Federal Records Management

FAQs for GRS 2.7, Employee Health and Safety Records

Download all Frequently Asked Questions of Individual GRS Schedules in a PDF


1. Why is item 030 not part of GRS 2.6, Employee Training Records?

Occupational health and safety training records do not meet the basic definition of GRS 2.6, item 030: “Records documenting training required by all or most federal agencies.” Not all agencies require occupational health and safety training for their employees. Additionally, hazardous waste program training (HAZWOPER) records must be retained for at least 5 years per 29 CFR Part 1910.120 Appendix E(9).


2. Whose records do these items cover?

These items apply to employee, contractor, and intern individual occupational medical case files.


3. What is the definition of a federal employee or contractor applicable to these items?

Executive Order 13991 Sec. 7. Scope. (a) (i) defines “federal employees” and “federal contractors” as employees (including members of the Armed Forces and members of the National Guard in federal service) and contractors (including such contractors' employees) working for the executive branch.

4. Does the GRS require agencies to create or collect these records?

No, agencies should follow the Safer Federal Workplace guidance regarding creation and collection of the records. The GRS provides agencies with the authority to dispose of records they collect.

5. Do agencies need an approved disposition authority from NARA to destroy unsolicited copies of vaccination cards or related documentation from the public?

No, an agency does not need an approved disposition authority from NARA because this unsolicited documentation is designated as non-record.

6. Where should my agency file these records?

NARA does not tell agencies how to file their records. The GRS only provides authority to dispose of records. Agencies should follow the Safer Federal Workplace guidance, or where applicable, guidance from the Office of Personnel Management. Agencies may choose to file these records in Employee Medical Files and use their authority for those records instead of GRS 2.7, items 063 or 065. 

7. Does item 063 apply to vaccine attestations received from new hires during the onboarding process? 

Yes. These records may be temporarily located with onboarding records when first collected during the onboarding process, but ultimately may be retained with other agency vaccine attestation records covered by item 063 of this schedule. Agencies also have the option of filing these records in occupational health files if that is their chosen practice.

8. What GRS item covers medical and religious accommodation requests?

We believe GRS 2.3, item 020, Reasonable accommodation case files, is appropriate for religious accommodations as well. We will be updating GRS 2.3, items 010 and 020, to clarify it includes religious accommodations as well as reasonable accommodations. 


Human Resources Schedules (GRS 2.1—2.8)

Do General Records Schedules for human resources records (section 2.0) apply to the records of personnel on staff solely as part of a detail or an Intergovernmental Personnel Agreement (IPA)?

Yes. Items in schedules 2.1 through 2.8 apply to records your agency creates as part of managing personnel on the Federal payroll. This includes those temporarily assigned to your agency on a detail or through an IPA, as well as those permanently assigned to your agency.


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