Todd Jerome Jenkins, MS, CSP, SMS, CHST, STSC

Safety Aficionado & Ph.D. Student

Safety Policy Access to Employee Medical and Exposure Records

This article is the first of a series of posts providing free safety policy templates for third-party vendors, such as ISNetworld, Avetta, and Veriforce. There is no guarantee that these sample policies will address the specific needs of a particular business. Please review the policy and make any necessary changes.

OSHA’s construction standard, 29 CFR 1926.33, points to the general industry standard 1910.1020 Access to employee exposure and medical records. The two standards are identical by reference. According to the standard, employers are responsible for Maintaining and providing Access to medical and exposure records.

Other federal, state, or local laws and regulations may limit the use and disclosure of medical records and exposure records that are individually identifiable. It is recommended to contact the Department of Health and Human Services to determine whether privacy regulations issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) may limit the disclosure of medical records to individuals/entities other than those who are the subject of the record.

Additionally, several letters of interpretation regarding employee exposure and medical records exist. There are too many to list and discuss here. You should consult a safety professional or an attorney if any questions or concerns arise based on the type of work performed.

Download the free safety policy here:

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