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.