Retention of power-press inspection records

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 12, 1978

MEMORANDUM FOR: ACTING REGIONAL ADMINISTRATOR
Dallas

ATTENTION: C. R. HOLDER

THRU: DONALD E. MACKENZIE
Field Coordinator

FROM: BRUCE HILLENBRAND
Acting Director Federal Compliance and State Programs

SUBJECT: Retention Period for Inspection and Maintenance Records as Required by 29 CFR 1910.217(e)(1)(i) and (e)(1)(ii)

This is in response to your memo of March 23, 1978, which requested guidance on the subject standards regarding the retention period for the inspection and maintenance records.

The Office of Safety Standards is presently reviewing the retention of record requirements of the various standards. Until such changes are accomplished, the following may be used as a guideline for compliance with 29 CFR 1910.217(e)(1)(i) and (e)(1)(ii): If an employer retains the last two records of the inspection and maintenance performed on each of his presses then he has complied with the intent of the standards.

A CSHO is authorized to review records which he believes are relevant to the inspection or investigation (29 CFR 1903.3). Usually, this authority is most likely to be exercised during an investigation of a complaint, fatality, or catastrophe to determine whether a violation of the Act or regulations occurred at the time alleged, or at the time of the accident. The employer's failure to maintain pertinent records may lead to the issuance of a citation. Therefore, this determination does not preclude an employer from retaining additional records, if in his judgment he feels they are essential to this operation. This guidance furthers OSHA's "common sense" approach for implementation of the Act and enforcement efforts.