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How long should I maintain documentation?

Whether it is a retirement, the departure of a key employee, transition to a new technology or one of the multitude of other reasons for change occurring in an organization, it is always important to have plans in place that allow the company to maintain access to documents related to environmental, safety and health activities.

Complete recordkeeping is the only way to show that you did things the way they were supposed to be done, according to the rules and regulations, at that point in time. Some 15 or 20 years from now, if there is an environmental pollution claim or a workers' compensation claim for a health issue, these will be the only documents you have that can help document your actions at the time of the occurrence of the incident, or to disprove/prove potential exposures to chemicals or physical hazards during the dates of employment of the employee.

When it comes to defending the company against regulatory issues, there are three key words: document, document, and document! It is always better to have hard evidence that you followed the regulations rather than to try and make your case based on rhetorical evidence.

For environmental issues, maintain records for a minimum of five years that show how you disposed of all hazardous wastes generated at the site for a minimum of three years. If you had your fixer or bleach-fix hauled off-site for disposal, keep a copy of the records showing who took it, the disposal location, and the volume. Maintaining these records for more than the minimum is always best. Other records to maintain beyond the minimum number of years include those related to personnel training programs, test results, waste analyses and other waste determinations.


On the safety and health side of things, minimum record retention is generally considered to be 30 years. The only exception to this rule is the OccuPational Safety and Health Administration's (OSHA) accident and injury Jog. Currently the OSHA 300 log, (which most photo processors are not required to maintain) needs to be kept for five years.

OSHA actually has regulations that outline how long records must be maintained. In 29CFR 1910.1020, "Access to Employee Exposure and Medical Records," OSHA outlines that records must be maintained for 30 years. There are some specifics involved concerning when that 30-year clock starts ticking. Some clocks tick to 30 years after the employee leaves employment, and some start ticking 30 years from the date of occurrence. Be sure to educate yourself on the difference and any state or local differences from this federal requirement.

Since we are in the age of scanners and large-storage-capacity hard drives, long-term storage is not really an issue. Regulatory agencies readily accept electronic copies of documents, so take some time to create electronic files of these documents.
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Publication:In Compliance
Date:Jan 1, 2008
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