If you have been in the occupational safety and health profession very long, you may have heard of this saying a few times, “If it is not recorded, it did not happen”. I know that if I only a dime every time I heard the saying, I would be retired by now. Nevertheless, the saying is extremely accurate in the Safety Management System world as well as the regulatory compliance world. A record is simply the evidence of compliance; either within an Safety Management Systemaccreditation or regulatory.
CONTROL OF RECORDS
Records are expected to exist to serve as verification of the Safety Management System operating processes as well as the organization’s conformance to either a third party certification or corporate standard and its own requirements. Procedures in this element are required for the maintenance of records, and specifically require that records are identifiable, retrievable, legible, safely stored, retained as appropriate (revision and annual review table), and traceable. Also, procedures in this element define the responsibilities for the identification and disposition of occupational safety and health records.
To elaborate a little more on the definition of record, as stated in the opening paragraph of this article, an occupational safety and health record can be defined as:
Furnishes objective evidence of activities performed or results achieved. A record’s primary function is to record the outcome or results of an activity or task. Unlike documents, records are not used to control day-to-day operations. Records include obsolete documents or out-of-date plans, which are retained for legal or other purposes.
Below is an example to further explain the difference between a document and a record:
An action plan is an example of a document that needs to be updated to be effective, whereas an example of a record would be an accident report which demonstrates a completed activity, and is not typically modified.
Developing a procedure for Control of Records shall identify the type of record, the location of the record, the record retention time period and the owner of the record. The type of records to include in the procedure are as follows, but not limited to this list.
- Occupational Health and Safety Policy;
- Safety Objectives;
- Hazard Identification, Risk Assessment and Risk Control Records;
- Management Reviews;
- Employee Training Records;
- Regulatory Compliance Reports;
- Safety Management System Compliance Reports;
- Consultation Reports;
- Incident Investigation Reports;
- Medical Test Reports;
- Industrial Hygiene Monitoring and Surveillance Reports;
- Powered Industrial Pre Use Inspection Sheets;
- Completed Preventive Maintenance Work Orders;
- Personal Protective Equipment Assessments
- Emergency Response Drill Reports
In conclusion, the Control of Records is a vital element with any Safety Management System for it will ensure the validation of compliance activities. The most common struggle within this element is to differentiate between a document and a record. Hopefully by reading this article, we have shed some light to eliminate the confusion going forward. Also, do not forget to review and revise your procedure along with the list of records at least, as a minimum on an annual basis. Doing so will ensure you are continually reviewing your legal obligations and updating your procedure to reflect the activities associated with a record.