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If an HVAC contractor finds mold in your duct work, is that test result an employee exposure record?

Scenario: To evaluate indoor air quality, an employer has the ductwork tested and air samples collected. The results show bacteria but determines it is non-toxic, is typical of office/work environments, and reflects background levels of contamination.

Often, when employers test for toxic substances or harmful agents, the OSHA will consider the test results to be an employee exposure record under 1910.1020 that must be retained for 30 years, even if the results are below an established action level or permissible exposure limit.

Question: Does OSHA consider this indoor air quality test results to be an employee exposure record? Yes or no?

Click below to see answer.

If an HVAC contractor finds mold in your duct work, is that test result an employee exposure record?: Answer

Answer: Because the substances found are non-toxic and typical of office environments, the test results are not deemed an employee exposure record. OSHA clarified this in a letter of interpretation dated August 8, 2002.

On the other hand, if test results caused an investigator to conclude that indoor microbial levels were hazardous and employees may have been exposed, then the records would be employee exposure records under 1910.1020. Also, if the results including testing for substances with known hazards such as carbon dioxide or particulates, the results would be considered employee exposure records even if the results were below an action level.