Safety Tips: Record Keeping

According to OSHA, the importance of recordkeeping is a critical part in employer’s safety and health efforts for a few reasons:

  1. Keeping track of work-related injuries and illnesses can help you prevent them in the future.
  2. Using injury and illness data helps identify problem areas. The more you know, the better you can identify and correct hazardous workplace conditions.
  3. You can better administer company safety and health programs with accurate records.
  4. As employee awareness about injuries, illnesses, and hazards in the workplace improves, workers are more likely to follow safe work practices and report workplace hazards. OSHA compliance officers can rely on the data to help them properly identify and focus on injuries and illnesses in a particular area. The agency also asks about 80,000 establishments each year to report the data directly to OSHA, which uses the information as part of its site-specific inspection targeting program. The Bureau of Labor Statistics (BLS) also uses injury and illness records as the source data for the Annual Survey of Occupational Injuries and Illnesses that shows safety and health trends nationwide and industrywide.
Record Keeping

Why keep records?

Organizations must consider what records are kept, how long they are kept, how they are kept and who has access to them. There are a variety of reasons for keeping health and safety records.

  • The business is legally required to do so. Certain legislation includes specific requirements for keeping medical and health surveillance records, inspection records, atmospheric monitoring records, accident, incident and disease records. This duty is more extensive in high risk industries, eg under the Control of Major Accident Hazards Regulations 2015. Other legally required records include safety policies, employers’ liability insurance certificates, risk assessments and working time records.
  • To demonstrate compliance with legal duties and to show effective health and safety management procedures are in place. Health and Safety Executive (HSE) inspectors and union health and safety representatives have a legal right to inspect health and safety records. HSE inspectors can ask to see the health surveillance records made under the Control of Vibration at Work Regulations 2005. Inspectors appointed under the Regulatory Reform (Fire Safety) Order 2005 can ask to see fire risk assessments, fire safety arrangements, fire drill and other relevant records.
  • To use as part of a defence against prosecutions or claims for compensation. For an injury this includes the following documents:
    • the Accident Book report and Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) reports, if applicable
    • treatment records
    • health and safety committee minutes where the accident was discussed
    • health and safety training records
    • service or maintenance records of the work equipment
    • all relevant risk assessments. The defendant can ask for other relevant documents when other Regulations are likely to be at issue, eg in cases where the Control of Substances Hazardous to Health Regulations 2002 (COSHH) are relevant, there are 16 documents listed including the risk assessment, records of the maintenance of personal protective equipment and the examination of local exhaust ventilation.
  • To provide data to monitor health and safety performance statistics and to show trends or problems in health and safety procedures.
  • To provide information for employees, eg safety policies and risk assessments.

How long should records be kept?

Statutory requirements : Certain legislative provisions require records to be kept for specified periods of time.

  • The Accident Book and RIDDOR reports: under RIDDOR .
  • Health records and health surveillance records: under COSHH, the Control of Asbestos Regulations 2012 (CAR), the Control of Lead at Work Regulations 2002 (CLAW), the Work in Compressed Air Regulations 1996, and the Ionizing Radiations Regulations 2017 (IRR).
  • Reports of inspections of equipment and plant; under the Construction (Design and Management) Regulations 2015, Provision and Use of Work Equipment Regulations 1998 (power presses), the Lifting Operations and Lifting Equipment Regulations 1998, the Pressure Systems Safety Regulations 2000 and the Work at Height Regulations 2005.
  • Monitoring records including air monitoring under COSHH, CAR and CLAW, and dose records and dose assessment after an accident under IRR.
  • Examinations and inspections of control measures (local exhaust ventilation and respiratory protective equipment) to protect against hazardous materials; under COSHH, CAR, CLAW and IRR.
  • Working time information; under the Working Time Regulations 1998.

Note that some records must be kept for up to 50 years.

How should records be kept?

Employers may keep records in any format, provided they are kept readily accessible and retrievable at any reasonable time for examination. There should be appropriate technical and organisational measures to ensure a level of security necessary to maintain ongoing confidentiality.

Particular concerns exist about the ability to access and read electronic records over time, since the rapid pace of change in technology can make the software used to create the records obsolete, leaving the records unreadable. Regular audits of the data should both demonstrate, and provide assurance of, its compliance with good practice standards such as ISO 15489, the international standard on records management.

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