Control of Disposition of Records - Record Retention - TS 16949 Clause 4.2.4.1

[Douglas E. Purdy]

Do I have a non-conformance to the standard (ISO/TS-16949) if my documented procedure states that the inspection records are to be retained for a minimum of two (2) years, but I keep the records (whether hardcopy or electronic copy) for more than two (2) years?

What kind of controls are required for the "disposition of records"?

 

[fuzzy]

Re: Control of Records (4.2.4) & Records Retention (4.2.4.1)

Do I have a non-conformance to the standard (ISO/TS-16949) if my documented procedure states that the inspection records are to be retained for a minimum of two (2) years, but I keep the records (whether hardcopy or electronic copy) for more than two (2) years?

What kind of controls are required for the "disposition of records"?

I may be a little rusty on TS, but I believe that you must have the language that would approximate the standard i.e.: "life of the program plus x years" or the catchall " x years or as required by CSR 's (Customer Specific Requirements)".

 

[AndyN]

Re: Disposition of Records - Record Retention (4.2.4.1) - TS 16949

Do I have a non-conformance to the standard (ISO/TS-16949) if my documented procedure states that the inspection records are to be retained for a minimum of two (2) years, but I keep the records (whether hardcopy or electronic copy) for more than two (2) years?

What kind of controls are required for the "disposition of records"?

As long as your retention times meet the customer requirements (as posted above) then, no.

Disposition doesn't need 'controls' as such. It means what are you going to do with the records when your retention time is up. Someone normally decides how to deal with them - keep them longer, move to archive, put them into Iron Mountain's control off site, shred them, burn etc. Maybe there might be controls over having them shredded etc. if there was danger of somebody getting their hands on them and selling them to the National Enquirer.........

 

[Jim Wynne]

Re: Disposition of Records - Record Retention (4.2.4.1) - TS 16949

As long as your retention times meet the customer requirements (as posted above) then, no.

Disposition doesn't need 'controls' as such. It means what are you going to do with the records when your retention time is up. Someone normally decides how to deal with them - keep them longer, move to archive, put them into Iron Mountain's control off site, shred them, burn etc. Maybe there might be controls over having them shredded etc. if there was danger of somebody getting their hands on them and selling them to the National Enquirer.........

For clarification, the standard says:

A documented procedure shall be established to define the controls needed for the...retention time and disposition of records.

The key words are the controls needed, which means that you decide (after consideration of customer, legal and regulatory requirements) what controls are needed, if any. Thus in the example given by the OP, the "control needed" has been determined to be retention for a minimum of two years, without mention of specific disposition requirements (which are presumably not "needed"). All inspection records retained for more than two years meet the requirement.

 

[AndyN]

Re: Disposition of Records - Record Retention (4.2.4.1) - TS 16949

Indeed, Jim. The authorization to keep (archive etc.) or dispose of records is a control........

 

[Sidney Vianna]

Re: Disposition of Records - Record Retention (4.2.4.1) - TS 16949

The automotive OEM's do indeed have a concern over records being kept longer than necessary. It might come to haunt them and the suppliers in case of product liability investigation. Below is the added text from Chrysler CSR document:

4. Requirements
4.1 ISO/TS 16949 Related Requirements​

4.1.1 Records Retention

(ISO/TS 16949 cl. 4.2.4.1)

Production part approvals, tooling records, purchase orders and amendments shall be maintained for the length of time that the part (or family of parts) is active (see 3.1 Definitions) for production and service requirements plus one calendar year unless otherwise specified by Chrysler

NOTE:
All Chrysler purchase orders/amendments are included in this requirement.

Organization purchase orders/amendments for Chrysler owned tooling are included in this requirement.

Quality performance records (e.g. control charts, inspection and test results) shall be retained for one calendar year after the year in which they were created.
Records of internal quality system audits and management review shall be retained for three years.
Retention periods longer than those specified above may be specified by an organization in their procedures.
The organization shall eventually dispose of records.​

These requirements do not supersede any regulatory requirements.

All specified retention periods shall be considered “minimums”.​

​

 

[Stijloor]

Re: Disposition of Records - Record Retention (4.2.4.1) - TS 16949

The automotive OEM's do indeed have a concern over records being kept longer than necessary. It might come to haunt them and the suppliers in case of product liability investigation. Below is the added text from Chrysler CSR document:[/LEFT]
[/LEFT]

"Eventually" is an ambiguous term. I am sure that the legal corporate guru's have opinions on how to deal with records that expired. Maintaining records longer than required may create a legal precedent (in times of trouble).

Stijloor.

 

[Boscoeee]

Re: Disposition of Records - Record Retention (4.2.4.1) - TS 16949

"Eventually" is an ambiguous term. I am sure that the legal corporate guru's have opinions on how to deal with records that expired. Maintaining records longer than required may create a legal precedent (in times of trouble).

Stijloor.

Records should be dispositioned according to legal and well thought out disposition processes documented by company QMS or business practices. If you are not required to have the records, it is not a good policy to maintain them from a risk standpoint.

In saying this currently I am working under a policy that record retention is open ended. And that is the way the Boss wants it.

 

[AndyN]

Surely, having a good records system, wherein the data shows that product met requirements and the processes were in control is a risk mitigation - especially in those markets where product liability legislation places the proof on the producer.

You would have thought that the auto industry would have more faith in a system they not only require of their supplier but subscribe to as well (most Chrysler plants etc are ISO 9000 registered.)