11.11 Recordkeeping

Compliance records must be retained for a period of five years. Owners and operators, including each PI, instructor, or supervisor who oversees a location where DCM is used or a person who uses DCM, are required to participate in the generation and maintenance of these records, as they are crucial in proving adherence to the restrictions set forth by the EPA. It is acknowledged that many of these records and documents are already maintained by the University and by individual research groups associated with overlapping programs such as Medical Surveillance, Training and Chemical Hygiene program elements.

  1. Exposure Control Records:  
    1. Lab-specific SOP will be maintained by the PI or area supervisor. 
    2. Documentation of personal protective equipment being used as part of the program will be maintained by PI or area supervisor.
    3. Lab-specific training records will be maintained by PI or area supervisor.
    4. Training records for centralized DCM training will be maintained by HSRM.
    5. Implementation records, including inspections, evaluations and exposure control updates, as well as confirmation that affected persons are properly implementing exposure controls, will be maintained by HSRM. 
    6. Maintenance, shutdown or malfunction documentation (e.g. fume hood failure) for facility exposure controls that cause air concentrations to exceed the ECEL or STEL will be maintained by Facilities Management. Each PI, instructor, or supervisor who oversees a location where DCM is used or a person who uses DCM is responsible for notifying HSRM immediately when such events are suspected to have occurred.
  2. Exposure Monitoring Records: Monitoring records will be maintained by HSRM for employees that may be potentially exposed including:
    1. All monitoring results, including copies of the notifications to the potentially exposed persons.
    2. The identities of all potentially exposed persons whose exposure was not measured and whose exposure is intended to be represented by the monitoring.
    3. Description of analytical methods.
    4. Information on air monitoring equipment, including calibration dates, limits of detection and malfunctions.
    5. Objective data being used to forgo initial exposure monitoring including: the use being evaluated, the source of the data, the measurement methods and results, and any other relevant information.
  3. Records Related to Any Eligible Exemptions: Will be maintained by HSRM.