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OSHA Right to Know: When an Employer Must Provide Copies of Records

Under OSHA’s “right to know” principles, employees and their representatives must be able to access safety and exposure information that affects their health at work. In many cases, an employer must provide copies of records—not just allow a quick look—so workers can understand chemical hazards, verify training, and make informed decisions.

This article explains the OSHA rules that drive access, the most common record keeping requirements for employers, and practical guidelines for record keeping—including the common question: how long must training records be kept on file?

What “Right to Know” Means Under OSHA

OSHA’s Right to Know is most commonly tied to the Hazard Communication Standard (HazCom), 29 CFR 1910.1200, which requires employers to:

  • Maintain and make accessible Safety Data Sheets (SDS)
  • Ensure proper labeling and warnings
  • Provide employee information and training on hazardous chemicals

But “right to know” also extends to employees’ rights to access certain records OSHA requires employers to maintain—especially exposure and medical records.

The Key Rule on Access: 29 CFR 1910.1020

The primary OSHA regulation requiring record access is 29 CFR 1910.1020 (Access to employee exposure and medical records). This standard requires employers to provide employees (and designated representatives) access to relevant exposure and medical records.

In practice, this means that an employer must provide copies of records when requested in many circumstances, and access must be provided in a reasonable time, place, and manner.

If you’re required to keep a record under OSHA rules, assume it may also be subject to employee access requirements—especially if it relates to exposure, hazards, or training.

Which Records Must Be Accessible (and When Copies Are Required)

Not every document in a safety program is automatically available, but OSHA is clear about several categories of records that employees can access.

Exposure records

Under 29 CFR 1910.1020, exposure records may include air monitoring results, biological monitoring, and other sampling data related to employee exposure to toxic substances or harmful physical agents.

If an employee or representative requests them, an employer must provide copies of records or otherwise make them available for copying.

Medical records

Employee medical records are also covered under 29 CFR 1910.1020, with confidentiality protections. Employees can access their own medical records; representatives may have limited access depending on authorization.

Hazard communication documents (SDS and chemical information)

Under 29 CFR 1910.1200(g), employers must ensure SDSs are readily accessible to employees when they are in their work areas during each work shift.

Although HazCom focuses on access rather than “copies,” many employers provide SDS copies upon request to support effective communication and training—especially where mobile access is needed.

Training documentation

HazCom training is required under 29 CFR 1910.1200(h), and many OSHA standards require training and documentation (for example, respiratory protection 29 CFR 1910.134, powered industrial trucks 29 CFR 1910.178, lockout/tagout 29 CFR 1910.147, and others depending on your operations).

While OSHA does not universally require a training “record” for every standard, record keeping requirements for employers often come from a mix of OSHA standards, company policy, workers’ compensation, and legal risk management. And where a training record is required or maintained, employees may request to see it—especially if it relates to their qualifications.

Record Keeping Requirements for Employers: What OSHA Expects

OSHA recordkeeping can mean two different things:

  • OSHA injury and illness recordkeeping (OSHA 300, 300A, 301) under 29 CFR Part 1904
  • Safety program records required by specific standards (exposure monitoring, fit testing, HazCom, etc.)

OSHA injury and illness logs (29 CFR 1904)

If your business is covered by Part 1904, you may need to keep:

  • OSHA 300 Log of Work-Related Injuries and Illnesses
  • OSHA 301 Incident Report
  • OSHA 300A Annual Summary (posted for a defined period)

OSHA also includes employee access provisions for these records, with certain privacy limitations.

Chemical safety and HazCom records

For HazCom, OSHA expects employers to maintain an SDS for each hazardous chemical and ensure employees can access them. Employers also need to ensure training is completed and effective, and many organizations document it as a best practice.

Guidelines for Record Keeping That Support Compliance

Good compliance is mostly about being able to produce accurate records quickly—during an inspection, after an incident, or when an employee asks.

Build a consistent system

Create standardized procedures so records are complete and easy to retrieve.

  • Use consistent naming conventions (chemical name, site, date)
  • Store records in a centralized location
  • Control versions so outdated SDSs aren’t used

Keep access fast and practical

“Right to know” fails when employees can’t actually get the information during the shift.

  • Ensure access is available without asking a supervisor to unlock an office
  • Support mobile access for field teams, warehouses, and multi-site operations
  • Train employees on how to locate SDSs and hazard info

Document what you train and when

Even when not explicitly required, documenting training helps demonstrate good-faith compliance.

Include:

  • Topic covered (HazCom, PPE, spill response, etc.)
  • Date and duration
  • Instructor
  • Employee names/signatures or electronic acknowledgements
  • Refresher triggers (process change, new chemical, incident trend)

How Long Must Training Records Be Kept on File?

There isn’t one universal OSHA retention period for all training records. The answer depends on the applicable standard and the type of record.

Here are practical, compliance-oriented guidelines:

  • Keep training records at least for the duration of employment when they support qualification to perform hazardous work (common best practice).
  • If a specific OSHA standard requires retention (for example, some exposure-related records), follow that requirement.
  • When training relates to exposure or medical monitoring programs, retention may align with 29 CFR 1910.1020 retention rules for exposure/medical records.

Retention under 29 CFR 1910.1020 (exposure and medical records)

OSHA’s access rule also includes retention requirements:

  • Exposure records: generally 30 years
  • Medical records: generally duration of employment plus 30 years

Training records aren’t always “exposure records,” but if your training documentation is tied to exposure monitoring or required under a standard that links to 1910.1020, longer retention may be appropriate.

When in doubt, keep training records longer than you think you need—especially for high-risk chemical processes—because documentation gaps often become major issues during investigations.

Common “Copies of Records” Pitfalls (and How to Avoid Them)

Employers often get cited or challenged not because they don’t have a program, but because they can’t produce records quickly.

Frequent issues

  • SDSs stored in a binder that isn’t accessible during all shifts
  • Multiple locations with conflicting SDS versions
  • Training completed but not documented consistently
  • Exposure records stored offsite without a clear retrieval process
  • No defined process for employee requests—delays lead to complaints

A simple internal process for requests

  1. Identify what record is being requested (SDS, exposure data, training proof, OSHA logs).
  2. Verify the requester’s rights (employee, former employee, designated representative).
  3. Provide access promptly and document the response.
  4. Protect confidential information appropriately (especially medical records).

How SwiftSDS Makes “Right to Know” and Recordkeeping Easier

Managing SDS libraries and related records across multiple departments can be messy without a centralized system. SwiftSDS helps address common SDS and chemical safety documentation challenges by providing:

  • A centralized SDS library that keeps documents organized and available
  • Mobile-friendly access so employees can retrieve SDS information during their shift
  • Support for HazCom alignment with 29 CFR 1910.1200 and GHS labeling/classification needs
  • Chemical inventory tools to track locations, quantities, and updates—reducing the risk of missing or outdated SDSs

If an employee asks for hazard information, a well-organized SDS system makes it far easier to respond promptly—supporting the practical reality behind “right to know.”

For more on building a stronger SDS program, see SDS management.

Call to Action

Right to know is only effective when employees can actually access accurate information fast—and when an employer must provide copies of records, you need a system that can deliver.

Want to simplify SDS access, improve record organization, and strengthen HazCom compliance? Explore SwiftSDS and build a safer, inspection-ready SDS program today.