Recordkeeping

Employers with employees experiencing occupational exposure to blood or other potentially infections materials mnst maintain a log of occupational injuries and illnesses under existing recordkeeping rnles but must also maintain a sharps injury log. This log must be maintained in a manner that 

Employers with employees experiencing occupational exposure to blood or other potentially infectious materials must maintain a log of occupational injuries and illnesses under existing recordkeeping rules, but must also maintain a sharps injury log. Maintain this log in a manner that protects the privacy of employees. The sharps injury log may include additional information that the employer must protect due to privacy requirements. Employers can determine the format of the log. At a minimum, the log must contain the following  

Type and brand of device involved in the incident Location of the incident Description of the incident 

The PMN regulations require that PMN submitters retain for five years (i) documentation supporting information provided in the PMN, (ii) documentation supporting the date of commencement of manufactme or import and (iii) production volume records for the first three years of manufacture or import. However, the statute of limitations for enforcement actions is five years and so it is important to be able to support the PMN submission for at least five years. It is prudent to retain this data much longer—for five years after the last manufacture or importation of the PMN substance—because there are continuing violations that relate back to the PMN submission, and the complete file and backup information will be important to defend against an enforcement action even it is brought many years after the PMN is filed. 

PMN Instruction Manual, 14-15. Note that this is primarily an issue of applying the fee for intermediate PMNs instead of consolidated PMNs. 

For example, each new act of manufacturing a substance could be a TSCA violation if the substance is not on the Inventory, and so it may be critical to refer back to the original PMN to prove that the substance was correctly described in the PMN. 

Employers may be self-insured if they are able to furnish to the workers compensation board satisfactory proof of their fiscal ability to directly pay the compensation and if they deposit an acceptable security, indemnity, or bond (Champa, 1982). Self-insurance is no insurance. Companies simply pay the claims themselves. 

Regardless of the program employers use to cover their workers compensation insurance, they ultimately pay the cost for that insurance in addition to overhead. Workers compensation is a cost of doing business that can be lowered through the administration of effective safety and health programs. 

Can all employees explain every existing and potential hazard to which they are exposed Do they know how to protect themselves and their coworkers from these hazards Can they explain precisely what they must do in the event of a fire or other emergency  

Training can help employees develop the knowledge and skills they need to understand workplace hazards. OSHA considers safety and health training vital to every workplace. 

Oklahoma Department of Labor, Safety and Health Management Safety Pays, 2000, http //www.state.ok.us/ okdol/. Chapter 13, pp. 81-90, public domain. 

OSHA Publication 2254 (Revised 1992), Training Requirements in OSHA Standards and Training Guidelines, public domain. 

Department of Labor, Office of Cooperative Programs, Occupational Safety and Health Administration (OSHA), Managing Worker Safety and Health, November 1994, public domain. 

3 Are the records kept together in a central area at facility  

4 Are the permit and other records reviewed at least annttally to ertstrre that reqttired conditions are being met  

5 Does facility have a tickler or some other system to track milestone dates for reporting, monitoring, permit renewal, manifest exception, and other actions  

7 Does facility periodically review permit records to check whether changes in eqrripment, materials, or operations reqtrire permit amendments  

9 If no to 1.7, describe how changes are monitored and permit amendments accomplished. 

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Establish a Recordkeeping System. It has always been important for the food manufacturer to maintain records of ingredients, processes, and product controls so that an effective trace and recall system is available when necessary. 

There are several widely used approaches for developing perspective about the significance of absolute risk estimates (Figure 16). The first approach is to compare the risk estimates to historical experience within your company, looking for similar events. Most companies have safety and loss recordkeeping programs that date back many years. But if directly related data are sparse, you may widen your comparison to extrapolate from near-miss incidents that could have caused the event of interest. You will not, however, frequently find solace from the company data—or even comparable industry data. 

As new practices are introduced to prevent indoor air quality problems, an organized system of recordkeeping will help those practices to become part of routine operations and to "flag" decisions that could affect lAQ. The best results can be achieved by taking time to think about the established channels of communication within your organization, so that new forms can be integrated into decision making with minimum disruption of normal procedures. 

General information on recordkeeping and how to assemble a report under Title in of the Superfunds Amendments and Reauthorization Act... 

Facility Chemical or Waste Recordkeeping, Reporting, and Compliance Assistance (e.g., manifests, labels, report generation) ... 

Primarily recordkeeping system for individual facilities. Includes information on chemicals and manufacturers and records of accidents and training. Chris Plus adds capability of storing and printing MSDS information and assists with the preparation of Tier I and Tier II reports and right-to-know requests. Doth systems contain database of 600 toxic substances and synonyms. 

Employee recordkeeping system. Tracks worker training, job location, and job assignments, as well as employee courses and qualifications. May be used in conjunction with TOXIC ALERT. 

Industrial Pollutant Monitoring for recordkeeping and report generation and Process Monitoring/Rcporting for process reports and other reports. Each requires 512K memory and lOMeg hard disk. 

Database management system for MSDS information. Modules include SARA, for assistance in creating reports for Title III, and SAFETY for accident and incident recordkeeping. 

SLUDGE MANAGER Resource Conservation Services, Inc. 42 Main Street Yarmouth, ME 04096 (207) 846-3737 Recordkeeping and database management for treatment plants and facilities that produce useful sludge. Requires 312K memory, 5Meg hard disk, and dBase II. 

Recordkeeping and analytical program for use in monitoring and maintenance of exhaust ventilation systems. Requires Apple II. 

Again, writing a plan that calls for regnlar inspections appears to have been implemented hy the sites andited. What has been lacking appears to be the execntion and recordkeeping. 

The only regulations found for organophosphate ester hydraulic fluids were for aryl phosphates. Two proposed rules for aryl phosphates address 1) exclusion from hazardous waste regulations and 2) additional testing, recordkeeping, and reporting under the Toxic Substances Control Act (TSCA). 

EPA/OPPT Test Rule Including Reporting and Recordkeeping (proposed) (aryl phosphates) Yes 40 CFR 704 and 799 57 FR 2138 EPA1992... 

EPA. 1992b. Environmental Protection Agency. Aryl phosphate base stocks proposed text rule including reporting and recordkeeping requirements. Fed Regist 57 2138-2158. 

Conversely, used oil that meets all specification levels, which is known as on-specification used oil, is not subject to any restrictions when burned for energy recovery. In fact, on-specification used oil is comparable to product fuel in terms of regulation. Once the specification determination is made, and certain recordkeeping requirements are complied with, the on-specification used oil is no longer subject to used oil management standards. 

In order to properly track the hazardous waste that is generated, transported, treated, stored, and disposed of, U.S. EPA imposes certain LDR notification, certification, and recordkeeping requirements... 

Each hazardous waste handler must comply with certain recordkeeping requirements for LDR notifications and paperwork. Generators, treatment facilities, and disposal facilities must keep copies of all LDR paperwork associated with the waste they ship or receive in their facility files for three years. 

In September 1999, U.S. EPA finalized a rule that established coordinated CAA and RCRA requirements for incinerators, cement kilns, and LWAKs, commonly known as the M ACT rule. This rule ensures that these facilities will avoid two potentially different regulatory compliance schemes by integrating the monitoring, compliance testing, recordkeeping, and permitting requirements of CAA and RCRA. 

Command post Supervision of all field operations and field teams Maintenance of communications, including emergency lines of communication Recordkeeping, including - Accident reports - Chain-of-custody records - Daily logbooks - Manifest directories and orders - Personnel training records - Site inventories... 

Worker safety studies are not likely to normally include a control substance (i.e., a material used in the study to serve as basis of comparison with the test substance). However, if a control substance is included as a treatment group, then it must (1) be fully characterized as to its identity, purity (or strength), and stability (and solubility, if appropriate) (2) be appropriately tested in mixtures with any carrier used and (3) meet all the other GLP recordkeeping, labeling, and storage requirements, as specified for the test substance. There is some regulatory relief here, however, in that water, by definition, is excluded from being considered a control substance, and vehicles (those substances added to enhance solubilization or dispersion of the test substance) are addressed separately in the FIFRA GLP Standards. 

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