Access to Medical and Exposure Records
Sample Policy
This sample Access to Medical and Exposure Records policy template is provided by the Missouri On-Site Safety and Health Consultation Program. The policy template is designed to assist employers in complying with OSHA’s standard for Access to Employee Exposure and Medical Records, 29 CFR 1910.1020. The policy template must be site specific. Modify the template to reflect the policies and procedures at your company. Since OSHA regulations set minimum requirements, you may choose to add additional information to your site specific policy. There is no requirement to follow this sample and its use does not guarantee compliance with the OSHA standard. We suggest having a competent person review your completed policy.
To prepare in the development of your policy, please follow these steps:
1. Read the Access to Employee Exposure and Medical Records
2. The following information may be useful in developing your policy:
3. Add information to make it site specific to your company.
4. For clarification or assistance, contact the Missouri On-Site Safety and Health Consultation at 573-522-SAFE.
Access to Medical and Exposure Records Policy
Date Created:
Date Reviewed:
1. Company Policy
(Name of Company) is committed to providing a safe and healthful work environment for our entire staff. The purpose of this policy is to ensure that employees know they can access their exposure records. This Policy has been developed in accordance with Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1020.
2. Responsibility
Employees may access any employee exposure records that show the measuring or monitoring of their own exposure to a toxic substance or harmful physical agent. If (Name of Company) does not have any records that specifically chart your own exposure levels, the employee may access the exposure records of employees who engage in similar work or working conditions and may have experienced exposures similar.
(Name of person or job title) will provide initial and annual training to each employee who has medical and exposure records.
3. Methods of Compliance
Employee exposure records include the following:
- Monitoring results of workplace air or measurements of toxic substances or harmful physical agents in the workplace, including personal, area, grab, wipe, or other forms of sampling results;
- Biological monitoring results, such as blood and urine test results; and
- Safety data sheets (SDSs) containing information about a substance’s hazards to human health.
Employees may also access any employee medical record concerning their health status that were created or maintained by a physician, nurse, health care professional, or technician. Employee medical records include the following:
- Medical and employment questionnaires or histories;
- Results of medical examinations and laboratory tests;
- Medical opinions, diagnoses, progress notes, and recommendations;
- First-aid records;
- Descriptions of treatments and prescriptions; and
- Employee medical complaints.
Employee medical records are to be stored for at least the duration of the employee’s employment plus 30 years, except for:
- Health insurance claims records that you maintain separately from your medical program and its records.
- First-aid records made onsite by a non-physician of one-time treatment and later observations of minor scratches, scrapes, or other injuries that did not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.
- Medical records of employees who have worked for less than 1 year as long as you offer all such records to the employee upon termination of employment.
4. Training
Employees or your designated representative may access your medical and exposure records in one of three ways:
- The employer may give you a copy of the document; or
- The employer may provide facilities for you to copy the document; or
- The employer may loan you the document to copy it offsite.
Upon first entering into employment, and at least annually thereafter, (Name of person or job title) will inform each employee of the following:
- The existence, location, and availability of employee records for exposure to toxic substances or harmful physical agents;
- The person responsible for maintaining and providing access to records; and
- The employee’s right of access to the records.
Note: Notification can be distributed during annual training sessions and safety meetings, in an annual letter to all employees, or through a bulletin board.
Appendix A
Notice To All Employees
If you are an employee who may have been exposed to toxic substances or harmful physical agents in the workplace, OSHA’s regulation may help you detect, prevent, and treat occupational disease.
You have the right to access relevant exposure and medical records and to know how OSHA’s standard covers you if you are any of the following:
- A current or former employee who is or may have been exposed to toxic substances or harmful physical agents;
- An employee who was assigned or transferred to work involving toxic substances or harmful physical agents; or
- The legal representative of a deceased or legally incapacitated employee who was or may have been exposed to toxic substances or harmful physical agents.
Designated employee representatives may access employee medical or exposure records and analyses created from those records only in very specific circumstances. Designated employee representatives include any individual or organization to whom an employee has given written authorization to exercise a right of access.
Employee medical records include the following:
- Monitoring results of workplace air or measurements of toxic substances or harmful physical agents in the workplace, including personal, area, grab, wipe, or other forms of sampling results;
- Biological monitoring results, such as blood and urine test results;
- Safety data sheets (SDSs) containing information about a substance’s hazards to human health.
- Medical and employment questionnaires or histories;
- Results of medical examinations and laboratory tests;
- Medical opinions, diagnoses, progress notes, and recommendations;
- First-aid records;
- Descriptions of treatments and prescriptions; and
- Employee medical complaints.
If you are interested in reviewing or copying any of these records contact (Name of person or job title) who will make the necessary arrangements.
Appendix B
Access to Medical and Exposure Records Training Roster
Training Performed By:
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Employee Name |
Employee Signature |
Training Date |
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