Access to Employee Exposure and Medical Records 

General Information 

Employees are informed of the provision of recordkeeping upon initial assignment and annually thereafter. Upon an employee’s first entering into employment, and at least annually thereafter, information must be given to current employees of the existence, location, availability and the person responsible for maintaining and providing access to records and each employee’s rights of access to these records. 

As an employee, you have the right of access to these records. Access to records must be provided in a reasonable time, place and manner. If access to records cannot reasonably be provided within fifteen (15) working days, J. J. White, Inc. shall within the fifteen (15) working days apprise the employee or designated representative requesting the record of the reason for the delay and the earliest date when the record can be made available. 

 Personal identifiers (name, address, social security number, payroll number, etc.) are removed from records before access is granted. Whenever access is requested to an analysis which reports the contents of employee medical records by either direct identifier (name, address, social security number, payroll number, etc.) or by information which could reasonably be used under the circumstances indirectly to identify specific employees (exact age, height, weight, race, sex, date of initial employment, job title, etc.), personal identifiers must be removed before access is provided. 

Except for a recognized collective bargaining agent, any designated representative must have the employee’s written permission for access to exposure records and analyses. It is necessary however, for the union representative to specify the occupational need for access to records absent the employees consent. Union representatives must have the employee’s written permission to access medical records. 

Key Responsibilities 

• V.P. of Health, Safety, & Environmental
  • Develops local medical records practices for all worksites in accordance with this procedure and ensures employees are aware of the requirements of this procedure
  • Responsible for the review, implementation and maintenance of the local worksite medical records procedure.
• Project Manager
  • Responsible for the implementation and maintenance of the medical records procedure for their facility and ensuring all assets are made available for compliance with the procedure
• Employees
  • All shall be familiar with this procedure and have access to their records.

Records Retention 

• Medical records must be preserved and retained for the duration of employment plus 30 years
• Employee exposure records must be retained for 30 years.

Additional Information 

The Access to Employee Exposure and Medical Records Standard (29 CFR 1910.1020) will be readily available for review by employees upon request. 

A copy of the J.J. White, Inc. Access to Employee Medical and Exposure Records policy is readily available for review by the Safety or Risk Management Department.