5.2 The records that are actually required
Maintenance departments produce a lot of paper and very little of it is required. Knowing which records OSHA actually asks for — and what fields each one must contain — is worth a surprising amount, because those are the records that get requested after an incident, and because most of them are three or four fields long. This chapter is a tour of the ones that exist, with the fields named.
1 The annual periodic inspection, and its certification
1910.147(c)(6)(i) requires the employer to "conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed." Four conditions on how it is done:
- (A) Performed by an authorized employee "other than the one(s) utilizing the energy control procedure being inspected." You cannot inspect your own lockout.
- (B) Conducted to correct any deviations or inadequacies identified. The purpose is correction, not confirmation.
- (C) Where lockout is used, it includes "a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected."
- (D) Where tagout is used, the review is with each authorized and affected employee, and covers the six tag limitations of (c)(7)(ii) as well.
Then the record. (c)(6)(ii): "The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection." Four fields: machine, date, employees included, inspector.
Note that the certification is per procedure and per machine, not per plant. A facility with forty machine-specific procedures owes forty inspections a year, each with its own record. This is the requirement most commonly discharged by a single annual audit of the program as a whole, which is not what (c)(6) says.
2 Training records
1910.147(c)(7)(iv) is two fields: "The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training." Name and dates. Nothing about content, duration or a signature from the trainee.
Retraining is a record too, because it is triggered by events. (c)(7)(iii)(A) triggers retraining on a change in job assignment, a change in machines, equipment or processes presenting a new hazard, or a change in the energy control procedures. (B) adds retraining whenever the periodic inspection reveals — or the employer has reason to believe there are — deviations from or inadequacies in an employee's knowledge or use of the procedures. (C): "The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary."
Where 1910.119 applies, the training record is longer. (g)(3): the employer prepares a record containing "the identity of the employee, the date of training, and the means used to verify that the employee understood the training." Three fields, and the third one is a verification of understanding, not attendance.
3 Equipment inspection records, by standard
Several machine standards require certification records with named fields, and they are strikingly similar to one another. The pattern is always: what equipment, when, who, and what was found.
| Standard | Record | Required fields |
|---|---|---|
| 1910.217(e)(1)(i)(C) | Certification record of each inspection, and each maintenance and repair task, under the general component of the press inspection program | Date of the work; signature of the person who performed it; serial number or other identifier of the press |
| 1910.217(e)(1)(ii)(C) | Certification record of each maintenance task under the directed component — the weekly clutch/brake, antirepeat and single-stroke work | Date; signature; press identifier. Note that the weekly inspections under the directed component are exempt from the (e)(1)(i)(C) record; the maintenance tasks are not |
| 1910.179(j)(2)(iii) | Monthly hook inspection, in addition to a daily visual inspection | Date of inspection; signature of the person who performed it; serial number or other identifier of the hook |
| 1910.179(j)(2)(iv) | Monthly hoist chain inspection, in addition to a daily visual inspection | Date; signature; identifier of the chain inspected |
| 1910.179(m)(1) | Thorough inspection of all running ropes at least once a month, kept on file where readily available to appointed personnel | Date; signature; identifier for the ropes inspected |
| 1910.179(k)(2) | Rated load test reports, "placed on file where readily available to appointed personnel" | The report; test load not more than 125 percent of rated load unless the manufacturer recommends otherwise |
| 1910.119(j)(4)(iv) | Documentation of each inspection and test performed on process equipment | Date; name of the person who performed it; serial number or other identifier of the equipment; a description of the inspection or test performed; and the results |
The 1910.119(j)(4)(iv) list is the most complete of the set — five fields including the results — and it is a good default shape for any maintenance record you design from scratch. If a record says what equipment, when, by whom, what was done and what was found, it will satisfy every requirement in this table.
4 Certifications outside the machine standards
Three more records touch maintenance work and are easy to forget because they belong to other subparts.
- PPE hazard assessment — 1910.132(d)(2). A written certification identifying the workplace evaluated, the person certifying that the evaluation has been performed, the dates of the assessment, and identifying the document as a certification of hazard assessment.
- Confined space alternate procedures — 1910.146(c)(5)(ii)(H). A written certification containing the date, the location of the space, and the signature of the person providing it, made before entry and available to each entrant.
- Confined space reclassification — 1910.146(c)(7)(iii). Documentation of the basis for determining that all hazards in a permit space have been eliminated, through a certification containing the date, the location of the space, and the signature of the person making the determination.
And 1910.333(b)(2)(i), which is a document rather than a record: "The employer shall maintain a written copy of the procedures outlined in paragraph (b)(2) and shall make it available for inspection by employees and by the Assistant Secretary of Labor and his or her authorized representatives." With the Note that the written procedures "may be in the form of a copy of paragraph (b) of this section." The regulation itself, printed and posted, satisfies it.
5 Incident records: 48 hours and five years
1910.119(m) has the tightest timing of anything in this chapter, and it applies to an incident "which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace" — the near miss is in scope.
- 1(m)(2) The investigation is initiated "as promptly as possible, but not later than 48 hours following the incident."
- 2(m)(3) The team includes at least one person knowledgeable in the process involved — "including a contract employee if the incident involved work of the contractor" — plus others with appropriate knowledge and experience.
- 3(m)(4) The report contains the date of the incident, the date the investigation began, a description of the incident, the factors that contributed to it, and any recommendations.
- 4(m)(5) A system promptly addresses and resolves the findings and recommendations, and resolutions and corrective actions are documented.
- 5(m)(6) The report is reviewed with all affected personnel whose job tasks are relevant to the findings, including contract employees where applicable.
- 6(m)(7) Reports are retained for five years.
Item (m)(3) names contract employees because maintenance is so often contracted, and item (m)(6) requires the report to be reviewed with the people whose tasks are relevant — which is the crew that will do the same job next time. Those two clauses are the difference between an investigation and a filing.
Separately, injury and illness recordkeeping under 29 CFR Part 1904 applies to everyone, PSM or not, and it is a different system with different criteria. The Safety Management and OSHA Recordkeeping subject on this site covers the 300 log, the 301 and the 300A; nothing in this chapter substitutes for it.
6 What a maintenance department actually owes
Collect the whole chapter into one list and it is shorter than most PM systems already produce. The value of knowing it precisely is that it tells you what must not be dropped when the department is busy.
| Interval | Record |
|---|---|
| Each shift | Cord- and plug-connected equipment and cord sets visually inspected before use — 1910.334(a)(2)(i). Ladders inspected before initial use in each work shift — 1910.23(b)(9). Powered industrial trucks examined at least daily, and after each shift where used round the clock — 1910.178(q)(7). No record is specified for these; the removal from service is the required act |
| Daily | Crane functional mechanisms, air and hydraulic systems, hooks and hoist chains inspected visually — 1910.179(j)(2). Aerial lift controls tested prior to use — 1910.67(c)(2)(i) |
| Weekly | Each power press inspected and tested for clutch/brake, antirepeat and single-stroke condition — 1910.217(e)(1)(ii)(A), with a certification record of the maintenance tasks |
| Monthly | Crane hooks and hoist chains, with certification records — 1910.179(j)(2)(iii) and (iv). Running ropes, with a certification record on file — 1910.179(m)(1) |
| Every 60 days | All power-transmission equipment inspected — 1910.219(p)(1) |
| Annually | Periodic inspection of each energy control procedure, with a four-field certification — 1910.147(c)(6). Certification that PSM operating procedures are current and accurate — 1910.119(f)(3) |
| On an event | Retraining on a change of assignment, machine, process or procedure — 1910.147(c)(7)(iii). Incident investigation initiated within 48 hours and retained five years — 1910.119(m) |
One line to keep from the whole list: the 60-day interval in 1910.219(p)(1) is the most widely missed hard requirement in general industry maintenance, and it is also the easiest to defend to a budget holder, because a drive inspection is a reliability task before it is a compliance task.
- 1910.147(c)(6) requires an annual periodic inspection of each energy control procedure by an authorized employee other than the one using it, and a certification naming the machine, the date, the employees included and the inspector.
- The 1910.147 training certification is two fields — each employee's name and dates of training — while 1910.119(g)(3) adds the means used to verify the employee understood the training.
- Press records under 1910.217(e)(1) and crane hook, chain and rope records under 1910.179 all take the same three fields: date, signature, equipment identifier.
- 1910.119(j)(4)(iv) is the most complete required record and the best default shape: date, person, equipment identifier, description of the inspection or test, and the results.
- 1910.119(m) requires an incident investigation initiated within 48 hours, a report with five named elements, review with affected personnel including contractors, and five-year retention.
- The 60-day power-transmission inspection of 1910.219(p)(1) is the most commonly missed hard interval in general industry maintenance.
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.