Standard 1910.1020 “Access to employee exposure and medical records” is the most important and far-reaching of OSHA’s regulations. When the standard became effective more than two decades ago, it could not have envisioned the explosive growth of global chemical exposure information such as REACH, ToxNet, HERO, among many others; GHS 2012 requirements for new safety data sheets; and health concerns triggered, such as the level of chemical exposure above which no person should be exposed — derived no effect levels (DNELs)— when PELs and TLVs are absent.
The epidemiological foundation of the standard to require maintenance of exposure and medical records for the duration of employment plus 30 years, with access to employees or their representatives, even when the employee is deceased, necessitates even the most casual employer to become very cautious with its requirements. An employer’s failure, for example, to inform employees of the standard’s content upon hire and annually thereafter, as required at 1910.1020 (g)(1), sets the stage for a lack of transparency.