Are confined space air monitoring records considered employee exposure records and subject to the 30-year retention requirements of 29 CFR 1910.1020 – Access to Employee Exposure and Medical Records?
The short answer is “no”. OSHA published an updated Letter of Interpretation (LOI) on November 3, 2023 clarifying this record retention requirement, and rescinded a previous LOI from 1996.
OSHA’s Confined Space standard includes a specific requirement for employers to maintain canceled entry permits for at least one year, which includes atmospheric testing records related to the permit. According to the updated LOI, employee exposure monitoring records generated for confined space entry are not subject to OSHA’s 30-year employee exposure record retention requirement. Permits with confined space atmospheric testing records need not be kept for 30 years unless testing is conducted to meet the requirements of another specific OSHA standard or to demonstrate compliance with 29 CFR 1910.1000. Otherwise, the Confined Space Standard takes precedence and permits, as well as monitoring records, need only be maintained for one year.
Click here to see the OSHA LOI that describes Confined Space atmospheric testing record retention requirements.
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