Does OSHA allow written programs to be kept in an electronic format?
January 19, 2009 by Fred HosierPosted in: In this week's e-newsletter, Latest News & Views, OSHA news, Recordkeeping
Various OSHA standards require employers to have written safety programs. Would a company satisfy such a requirement by keeping the documents solely in an electronic format?
Yes, says OSHA.
ESIS, Inc., a global risk control services company, asked OSHA whether it’s acceptable to keep required written safety programs in electronic form only.
Traditionally, programs such as those for bloodborne pathogens, hazard communication and permit-required confined spaces have been kept in separate binders where employees can refer to them, as required by OSHA standards.
In its request for clarification of OSHA rules, ESIS also noted that keeping forms on a company intranet can provide significant benefits in consistency, ease of use, and accuracy in maintaining and updating these materials in a timely manner.
OSHA agreed that companies could benefit by keeping these programs on an employer’s Intranet, as long as the program meets all other requirements of the standard in question.
Employers must make sure employees know how to easily access the electronic records.
OSHA’s Standard Interpretation Letter on this topic is available here.
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Tags: electronic records, OSHA, standard interpretation letter

January 26th, 2009 at 3:38 pm
is there a consideration for power outage?
January 28th, 2009 at 9:43 am
Keeping program in an electronic format is acceptable and preferred especially in light of paper use reduction measures. However the lynch pin is that it has to be accessible to all employee or subcontractor employees (if they are working under your program)at all times. Often times when entering a tank or excavation you just dont have the intranet connection you were hoping for. In additional site specific elements for remote job site require including certain program elements such as who the onsite program administrator is, where onsite would I find the reference information, etc. Unfortunately, the issue becomes more cloudy when you add subcontractors to the mix in a situation where they are working under your program.