- Record Type:OSHA Instruction
- Current Directive Number:ADM 12.5
- Old Directive Number:ADM 12.5
- Title:OSHA Compliance Records
- Information Date:
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.
- 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
- 6. OSHA Instruction CPL 2-2.20A, Industrial Hygiene Technical
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
- 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
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
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
- (7) Nonformal Complaints.
- 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
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
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
- 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
- 4. Compliance-related subject files may be filed in a different
official file station, possibly with other subject files, if
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
- 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
- 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
- |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
- 2. Inspection case file folder labels and related case file
labels such as nonformal complaints are prepared differently. (See Appendix
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.)
- 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
- 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
- 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
- Letter-size 7530-00-663-0031 (9-1/2 x
- 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
- Lateral Letter-size 7530-00-881-2957 (9-1/2 x 12
- 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
- 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
- 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
- Pressure-Sensitive 7530-00-054-1575 Label (2 x
- 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
- Letter-size 7530-00-989-0692 Legal-size
- 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
- c. Inspection Case File Guide Cards. Use guide cards
same as B.4.a. above except first position.
- Letter-size 7530-00-988-6541 Legal-size
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
- 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
- e. Which are precedent-setting court cases, or
- f. Which are otherwise of great value as reference
- 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
- 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
- 8115-00-117-8249 Box, Record 25 per bundle
- 8115-00-117-8344 Box, Record 25 per bundle (seal at
- 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
- 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
- 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
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
- (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
- +-------------------------------------------+ |CPL 2B
Refused Inspections FY-86| | Destroy
- 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 |
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
- 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
- |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
- 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
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
- 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
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
- 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
- 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
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.
- Abate Alleged Violation.
- Penalty. (This includes amendments. Place
amendments on top of the original OSHA-2.)
- Unhealthful Working Conditions, or Hazard Correction
- Health Hazards. (This includes related complaint
- NOTE: File written complaints immediately behind
the OSHA 7.
(10) OSHA 1A Narrative. (This includes injury and illness data supporting the OSHA-1A)
- 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.
- 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
- (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
- NOTE: Negatives are located in an envelope on the
left side of the folder.
- (14) OSHA 1B/ Worksheet.
- 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
- (a) OSHA 91A Air Sampling
- (b) OSHA 91B Air Sampling
- (c) OSHA 93 Direct Reading
- (d) OSHA 98 Screening
- (e) OSHA 92 Noise Survey
- (f) OSHA 99 Octave Band Analysis and Impact
- NOTE: These are sampling data forms which are
filed behind the appropriate OSHA 1B/1B (IH) and for which no citations were
- (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.
- (18) Field Notes. (Number field notes as a
- (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
- (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
- 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
- 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
- 4 Undeveloped film should be destroyed 3
years after the case was closed as it is no longer useable at that
- (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
- 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
- (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.
- (4) OSHA 167I Inspection Record Update. (This also
includes OSHA 1 forms for modifications only.)
- (b) Carbon copy of penalty
- (d) Letter of refusal to pay past due
- (b) Employer statement of
- (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
- (g) Contract work proposal (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
- (a) Review Commission orders.
- (c) Transmittal to Solicitor.
- (d) Notice of receipt of case.
- (e) Certification of final order.
- (h) Final order of Commission
- (a) Informal settlement
- (b) Informal conference
- (c) Denial of entrance information including
application, warrant and related information.
- NOTE: If an OSHA 7 is completed, file the
complaint behind the OSHA 7 on the right side of the
- (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
- 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
- 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.
- 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
- 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
- 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
- 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
- 7. Primary SIC. Enter the primary industry SIC Code for
- 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
- 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
- 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
- 17. Disposition Action. This item shows what disposition
was made of the case file when it left the office. The item is divided into
- 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
- 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
- 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
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
- 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
- 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
- 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.
- 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
- 2. File this transmittal page after the signature page of the
instruction as a record of this change.
- 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
- 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
David C. Zeigler Director Administrative Programs
Distribution: National, Regional and Area Offices, OASAM
ITEM NUMBER: 1 ITEM NUMBER: 2
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
- b. Other Copies: Destroy when 2 years
ITEM NUMBER: 3 ITEM NUMBER: 4
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
ITEM NUMBER: 5 ITEM NUMBER: 6
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.
ITEM NUMBER: 7 ITEM NUMBER: 8
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
- 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.
ITEM NUMBER: 11 ITEM NUMBER: 12
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
ITEM NUMBER: 13 ITEM NUMBER: 14
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.
DISPOSTION: a. Record Copy. DISPOSITION:
- Destroy when 3 years old.
- b. Other Copies. Destroy material not placed in the
record copy when the file is consolidated.
ITEM NUMBER: 15 ITEM NUMBER: 16
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
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.
ITEM NUMBER: 17 ITEM NUMBER: 18
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.
ITEM NUMBER: 19 ITEM NUMBER: 20
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
ITEM NUMBER: 21 ITEM NUMBER: 22
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.
ITEM NUMBER: 23 |ITEM NUMBER: 24
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 |
ITEM NUMBER: 25
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.
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
- 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
- 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
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
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
- 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
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
- (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
- (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
- (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
- (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
- (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
- 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
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
- 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
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
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
- 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
4. Question: Why have a files custodian and "classifier" in
- 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
- 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
5. Question: Who should do files classification for inspection
- 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
- 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
- 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
8. Question: Why should we recall inspection case files from
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
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
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
- 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
- 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
- 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?
- 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
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?
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
- 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
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
30. Question: How far back do we go in separating inspection
- Answer: ALL inspection case files in the FRC not
separated into health and safety must be separated.