• Record Type:
    OSHA Instruction
  • Current Directive Number:
    ADM 12.5
  • Old Directive Number:
    ADM 12.5
  • Title:
    OSHA Compliance Records
  • Information Date:
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA Instruction ADM 12.5 November 15, 1989 Office of Human Resources and Organizational Management

Subject: OSHA Compliance Records

A. Purpose. This instruction provides instructions and procedures for the maintenance and disposition of OSHA compliance case files and related files concerned with Federal inspection of worksites including those in Federal agencies. This instruction supersedes any conflicting records filing and disposition instructions for compliance-related records.

B. Scope. This instruction applies to OSHA area offices and subordinate offices maintaining compliance case files and related files.

C. References.

1. OSHA Instruction ADM 1-1.12A, The Integrated Management Information Systems (IMIS) Forms Manual.
2. OSHA Instruction ADM 12.1, OSHA Classification System.
3. OSHA Instruction ADM 12.4, OSHA Records Management Program.
4. OSHA Instruction ADM 12.6,Safeguarding Asbestos-Related Documents and Data.
5. OSHA Instruction CPL 2.45B, Revised Field Operations Manual (FOM).
6. OSHA Instruction CPL 2-2.20A, Industrial Hygiene Technical Manual.

D. Action. OSHA Regional Administrators shall:

1. Ensure that all OSHA field offices which maintain compliance case files or related files shall arrange, file, maintain, and dispose of compliance-related records in accordance with the procedures set forth in this instruction.
2. Implement the provisions of this instruction not later than 6 months after the date of this instruction. Exception: The identification and separation of health inspection case files held in a Federal Records Center (FRC) but not separated into health and safety categories shall be implemented not later than 1 year after the date of this instruction.

E. Definitions. The following definitions of records management terms are intended to give field personnel an understanding of basic concepts used throughout this instruction.

1. Record. A record is information in any form created and/or maintained by OSHA whether on paper, magnetic disc or diskette, film, or video tape and which documents the work or activities of the agency. It includes correspondence, reports, completed forms, case files such as inspection case files, and the like.
2. Records Maintenance. Records maintenance is filing and retrieving records for use.
3. Records Disposition. Records disposition means getting records out of high cost office space through disposal (destruction), transfer to a FRC, or storage in agency space.
4. Compliance Subject Files. Compliance subject files consist of groupings of records (usually correspondence) arranged by the subject or function to which the records relate. Subject files do not include case files. Subject files dealing with inspections in general and other compliance activities are filed in the appropriate subject folder. (Refer to OSHA Instruction ADM 12.4 and OSHA Instruction ADM 12.1.)
5. Compliance Case Files. Compliance case files consist of all record material relating to a specific subject and pertain directly to one specific person, organization, company, project, or the like. The case deals only with the specific item for which the file was established, from beginning to end. Examples include an establishment file on a particular firm or company and an inspection case file on a specific inspection at a particular establishment.

F. Records Maintenance and Disposition.

1. Appendix A provides files maintenance instructions including prescribed listings of filing supplies.
2. Appendix B provides records disposition instructions including records transfer procedures.
3. For additional information on records maintenance and disposition, refer to OSHA Instruction ADM 12.4.

G. Compliance Records Files and Records Disposition Schedule. Appendixes C and F contain the files and disposition categories for all compliance-related records. Their purpose is to define and provide instructions for the files maintenance and disposition of these records. The types of file or record categories and/or record disposition categories are discussed below:

1. General Material. This record category covers compliance-related subject files. This includes chronological files where the office does not maintain subject files. NOTE THAT ALL OFFICES SHOULD MAINTAIN SUBJECT FILES AS THE RECORD COPY. Chronological files constitute an additional reference file maintained as a cross-reference to the record copy in the subject files.
2. Policy Material. This record category covers policy, precedent, and other similar material relating to planning, developing, and directing the Federal Inspection Program. This category does not include compliance plans or other compliance operational instructions.
3. Reports. This record category covers compliance-related reports which are not specifically related to individual inspections or other individual compliance actions.
4. Meetings. This record category covers compliance-related meetings and committees except those related to individual inspections or other individual compliance actions.
5. Inspection Case Files. This record category covers all inspection case files in federally inspected States and in Federal agencies. It consists of the following subdivisions:
a. Active/Open Inspection Case Files.
b. Contested Cases.
c. Closed Inspection Case Files. This is a filing category. The records disposition schedule breaks this category into the following items:

(1) Closed Safety Inspections.

(2) Safety General Duty Inspections.

(3) Safety Fatalities/Catastrophes.

(4) Safety In-Compliance Inspections.

(5) Health Inspections with Sampling Data.

(6) Health Inspections without Sampling Data.
(7) Nonformal Complaints.

(8) Refused and Attempted Inspection Files.
6. Establishment File. This record category covers all compliance-related materials which relate to a specific establishment but which are not limited to a specific inspection. Establishment case files are started for each establishment that contains unusual or special circumstances or situations; such as unusual processes, engineering controls, unusual toxic chemicals and other toxic products, and the like, which will probably result in a continuing need for information. Such a file may include health hazard evaluations, process descriptions, production data, product toxicity data, engineering controls, and other long-term safety and health data and related information of value in preparing for inspections.
7. Invalid Complaints File. This record category covers complaints which are not related to occupational safety and health or are not covered by OSHA.
8. Discrimination File. This record category deals with allegations of employer discrimination or retaliation against employees who call attention to alleged violations or who cooperate with OSHA inspections. The category consists of copies of materials sent to the regional office for investigation and does not include investigative materials.
9. Compliance Index File. This record category covers card (OSHA 47) or electronic files used to provide reference and case tracking capabilities for compliance case files including inspection case files.

H. Inspection Case File Organization. Appendix D provides instructions and procedures covering structure and content structure and control. It contains information on external and internal file structure, folder label preparation and inspection case file subdivision.

I. Compliance Indexing System. Appendix E provides instructions for the use of OSHA Form 47, Inspection Case Summary, or the basic information to be included in an automated system as an alternative to the use of the OSHA 47. The form provides a format for listing records disposition and summary case file information.

J. Implementation. Appendix G provides instructions and procedures for records conversion and implementation.

K. Questions and Answers. Appendix H provides information on frequently asked questions and their answers.

L. Assistance. Contact your Regional Records Management Officer for information and solutions to problems. The Regional Records Management Officer may contact the OSHA Records Management Officer, OHROM, as necessary.

David C. Zeigler Director Administrative Programs

DISTRIBUTION: National, Regional, Area, and District Offices All Compliance Officers OASAM's

Appendix A


A. Introduction. This appendix provides information on the maintenance of records in agency offices including records administration, classification, filing, label preparation, records controls, and filing supplies.

B. Files Custodian. Each office will assign one person to be responsible for managing the files in each official file station containing compliance-related records in accordance with OSHA Instruction ADM 12.4. The files custodian should have physical custody of the files in the official file station and be responsible for records classification, filing, loan, and disposition.

C. Files Stations.

1. All official records relating to compliance records will be filed in the appropriate file station in accordance with OSHA Instruction ADM 12.4.
2. Each official file station should be convenient to those people using the files. Be sure those using a specific group of files have easy access and are located as close to the files as possible.
3. Each official file station should be physically located so they are under the control of the files custodian responsible for those files.
4. Compliance-related subject files may be filed in a different official file station, possibly with other subject files, if desired.

D. Files Classification.

1. Determining Classification.
a. Classifying records involves the ability to read quickly and with understanding, to analyze subject matter, to select the most appropriate subject classification, to recognize related subject matters of sufficient importance to warrant cross-referencing, and to distinguish between papers which belong in case files and those which belong in subject files.
b. The classifier may be a area director, supervisor, compliance officer, secretary, clerk-typist, etc. The classifier needs a good general knowledge of what the agency does, how it is done, and who does it. The classifier also needs complete and detailed knowledge of the functions and operations of the office, and of those file subjects which relate to such functions and operations. It is also useful to know what kinds of files have been needed in past operations.
2. Subject File Material. Papers to be filed in subject files are marked in the upper right corner (in red) with file codes taken from Appendix D of OSHA Instruction ADM 12.4.
3. Case File Material. Papers are marked in the same manner as the subject material but with a case file identifier. Not all papers for case files need to be marked, however. Certain forms and reports used in inspections show numbers, names, and other identifying characteristics which are self-classifying, and need no further identifying markings to ensure that they are correctly filed.

E. Filing. The filing of subject or case file materials can be easily accomplished as follows:

1. Assemble papers to be filed in the subject files alphabetically by their primary file codes, and within each primary code by secondary and tertiary file numbers.
2. Assemble papers to be filed in case files according to the arrangement scheme in use such as alphabetically, numerically, etc.
3. Assembly instructions for inspection case files may be found in Appendix C.
4. Inspection case files will be filed in accordance with the provisions of Appendix C.
5. Additional information about files maintenance may be found in OSHA Instruction ADM 12.4.

F. Folder Label Preparation.

1. File folder labels should be prepared to achieve uniformity. Use white pressure sensitive labels (See paragraph D. 2. for description.) Show the file code (such as CPL 2 or FAP 1 for subject file material on Inspections), folder title, period covered by the folder (fiscal year - FY) and the disposition date. Additional information on file folder and file label preparation may be found in OSHA Instruction ADM 12.4.
a. Subject Files. The file code and subject title appear on the label of each subject file folder exactly as they appear in the file outline in Appendix C of OSHA Instruction ADM 12.4 (unless deviations have been approved for use.). The following is an example:
|CPL 2 INSPECTION FY-86 | | Destroy 10/89 | |____________________________________________|
b. Subject-Expansion Files. These contain an addition or expansion of a subject file. The subject-numeric file code (such as CPL 2) is followed by a further alphabetic breakdown. Subject-expansions are done at the local office's option. The following is an example:
|CPL 2A Establishment Files FY-86 | | Destroy 10/89 | |_______________________________________________|
c. Case Files. The following is an example of a folder label for an establishment case file.
|CPL 2A (Ace Foundry, Moline, KS) | | (Subs. J.K. Steel Co.) | | Destroy When Closed | |_______________________________________________|
The establishment case file shows the establishment name in parenthesis to distinguish the case file from the establishment subject file in paragraph F.1.b. on page A-3. The fiscal year is not shown on the establishment case file since the case file would be destroyed when the establishment either goes out of business, changes owners, or is otherwise not needed.
2. Inspection case file folder labels and related case file labels such as nonformal complaints are prepared differently. (See Appendix C.)

G. Charge-Out. Set up a records charge-out system if records are to be removed from the official file station and/or immediate work area. Use a charge-out card (OSHA-157 when a document is removed or OSHA-158 when the folder is removed). Staple a File Transmittal Card (OSHA-156) when the document or folder will be used outside the immediate work area. (For additional information, see OSHA Instruction ADM 12.4.)

H. Cutoff.

1. Cutoff or close out subject files once a year. Start a new set of folders for the current year (FY) Usually, subject files are cutoff at the end of the fiscal year (September 30).
2. Bring forward to the new folders material on policy or other material which is still current.
3. Separate inactive subject files or closed case files physically from active files.

I. Records Control.

1. When necessary, provide controls so records may be easily located within the office or on loan to other offices. Inspection case files must be controlled through the use of a charge-out system. Be sure other records you propose to control are worth the time and effort in controlling them.
2. A tickler system is necessary to identify who has the controlled records. The tickler system might be a log, a card file, a file in an office automation system, or simply an OSHA-158 placed in the file drawer in place of the folder. The type of tickler system used is dependent upon the volume of records removed from the files.
3. When controlling a folder, staple an OSHA-156 to the back of the file folder so that the OSHA-156 is visible. Follow up periodically to verify location and to retrieve the file.

J. File Folders, Labels, and Guide Cards.

1. Standardization of Filing Supplies. The types of folders, labels, and guides used and their preparation affect the appearance and efficiency of the files including faster and easier retrieval of records.
2. File Folders.
a. Standard Folder. The standard file folder is composed of kraft paper, 11-point weight (147 pound), letter-size, square-cut, top reinforced tab, without prong fasteners, scored to indicate label positions. The GSA Stock Number for the standard folder is:

Kraft Folder GSA Stock Number
Letter-size 7530-00-663-0031 (9-1/2 x 11-3/4 inches)
b. Standard Lateral Folder. For open shelf or lateral file equipment, the standard lateral folder is of the same composition as the standard file folder described above except the tab, instead of being positioned on the top (top tab) is located on the right side of the folder (side tab).

Kraft Folder GSA Stock Number
Lateral Letter-size 7530-00-881-2957 (9-1/2 x 12 inches)
c. Legal-size Folders. Do not use legal-size folders for compliance-related records.
d. Special Use Folders. These folders are used for inspection case files. They may also be used for establishment files. (See Figure A-1 for illustrations of special use file folders.)
(1) Kraft Folders. Use folders similar to the standard file folder (see paragraph D.2.a. on page A-6) except with two built-in 2-3/4 inch prong fasteners. Specify letter-size. Regional or area offices will procure from commercial sources of supply.
(2) Pressboard Folders. Use these folders to house inspection case files or establishment files which are at least 1 inch thick. (Pressboard, 25 point weight, square cut, top tab with two 2-3/4-inch fasteners mounted on to (9-1/2" side) on inside covers, 2-inch expanded cloth gusset with "W" fold See Figure A-1.) When ordering, specify letter-size (9-1/2 x 11-3/4). Regional or area offices will procure these folders from commercial sources of supply.
3. Folder Labels.
a. Subject and Case Files. Use standard GSA file folder labels, either plain white or with stripe, as appropriate.

Label GSA Stock Number
Light blue stripe 7530-00-557-4368 Green stripe 7530-00-557-4369 Orange stripe 7530-00-557-4370 Dark red stripe 7530-00-557-4371 Yellow stripe 7530-00-557-4372 Goldenrod stripe 7530-00-557-4373 Gold stripe 7530-00-557-4374 Silver stripe 7530-00-557-4375 White, no stripe 7530-00-557-4376
b. Inspection Case Files. Use GSA pressure-sensitive, white, fanfolded labels for labeling inspection case files and related files such as informal complaints, uninspected denials, attempted inspections, and the like.

Label GSA Stock Number
Pressure-Sensitive 7530-00-054-1575 Label (2 x 3-1/2 inches)
4. File Guides.
a. Regular Guides (top tab). Use guide cards with top tabs, all positions, 1/3 cut, angular metal window, 25 point, gray pressboard.

Guide Card GSA Stock Number
Letter-size 7530-00-989-0692 Legal-size 7530-00-989-0694
b. Lateral Guides (side tab). Use guide cards same as B.4.a. above except with 1/2 cut side tab. Procure these guide cards from commercial sources.
c. Inspection Case File Guide Cards. Use guide cards same as B.4.a. above except first position.

Guide Card GSA Stock Number
Letter-size 7530-00-988-6541 Legal-size 7530-00-988-6549


Records Disposition

A. Disposition. Disposition means the disposal (destruction), retirement, transfer or miniaturization of records. (Refer to paragraph E.1. on page 2 of the instruction for a definition of "record.") A recommended guideline is that any file station should keep only ACTIVE records on hand. Disposition of inactive subject or closed case files should be made following the approved records disposition schedule shown in Appendix F. Regular disposition frees space for new files and reduces the need for continual acquisition of file cabinets and expansion of office space.

B. Destruction of Records. Records should be destroyed upon the end of their disposition period in accordance with an approved disposition schedule.

1. Unclassified Records. Unclassified records may simply be placed in a waste basket.
2. Administratively Controlled Information and Classified Information. Administratively controlled information (including Privacy Act material and individual medical information) and classified information must be destroyed by shredding, burning, pulping or some other method which ensures that the information cannot be recovered. Destruction of this material must be witnessed by OSHA personnel, employees of other Federal agencies, or contract personnel who have had Federal background checks performed and are bonded. Appropriate security clearances are also required for classified information. Note the special requirements for asbestos-related records in OSHA Instruction ADM 12.6.

C. Transfer of Records. Effective controls must be maintained over retired records because they are subject to recall and re-use.

1. File Survey. File custodians should survey all compliance-related files in their custody no later then August 1 of each year and set aside the records which will be eligible for retirement on September 30. Records must have at least 3 years of the retention period remaining at the time the records are to be sent to the FRC.
2. Mandatory Transfer. Send inspection case files to a FRC not later than 3 years after the case is closed. They may be sent to a FRC at any time before the case has been closed 3 years at the discretion of the transferring field office.
3. Exceptions to Mandatory Transfer. Field offices MAY, if desired, maintain inspection case files at the field office until the end of the retention period if the case file is of special interest to the field office. Special interest compliance case files include those cases:
a. Involving companies in industries having no fixed worksite as in the construction industry,
b. That could result in repeat violations,
c. Involving multiple worksites in different geographical areas or States,
d. Which are unique or very unusual such as copper smelters,
e. Which are precedent-setting court cases, or
f. Which are otherwise of great value as reference sources.
4. Preparing Records for Transfer.
a. After selecting the records to be transferred to the FRC, divide the records into groups by disposition schedule item number and either the year created (for subject files) or the year closed (for case files). Each item number and fiscal year combination is one accession on the records transfer form. (Also see OSHA Instruction ADM 12.6 for instructions relating to asbestos-related records.)
b. Contact the FRC for the correct record containers and procedures for transferring nontextual records, such as undeveloped film, to the FRC.
5. Records Center Containers. Information in addition to that given below may be found in OSHA Instruction ADM 12.4.
a. Standard Containers. The box used to transfer records to the FRC is the records center box or carton measuring 14-3/4 x 12 x 9-1/2 inches. Each carton holds approximately 1 cubic foot of records. There are two combination letter and legal size records boxes available.

National Stock Number Description Unit of Issue
8115-00-117-8249 Box, Record 25 per bundle (Tuck-bottom)
8115-00-117-8344 Box, Record 25 per bundle (seal at bottom)
b. Nonstandard Containers. Contact the FRC for instructions on obtaining the appropriate box to use for transferring the records if using lateral file folders and they will not fit the standard 14-3/4 x 12 x 9-l/2-inch records boxes or if nontextual information, such as rolls of undeveloped film, are to be sent to a FRC.
6. Preparing Records Transfer Forms.
a. Preparing SF-135, Records Transmittal and Receipt. Follow the instructions on the reverse of the SF-135 and also in OSHA Instruction ADM 12.4.
b. Supplemental Records Listing for SF-135. When preparing the SF-135, the transferring office will prepare a Supplemental Records Listing of the records being transferred and will maintain a copy of the listing with the transferring office copy of the SF-135. (For additional information, see OSHA Instruction ADM 12.4.)
7. Submission of SF-135.
a. The transferring office shall send the original and three copies of the SF-135 to the FRC or, if the Regional Management Officer is the approving official, to the appropriate regional office which will review, approve, and forward the SF-135 to the appropriate FRC.
b. The appropriate FRC will assign accession numbers for each series of records. Exception: Region III offices in Virginia, Maryland, and West Virginia will request assignment of accession numbers from the Regional Records Management Officer (RRMO). The RRMO will obtain the accession numbers from the OSHA Records Management Officer. Federal offices in those States are served by the Washington National Records Center which relies on agencies to issue accession numbers.
8. FRC Review. The FRC will review the SF-135 for completeness and determine the propriety of the transfer. Be sure to cite the disposal schedule number and the applicable item number in block 6(h) of the SF-135. If the disposal authority is not shown on the SF-135, the FRC will return the SF-135 for completion of that block.
9. Shipment of Records.
a. Notification to Field Office. If the FRC approves the transfer, the FRC will return the SF-135 to the originating field office indicating approval to transfer the records.
b. Shipment. The transferring field office will ship the records to the FRC and also place a copy of the SF-135 in the first box of the first accession of the shipment. Be sure the accession number (example: 100-85-0023) and the box number (example: 5 of 10) are written on front (unstitched side) of the box and the folders face front. (Refer to OSHA Instruction ADM 12.4, for additional information.)
c. Administratively Controlled Materials. Seal those boxes which contain administratively controlled information, including all materials subject to the Privacy Act, and ink stamp the boxes "Administratively Controlled Information-Restricted Company Information" or write that designation across the sealing tape. Escort by OSHA personnel is not necessary during shipment. Use of special postal services such as Registered or Certified Mail is also not necessary.
10. Receipt of SF-135 from FRC.
a. The FRC will send a copy of the SF-135 to the transferring office.
b. The transferring field office will send a copy of the accessioned SF-135 to the regional office. The transferring office will maintain the agency record of the SF-135. The regional office will maintain the regional records security copy.

D. Reference Services. Federal Records Centers provide reference service to all Federal agencies.

1. Routine Requests. Use GSA Optional Form (OF) 11, Reference Request, Federal Records Center, to retrieve records from the FRC. The OSHA Record Group Number is 100.
2. Emergency Requests. Contact the FRC by telephone and make arrangements to either pick up the records or have them mailed. The requesting office shall contact the FTS Operator or refer to OSHA Instruction ADM 12.4, Appendix A, for the telephone number of the appropriate FRC.
3. Requesting Office. The office transferring records to the FRC is the only office authorized to recall or reference those records. ALL OTHER OFFICES MUST MAKE THEIR REQUEST THROUGH THE TRANSFERRING OFFICE.



A. This appendix provide information on compliance-related records, including subject and case files, and compliance file folder labeling requirements.

B. The following paragraphs constitute a listing, including descriptions and filing instructions, of compliance-related files including subject and case files. For additional information on files operations, including the creation and labeling of subject-expansion folders, see OSHA Instruction ADM 12.4. Information concerning the approved disposition/retention periods for these files may be found in Appendix F.

C. Compliance File Folder Labeling.

1. Inspection-Related Case Files.
a. Inspection Case Files. Folder labeling for these files is accomplished as required by Appendix D, paragraph C.2. on page D-1.

b. Other Inspection-Related Case Files.
(1) Folder labels for nonformal complaints, refused inspections, attempted inspections and referrals show the same information as inspection case files.
(2) If all of the individual files in a case file group (such as refused inspections, attempted inspections or similar files) are to be:
(1) Grouped in one folder or group of folders (not filed as one folder per case), and
(2) Maintained separately from the inspection case files; then
(3) Prepare the file folder label in accordance with Appendix A, paragraph F.1.b. on page A-3 and as shown below:
+-------------------------------------------+ |CPL 2B Refused Inspections FY-86| | Destroy 10/89| +-------------------------------------------+
This example shows the subject file category "CPL 2 inspection" expanded the subject-expansion "CPL 2B Refused Inspections." A subject-expansion category is an addition or expansion of an approved file category. Other possible subject-expansions of CPL 2 include fatalities, catastrophes, attempted inspections, and non-formal complaints. Subject-expansions are created by local offices for use at their option. (Refer to ADM 12.4)
2. Other Compliance-Related Case Files. File folder labels for establishment files, discrimination complaints, invalid complaints, and similar case files shall conform to the requirements of Appendix A, paragraph F.1.a., b., and c. on pages A-3 and A-4. Examples of a subject-expansion for establishment files and an individual establishment case file are given below:
| CPL 2C Establishment Files FY-86 | | | | Destroy 10/89 | |___________________________________________________|
| CPL 2C (Alhambra Cotton Company, FY-86 | | Alhambra, AL) | | Destroy When Closed | |___________________________________________________|

Appendix D


A. Introduction. This appendix outlines the structure and content of inspection case files. (For additional information concerning inspection case files, related forms, and procedures, refer to OSHA Instruction ADM 1-1.12A, OSHA Instruction CPL 2.45A, OSHA Instruction CPL 2-2.20A, and other related OSHA directives.)

B. Inspection Case File Definition. An inspection case file shall be composed of all essential documents relating to a single inspection of an establishment. Separate inspections of the same establishment shall be filed in separate inspection case files. However, actions which form an essential part or continuation of the original inspection, such as followups and interim monitoring inspections, shall be filed in the original case file. Simultaneous health and safety inspections of the same establishment shall be filed separately if they constitute complete, separate inspections.

C. External File Structure.

1. Alphabetic Filing.
a. Use the alphabetic filing rules developed for the IMIS when filing compliance-related records alphabetically. These rules are contained in OSHA Instruction ADM 1-1.12A.
b. Do not use the standard Federal alphabetic filing rules shown in OSHA Instruction ADM 12.4 as the IMIS alphabetic filing rules are inconsistent with the prescribed Federal Government system.
2. Label Preparation. The inspection case files shall conform to the information labeling scheme shown below:
a. Each folder may have two labels. (for lateral file folders, the first position is the top label and second position is the bottom label). If desired, the second position information may be written on the folder instead of typed on the label. (See Appendix A for a listing of file folders and labels.) Type or write only the following information on the appropriate folder label or in the folder label position.
|FIRM NAME INSPECTION NUMBER | | | |SITE ADDRESS CSHO INDENTIFICATION | | | |CITY, STATE, ZIP CODE | |_______________________________________|
| RECORDS DISPOSITION SCHEDULE ITEM NUMBER | | FISCAL YEAR CLOSED | |_____________________________________________|
b. When a safety 5(a)(1) violation is involved in a combined health and safety inspection and no sampling data is collected, show "Item 8a" as the records disposition schedule item on the second position label. This safety inspection records disposition schedule item is cited as the disposition period for the safety inspection because it is longer than the disposition period for a health inspection without sampling data (10 years vs 6 years).
c. The first position filing label listed in paragraph C.2.a. on page D-1 shall be a plain white label. The label used shall measure approximately 2 x 3-1/2 inches. (See Appendix A, paragraph J.3.b. for a description of this label.)
d. The folder tab's second position shall indicate the file code and the fiscal year closed. Type, stamp or write the information. If desired, the fiscal year closed may be color coded with a colored felt tip pen. (See Appendix A, paragraph J.3.a. for a listing of approved file folder labels.) (See Paragraph C.3.a. on page D-3 for a listing of color codings for disposition of the inspection case files.) The information may either be written directly on the folder tab or a label may be used.

3. Color Coded Folders or Labels.
a. In the absence of an automated system to identify the disposition categories of the inspection case files and selected related files, the color coding scheme outlined below will be used to identify the types of inspection case files and related files which fall under the records disposition schedule items also listed below. Do not color code records disposition items from Appendix F which are not included below. The other inspection-related files are disposable 3 years after case is closed (for item 10) or when 3-years-old (for item 19).

Records Disposition Type of Inspection Dot or label Schedule Item Case File Color

7 Closed Safety Inspections Blue
8 Safety General Duty Inspections Green
9 Safety Fatalities/Catastrophes Orange
11 Health Inspections Red
12 Non-Sampling Health Inspections Yellow
13 Referrals Goldenrod
13 Complaints Silver
b. Use pressure-sensitive color filing dots for the types of inspection case file listed in a. above. Place the dot in the third position (right edge) of the folder tab. Standard GSA colored file folder labels may be used as an alternative to the filing dots. (Refer to Appendix A, paragraph J.3.a., page A-6, for listing of standard GSA file folder labels.)
c. Color coding folders or labels for alphabetical filing is NOT recommended unless there is adequate space on the inspection case file folder to include the mandated labels which include all the information (including disposition information) specified paragraph C.2.a. on page D-1.

D. Internal File Structure.

1. Forms and Notes. All official forms and notes constituting the basic documentation of a case must be part of the case file. This material shall be attached to the RIGHT side of the case file folder in the order noted in paragraph E.1.a. All official forms and notes relating to follow up inspections shall be maintained in the same order, but shall be placed on top of the forms and notes relating to the original inspection.
2. Correspondence. All correspondence relating to the case shall be attached to the LEFT side of the folder in reverse chronological order; that is, with the most recent correspondence on top. (See paragraph E.1.b. for a description of the types of materials included as correspondence.)
3. Mail Receipts. Mail receipts shall be attached to the documents to which they relate. Be sure information is not covered by the receipt. If a mail receipt cannot be placed on the back of the related document, place the receipt on a blank sheet of paper and staple the paper to the applicable document.
4. Miscellany. Miscellaneous inspection case file documentation not clearly falling into either paragraph D.1. or D.2. above shall be filed as correspondence on the LEFT side of the folder. If too voluminous to fit easily into the inspection case file folder, file the information in a separate location but note the location on the inspection case file folder. If an establishment folder has been started on a company establishment, worksite, etc., safety manuals and similar material should be placed in the establishment folder and a crossreference note placed in the inspection case file. Make note that an establishment folder is a file on a company which was set up because of unusual conditions or situations and which contains correspondence, reference material, and other information which relate to a specific employer or establishment, but which are NOT associated with a specific inspection or compliance activity. These materials could include a Federal agency's action plan, a list of competent persons or anything else related to safety or health matters in the company or establishment.

E. Filing Arrangement.

1. Inspection Case File Contents.
a. Forms and Related Documentation. The following listing is an itemization of the OSHA forms and related documentation which shall appear on the RIGHT side of the case file, IN ORDER FROM TOP TO BOTTOM. File amendments and any official notes with the forms to which they relate.

(1) OSHA 2B Notification of Failure to
Abate Alleged Violation.

(2) OSHA 2 Citation and Notification of
Penalty. (This includes amendments. Place amendments on top of the original OSHA-2.)

(3) OSHA 2H Notice of Unsafe or
Unhealthful Working Conditions, or Hazard Correction List.

(4) OSHA 8 Notice of Alleged Imminent


(5) OSHA 1MOD Inspection

(6) OSHA 1 Inspection Report.

(7) OSHA 170 Investigation Summary.

(8) OSHA 36 Fatality/Catastrophe Report.

(9) OSHA 7 Notice of Alleged Safety or
Health Hazards. (This includes related complaint letters).
NOTE: File written complaints immediately behind the OSHA 7.
                      (10)  OSHA 1A   Narrative.  (This includes injury
                                      and illness data supporting the

(11) OSHA 94 Note Taking Sheet.
NOTE: Although the OSHA 94 is prescribed for use with the OSHA 1A as a continuation sheet by OSHA Instruction CPL 2.45A, it may be used with any of the compliance-related forms as a continuation or note taking sheet.

(12) OSHA 1B/ Worksheet.

NOTE: File here those forms which describe alleged violations that will appear on the citations. The OSHA 1B/1B(IH) forms are separated by sampling data forms. If a "General Duty" letter was sent, the related forms shall be the first set of forms in this category.

(a) OSHA 91A Air Sampling
(b) OSHA 91B Air Sampling Report.
(c) OSHA 93 Direct Reading Report.
(d) OSHA 98 Screening Report.
(e) OSHA 92 Noise Survey Report.
                              (f)  OSHA 99    Octave Band Analysis and
                                              Impact Noise.
NOTE: These are sampling data forms and continuation sheets which relate to the violation described on the OSHA-1B/1B(IH). Sampling forms and continuation sheets are placed behind the individual OSHA-1B/1B(IH) to which they relate. If the sampling forms relate to more than one (1) OSHA 1B/1B(IH), place the sampling forms behind the first OSHA 1B/1 B(IH) to which they relate. Note the location of the sampling forms on all other related OSHA 1B/1B(IH)'s.

(13) OSHA 89 Photo Mounting
NOTE: Negatives are located in an envelope on the left side of the folder.
(14) OSHA 1B/ Worksheet. 1B(IH)
NOTE: File here those forms which do not result in cited violations. This includes related sampling data forms and continuation sheets.) If the sampling forms relate to more than 1 OSHA 1B/1B(IH), place the sampling forms behind the first OSHA 1B/1B(IH) to which they relate. Note the location of the sampling forms on all other related OSHA 1B/1B(IH)'s.
(a) OSHA 91A Air Sampling Worksheet.
(b) OSHA 91B Air Sampling Report.
(c) OSHA 93 Direct Reading Report.
(d) OSHA 98 Screening Report.
(e) OSHA 92 Noise Survey Report.
(f) OSHA 99 Octave Band Analysis and Impact Noise.
NOTE: These are sampling data forms which are filed behind the appropriate OSHA 1B/1B (IH) and for which no citations were issued.
(15) Technical Information. This includes information supporting violations, employer's safety and health reports, material safety data sheets, and the like.
NOTE: Safety and health data and related information of long-term value in preparing for inspections shall be filed in the appropriate establishment file.

(16) OSHA 168 Inspection Assignment.

(17) OSHA 90 Referral Report.
(18) Field Notes. (Number field notes as a unit.)

(19) Compliance Plans.

(20) Other Materials.
(a) Developed Film. Place photographic negatives in envelopes and slides in plastic holders on the right side of the inspection case file folder or file photo negatives and slides in a separate location and note that location on the right side of the inspection case file folder.
(b) Undeveloped Film. These undeveloped rolls of film are related to specific inspections but were not developed because of no specific need or because the case was not contested.
1 This film is potential record material as long as it is useable.
2 File in a separate location and note that location on the right side of the inspection case file folder.
3 Label the film with the company name and the inspection number and the fiscal year the case was closed. Bundle all the film relating to a specific inspection together.
4 Undeveloped film should be destroyed 3 years after the case was closed as it is no longer useable at that time.
(c) Video Tape. These video tapes are related to specific inspections. Video tapes are record material and are an integral part of the inspection case file to which they relate. Follow the instructions in paragraphs (b) 2, 3, and 4.
b. Correspondence and Miscellaneous Information. The following is a list of the types of correspondence and miscellaneous case documentation which shall appear on the LEFT side of the case file.
(1) Method of Filing. This material shall be FILED IN REVERSE CHRONOLOGICAL ORDER (i.e., with the most recent correspondence and other information on top). DO NOT file this material in the order in which it is listed below. The diary sheet and the forms in paragraphs E.1.b. (2) through (6) on page D-10 are an exception to the reverse chronological order rule.
(2) Diary Sheet. This sheet is placed on the top of the material on the left side of the folder. The diary sheet may be used to note important telephone and face-to-face conversations, the date of important actions such as opening inspection date, date citation sent and any other activities deemed important enough to note on this summary of contacts. It also serves as a finding aid to the memoranda of conversation and memoranda to the record which were written to document the information imparted in these personal contacts. The diary sheet may also be used to document the receipt date of important correspondence. Do not use the diary sheet to record conversations or other messages.

(3) OSHA 166 Citation Record Update.
(4) OSHA 167I Inspection Record Update. (This also includes OSHA 1 forms for modifications only.)

(5) OSHA 167C Complaint Record Update.

(6) OSHA 163 Penalty Payment Report.

(7) Penalty Information.

(a) Request for payment.
(b) Carbon copy of penalty reminder.

(c) Copy of check.
(d) Letter of refusal to pay past due penalty.

(8) Abatement Information.

(a) Letter of abatement.
(b) Employer statement of abatement.
(c) Petition for Modification of Abatement (PMA) request and correspondence.
(d) Letter of past due abatement.
(e) Progress report of abatement.
(f) List of detailed expenditures for abatement.
(g) Contract work proposal (abatement agreements)

(9) Planned Method of Abatement.
(a) Letter requesting and correspondence relating to planned method of abatement.
(b) Letter of transmittal of planned method of abatement to field office for the Solicitor.
(c) OSHA acknowledgment of receipt of planned method of abatement.
(10) Contested Case Information and Correspondence.
(a) Review Commission orders.

(b) Letter of contest.
(c) Transmittal to Solicitor.
(d) Notice of receipt of case.
(e) Certification of final order.

(f) Final order.

(g) Statement of order.
(h) Final order of Commission decision.

(11) General Correspondence.
(a) Informal settlement information.
(b) Informal conference information.
(c) Denial of entrance information including application, warrant and related information.

(d) Letter of complaint.
NOTE: If an OSHA 7 is completed, file the complaint behind the OSHA 7 on the right side of the folder.
(e) Employer correspondence.
(f) Transmittal to Solicitor.
(g) Followup correspondence.
(h) Solicitor's correspondence.
(12) Informal Documentation. This includes memoranda to the file, memoranda of conversation, and similar informal documentation recording telephone calls, visits, meetings, and the like.
2. Numbering System for Forms.
a. Number the OSHA 1B/1B(IH)'s including sampling data forms as a unit such as 1 of 10, 2 of 10, 3 of 10, etc.
b. Number field notes as a unit: Page 1 of 20, Page 2 of 20, Page 3 of 20, and so on.
c. You may number individual forms, such as the OSHA 1A, when there are several copies of the form. Number as 1 of 5, 2 of 5, 3 of 5, etc.
d. DO NOT organize the case file documentation into appendixes. You may use divider tabs to permit easy reference.

e. DO NOT page number the case file as a unit.
3. Subdivision of Inspection Case Files. Elements of an inspection case file such as specific forms or groups of forms, citation-related photo worksheets, field notes, abatement information, informal conference information, and the like may be identified for easy reference using dividers with index tabs. This will allow compliance officers and others to quickly and easily find frequently referenced forms or groups of forms.

Appendix E


A. Introduction.

1. The Compliance Index File is intended to be a summary of the past inspection history of the company or establishment and serves as an aid in researching past violations, contest records, and the like.
2. Either electronic information retrieval systems or the OSHA 47, Inspection Case Summary, April 1989 edition, will be used for the file.
3. When the OSHA 47 is utilized for the compliance index file instead of an automated retrieval system, follow the instructions shown in the paragraphs below. The OSHA-47 is an 8-1/2 x 11 inch cut sheet form which may be completed manually, by typewriter or as computer output.

B. Establishment and Maintenance of the OSHA 47.

1. An OSHA-47 is completed when an inspection is completed and when action is completed on a nonformal complaint, refused inspection, attempted inspection, or for referrals handled via letter.
2. The OSHA-47 will be maintained alphabetically by the name of the company or establishment. (See OSHA Instruction ADM 1-1.12A concerning alphabetical filing rules and Appendix F of this instruction for the correct records disposition item.)

C. Completion of the OSHA 47. Fill out the blocks on the OSHA-47 in accordance with the following instructions: (Refer to Figure E-1 for a sample of an OSHA-47.)

1. Firm Name. Enter the complete name of the company or corporation.
2. Closing Conference Date. Enter the date of the inspection's closing conference.
3. Date Case Closed. Enter the date upon which all actions concerning the case were completed. This includes completion of the inspection, end of the abatement period, when payment was received for fines levied, or when contest was settled including when all appeals were completed.
4. Inspection Number. Enter the inspection number.
5. CSHO ID. Enter the CSHO identification number.
6. Reporting ID. Enter the appropriate reporting ID for the field office conducting the inspection from OSHA Instruction ADM 1-1.12A.
7. Primary SIC. Enter the primary industry SIC Code for the establishment.
8. Contest Docket Number. If a citation or penalty is being contested, enter the docket number assigned.
9. Inspection Site (Street Address). Enter the name of the establishment (if different from the firm name in block 1) and the complete mailing address of the inspected premises. If the firm address is not the inspection site, enter the firm address to the right of the inspection site address.
10. Management Representative. Enter the name and title of the company representative.
11. Scope of Inspection. This block consists of several check boxes dealing with the scope of completeness of the inspection. Check the applicable items.
12. Types of Violations. Check those boxes for the appropriate violation/citation(s). If no violation was found, check the "In-compliance" box.
13. Inspection Category. This block has check boxes which describe the category of the inspection. Check or X the appropriate boxes. (Refer to Appendix C, paragraph F.4.)
14. Type of Inspection. This block consists of several check boxes and the descriptions relating to them. Check the box of the description which is the primary reason the inspection was initiated.
15. Disposition Item Number. Enter the applicable records disposition schedule item number from Appendix F.
Note: When a safety 5(a)(1) alleged violation occurs in a combined safety and health inspection and no sampling data was collected, show records disposition schedule item number 8a and dispose of the case file in accordance with that schedule item.
16. Scheduled Disposition Date. Enter the year when the inspection case file is scheduled for disposition; i.e., when the file is supposed to leave office space and will be destroyed or sent to an FRC.
17. Disposition Action. This item shows what disposition was made of the case file when it left the office. The item is divided into two parts:
a. To FRC. Accession Number. When the inspection case file is sent to a Federal records center for storage, enter the accession number from the standard Form 135, Records Transmittal and Receipt, Block 6, columns (a), (b), and (c).
b. Destruction Date. If the inspection case file has passed the end of its disposition period, enter the date the case file was destroyed (either in the office or in the FRC).
18. Citation Identification. Enter the citation number (Cit. No.), the item number (Item No.), and the code for each citation/violation (CT).
19. Standard, Regulation, or Section of the Act Allegedly Violated. Enter the appropriate information under each column. For the "Part" column, enter only the last two digits.
20. Penalty. Enter the appropriate dollar amounts for the "Proposed" and "Final" columns. If the citation and/or penalty is contested, enter the appropriate code under the contest (C) column.
21. Substance Code. Enter the appropriate substance code.
22. Final Order. Enter the date of the final order for each citation item under the "Date" column. Under the "Decision" column, enter the appropriate code. When using code "M" to indicate a modified decision, explain how the decision was modified. If more space is needed, continue on a blank 5 x 8 inch card and staple the card to the back of the OSHA 47.

Appendix F


A. Description of Schedule. The compliance related records listed on this records disposition schedule are records created or accumulated by OSHA area offices and subordinate field offices. It does not include records maintained in regional offices. This schedule covers records related to compliance inspections.

1. Records Disposition Schedule Number. The records disposition schedule number assigned to the compliance-related records on this records disposition schedule by NARA is NC1-100-82-1.
2. Records Disposition Authority. The number of the records disposition schedule (plus the number of the individual records disposition item) cited in paragraph A.1. above is the sole authority granted to OSHA field offices to dispose of compliance-related records including inspection case files. This number, together with the item number, is cited when the authority allowing OSHA field offices to dispose of compliance related records must be cited on a document. This includes citing the records disposition authority on an SF-135, Transfer of Records, permitting transfer of records to an FRC.
3. Supersession. This schedule supersedes all records disposition items in Schedule NC-174-254 dated July 1, 1974 and those items in Schedule NC1-100-77-1 dated November 1, 1977 but only as those items apply to area offices and subordinate offices and to compliance-related files including inspection case files, establishment files, discrimination files, and other similar files relating to OSHA Federal compliance activities including Federal agency compliance activities. This schedule applies to all inspection operations offices consisting of area offices, and subordinate field offices. This includes successor offices and organizations.

B. Records Disposition Schedule NC1-100-82-1 Items and Disposition. The records disposition schedule contained in this appendix consists of 4 columns.

1. Item Number. The first column gives the item number of the particular series of records covered by that item on the schedule.
2. Title. The second column shows the title of the series of records; such as, "Reports," "Closed Safety Inspections," "Health Inspections," and the like.
3. Description. The third column is an explanation of the types of records which are included in that item.
4. Disposition.
a. The fourth column shows the authorized disposition instructions for the series of records covered by the records disposition schedule item.
b. Some of the items in this column show sub-item listings. They may be identified by a letter prefix (a or b). For example, the first disposition listing in Item 1 is Item 1a for the field office record copy of general record material. Item 1b covers other copies.
c. Unless otherwise specified by the regional office, the record copy is always located in the area office.

Subject: Change 1 to OSHA Instruction ADM 12.5, OSHA Compliance Records

A. Purpose. This change instruction transmits revised pages to OSHA Instruction ADM 12.5.

B. Scope. This instruction applies OSHA-wide.

C. Reference. OSHA instruction ADM 12-7.4, Safety Fatality and Catastrophe Case File Disposition.

D. Action.

1. Remove pages F-3 thru F-7 and replace them with the attached changed pages. Changes are marked in the left margin by a vertical line.
2. File this transmittal page after the signature page of the instruction as a record of this change.

E. Explanation.

1. The disposition period for safety fatality/catastrophe inspection case files was changed form a 10 year retention to Permanent retention for item 9 on page F-4. In order to capture all safety fatality/catastrophe inspection case files, the disposition for item 24, safety inspections closed on or before September 30, 1982 on page F-7 was also changed form 10 years to Permanent. Refer to OSHA Instruction ADM 12-7.4 for the new disposition instructions for these permanent records.
2. The references to OSHA Instruction ADM 12.6A in items 11 and 12 on page F-5 have been removed because that instruction was canceled.

David C. Zeigler Director Administrative Programs

Distribution: National, Regional and Area Offices, OASAM


TITLE: General Material TITLE: Policy Material

DESCRIPTION: General correspondence DESCRIPTION: Records and other and other material relating to materials reflecting policy, inspection activities in federally precedent, and the like relating to inspected States or within Federal planning, developing, and directing agencies. the Federal Inspection Program. The The Agency Record Copy of these documents is maintained in other offices. This material does not include published instructions, notices, and other directives, manuals, and the like.

DISPOSITION: a. Record Copy: DISPOSITION: Destroy when

Destroy when 3 superseded or obsolete. years old.
b. Other Copies: Destroy when 2 years old.


TITLE: Reports TITLE: Activity Reports

DESCRIPTION: Covers all inspection DESCRIPTION: Periodic summaries or compliance activities except of work performed by those which are covered elsewhere administrative or program in this schedule such as reports personnel. properly part of an inspection case file. The Agency Record Copy of substantive reports is maintained in other offices.

DISPOSITION: a. Record Copy: DISPOSITION: Destroy when 2

Destroy when 3 years old. years old.
b. Other Copies: Destroy when 2 years old.


TITLE: Meetings/ TITLE: Active/Open Committees Case files

DESCRIPTION: Meetings and DESCRIPTION: Includes all committees that relate to safety inspection case files upon and health inspection functions and which an action remains to be activities. The Agency Record Copy completed. Except inspection of these records is maintained in case files in contest, see other offices. Does not include Item 16. advisory committes.

DISPOSITION: Destroy when 3 years DISPOSITION: Place in closed or old when no longer needed for case file after all actions have reference. been completed. See items 7 thru 13 below.


TITLE: Closed Safety TITLE: Safety General Duty Inspections Inspections

DESCRIPTION: Safety inspection case DESCRIPTION: Consists of case files relating to a specific safety files of safety inspections, where inspection in a specific General Duty Clause (5.a.1 of the establishment. Includes related Act) violations occurred. Includes follow up inspections and Proposed related follow up inspections and Modification of Abatement (PMA) PMA monitoring reports. monitoring reports.

EXCEPT: Combined health and safety EXCEPT: Case files involving inspections, General Duty safety fatalities or catastrophes, see inspections, safety in-compliance Item 9. inspections, safety fatality and catastrophe inspections and safety inspections classified as special interest, see items 8 thru 12 below.

DISPOSITION: a. Record Copy. DISPOSITION: a. Record Copy.

Transfer to Federal Transfer to FRC Records Center (FRC) not later than 3 not later than 3 years after case years after case is is closed. closed. Destroy Destroy 10 6 years after case years after case is closed. is closed.
b. Other Copies. Destroy b. Other Copies. material not placed in Destroy material the record copy when not placed in file is consolidated. the record copy when file is consolidated.

|ITEM NUMBER: 9 ITEM NUMBER: 10 | |TITLE: Safety Fatalities/ TITLE: Safety In-Compliance | Catastrophes Inspections | |DESCRIPTION: Case files of safety DESCRIPTION: Case files of safety |inspections involving Catastrophes inspections where no violations were |fatalities and/or catastrophes. cited. Includes inspections where |Includes related follow up only a records review was conducted. |inspections and PMA monitoring |reports. | |THIS ITEM HAS BEEN SUPERSEDED BY |SCHEDULE N1-100-90-1, ITEM 23. |REFER TO OSHA INSTRUCTION |ADM 12-7.4 FOR ADDITIONAL |INFORMATION. | |DISPOSITION: a. Record Copy. DISPOSITION: a. Record Copy. | Transfer to FRC Destroy 3 years | not later than 3 after case is | years after case closed. | is closed. Destroy | 10 years after case | is closed. | | b. Other Copies. Destroy b. OtherCopies. | material not placed in Destroy material | the record copy when file not placed in | is consolidated. the record copy when file is consolidated.


TITLE: Health Inspections TITLE: Non-Sampling Health


DESCRIPTION: Case files of DESCRIPTION: Case files of industrial hygiene inspections and industrial hygiene inspections and combined safety and industrial combined health and safety hygiene inspections. Includes in-compliance inspections. Consists health and combined health and of inspecitons where sampling data safety in-compliance inspecitons. was not collected. Also includes related follow up inspections and PMA monitoring EXCEPT: Combined health and safety reports. (Also refer to OSHA inspections which involve safety instruction ADM 12.6 for information General Duty Clause inspections, regarding asbestos-related records.) dispose in accordance with Item 8.

DISPOSITION: a. Record Copy. DISPOSITION: a. Record Copy.

Transfer to FRC not Transfer to FRC later than 3 years not later than 3 after case is closed. years after case is closed.
Destroy 40 years after Destroy 6 years case is closed. after case is closed.
b. Other Copies. b. OtherCopies. Destroy material not Destroy material placed in the record copy not placed in when file is consolidated. the record copy when file is consolidated.


TITLE: Non-Formal Complaints TITLE: Reserved and Referrals

DESCRIPTION: Inspection case files DESCRIPTION: Reserved relating to complaints and Referrals or referrals concerning unsafe or unhealthy conditions in an establishment. No inspection is made of the establishment. Except for nonformal complaints which become formal and referrals which result in an inspection, see Items 8 thru 12, as appropriate.


Destroy when 3 years old.
b. Other Copies. Destroy material not placed in the record copy when the file is consolidated.


TITLE: Reserved TITLE: Contested

Cases Duplicate File

DESCRIPTION: Reserved DESCRIPTION: This category covers

duplicate inspection case files when the establishment or firm appeals a citation or penalty. The original file is sent to the Solicitor and remains there until the appeal is decided. After the original file is returned to the originating office, merge the duplicate file into the original file destroying all duplicate documentation.

DISPOSITION: DISPOSITION: When the original file is returned to the originating office, merge the duplicate file into the original file destroying all duplicate documentation. Dispose inaccordance with the applicable inspection case file disposition item.


TITLE: Reserved TITLE: Establishment Files

DESCRIPTION: Reserved DESCRIPTION: Case files of

establishments, companies, firms or Federal, State or local government worksites which do not relate to a specific inspeciton. This includes health hazard evaluations, process descriptions, production data, product toxicity data, engineering controls, Federal agency action plans, lists of competent persons , and any other information of value relating to safety and health matters.

DISPOSITION: DISPOSITION: Destroy when establishment or firm no longer exists or when no longer needed, whichever occurs first.


TITLE: Refused and Attempted TITLE: Invalid Complaints Inspection Files

DESCRIPTION: Records and other DESCRIPTION: Complaints which materials relating to proposed are not related to occupational inspections which did not occur safety and health or are not covered because entry was denied by the by OSHA. Includes appeals where the establishment and a magistrate, area office director determines the the Solicitor, or the agency complaint is invalid for redress and made a determination not to and the complainant appelas the proceed. Also includes proposed decision. inspections which did not occur because a decision was made not to EXCEPT: Successful which appeals attempt an inspection because the which are filed in the appropriate firm was no longer in operation, item elsewhere in this schedule. the occurrence of a labor action, or a similar situation.

DISPOSITION: a. Record Copy. DISPOSITION: Destroy when 1

Destroy when 3 year old. years old.
b. Other Copies. Destroy when 1 year old.


TITLE: Discrimination TITLE: Reserved

DESCRIPTION: Records dealing with DESCRIPTION: Reserved employer discrimination or retaliation (under Section 11(c) of the Act) against employees who report violations of the Act or cooperate with OSHA inspections. Consists of copies of materials sent to another office for investigation. Does not include investigative files.

DISPOSITION: Destroy when 1 year DISPOSITION: old.



TITLE: Compliance Index File |TITLE: Safety Inspections Closed

| on or before September | 30, 1982 | DESCRIPTION: This file consists of |DESCRIPTION: Includes all safety card files (OSHA 47 or equivalent |inspection case files closed on or including predecessor or successor |before September 30, 1982. forms) or information maintained in | office automation equipment or in |THIS ITEM HAS BEEN SUPERSEDED BY printout form as an alternative used |SCHEDULE N1-100-90-1, ITEM 23. to provide referenc and case |REFER TO OSHA INSTRUCITON ADM 12-7.4 tracking capabilities for the |FOR ADDITIONAL INFORMATION. inspection case files. | | | DISPOSITION: Destroy when no longer |DISPOSITION: a. Record Copy. need for reference but not later than| Transfer to FRC 40 years after case is closed or 12 | if 3 years of years after State assumes inspection | retention period duties. | remains, Destroy | 10 years after | case is closed. | | | b. Other Copies. | Destroy material not | placed in the record | copy when file is | consolidated.


TITLE: Health Inspections Closed on or before September 30, 1982

DESCRIPTION: Includes all industrial hygiene inspection case files and combined safety and industrial hygiene inspection case files closed on or before September 30, 1982.

DISPOSITION: a. Record Copy.

Transfer to FRC if 3 years of the retention period remains. Destroy 40 years after case is closed.
b. Other Copies. Destroy material not placed in the record copy when file is consolidated.

Appendix G


A. Introduction. This appendix provides instructions and procedures for implementing this instruction.

B. Action To Be Taken. Field offices will implement this instruction not later than 6 months after the date of this instruction except for the longer implementation period in paragraph B.5. below for records in the FRC. Implementing the instruction means:

1. Converting the filing labels on all compliance case files (including inspection case files) opened on or after the date of this instruction.
2. Applying the records disposition schedule items to all current compliance-related subject files.
3. Arranging all inspection case files opened on or after the date of this instruction in accordance with Appendixes C and D.
4. All inspection case files eligible to be sent to the FRC are arranged into the appropriate safety and health file categories in Appendix C.
5. All health and safety inspection case files previously sent to the FRC together as one accession and not separated by disposition Items 24 and 25 in Appendix F are identified and separated.
a. Implement paragraph B.5. not later than 1 year after the date of this instruction.
b. Field offices will contact the appropriate FRC to determine what actions are necessary to properly identify and assign new retention/disposition periods to these records in the FRC.

C. Implementation Responsibilities.

1. The OSHA Records Management Officer shall monitor regional implementation of this instruction.
2. Regional Records Management Officers shall oversee and review the progress of field offices in the implementation of this instruction, and to assure that all supplies needed for implementation of the instruction are available to field offices.
3. Field office directors are responsible for implementing this instruction as soon as possible but not later than 6 months after the date of this instruction. Health and safety inspection case files previously sent to the FRC commingled in single accessions must be separated into separate health and safety accessions within 1 year after the date of this instruction.

D. Records Conversion Preparation. Beginning a new records system or converting from an old system to a new system requires careful planning and thoughtful implementation if the new system is to succeed.

1. Instructions. Read and review this instruction until you are familiar with its contents.
2. Obtain Filing Supplies. Obtain the filing supplies required by the system. The instruction contains descriptions of all the filing supplies you will need.
3. Obtain Records Transfer Boxes. Obtain enough boxes to hold all the inspection case files that will be transferred to the FRC. (Refer to Appendix B of this instruction for information on where to obtain boxes and GSA stock numbers.)

E. Conversion of Compliance-Related Records.

1. Set up subject file folders for compliance-related records in CPL 2 and FAP 1. These folders shall only contain general material dealing with miscellaneous information or documents relating to each of those subjects as defined and explained in Appendix C of this instruction. Do not include information relating only to specific case files in these folders. Note that the disposition schedule items that apply to these general material folders are items 1.a. or 1.b. in Appendix F. Prepare folder labels as shown in Appendix A, paragraph F.1., page A-3, and Appendix D, paragraph C.2., page D-1.
2. Set up compliance-related case file folders as specified in Appendix A, paragraph F.1., page A-3, and Appendix C, paragraph C., page C-8.

F. Conversion of Inspection Case Files. Inspection-related case files such as nonformal complaints, referrals, refused inspections, and attempted inspections are included in this paragraph. The tasks for conversion are outlined below:

1. Files Opened On or After the Date of the Instruction. All inspection case files opened on or after the date of this instruction must be arranged in accordance with the new file structure and the new labeling format outlined in Appendix C.
2. Files Opened Before the Date of this Instruction. Do not change the file structure or labeling format of those inspection case files opened before the date of this instruction. Do not place them in new file folders. You may structure recently opened inspection case files to conform to the new file structure.
a. Transfer to FRC.
(1) Transfer those inspection case files eligible for transfer to a FRC. Refer to Appendix B for information on transferring records to the FRC. DO NOT relabel, place in new file folders, or change the order of the case file contents to conform to the new system.
(2) Revise disposition periods of records in the FRC that cite Records Disposition Schedule NC-174-254 as the disposal authority on the SF-135. The inspection case files located in the FRC must have their disposition periods changed to reflect the new dispositions in Appendix F of this instruction.

b. Recall of Inspection Case Files.
(1) If safety and health inspection case files are interfiled or commingled in one accession in the FRC, contact the FRC to determine if the health inspection case files must be withdrawn and reaccessioned. If so:
(a) Recall all health inspection case files from the FRC which were interfiled with safety inspection case files.
(b) When applying to withdraw health inspection case files from the FRC, check the "Permanent Withdrawal" block on the "Nature of Service" line on the Optional Form 11, Reference Request - Federal Records Centers.
(c) After the records have been received, repack the records in new records transfer boxes.
(d) Resubmit the records on new SF-135 records transmittal forms. Follow the instructions in Appendix B.
(2) If the FRC determines that repacking health case files into separate boxes is not necessary + because the health and safety inspection case files are contained in separate boxes in the same accession or for any other reason, amend the disposition items on the Standard Form 135 transfer papers by letter. Be sure to cite the accession + numbers, and the revised disposition authority and disposition date for each box in the accession.
3. Compliance Summary Card. Complete OSHA Form 47 for all inspection case files in the area office which are active/open on the date of this instruction. As an alternative to maintaining OSHA Form 47, the information may be maintained in an electronic information retrieval system.

G. Internal Procedures.

1. Offices should develop internal operating procedures for managing the inspection case files and other compliance-related records. Internal procedures are particularly useful when professional employees find it necessary to service the files and when familiarizing new employees in file operations.
2. Internal operating procedures should spell out in detail who is responsible for specific actions, the rationale for the action, criteria used while performing the action, and the order in which actions are performed.

Appendix H


This appendix consists of frequently asked questions and comments received from offices reviewing drafts of this instruction and the answers to those questions and comments.

1. Question: Are Federal agency programs covered by this

Answer: Yes.

2. Question: Why should field offices prepare file folder

labels as shown in Appendix A, paragraph B.5.?
Answer: Appendix A provides a restatement of the agency's records management policies contained in OSHA Instruction ADM 12.4. This instruction enumerates agency policy and procedures concerning records management including preparation and format of file folder labels.

3. Question: Why should we use the charge-out system

mandated by Appendix A, paragraph G? Charge-out systems do not work except in large organizations with central files.
Answer: The advantages of the simple charge-out system in the instruction in a small office, such as an area or district office, with limited clerical resources are many. One advantage is the time saved professional staff in knowing where charged-out files or papers are located without engaging in long, often fruitless, searches. Any charge-out system will work if the users wish it to work. Charge-out systems can easily work and work well if the users decide or are instructed to abide by the rules.

4. Question: Why have a files custodian and "classifier" in

each office?
Answer: ONE person must be responsible for the files or there is no control and files and papers will often be lost or misplaced. A files custodian will see that charge-out procedures and good files discipline are observed.
A "classifier" is needed to be sure all materials are filed in a location where they can be easily retrieved. This is not an easy task unless the person classifying records knows what the office does, why it does it, and how people will request filed materials. The files custodian and the "classifier" are usually the same person.

5. Question: Who should do files classification for inspection

case files?
Answer: Clerical personnel are usually responsible for files classification. Secretaries often know more about office procedures,the subject(s) of record request, how (and why) records are retrieved, and the office's records than anyone else. The "classifier" must know and understand office organization, procedures, and operations; and records organization, management, and operations. If desired, the "classifier" could also be a supervisor or compliance officer if specialized knowledge is needed for proper records classification.

6. Question: Why should the regional office maintain a

reference copy of the SF-135? If the area office closed, the records would be transferred to the regional office or to another area office.
Answer: Are you sure? In many agencies, SF-135's have been frequently lost in office consolidations, moves, or closings by people whom you would expect to remember to transfer the SF-135's. All too often, the SF-135's are destroyed through oversight or because other, more important things needed to be done at the time.

7. Question: Why does the FRC refuse to accept safety

inspection case files after 3 years after the case is closed?
Answer: The FRC refuses to accept records having less than 3 years of their retention period remaining when sent to the FRC. The purpose of this regulation is to reduce FRC expenditures for records accessioning, records reference services, records disposition, and fixed costs.

8. Question: Why should we recall inspection case files from

the FRC?

9. Answer: Records having different retention periods may

not be stored in the same box or in the same accession. If the health inspection case files, which are interfiled with safety inspection case files, are not recalled, the FRC will send all the interfiled inspection case files back to you for storage.

9. Question: Is the mandatory transfer of inspection case

files 3 calendar years or 3 fiscal years?
Answer: The OSHA record year is the fiscal year. (Except: Records required to be maintained for a different record year such as payroll or leave records.) The mandatory transfer of inspection case files is in 3 FISCAL years. However, records which were filed by calendar year may be retired on a calendar year basis. Set up new files by fiscal year rather than calendar year.

10. Question: Does the FRC accept partially filled boxes?

Answer: No. All boxes should be filled as much as possible. If necessary, move records from one box to another. Boxes should have approximately 2 inches of free or "finger" space. A partially filled box is acceptable only if records will be interfiled in the box after the box has been sent to the FRC. Indicate on the SF-135 which boxes are partially filled and will have records sent to the FRC for interfiling at a later date.

11. Question: For attempted inspections in Appendix C,

paragraph B.5.C. on page C-4, do you have to have a separate folder for each?
Answer: No. These may be filed together in one folder or a group of folders, if desired.

12. Question: Why file contested cases in special categories

instead of under "open" files?
Answer: The "open" file category contains the record copy of original or follow up inspections in progress, undergoing abatement of hazard, etc.
In contested cases, the record copy is not in the field office but is in the Solicitor's office. The field office has a copy of the official file. Extra copies, especially suspense copies, of records are not filed with the records but are held separately so there is no mistake about the identity of the record copy.

13. Question: Why have establishment files? This is a time

consuming project. How can this be performed uniformly and properly in a timely manner?
Answer: Inspection case files deal with one inspection. Establishment case files deal with materials having long-term significance. Subsequent inspections of an establishment require the inspector to go from inspection case file to inspection case file searching each case for relevant information. Placing information of long-term significance in one location for reference will reduce search time thereby freeing professional staff time for more productive uses.

14. Question: Are active/open inspection case files to be filed

separately from other categories?
Answer: Yes.

15. Question: Closed inspection case files are currently in one

location with out-of-business inspections, nonformal complaints, etc. interfiled. Do we continue this?
Answer: Yes.

16. Question: How do we label compliance-related files such as

nonformal complaints, establishment files, etc.?
Answer: Refer to Appendix C for information on labeling compliance-related case files.

17. Question: Our office uses alphabetical color coded labels

and alphabetic letters. What do we do with the new labeling scheme?
Answer: You may continue to use alphabetically color coded labels as long as there is sufficient space on the folder tab to place the first position label and record the information in the second position as specified in Appendix D. The information on the first position label must be complete as specified in that appendix. The records disposition color coded label or dot required in Appendix D, paragraph C.3. on page D-2 may be placed in the second position to allow space on the folder tab for the alphabetical color coded label.

18. Question: How do we file Federal agency inspections?

By department, agency, etc.?
Answer: File alphabetically in descending organizational structure as follows:
a. Department or independent agency,
b. Bureau, agency, or administration, and
c. Office, establishment, or worksite.

19. Question: Why do you separate the left side of the file

into seven separate categories?
Answer: We don't. Correspondence is filed in reverse chronological order with a few exceptions which are shown in Appendix D, paragraph E.1.b on page D-8.

20. Question: Why not use a diary sheet?

Answer: We are using a diary sheet as a record of the dates of informal communications and case events. These communications and events are recorded on a memorandum for the record or a memorandum of conversation and are then filed in reverse chronological order as the communication or event occurs.

21. Question: Why not file the informal settlement agreement on

the left side in chronological order?
Answer: It is.

22. Question: Why not number all pages starting with the OSHA

Answer: Page numbering is done to aid in searching and identifying information. The inspection case file is not page numbered as a whole. Groups of forms, such as the OSHA 1B and 1B/(IH)'s, may be page numbered. Those portions of the inspection case file not page numbered do not require additional locational information. Page numbering is not done as an aid in furnishing information in response to Freedom of Information Act requests.

23. Question: Why attach mail receipts to the back of

Answer: They are less likely to be separated from the document to which they relate.

24. Question: In Appendix D, is correspondence and

miscellaneous information filed in reverse chronological order only?
Answer: Yes, except for the diary sheet, film negatives and videos, and OSHA Forms 163, 166, 167C and 167I.

25. Question: If a letter of complaint results in an OSHA 7,

where should the letter be filed?

Answer: Behind the OSHA 7.

26. Question: Are labels placed side-by-side or one under the

other on the inspection case file folder?
Answer: They are placed side-by-side unless lateral files are used.

27. Question: Is it necessary to complete an OSHA Form 47 if

case file information is maintained on an electronic information retrieval system (ALTOS or other microcomputer) or on the HOST computer?
Answer: No, as long as the information on the OSHA 47 is maintained in the electronic information retrieval system. OMDS is exploring the feasibility of developing software for the use of all area offices.

28. Question: Can we destroy all safety in-compliance

inspection case files 3 years after the case is closed without sending them to the FRC?
Answer: Yes. The retention period is completed after the 3 years and they may be destroyed.

29. Question: How do we separate health from safety inspection

case files stored in the FRC when they were sent to the FRC commingled?
Answer: Query the IMIS concerning health inspections and recall those inspection case files from the FRC. (Refer to Appendix G.)

30. Question: How far back do we go in separating inspection

case files in the FRC?
Answer: ALL inspection case files in the FRC not separated into health and safety must be separated.

Archive Notice - OSHA Archive

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.