The rule does not require creation of any records, only preservation.
Access means the right to examine and copy records.
Employers are to inform their workers initially and at least annually of their rights to access to medical and exposure records. Records requests need not be in writing except where trade secrets are involved. Union and health professionals must have specific written consent to gain access to employees' personal medical records but may examine exposure records without such consent. However, they must state the specific record needed and the occupational health need for gaining access to the information. Health professionals include physicians, occupational health nurses, industrial hygienists, toxicologists, and epidemiologists who provide medical or other occupational health services to exposed employees.