Document, Document, Document
by Janet L. Keyes, CIH and Carol Keyes,CSP
Inspect your eyewashes each week. Inspect your vehicle lifts each month. Check your fire extinguishers each month.
Make sure your exit signs work and your garage doors don’t descend on anyone and your frame rack slings aren’t damaged. Inspect your floor jacks at least every six months. Calibrate your CO/NOx detectors. Train employees in safe work practices and your AWAIR program. Employee got a minor cut? Fill out a First Report of Injury and report it to your insurer. Inspect your hazardous waste. Ship off your waste paint. And document all that.
Whew. Worn out yet?
Why can’t you just take our word for it that employees were trained? Why do I need to mark off on that little tag that the fire extinguisher is okay? A little cut is just one of those things that happens. Isn’t that just a lot of paperwork?
That’s one of the unfortunate things about safety – documentation is demanded. It’s partially for regulators. If I ask you if your employees have been trained on the chemicals with which they work, I can guess what your answer will be: of course they have! We went over that when we hired them. And they learned that stuff in technical school. And besides, a lot of our staff are certified. That proves they know the hazards of brake cleaner or paint thinner.
Before you assume that, know that regulators have heard that line before, many times. An OSHA inspector will interview employees. Without a doubt, the employees will be asked what safety training they’ve had. If they say they don’t recall any and you say they’ve had safety training annually, who is to be believed? If you can produce an outline and roster, showing that they put their name on that roster and listing what the training covered, who is to be believed? It’s no longer your word against an employee’s poor memory.
Many years ago, before the 1976 Resource Conservation and Recovery Act (RCRA) created regulations on how hazardous waste needed to be handled, toxic and flammable waste disposed of by companies that thought they were acting responsibly ended up in landfills. Drums leak. Landfills leak. And the groundwater we rely on for drinking water became contaminated. RCRA required cradle to grave documentation of hazardous waste – documenting when it left the originating facility, documenting how it was transported, and documenting that it ended up at a licensed disposal facility. It’s now rare to hear of drums left in ditches or farmers’ fields.
RCRA works because of that documentation. Of course, bad people can still dispose of waste illegally. But manifests bring in some accountability that had been lacking.
Why document that little cut on your detailer’s thumb? He didn’t even bandage it. Most of the time, that documentation does seem like needless paperwork. You send it in to your workers’ comp carrier, they open a file, close the file, and nothing more is heard of it. But what if it becomes infected? You’ve gone from a tiny cut to extensive medical care and days away from work. If you document that small injury when it occurred, you don’t have to try to recall what happened. And you won’t delay care for your employee because of confusion about whether it’s covered under workers’ comp.
Is all that paperwork accumulating so much that you could wallpaper your entire shop with it? Go electronic. There’s no mandate to have paper copies of everything. Even hazardous waste manifests are going electronic. Set up a safety folder on your computer – or even a safety folder on a shared drive or a platform such as Google Docs or Dropbox, so you can share the folder with your managers and employees. Have subfolders for training, for waste management, injuries, inspections…subdivided by year if the folder gets large. Use your phone to quickly scan and upload the documents (there are free scanning apps).
Purge your files periodically. Keep hazardous waste manifests forever. Keep inspection reports for a year or until superseded. Discard obsolete programs – there’s no reason to keep an emergency plan that lists people who retired five years ago. And contact us if you want a copy of our recommendations for document retention.
Paperwork is a pain. But it provides you with memory jogs. It allows you to track problems, so you can resolve them. And it provides proof to regulators that you are acting responsibly.
For additional information, contact Complete Health, Environmental & Safety Services, Inc (CHESS) at (651) 481-9787 or chess-safety.com.
Want more? Check out the September 2026 issue of AASP-MN News!