Annual OSHA Medical/Exposure Records Refreshment Training
Example of an “Exposure Record”
Exposure records are documents that detail an employee’s contact with toxic substances, harmful physical agents, or biological hazards. These records are important for monitoring workplace safety and may include:
- Air monitoring results (e.g., measurements of airborne contaminants or particulates)
- Noise exposure measurements (such as decibel levels over time)
- Sampling data for chemicals (like silica, lead, solvents, or asbestos)
- Safety Data Sheets (SDS), providing details about hazardous substances used at the workplace
- Biological monitoring results (for example, blood lead levels, without personal identifiers)
What Counts as a “Medical Record”
Medical records are maintained by a licensed healthcare professional and provide a history of an employee’s health in relation to workplace exposures. Medical records may include:
- Medical exams and evaluations related to workplace exposures
- Physician opinions and written recommendations regarding an employee’s health and work restrictions
- Medical questionnaires (for example, respirator use evaluations)
- Records of work-related illnesses, symptoms, or medical events
- Biological monitoring results linked to an individual employee (such as individual blood test results)
Employee Rights Under the Standard
Employees (or their designated representatives) are entitled to certain rights regarding their exposure and medical records, such as:
- Accessing their own exposure and medical records
- Requesting copies of these records at no cost
- Reviewing records promptly, typically within 15 working days
- Knowing which substances or hazards they have been exposed to on the job
- Receiving explanations of the records from a knowledgeable person if requested
Employer Responsibilities
Employers are required to:
- Maintain exposure and medical records for at least 30 years
- Provide access to these records for employees, their representatives, or OSHA when requested
- Keep all records confidential and stored securely to protect employee privacy
- Inform employees each year of their rights under the standard
- Provide Safety Data Sheets (SDSs) and exposure data for any hazardous substances used onsite
- Ensure medical records are released only with written permission from the employee
Privacy & Confidentiality
- Medical records are strictly confidential and protected by law
- Supervisors and safety staff can only access information necessary for work restrictions, not private medical details
- Only the employee or their authorized representative can request full medical records
Why This Matters on the Job
- Long-term exposure to chemicals, dust, noise, or radiation may not result in immediate symptoms but can cause serious health issues over time
- Maintaining these records helps identify patterns of exposure and can prevent future illnesses among employees
- Exposure and medical records support workers’ compensation claims and enable long-term health tracking
- Keeping thorough records ensures transparency and fosters trust between employers and employees
Real‑World Examples
- A worker exposed to silica dust requests past air monitoring results to check exposure levels
- An employee in a hearing conservation program asks to review their audiogram history to monitor hearing changes
- A designated representative requests exposure data for a crew handling a solvent
- OSHA requests exposure records from the employer during a workplace inspection
Key Takeaways for the Crew
- You have the right to know what substances you have been exposed to at work
- You have the right to access your exposure and medical records at any time
- Employers must keep these records for at least 30 years
- Your medical information is confidential and protected
- If you need copies of records or have questions, ask your supervisor or safety manager
Discussion Questions for the Crew
- Do you know who to contact if you want to review your exposure or medical records?
- Have you ever worked with a substance and felt unsure about the hazards or risks?
- Do you know where Safety Data Sheets (SDSs) are kept on this job site?