OSHA Document Demands
At some point during an inspection, the CSHO will likely ask to see documents related to the worksite.
You should have a procedure to handle these requests properly.
You want to control the information given to OSHA to avoid disclosing sensitive or privileged info.
The most commonly requested documents are your 300, 300A and 301 logs. You must produce these within 4 business hours of OSHA’s request.
There is no set time limit to turn over any other non-log documents.
Here are some best practices for responding to a document request:
During the inspection:
-Ask that any document request be put in writing .
-Do not have documents out in plain sight for the CSHO to find.
-Do not volunteer information that the CSHO does not ask for.
When producing the documents:
-Redact personal medical records (unless OSHA has proper authorization)
-Determine whether any trade or business secrets are being disclosed so as to take protective measures.
-Create a Document Control Log to keep track of all documents given to OSHA.
-Create an exact copy of the complete document set given to OSHA and keep for your records.
What procedure do you have in place for producing documents on your worksite?
Comments (2)
I was involved with a multiple week OSHA facilities audit. We had people dedicated to the documents side of the effort and followed the guidance you have presented above. All of the correspondence was directed through our refinery attorney and paralegal.