Does a school have to record disclosures made under FERPA’s health or safety emergency exception?

Yes.  When an educational agency or institution makes a disclosure under the health or safety exception, it must record in the student’s education records the articulable and significant threat that formed the basis for the disclosure, and the parties to whom the information was disclosed.  See § 99.32(a)(5). 

K-12 School Officials
Postsecondary School Officials
Exceptions - Health and Safety Emergency