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Retention of medical records for office workers

Summary A medical center asked which medical records employers must retain under OSHA’s access standard. OSHA said orthopedic X-rays need not be retained unless they relate to employees exposed to toxic substances or harmful physical agents, and records for unexposed office workers do not need to be retained. The answer matters to employers organizing occupational medical records.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-12-04-0
Date issued
December 4, 1989
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Recordkeeping Medical Records
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

December 4, 1989

Mr. Craig A. Townsend
Administrator
Bayshore Medical Center
[Recipient address omitted]
Dear Mr. Townsend:

This is in response to your letter of October 4, 1989, concerning retention requirements for medical records.

Medical records that employers must retain are contained in 29 CFR 1910.1020(b), which is the scope and application portion of the standard captioned "access to employee exposure and medical records". Orthopedic x-rays do not have to be retained provided that are not pertaining to employees exposed to toxic substances or harmful physical agents. If office workers are exposed to unregulated toxic substances, then medical records pertaining to their exposure must be retained. If office workers are not exposed to toxic substances or harmful physical agents, their medical records do not have to be retained.

I appreciate the opportunity to clarify this matter for you.

Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs

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