Can jobsite training records be kept in an electronic format?

There is no Occupational Safety and Health Administration (OSHA) requirement for training records that applies in all situations. Recordkeeping requirements vary between standards, and many rules don’t include specific requirements.

OSHA has weighed in on electronic records in a letter of interpretation dated April 10, 2000. The Agency writes:

“OSHA training standards generally require the employer and trainers to sign a certification record which includes the identity of the person(s) trained; signatures of the workers are not required...OSHA would have no objection to the use of an electronic signature pad.”

Another OSHA letter of interpretation dated August 14, 1997, states, in part:

“A search of all OSHA standards found that there is no standard that requires the employer to obtain the worker’s signature...most OSHA standards concerning training require the employer and trainers to sign a certification record which includes the identity of the person(s) trained.”

So, OSHA is open to companies keeping an electronic database of training records. However, because there is limited OSHA guidance on this issue, employers should discuss the matter with their local OSHA area office or their state OSHA Consultation Services.