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Record-keeping

EHS record keeping is one of the most important chores for EPA and OSHA compliance. If you do not have a good EHS filing system you do not really have a good compliance and management program. This is the main aspect of a regulatory agency inspection. They will meticulously inspect and search the records for any sign of deviation from requirements.  This is the easiest violation to them to document and then be able to send you a written warning. Review and organization of your record-keeping methods need to be part of your annual self-audit.

The EHS records should obviously be kept in a file cabinet and the file drawer may need to be dedicated to EHS only as these records will fill a drawer over time.

Paper records should be filed in these folders. Here are some ideas:

Environmental

Permits and licenses (and applications)
Local and state EPA regulations
Correspondence (including important emails)
Reports to agencies
Waste removal records
Vendors/receipts
Training records (file a copy in employees personnel file)
Training materials Auditing/Inspections Lab analysis
Other folders that you want

Safety

Material Safety Data Sheets (MSDS) — web-based services are available such as 3E may be the best method if you have multiple locations Accident reports and records relating to job related injuries/illnesses

Training logs and documents
Training materials
Vendors and receipts (safety supplies)
Self-auditing and self-inspections
Agency inspections
Agency correspondence (Fire, OSHA, Health) including reports Local and state regulations
Safety guides from manufacturers

Electronic Records

Many records are sent or received through the computer — website downloads, emails with attached documents, PDFs, Word.docs, spreadsheets etc. You may also have regulatory reports submitted through their web interface connecting to their database. Either paper or electronic is sufficient for compliance purposes except where paper reports are submitted via mail (preferably certified).

The question is: should there be a paper record of all of these? No, but it is recommended only the important electronic information be printed and filed so there is a continuity. A thorough search for information would require searching both types of records.

Emails could be dragged and stored in an EHS folder. Likewise, documents on your hard-drive should probably be put into an EHS folder. You might find it helpful to break the folder into main topics.  You could also make your own control panel — a page with links to web resources, folders on your hard-drive or important and frequently used applications such as spreadsheets, databases, AESE Online, MSDSs online. You can make a short cut on your desktop and/or browser tab.

 

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