OSHA Instruction ADM 12.8 October 3, 1994 Office of Management Systems and Organization

SUBJECT: Maintenance, Disposition, and Recall of Videotaped and Audiotaped Inspections.

A. Purpose. This instruction provides information for the maintenance, disposition and recall of videotaped or audiotaped inspections.

B. Scope. This instruction applies to all OSHA field offices.

C. Reference.

1. OSHA Instruction ADM 12.4, OSHA Records Management Program.

2. OSHA Instruction ADM 12.5, OSHA Compliance Records.

3. OSHA Instruction ADM 12-7.4, Safety Fatality and Catastrophe Inspection Case File Disposition.

4. OSHA Instruction CPL 2.98, Guidance for Case File Documentation for Use with Videotapes and Audiotapes.

D. Action. Regional Offices and Area Offices shall implement the records maintenance, records transfer and records recall procedures contained in this directive when maintaining, retiring, or recalling inspection case files containing videotapes or audiotapes to Federal records centers.

Note: The information in this instruction will be included in a future update of OSHA Instruction ADM 12.5, OSHA Compliance Records.

E. Background.

1. NARA Records Reappraisal. The National Archives and Records Administration (NARA) reappraised an accession of safety fatality and catastrophe inspection case files in the Washington National Records Center (WNRC). NARA declared the accession to have permanent and continuing value. This reappraisal was applied to all safety fatality and catastrophe inspection case files.

2. Videotaping Inspections. OSHA has, in recent years, begun to videotape inspections. This practice has reached the point where significant numbers of inspection case files containing videotapes will need to be retired to FRC's.

3. Videotape Fragility. Videotape, like most other audiovisual and all magnetic media, is fragile and easy to erase or misplace.

4. Videotape Lifetime. The expected lifetime for videotape is approximately 10+ years in an environment that is not climate controlled. This means the quality of the image cannot be guaranteed over 10 years. The environment in most FRC's is not climate controlled.

5. Safety Fat/Cats Retention. Safety fatality/catastrophe inspection case files containing videotapes or audiotapes cannot be retired to a FRC that lacks climate controlled records storage space. NARA increased the disposition period for these inspection case files from 10 years to permanent (forever)

6. IH With Sampling Data. Health inspection case files with sampling data containing videotapes or audiotapes cannot be sent to a FRC that lacks climate controlled space. These inspection case files have a 40 year disposition period.

7. NARA Long Term Record Storage. OSHA requested NARA approval to place safety fatality/catastrophe and health with sampling data inspection case files containing videotapes into climate-controlled space at the WNRC for storage. NARA has agreed to our request.

F. Multi-Media Inspection Case File.

1. Multi-Media Definition. An inspection case file consists of all materials, regardless of media, used to record the inspection including pre-inspection preparations, inspection records such as field notes, process information, interviews, and inspection forms, and the post-inspection record of inspection-related activities including settlement, contest, penalty payments, abatement and the like.

2. Tapes Defined. Hereafter as used in this instruction, tapes means audiotapes and/or videotapes.

3. Tape As A Record. Where photographs, videotapes or audiotapes are used to show hazards, accidents, or simply to record comments of the CSHO or others during an inspection, they become a record of the inspection. They are subject to the disposition period for that inspection. Maintaining the audiovisual media as part of the inspection is important. NARA documentation regulations require the inspection record contain the best evidence to support any observed Violations.

4. CD-ROM or Other Similar Records.

a. CD-ROM or other similar electronic technology may be used instead of the paper, photographs, audiotape and videotape records. Those records could then be disposed assuming ALL the record information is scanned or otherwise input onto the CD-ROM or similar electronic technology media where the image is retained on a disk and where the image cannot be altered or is otherwise protected by written procedures and security safeguards against alteration.

b. CD-ROM or similar technology cannot be used to transfer fatality or catastrophe (accident) inspection case files (permanent retention) to the National Archives since this is not an archival quality medium. The records must be returned to an archival quality medium such as paper, videotapes, or electronic media on archival quality tape meeting appropriate standards and following appropriate procedures to assure the records are transferable.

G. Maintenance and Disposition of Records. All inspection records, regardless of media, must be retained and disposed in accordance with the records disposition schedule item for that type of inspection (e.g., safety fatality/catastrophe, 5a1 violations, health with sampling data, etc.). The following appendices contain specialized instructions for the maintenance and disposition of inspection case files containing tapes:

1. Appendix A covers the assignment of accession numbers for records to be sent to the WNRC. Note the changed procedures for those offices in Region III that regularly send their records to the WNRC.

2. Appendix B describes maintenance and disposition of case files containing tapes.

3. Appendix C provides information on retiring inspection records containing tapes to FRC's and the WNRC.

4. Appendix D covers recall of records from the WNRC.

David C. Ziegler Director Administrative Programs

Distribution: National, Regional, and Area Offices OASAM

1. Assigning Accession Numbers. The WNRC usually requires each agency to assign accession numbers to its own records instead of assigning the numbers itself.

a. Offices Assigning Numbers for WNRC. Each Regional Office is authorized to assign accession numbers TO ACCESSIONS TO BE RETIRED TO THE WNRC.

b. FRC Assigned Numbers. Accessions to be retired to the FRC's will continue to be assigned by the FRC's.

c. WNRC Number Assignment System. The assignment of WNRC accession numbers by regional offices is as follows:

     100-FY-0001    to 0099        (Reserved for the OSHA
                                   Records Officer)
               0101 to 0199        Boston
               0201 to 0299        New York
               0301 to 0399        Philadelphia
               0401 to 0499        Atlanta
               0501 to 0599        Chicago
               0601 to 0699        Dallas
               0701 to 0799        Kansas City
               0801 to 0899        Denver
               0901 to 0999        San Francisco
               1001 to 1099        Seattle

d. Accession Number Structure. The accession number structure remains the same. It is: Record Group-Fiscal Year-Consecutive Number.

(1) The OSHA Record Group is 100.

(2) Fiscal Year is self-explanatory.

(3) The first 2 digits of the consecutive number defines the region (e.g., 0401). The last 2 digits of the consecutive number are the number of the particular accession of records (e.g., 0401).

For example:

In the example above, the record group for OSHA is 100, the fiscal year is 1993, the region is 04 meaning the Atlanta Regional Office, and this is the 1st accession issued by that region for records destined to be retired to the WNRC.

2. Accession Number Assignment for Field Offices in the District of Columbia, Maryland, West Virginia and Virginia. OSHA field offices in these States retire all their records to the WNRC. Field Offices in these states will apply the accession number system in this appendix to all their records. Accession numbers must be assigned by the Philadelphia Regional Office. Area offices will not assign accession numbers.

MAINTENANCE AND DISPOSITION OF CASE FILES CONTAINING TAPES

1. Filing. Inspection case files containing tapes will be maintained in the same manner as case files without tapes. Continue to file as specified in OSHA Instruction ADM 12.5.

2. Internal Case File Organization. The internal organization of inspection case files containing tapes will remain the same as inspection case files without tapes.

3. Filing Audiovisual Media. (Note that Appendix C, paragraph 2b on pages C-3 and C-4 requires long retention (over 10 years) taped records, including large video tape formats (such as VHS), to be retired to the WNRC in separate accessions from the paper record.)

a. Single Inspection Tapes. Tapes may be filed in the case file or separately at the regional office's discretion. When filed separately from the case file, note in the case file where the tapes are filed. This does not affect the requirement to separate long retention (over 10 years) papers from tapes when the paper and tapes are sent to the FRC or WNRC in separate boxes and/or accessions. Refer to paragraph 5 on page B-2.

b. Filing Multi-Inspection Tapes. Tapes containing 2 or more inspections may be filed with the longest retention inspection case file or may be filed separately from the case files to which they relate at the regional office's preference. Note in the case files the location of the tape.

c. Case Filed Tapes. If tapes will be filed in the case file, tapes should be placed in an envelope or a heavy paper, cardboard or plastic holder to protect the tape(s) against damage. The envelope or holder should be fastened to the folder.

4. Filing Multi-Employer Inspection Records.

a. Multi-employer inspections present problems in filing media such as video tapes since more than one employer may be on the tape and the inspection record for several companies may be so commingled that extracting one company's record would be very difficult.

b. In accordance with longstanding records management practice, tapes which contain commingled inspections will be filed with, or under, the name of the company having the longest disposition period. Other companies must be cross-referenced on the outside of the tape and the location of the tape noted on the appropriate inspection case files for those companies.

5. Media Considerations in Disposition.

a. Audio- or Videotaped Inspection Records.

(1) Coordinate Retirement. The audiovisual portion of an inspection record has the same disposition as the remainder of that record. They are part of the inspection record. Their disposition must be coordinated and they must be retired at the same time. (Except for In- Compliance records, see paragraph 8 on page B-3.

(2) Similar Inspections. When a VHS or other size videocassette, such as 8 mm., contains the video record of 2 or more inspections, all inspections on the cassette must relate to the same type of inspection (one item on the disposition schedule) (e.g., safety fatality/catastrophe, health with sampling data, 5a1 violations, etc.). The same applies for audiotapes. If inspections having different disposition periods are mixed together on the same tape, those inspection records on the tape must be copied to other tapes so only one type of inspection is recorded on each tape.

b. Paper Inspection Records. Follow the directions in OSHA Instructions ADM 12.4 and 12.5 when preparing paper records for retirement to the WNRC or FRC.

6. Climate-Controlled Conditions For Tapes. Minimum life expectancy for tapes is 10 years. Tapes with a retention period over 10 years and held substantially past the records center retirement period must be kept in climate-controlled conditions. Office space is acceptable IF the environmental conditions in the office are stable without wide fluctuations in temperature and humidity.

7. Retirement of Multi-Employer Inspection Records. Multi-employer inspection files, such as multi-employer construction industry inspection files, are handled differently from other taped inspection files.

a. Primary Inspection File and Tape Retirement Location. The tape will be filed with the paper file type having the longest disposition period. The tape will be retired along with the paper inspection case file for that inspection. Also see paragraph 1 in Appendix C.

b. Other Inspection Files. The paper case files relating to the other simultaneously conducted employer inspections will be retired as if the inspection was not taped. (See paragraph II of this appendix.) However, mark the folder and the SF-135 folder listing with the location of the tape for future reference.

c. Permanent or 40 year Retention Portions of Multi-Employer Inspection Files.

(1) Where the inspection was the result of an accident or contains a health with sampling data inspection, the preferred method of retirement to the WNRC is separating the permanent fatality/ catastrophe portion and/or the 40 year retention portion from the other simultaneously conducted employer inspections. A separate tape may be used for these portions of the inspection.

(2) Alternatively, Area offices may retire the entire tape with the permanent or 40 year retention inspection, as appropriate. However, if this option is chosen, the entire tape, including any 3, 6 and 10 year retention inspections, will be subject to FOIA requests for the retention period of the permanent or 40 year retention records.

8. Retirement of Safety Fatality/Catastrophe and Health Inspection Case Files With Sampling Data and Tapes.

a. Retirement to WNRC. Field offices will retire only those safety fatality/catastrophe and health with sampling data inspection case files that CONTAIN TAPES to the WNRC. Refer to Appendix C for instructions about transferring records to the WNRC.

(1) Health with sampling data inspection case files are subject to Records Schedule NC1-100-82-l, items 11 and 25 (Refer to OSHA Instruction ADM 12.5)

(2) Safety fatality/catastrophe inspection case files are subject to Schedule N1-100-90-l, item 23 (Refer to OSHA Instruction ADM 12-7.4).

b. Retirement of Multi-Media Inspection Records. Paper and tape portions of inspections must be retired to the WNRC at the same time. If tapes are held in the area office past the FRC transfer period, the paper portion of the inspection record must also be held.

9. Disposition of Tapes in In-Compliance Inspection Case Files. Where audio- or video-tapes are used to record inspection information during inspections that do not uncover violative situations (in-compliance inspections), the tape record of the inspection may be reused after complete erasure. The tape should be held for a sufficient time to assure the tape is not needed to document that no violations were observed. In-compliance tape records do not need to be kept as long as the remainder of the file because they document no violations and may be treated as routine surveillance tapes.

10. Retirement of Other Inspection Case Files With Videotapes. Inspection case files with tapes to be retired to the local FRC consist of those disposable under records schedule NC1-100-82-1. They are general safety inspections (item 7), inspections with safety general duty clause (5a1) violations (item 8), and health without sampling data inspections (item 12)

11. Retirement of Inspection Case Files Without Tapes. Field offices will continue to follow established procedures for transferring inspection case files WITHOUT VIDEOTAPES to Federal records centers. This includes permanent retention inspection case files.

EXCEPTION: The Philadelphia Regional Office will follow the accession number assignment system in Appendix A for all records in field offices located in the District of Columbia, Maryland, Virginia and West Virginia. Refer to OSHA Instructions ADM 12.5 and ADM 12-7.4.

This appendix provides specialized information for the retirement of permanent records and special records such as video and audio tapes to FRC's and the WNRC. Also refer to OSHA Instructions ADM 12.4 and ADM 12.5 for additional information about retiring records to the WNRC and FRC's.

1. Preparing Records for Transfer.

a. Multi-Year Retirements. If the volume of paper records is less than 1 full box, multiple years may be retired together All related tapes also must be retired at that time.

b. Lone Retention Tapes (over 10 years).

(1) Place paper and take records in separate boxes. The paper and tape cannot be retired to the WNRC in the same box because of the relative fragility of the taped record, its bulky shape (for VHS), the lengthy disposition period and WNRC requirements.

(2) Store tapes up on end in the box. Do not store them flat. This will avoid damage to the tape.

c. Short Retention Tapes (10 years or less).

(1) VHS format videotape. VHS format videocassettes cannot be transferred to the FRC in the case file to which they relate. Place paper and videotape records in separate boxes.

(2) 8 mm. and other small videotape formats and audiotape.

1 Tapes containing a single inspection may be placed in the case file and retired with the paper records.

2 Audiotapes and small format videotapes containing 2 or more inspections may be retired to the FRC in boxes separate from the paper record. As an alternate, the tape may be placed in the case file containing the longest retention and sent to the FRC as part of that file. Note on the other case files and on the accession box listing where the video record of the other inspections are filed.

2. Preparing Records Transfer Forms. Refer to the sample completed SF-135 forms found in Figures 1 and 2 on pages C-4 and C-5, respectively, of this appendix. For additional information on preparing records transfer forms and shipment of records, refer to OSHA Instructions ADM 12.4 and ADM 12.5.

a. SF-135 Preparation.

(1) Preparation. Prepare the SF-135, Records Transmittal and Receipt, as usual, with the additions explained below.

(2) Note on SF-135 for Tamed Inspections. Note on the SF-135:

(a) Videotapes and/or audiotapes are included in the accession.

(b) Any special boxes used to house the records. Provide the size and GSA stock number (if any) of the boxes.

(c) The appropriate box numbers for those boxes containing videotapes when the videotapes are retired in separate boxes from the paper records in the same accession.

(d) The appropriate codes below when video or audio tapes are included in the accession. Place the code in block 6, column f on the SF-135.

VDV Video Recordings, VHS Format Tape Cassette.

VID Video Recordings, Unspecified. Use for 8 mm. cassettes.

b. Long Term (More Than 10 years) Inspection Case Files (Safety Fatalities/Catastrophes and Health with Sampling Data).

(1) Transferring to WNRC. Transfer paper and tape segments of inspection case files to the WNRC under separate accessions on ONE SF-135. Place on the SF-135 only those inspection case files disposable under one item on a records schedule AND PROVIDED THE DISPOSITION DATE OF THE RELATED ACCESSIONS ON THE SF-135 IS THE SAME.

(2) Permanent Accessions Containing Tapes. For permanent records, note on the SF-135 that NARA has agreed to allow OSHA to list 2 accessions (one paper and one tape) on the SF-135.

c. Short Term (10 Years or Less) Special Records (Audio-or Videotapes) Sent to the WNRC or FRC with the Paper Record. Include a note in the records description that the tapes in the audio- or videotape accession are integral to the inspections in the paper records accession.

d. Special Records (Audio- or Videotapes) Sent to the WNRC or FRC Separate From the Paper File.

(1) Temporary Records. For VHS format video-cassettes, specify which box(es) contain VHS videotapes. Do not place VHS videotapes and paper records in the same box. Any of the boxes specified in paragraph 3 on page C-5 of this appendix may be used to store videotapes.

(2) Permanent Retention Records. Specify which accession(s) contain tapes. Do not place tapes and paper records in the same accession. Any of the boxes specified in paragraph 3 on page C-6 may be used.

(For Figure 1, Permanent Retention SF-135 Example, see printed copy)

(For Figure 2, Temporary Retention SF-135 Example, see printed copy)

e. Folder Listing. A folder-by-folder listing must be prepared in accordance with OSHA Instructions ADM 12.4 and ADM 12.5. For permanent records, the folder-by-folder listing must accompany the SF-135. For temporary Records, retain the folder listing to recall records. Do not send the listing with the records.

f. Records Center Containers. The following containers or boxes may be used to retire records to the WNRC or FRC. (Refer to OSHA Instruction ADM 12.4 for a listing of generally available records center boxes for paper records and some boxes for use with special records including videotape.)

a. Standard Shipping Boxes. Use the standard size 1 cubic foot boxes (14 3/4" X 12" X 9 1/2") (NSN 8115-00-117-8249 (tuck-bottom) (the preferred box) or NSN 8115-00-117-8344 (w/o tuck-bottom) or the 15 X 12 X 9 7/8 (NSN 8115-00-290-3379) standard file/lateral file box) These boxes are available for paper records and for tape cassettes.

b. Half Cubic Foot Box. The special purpose 1/2 cubic foot box (14 3/4" X 9 1/2 X 4 7/8") (NSN 8115-00-117-8338)listed in OSHA Instruction ADM 12.4 also may be used for tapes.

c. Special Boxes. NARA has given OSHA permission to use smaller boxes when the tape volume is less than 1/2 cubic foot.

(1) Microfilm Boxes. Audio- or videocassettes may be shipped in microfilm boxes (14 3/4 X 6 1/2 X 4 1/2) (NSN 8115-01-025-3254) . When more than 1 microfilm box of cassettes will be retired, place 2 microfilm boxes in the 1/2 cubic foot box specified above.

(2) Other Small Boxes. NARA has not yet been able to identify a generally available smaller box for audio- or videocassettes. VHS videocassettes measure 7 3/8 x 4 1/8 x 1 inches while 8 mm. videocassettes measure 4 11/16 x 2 7/16 x 9/16 inches. Cassette containers or boxes will increase the dimensions slightly. Contact the records center to determine if the dimensions of the locally available box you propose to use are acceptable to the WNRC or FRC.

4. Shipment of Records. WNRC and FRC rules regarding placement of records in boxes and identification of access ions and boxes are strict. Failure to follow instructions can result in return of the records to the transferring office. Refer to Figure 3 below to see a properly addressed box.

a. Always use an approved records box.

b. Face the records toward the front side of the box. This is the UNSTITCHED/UNSTAPLED side of the box.

c. Write the accession number on the upper left-corner on the front side of the box.

d. Number the boxes on the front side on the upper right corner. Number the boxes in each accession consecutively, such as: 1 of 3, 2 of 3, 3 of 3.

e. Make the numbers as big as possible. Use a felt-tipped chisel-point black marker.

f. Do not use labels for accession or box numbers.

g. Do not write on sealing tape. Do not place tape over accession or box numbers.

(For Figure 3, Records Transfer Box Examples, see printed copy)

The WNRC and FRC's have different records recall procedures. Continue current procedures when requesting records from FRC's. Follow the instructions below when requesting inspection case files with tapes from the WNRC.

1. Authorized Agency Contacts.

a. Record Listing. The WNRC requires that agencies provide a listing of contacts authorized to request records from the WNRC. Persons not on the authorized list are not allowed to recall records.

b. Contact List. The OSHA Records Officer notifies the WNRC of persons authorized access to OSHA records in the WNRC.

c. Field Contacts. The OSHA Regional Records Officers are the OSHA field contacts for the WNRC. Refer to the latest edition of OSHA Notice ADM 12, Records Management Program Contacts, for a listing of OSHA Regional Records Officers.

2. Requesting Office. Area Offices wishing to request records from the WNRC shall request the Regional Records Officer to recall the records on an OF-11, Reference Request-Federal Records Center. Refer to OSHA Instruction ADM 12.4 for more detailed instructions on recall of records.

3. Routine Requests to the WNRC.

a. Mail. The Regional Records Officer will mail the OF-11 to the WNRC. The NARA standard for WNRC processing of the records for shipment to or pickup by the requesting agency is 24 hours after receipt of the request.

b. FAX.

(1) Regional Offices. OSHA regional offices may fax requests to the WNRC for routine requests. Regional offices will note on the OF-11 fax request that routine fax requests were approved by Andrew Jones, Assistant Chief, Reference Services Branch, WNRC, on 1-21-93 to the OSHA Records Management Officer.

(2) National Office. Faxed routine requests will not be made by Washington Metropolitan Area offices. Only emergency fax requests are allowed for Washington Metropolitan Area offices.

4. Freedom of Information Act (FOIA) or Privacy Act. FOIA or Privacy Act requests should be noted on the OF-11 for expedited service.

5. Emergency Requests. The Regional Records Officer shall call or fax the WNRC for emergency service only in rare cases of genuine emergency.

a. Pick Up Service Standard. Emergency requests require that the records need to be picked up in less than the WNRC 24 hour service standard.

b. Pick Up. The Regional Office will make arrangements with the WNRC and the National Office for pick up of records in an emergency.

c. Authorization. The person picking up the records must be listed on an approved authorization listing or receive a one-time authorization to pickup the records.

d. Requesting Authorization. Request one-time authorizations to pick up records at the WNRC by submitting a memo or fax to the OSHA Records Management Officer. The memo should contain name, organization, social security number, accession and box numbers, record location code in the WNRC and the date the pickup will be made.

e. Emergency Defined. An emergency is limited to those cases where failure to receive the records immediately would cause the agency harm as in missing a court-ordered deadline, receiving rush Congressional requests for information, accidents where the information is needed immediately, or in a similarly serious situation.