We currently set our record retention for all documents as five years, now we haven't reach the five year mark and our record retention area is now approaching to be full. Slowly, we are transferring some of the records in an electronic format. However, we would like to reduce it to three years retention plus one year in the active file?Would it be okay? Does our auditor would clearly agree with us? How do we define this? How do we classify the following documents to be retained? Please comment.

Thanks,

Raffy

Record retention is best looked at by your document types, life cycle of your product(s), importance of the information and impact on your, and your customers', business. Also get your financial/legal people involved to help identify items that need to be kept for legal or tax purposes, etc.

If you have records that contain information that is transferred to another form, you may not have to keep them as long as some others. An example might be if you are keying information into your computer systems from forms filled in by hand. Maybe you only want to keep the hand-written records for one year (or less) and the computer record becomes your "official" record. Use your history of data entry accuracy to help you here.

Obviously, if you work in a sector where product life cycles are long and impact on safety is high, you may want to keep records a longer time. But you are not going to add any value by keeping your internal audit records for five years. A typical audit cycle is three years, why hang on to those records for 5, for example.

The problem that I have seen most often is that too many companies just say "we will keep the records for 5, 7, 10 or how many ever years." If you spend a little time up front and figure out how long you really need the records, you can reduce costs dramatically in record retention. 1) man-hours spent moving files to different locations as you run out of room. 2) Additional storage areas, new construction or remodeling. 3) Reduced number of filing cabinets/boxes, etc. 4) If you are really into the tree-hugging (I am) you can often times re-use the folders for items with a less-lengthy retention.

I hope this helps somewhat, I remember the first ISO system I did and record retention seemed like an overwhelming menace. Just look at things with the viewpoint of "How many times do I reference this after 1 year, after 3 years, after 7 years, etc. etc." It's kind of like cleaning out the closets or the utility shed!

I agree wholeheartedly. A lot of places take the shortcut and blanket their entire system with a retention period that's way too long for many records. I've had situations where the retention period has been defined as short as one week (the daily data was transferred to a summary report each week).

I think the best approach is a record master list that identifies each record in the system. For each record, critically evaluate how far back you really use them. I think you'll be surprised at how infrequently some records are really used.

Remember that you as the supplier have every right to dictate the retention period (as long as your retention doesn't violate a customer requirement). If your retention period is too short and starts affecting the integrity of your quality system, your internal control systems should catch the problem.

Thank you for the quick response.
Raffy

Hi,
Were having a problem in keeping our records. Since in our procedures it must be kept for five years. Our company starts five years ago, and now our retention area for all quality records and documents are all full. What could be the exact retention years we have to specify? Please help me.
Thanks in advance,
Raffy
ffyra@yahoo.com

In our case - we select retention timeframes according to the importance of the document.

Some are kept 5 years - some are kept for 3 some are "Archived" to computer files every year (which reduces the ammount of space needed) Some are boxed up - identified by date period and stored after 1 years retention. From an ISO viewpoint things like Management review meeting minutes - Ncr files etc. the timeframe for registration is 3 years - so we keep them no longer that that.

Regards
Jim

The retention of records depends on the organisational policy. This can be described in the company's apex manual. It varies from two years to five years.

Don't forget you also need to consider: Customer Contract req, regulatory and statuatory req, as well as the direct value of the informaiton.

We use an off-site Records Management Storage for long-term retention. But you should evaluate the $/benefit as well as consider if you are keeping records in the best 'format type'. If you enter any data into computer - you should only have short-term need for hardcopy retention (presuming, of course, that you have proper file back-up systems in place).

Hello!
In our organisation , we have a problem with retention period because of lack of space.
When implementing ISO 17025, the retention period has to follow the requirements of the accrediating body. We will be applying to NATA for medical testing . To quote a example, the retention period for wax blocks, slides is 20 years!!.but we do not have the space. Has anyone such problems?

Originally posted by lily:
Hello!
In our organisation , we have a problem with retention period because of lack of space.
To quote a example, the retention period for wax blocks, slides is 20 years!!.but we do not have the space. How much space would 20 years worth fill up?

Regards
Jim

Lily,

Management better start working on that contingency plan, or update it. I don't think a customer cares what you do as long as the record retention timetables are being met. Just the facts of life and business!

Good luck!

ASD...

Hi
Thank you for the response I had. It help me to define a specific retention time for our quality records.

Quote:
Originally posted by Jim:
"In our case - we select retention timeframes according to the importance of the document."

First, I identify a huge list of quality records, then one by one, distinguised the importance of each records. I aslo seek the help of our MR to find out what are records to be disposed. And finally I eased out the pain what should be left in our retention area.

Quote:
Originally posted by Jim:
"Some are kept 5 years - some are kept for 3 some are "Archived" to computer files every year (which reduces the ammount of space needed)"

I agree with the above quote by Jim, I also identify some documents that need to be archive for five years and some are three years life span. However, with regards to the computer files, how would be able to identify the archived files? :confused:
We made a program in Access. A database on how we could ease the pain of finding the records on a huge list, different boxes...:(

Quote:
Originally posted by Al Dyer:
Management better start working on that contingency plan, or update it. I don't think a customer cares what you do as long as the record retention timetables are being met. Just the facts of life and business!

How about if one of our customer requires us to keep the record for as long as ten years, how are we going to deal with it???:confused:
Do we need to specify the retention time for that specific customer, saying that we are keeping their records for ten years???
Thanks in advance,
Raffy
ffyra@yahoo.com

Keep your documents in accordance to:
1- Legal requirements
2- As required by contract or other devices
3- Potential for litigation
4- Frequency / need of referencing
5- As you see fit to do so

Remember, they're your documents. You decide what to do with them and when to do it.

;)

Raffy, you posted"

How about if one of our customer requires us to keep the record for as long as ten years, how are we going to deal with it???
---------------------------------------------------------------------------------

Even if such a situation was not part of contract review the company is in a hard place. It has to weight the benefits of meeting customer requirements or dumping the customer.

If the customer is say, 50% of sales I would think the company would bend over backwards. If it is a now and again customer that generates say, .5% of sales the company needs to decide if it is worth the effort to meet their requirements.

With the electronic processes available today I think that retention times are basically a non-issue. A 20 gig hard drive to store records costs about $150.00 and in tandum with a scanner, the sky is the limit.

Good luck!

One way to reduce space of records is to put them on a disk. I have heard of companies that do that on a full time basis. Document compression can also save space ( use one form for 2-3 records. this is helpful especially if they are related.) As far as retention times that is up to you. We have records that are only kept one month and employee records are kept 1 year after termination( we have several that have been here 25 years). A few questions that I would ask is:
1. What purpose will this record serve if I keep it 5 years and how can it help me.
2. What are the legal implications of this record?
3. Is this also a record for osha, accounting,etc
One last word, set your retention times as minimum times

We're storing as much as possible electronically. With our current network back-up system, we keep on site the 'recoverable' back up for 2 weeks, and send the monthly tape back-up off site for storage. It doesn't take up much room (smaller than VCR tape) and is readily accessible.

The year was 1971. I was working in a hospital as an EEG technician. Back then, an EEG was a paper tracing. Paper. A very long (often 50 to 150 feet long) paper tracing. No computer links. No video displays. With medical retention requirements for records we had built up a room 10" x 8' completely. I remember researching a 'solution' which was rejected - a company routinely did this with printouts from large companies - they had a machine which took these long, long printouts and fed them into a 'burster' which tore each sheet at the perforation, photo'ed it and then spit it out. They even shredded originals upon request. You ended up with one or more microfiche or you could go with roll microfilms.

How things have changed... There are now so many options that it's amazing.

I think the most important thing, you should analyze (after five years of operation, if all records you have are the records you need, some records are posible aren`t necesary or you can integrate with other. In this way you minimize the work of administration of them, reduce space and optimize an improve your system.
Regards
Arte:bigwave:

;) Hello All,

I have started storing all Records electronically. Any records that are created as hard copy are scanned and saved in the appropriate file. This system is backed up on CD monthly, All CD's will be archived on our server so if I need to see a record from a specific date all I do is type in the date and file name and my archive will tell me which disc that record is on.:cool:

I have stated minimum retention times in my procedures with no referance to maintaining a disposition of records. I see nothing in 9K2K that requires me to maintain a record showing the destruction of records:frust: As long as my records are retained for the stated minimums. Why would anyone care if I decide to keep my CD archive for 10 years.

If anyone sees a problem with my logic let me know...


Regards,


Curt

The way I read ISO92K section 4.2.4 it says that there shall be a procedure to account for the disposition (disposal) of records. It doesn't say how, when, or why, but the process must be defined/documented in a procedure.

I guess you could say that we retain all records for 20 years!

MHO from a TS guy:bigwave:

Not knowing how many records you create in a month and your particular industry and potential liability, you may want to consider backing up more often than monthly.

Al,

in your opinion does stating my minimum retention times :ca: ?

Thanks,

Curt

Gpainter

We create about 1500 records every month so far it seems to be working fine.:bonk: I don't destroy any Hard Copies until I have made my back up...

Thanks for the input,

Curt

Stressed,

I think you might need to go into more detail in a procedure:

---Auditor Cap On---

-How do you track your records to know when to dispose of records?

-What is your method to communicate to various personnel that records need disposition?

- How do you document that the records were disposed of?

-What are your methods of disposal?

At one place I was at we had our 1st 6 Mo. surv. audit. The auditor asked me for proof of record disposition. I told him that our minimum retention time for any record was 1 year and that we had not disposed of any records yet.

He agreed and asked to show what system was in place to ensure that the process would be performed in the future. I showed him a form that is sent out to all department managers telling them they the following records need to be disposed of. The manager disposed of the records and noted on the form that yes they were disposed of and how they were disposed.

The signed acknowledgement was returned and stored. Verification was done through simple follow-up and internal audits.

Just food for thought. Minimum retention times may be stated but there does need to be a system to follow through.

Hope I didn't muddy it up too much!

:bonk: :bonk: Al,

I could write a script to run at the end of every fiscal year that tells me I have files needing disposition.:( I could document disposal by doing a screen print showing the files that need disposal and the date they were deleted from the server or disc. The only problem I can see in this logic is that not all records will have the same retention times.:confused: I suppose I could:ca: with clever verbage in my procedure but that could cause more trouble than it is worth.

All of the back up discs are in my control so notification doesnt present a problem.

I have a similar program monitoring my CAR log that prompts me when there has been no activity for 3 days on a particular CAR. When I get this prompt I E-Mail all involved with that CAR and save a copy of my E-Mail with that CAR this seems to be working very well.:thedeal:

Thanks You for all of your input it helps a great deal.

Curt

For quality records , I incorporate the retention times stated in the standard. Records that require long retention periods are tied into production schedules/releases, so that when we are notified by the OEM that a part is no longer active we can update our record file. Other records; audits, calibration recall, follow-ups are all set up in "MS outlook" with the apprpriate people notified.
Works for me.

Sam,

What do you mean when you refer to "the retention times stated in the standard" ? Which standard are you referring to? I don't see this information.

Also, for the Outlook functions: are you using the calendar mode, and how do you have this set up?

:bigwave:

Lucinda, Refer to QS-9000 para. 4.16.1.
Yes I use the calendar mode; I schedule an appointment to remind myself and a meeting if other people are involved.

Hi
How about calibration records? Is it still worth that we keep that record until the life of the equipment? Or can we dispose it based on our procedure of five years?:confused:
Thanks in advance,
Raffy

I thought this was already over, however, last week our documents that was been subjected for review had some findings on 4.2.4 Control of Records. We had established a retention period for our inspection records however for other quality records we don't have any. I had problems with regards to record retention: :frust: 1. Some records are kept by other department(s). I don't have a control on those records. Does this mean, we need to specify in detail the records that are kept by other department(s)? Do they need to write a procedure on how do they kept? Store? and Retention? :confused:
2. We already reached the five year retention time of the documents and records. I don't know how where do I start? If the retention time already expire, does it mean we need to dispose all records at hand? Or do we need to evaluate all records that expired retention time? :frust:

Thanks in advance.
Best regards,
Raffy

I thought this was already over, however, last week our documents that was been subjected for review had some findings on 4.2.4 Control of Records. We had established a retention period for our inspection records however for other quality records we don't have any. I had problems with regards to record retention: :frust: 1. Some records are kept by other department(s). I don't have a control on those records. Does this mean, we need to specify in detail the records that are kept by other department(s)? Do they need to write a procedure on how do they kept? Store? and Retention? :confused:
2. We already reached the five year retention time of the documents and records. I don't know how where do I start? If the retention time already expire, does it mean we need to dispose all records at hand? Or do we need to evaluate all records that expired retention time? :frust:

Thanks in advance.
Best regards,
RaffyI feel your frustration, Raffy.

From a quick review of the posts for the last two years, it seems you aren't too far off track. Please take time to review the more recent posts in this thread:
http://elsmar.com/Forums/showthread.php?t=6939 (http://elsmar.com/Forums/showthread.php?t=6939)
One thing you might add to your procedure for record retention is a method to review records as their five year anniversary arrives and make a decision to do one of three things:
destroy
ship them to a customer who has mandated a longer retention period
microfilm or scan them into a computer for archival purposes and then destroy hard copies (microfilm or computer files thus created get a new review date for retention.)
Sometimes folks are confused between documents and records (a special subset of document.) Records often have a definite life span, documents do not. For example, inspection records can have a definite life span ranging from days to years. A document like a corporate charter may have an unlimited life span (until the corporation is merged or dissolved.) A document like revision 1 of a drawing that is in its 10th revision, even if it's only weeks or months old, can readily be destroyed if it is obsolete and no longer required for reference or repair purposes.

Depending on the records in other departments, they may or may not fall under your Quality Management System. If they do, then, yes, you need to have a way to "control" those documents by requiring the other departments to follow a Procedure related to storage, retrieval, retention, and destruction of those records, even if you don't physically deal with the documents (purchase orders, shipping documents, billing and accounts receivable records, accounts payable to suppliers, machine maintenance records, employee time sheets, salesman phone logs, etc. are examples of kinds of records organizations may keep in other departments, none of which need be included in your Quality Management System.)

I hope you find the answers you need between my answer and the thread cited above.

Hi Raffy -

I hope this helps - attached is my Control of Quality Records Procedure and the first page of our Record Retention List.

Never pitch a weibull plot. Everything else has an optimum frequency for review and retention. On the day before Christmas vacation I try to touch all of the quality documents documents that could have been reviewed (including weibull plots) by me within the last year.

Hi Wes Bucey,

Your right! I'm already frustrated especially this times as our Certification Audit
is now fast approaching, I just hope I could close all the findings that was been
found by the auditor who reviewed our documents.

Now I'm now confused with regards to document and records. Was there a need to
keep the documents for many years or shall we say that were just going to
those documents on the latest revision? I thought documents and records are
of the same in nature, with the same treatment with records.... :confused: Please
enlighten me more on this aspect.

Thank you, Wes.

Hi Cari Spears,
I already downloaded the attached file, I think I would use the file and make some
revisions which are applicable to us.
Thank you too, Cari.

Best regards,
Raffy

Hi Wes Bucey,

Your right! I'm already frustrated especially this times as our Certification Audit
is now fast approaching, I just hope I could close all the findings that was been
found by the auditor who reviewed our documents.

Now I'm now confused with regards to document and records. Was there a need to
keep the documents for many years or shall we say that were just going to
those documents on the latest revision? I thought documents and records are
of the same in nature, with the same treatment with records.... :confused: Please
enlighten me more on this aspect.

Thank you, Wes.
Best regards,
RaffyHere's my quick and dirty [sardonic laugh here] division between document and special subset of document called "record" with a brief yardstick for control and retention:

Documents are all written or drawn papers (whether hard copy or strictly electronic) used by an organization in its business. Some of these documents are "plans" or "designs" on performing some process within the business. These documents may change or become obsolete as plans are revised or no longer needed.

Records are a special subset of documents which represent the history of some activity (hours worked, results of inspections, number of products made in a shift, etc.) Just as a good historian does not rewrite history, so, too, a good organization does not rewrite a record. Records may be continuous (a weekly time card, for instance which has new data added every day) or they may be unique for a date and time (a receiving inspection record for a particular lot of goods.) Unless there is an obvious error (data entered under a wrong date or column on a form?), records remain unchanged until they reach the end of their retention period. Some organizations use the data from records to make "reports" which are rarely controlled documents (except for confidentiality purposes) in the sense that Quality organizations use the term "control" (reports might be Shipments on ALL Orders During October)

Retention
An organization makes a decision when a document [i](including records) is created as to a point in the future when it will make a decision whether the document is still needed or can be discarded. (At the same time, it makes a decision whether the document will be "controlled" or not.)

The most efficient organizations create a method of retrieving and evaluating those documents at the end of the initial retention period. Some documents may have retention periods calculated in seconds or minutes (a note for the UPS driver NOT to pick up Friday because the plant will be closed for inventory.) Other documents have a longer life span (blueprints for a classic product that sells year after year - Radio Flyer wagons?) Almost by definition, records have a definite life span, dictated by customer or regulatory requirement (inspection records, material C of C, tax records) or by the organization (supplier performance records.)

Here are some working definitions about "Control" which many Quality professionals agree with. Some readers may have additions or subtractions according to their experience.
Control
"Control " has a special meaning in a Quality organization. It implies a series of actions on a product, document, or process which determine the "five W's" of information (who, what, when, where, why) about the controlled object. Further, "control" implies a record is kept of those actions. (See Control process , Controlled , Controlled conditions, Controlled copy, Process Control)
Control process
Procedures to create and monitor methods and documents. A Control Process ensures appropriate people have input in creating the method or document and uniform practices are followed in implementing the necessary actions. (Compare with Process Control.)
Controlled
Means assuring only the most recent authorized version or revision of a design, document, or part is in process by actively removing all outdated or nonconforming versions, marking them as such, and keeping them segregated from the active design or production process except for archival reference.
(note the point about keeping segregated from ACTIVE design process - the activity of creating or amending/revising a document is controlled with a separate process from controlling finished and released documents.)

Controlled conditions
Throughout the Quality world, "control" implies the controlling entity (1) has a written Plan; (2) follows the Plan; (3) records the activity performed following the Plan; and (4) has a system for evaluating the record to decide whether to modify the Plan. "Controlling the conditions" of production merely means adhering to the four steps of the Plan.

Controlled copy
"Control " implies we will keep a register of the authorized holders of any document created by us. When any event occurs related to a controlled document, we notify the registered holders, requiring them to acknowledge the notice. When we change or revise a document, we send registered holders the updated version and require them to return or confirm destruction of the outdated document to us. Compare with "uncontrolled copy" where the holder is responsible for maintaining an updated copy.
(All documents are not controlled - review the note to the UPS driver taped to the door or a sales letter to a prospect, soliciting business.)
Process Control
The activity performed to limit the natural variation inherent in any process to keep the process or product within the limits of the design specifications. (Compare with Control Process.)

Gosh, I know this was long, but I'm trying to eliminate any ambiguity. However, if you are still concerned about this, send me an email or a private message, include the findings from your auditor. This topic of documents, records, control, and retention normally takes up 2 to 3 seminar or workshop hours.

Wow, Wes! Lotsa good information there. Just curious: Are you a lawyer, or otherwise deeply involved in some type of super-critical records retention?

Wow, Wes! Lotsa good information there. Just curious: Are you a lawyer, or otherwise deeply involved in some type of super-critical records retention?Thanks.
Lots of formal legal training, primarily "agency and contract" and uniform commercial code. Not a member of the bar.

I like to use the "inoculation" technique:
Establish bona fides on first go around. No "sandbagging." Most folks are happy to have a guy dot the "i's" and cross the "t's" so there is no ambiguity.

If you are ASQ, check my member Profile on the ASQ web site.

Over the years, I've dealt with a lot of regulators and other assorted ankle biters (FDA, FAA, Big 3 automotive, medical equipment manufacturers, etc.) The key point is ankle biters are basically lazy people and the easier you make it for them, the happier everyone will be.

Personally, I dislike keeping even a personal calendar, but l love the feeling of power when I can lay my hands on any document in our organization in less than five minutes and know without doubt it is the most up-to-date. I love the looks of amazement on faces of customers, regulators, bosses when they, too, can do it. It's like teaching everyone MAGIC!

It occurs to me to mention that documents created by others may come into an organization's Control System. Examples are:
purchase orders
supplier's shipping and inspection data
government regulations
Corrective Action requests from customers
etc.
Once these third party generated documents come into an organization's Control System, they are treated like records - not changed, revised, etc. When the creator of the document delivers an update, the previous version may be discarded or kept in an archive, based on an organization's policy about that kind of document.

Hi Wes, :bigwave:

Thank you for the comprehensive information you've discussed.
It was a great help. Basically, I'm still concerned on the retention. We
do have a system for retention but it was just defined on one specific
record, its not a general procedure. The problem is that not all of
our quality records are defined on the procedure that was been
submitted for review as quoted by the auditor.

But anyway, I would like to thank you for this. I highly appreciate your
concern. :o

Best regards,
Raffy :cool:

Hi Wes, :bigwave:

Thank you for the comprehensive information you've discussed.
It was a great help. Basically, I'm still concerned on the retention. We
do have a system for retention but it was just defined on one specific
record, its not a general procedure. The problem is that not all of
our quality records are defined on the procedure that was been
submitted for review as quoted by the auditor.

But anyway, I would like to thank you for this. I highly appreciate your
concern. :o

Best regards,
Raffy :cool:Look. I don't want to seem like the Grinch Who Stole Christmas, but Document retention is serious business. Read this:
[Emphasis in bold or underline is mine]
http://www.cfo.com/article/1,5309,7785%7C%7CA%7C16%7C4,00.html

Document Retention

Should It Stay or Should It Go?
Joan Urdang, CFO Magazine October 01, 2002
A federal district court judge in Arkansas ordered sanctions against Cooper Tire & Rubber Co. earlier this year for destroying documents related to a product-liability case. Although the documents were shredded in accordance with the company's existing document-retention policy, the judge ruled that Cooper "should have known [the documents] were relevant to litigation" and therefore they "should have been preserved."

The Sarbanes-Oxley Act of 2002 looks at Cooper's behavior--known as spoliation--even more harshly. The new law makes it a crime to intentionally change or destroy a record that might be germane to any federal investigation. The punishment? Up to 20 years in jail.

Not so long ago, the question of whether to keep or destroy a company's documents was often answered by someone in the facilities or waste-management department. No more. High-profile fiascos like that at Arthur Andersen have raised the stakes. "Document-retention policies are now corporate-governance issues, with responsibility going to the top," says Bob Johnson, executive director of the National Association for Information Destruction Inc.

As senior managers try to find the right balance between what to save and what to destroy, some say they have gone from one extreme to the other. "Companies are saving too much now," says attorney Simon Lorne of Munger, Tolles & Olson in Los Angeles. They are being driven to do so, he says, not by their auditors, but by newspaper headlines.

"A lot of public companies are in a defensive posture," contends Quentin Faust, an attorney in the Dallas office of Arter & Hadden LLP.

There are legitimate reasons for destroying documents, as long as a clear policy is in place. While there is no such thing as a "one-size-fits-all" approach, there are certain guidelines, says Faust. First, it should be applied in a consistent way: it's hard to say that something was destroyed in accordance with a company's policy if the policy is applied randomly. Second, it must also be able to accommodate requests for documents that were scheduled to be destroyed if they are needed for legal or other reasons.

In my opinion, a first step is to Google for Record Retention or Destruction outfits like National Association for Information Destruction Inc. to pick up some basic guidelines. Then, the suits in an organization should take a hard look at their policies. This is one of those issues that can come and bite your gluteus maximus if you ignore it.

Hi Wes,

Thanks for your help and thanks for the information.

Best regards,
Raffy

Customer Specific requirements of the big three OEMs and others who embrace and specify their specific record retention and disposal have to be met for registration. :agree1:

We have been working this issue from quite sometime. Some of our document are to be kept indefinetly and the old way of sticking them in a box; sending them offsite and maintaining them needed redefined.

We have been looking at a third party scanning in the documents within the boxes in a pdf format to a CD making sure the information in the box is needed (you won't believe what folks stick in a box and send out) just for the
indefinite retention time.

Our next course of action is to by scanners/copiers for various areas of the plant to scan documents to the network eliminating the need to send them offsite. The network is backed up by MIS.

Hope this helps.