NIOSH Testimony on Access to Employee Exposure and Medical Records by J. D. Millar, September 14, 1982.
This testimony concerns the interests of NIOSH regarding proposed changes in the current regulation dealing with access to employee exposure and medical records. OSHA proposes to limit the employees covered by the regulation through several changes in the current regulation. If the company monitors office exposures, NIOSH recommends that the regulation also allow access to records by office workers and service workers for whom there is reason to believe exposure may have also occurred. This testimony also discusses the use of the Registry of Toxic Effects of Chemical Substances (RTECS), the retention of records, the rights of temporary employees for information, microfilming of x-rays, and trade secrets. Problems with the use of the RTECS list as the basis for defining a toxic substance include incompleteness of the list, the addition of new substances to the list, the lack of evaluation of references for the file, and the exclusion of substances which do not fit the toxicological criteria for the list.