific OSHA standards require employers to offer workers exposed to certain hazards.