>>each employer shall assure the preservation and retention of records
as follows:<<

Medical records created or held by an employer are a whole different
ball game.  Employee related medical records of an employee of a clinic
must follow the OSHA rules unless they are an exempted employer (like
state employees).  However, the reference has nothing to do with patient
records maintained by a medical facility.  That's a whole different body
(or absence) of law.

Bill R

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