What is your company’s safety training record retention policy? Where do you find out how long you are supposed to keep all those sign-in sheets? What if there’s no rule, then what's the best practice?
OSHA requires that every employer make safety and health a top priority and ensure a safe working environment. OSHA's job is to provide leadership and encouragement to employers to take that responsibility seriously. They do this through enforcement of regulations as well as educational programs for employers to help them navigate the rules and awareness opportunities for employees so they know of their rights to a safe workplace.
Employers have a duty to protect workers from injury and illness on the job by developing and implementing a safety and health program that includes safety training and optimally, regularly scheduled safety meetings or toolbox talks.
Question: How long does my company need to keep safety meeting sign-in sheets and safety training records?
Short Answer: OSHA doesn’t say. Unfortunately, OSHA does not provide a simple guideline that would apply to all training records.
But of course, it couldn’t be easy, could it?
Better Answer: To ensure your company is holding onto training records for the required length of time, review the specific standards that the training may fall under and make sure your recordkeeping policy is at least as strict as the standard.
Most OSHA standards that required employee training do not specify the length of time that the training records need to be kept. For example, Fall Protection and Lockout/Tagout training is required, but the standard just says the training must be documented and kept up-to-date. This implies that the training records should at least be maintained for the duration of the employee’s employment.
As you can see, even with these examples above, the requirements are all over the place and there is no clear overall requirement for all training records.
Also, keep in mind, there is no specific requirement for how long any company must keep safety meeting and toolbox talk sign-in sheets. For more information, here’s a great article on OSHA Safety Meeting Requirements.
SHRM has a comprehensive article on recommended document retention periods based on OSHA standards and documents that could be useful if you’d like to take a closer look: Know OSHA’s Document Creation, Retention Requirements.
To make things less complicated, here are some recommendations on safety training records retention.
To find out more about the training requirements that may be applicable to your company, OSHA has put together a publication that you can search through easier than the online standards. Open up or download the PDF version of Training Requirements in OSHA Standards, and then you can search by typing CTRL-F on the screen. CTRL-F will open up a FIND box at the top of the document so you can search any terms like training, records, PPE, fall protection, lockout/tagout, etc. that will help you start to gather more definitive details on your training and record-keeping requirements.
For more ideas on preparing for and holding safety meetings check out 4 Simple Steps to Effective Safety Meetings and don’t forget to browse the Weeklysafety.com blog for other excellent articles on improving your safety program.
To learn more about why OSHA believes safety meetings are a vital component of safety and health programs visit: Q & A’s for Small Business Employers.
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