Answer Library / Recordkeeping OSHA letter · 2018-07-16

Does posting the OSHA 'It's the Law' poster satisfy the annual employee notification requirement for exposure and medical records?

Quick answer

No. OSHA says posting the 'OSHA Job Safety and Health: It's the Law' poster does not meet the employee notification requirements for exposure and medical records (29 CFR 1910.1020(g)(1)). The poster covers general OSH Act rights, while 1910.1020 requires specific information about record existence, location, availability, and access rights.

A construction company safety professional asked whether posting OSHA's Federal Labor Laws poster once a year would satisfy the employer's duty under 29 CFR 1910.1020(g)(1) to tell employees about the existence, location, and availability of exposure and medical records, who maintains them, and each employee's right to access them.

OSHA answered no. The poster informs workers of their rights under the Occupational Safety and Health Act, and all covered employers must display it under 29 CFR 1903.2 — but that is a separate obligation. The information required by 1910.1020(g)(1) is different, and much of it cannot simply be posted because of privacy protections around medical information.

OSHA explained that exposure records include environmental (workplace) monitoring information, biological monitoring results, and safety data sheets indicating a human health hazard (29 CFR 1910.1020(c)(5)), while medical records concern an employee's health status made or maintained by a physician, nurse, other health care personnel, or technician (29 CFR 1910.1020(c)(6)).

The bottom line: employers must inform employees at hire and at least annually about these records' existence, location, and availability, and must provide records within 15 working days of a request (29 CFR 1910.1020(e)). The wall poster does not substitute for that notification.

29 CFR 1910.1020(g)(1)29 CFR 1903.229 CFR 1910.1020(c)(5)29 CFR 1910.1020(c)(6)29 CFR 1910.1020(e)
Source: OSHA Standard Interpretation letter, 2018-07-16 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

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