Most of us know that OSHA requires us to retain our canceled PRCS Entry permits for one year to be able to do our annual review of our program, which is also an OSHA requirement. However, and this is a HUGE “however,”…if the permit’s air monitoring section shows there was any exposure to a contaminant, that permit would fall under 1910.1020 retention requirements (e.g., 30 years). OSHA stated in an 11/26/1996 LOI…
“Those results which show the composition of an atmosphere to which an employee is actually exposed (even if the employee is using a respirator) are exposure records under 29 C.F.R. 1910.20(c)(5). Conversely, if the employer determines as the result of initial air sampling not to allow entry into a confined space until additional ventilation and purging of the atmosphere has occurred, the sample would not be considered as exposure record because no employee would ever have been exposed to the atmosphere sampled. Once the employer takes corrective action so that an employee can enter, however, the results of subsequent air sampling that show the atmosphere the employee actually entered would be considered exposure records.”
Regarding the root issue of whether atmospheric sampling or exposure monitoring tests are considered an employee exposure record, OSHA has answered this question in Appendix E (page E-16) of OSHA Instruction CPL 2.100.
