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Standard Interpretations
08/14/1997 - Electronic recordkeeping of employee safety training records. |
Standard Interpretations - Table of Contents |
Standard Number: | 1910; 1915; 1917; 1918; 1926; 1928; 1960 |
August 14, 1997 Bruce A. Lepore Workplace Health and Safety Manager East Bay Municipal Utility District 375 Eleventh Street, Mail Stop 704 Oakland, California 94607-4240 Dear Mr. Lepore: This is in response to your letter of March 29 regarding the use of electronic recordkeeping of employee safety training records. As you discussed with Helen Rogers of my staff, the Occupational Safety and Health Administration (OSHA) has no jurisdiction over state or local government employers, and it is the State of California (Cal-OSHA) that has occupational safety and health jurisdiction over the East Bay Municipal Utility District. You state that you are considering placing a bar code on each employee's ID card so that when the employee enters or leaves the classroom the card will be scanned with a wand. Since the wand contains a microchip, it is programmable to show all required information (class time, date, location, instructor, curriculum, etc.) as well as the arrival and departure time for the student. The data will then be downloaded directly into your training data base. Specifically, you ask: Must an employer keep "hard copies" of signed attendance sheets of each class taught to prove employee attendance, or is electronic recordkeeping allowed? A search of all OSHA standards found that there is no standard that requires the employer to obtain the employee's signature. Instead, most OSHA standards concerning training require the employer and trainers to sign a certification record which includes the identity of the person(s) trained. With regard to your bar code suggestion, if safeguards are taken to ensure that the ID card being scanned belongs to the employee being trained, there should be no problem accepting this method of documenting employee training. Cal-OSHA, however, may have somewhat different requirements; therefore, you should contact the following for information specific for California standards: [California Department of Industrial RelationsIf you have any questions, please call [the Office of General Industry Enforcement at (202) 693-1850]. Sincerely, John B. Miles, Jr., Director [Directorate of Enforcement Programs] [Corrected 10/22/2004] |
Standard Interpretations - Table of Contents |
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