Do you know how long you are required to keep those old material safety data sheets (MSDSs – now referred to as safety sheets, SDSs) that keep piling up in your office? Because illnesses resulting from workplace exposures often do not manifest until many years later, Cal/OSHA requires all California employers to maintain records of employee exposure to hazardous agents, medical records, and SDSs for at least 30 years. Cal/OSHA defines a hazardous agent as any chemical, biological, or physical agent that is shown to be a health hazard and has an SDS indicating the material may post a health hazard to humans.
- Workplace exposure monitoring, including personal, area, grab, wipe, or other form of sampling. Types of records include personal exposure monitoring for hazardous chemicals, radiation badge monitoring, and ergonomic assessments.
- Biological monitoring results, which directly assess the absorption of a harmful agent by body systems. An example of this is employee bloodborne pathogens post-exposure documentation.
- SDS retention. SDSs must be maintained identifying chemical health hazards in the office.
- Other employee medical record not listed above, such as hepatitis B vaccination status.
Note: In the absence of #1-3 above, an employer must keep a record such as a chemical inventory or any other record which reveals the identity of a hazardous agent and where and when the hazardous agent was used in the office.
The requirements for records retention are covered in California Code of Regulations Title 8 Section 3204 Access to Employee Exposure and Medical Records. Subscribers of our OSHA Review Compliance Program can find these regulations in the back of Section X in the OSHA Review binder or they can be downloaded from OSHA Review’s website – www.oshareview.com, in the clients-only section under Professional Documents.
Since 1992, OSHA Review, Inc. has provided dental professionals with comprehensive programs to support regulatory compliance and infection control. We are a registered continuing education provider in the state of California, specializing in Dental Practice Act, infection control, and OSHA training.