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NQA-1 Requirement 17 Quality Records - Facility Types and Temporary Storage

P

PittsburghBrass

#1
Greetings all.
I have seen some discussions on this topic, but not quite addressing my question, so I am looking for some guidance on this from nuclear qa gurus...specifically...
I'm looking for clarification/guidance on parapragh 602 facility types and paragraph 603 temporary storage.
Paragraph 602.1...Our facility has a vault. We know that the vault door is rated for 2-hour fire-safe. Is this sufficient? Meaning, does the room itself require a fire rating in addition to the vault door? Seems silly on one level, but I wouldn't be shocked if the room attached to the vault would also need to be fire-rated, given the regulation seen at nuclear-level. Would standard file cabinets within our 'standard' room with the 2-hour fire-rated vault door satisfy the requirement? Our auditor seems unsure.
Paragraph 603...Do requirements of temporary storage on nuclear records, (1-hour fire-safe container) imply that during the course of working on an NQA-related work order, records must be filed while the order is being processed/worked-on? Seems strange.
Thanks in advance for your reply.
 
E

Echols

#4
Greetings all.
I have seen some discussions on this topic, but not quite addressing my question, so I am looking for some guidance on this from nuclear qa gurus...specifically...
I'm looking for clarification/guidance on parapragh 602 facility types and paragraph 603 temporary storage.
Paragraph 602.1...Our facility has a vault. We know that the vault door is rated for 2-hour fire-safe. Is this sufficient? Meaning, does the room itself require a fire rating in addition to the vault door? Seems silly on one level, but I wouldn't be shocked if the room attached to the vault would also need to be fire-rated, given the regulation seen at nuclear-level. Would standard file cabinets within our 'standard' room with the 2-hour fire-rated vault door satisfy the requirement? Our auditor seems unsure.
Paragraph 603...Do requirements of temporary storage on nuclear records, (1-hour fire-safe container) imply that during the course of working on an NQA-related work order, records must be filed while the order is being processed/worked-on? Seems strange.
Thanks in advance for your reply.
My company does not have a vault, so we use the Dual Storage method. However, I have encountered your situation during audits. NQA-1 2008 Ed./2009 Add. Part III, Subpart 3.1, Nonmandatory Appendix 17A-1 refers to the NFPA-232 for guidance on single storage facilities and containers. From my experience, you have to have an authorized agency actually "rate" your vault as being 2-hour fire-safe and you must have this documentation available for audit. I haven't actually read NFPA-232, so it may be worthwhile for you to do so.

In regards to temporary storage of records, my company does have a 2-hour rated file cabinet that we use for "in-process" safety-related and Code orders. The rule I use is once the document becomes an official QA record (i.e. the record has been approved by the proper authority), then it needs to be kept in the respective Sales Order file in our 2-hour rated file cabinet.
 
N

Norm Moreau

#5
A little late to the game, sorry. The point about certifying the room is a good one. Who says or said it was a 2 hr rated room? With Fire King file cabinets there is a certificate and/or plate that says their rating. Whatever, it is make sure it ties to a professional organization such as NFPA.

Assuming that the rating is ok, then the answer to the other rooms being rated or file cabinets in the room being rated is, no they do not have to be fire-rated.

Regarding temporary storage. Rule-of-thumb if there are records that will not be completed by the end of the day, i.e., work in progress, like in-process inspections done, but final won't be complete until the next day or later - put them in temporary storage at the end of the day.
 
E

Echols

#6
A little late to the game, sorry. The point about certifying the room is a good one. Who says or said it was a 2 hr rated room? With Fire King file cabinets there is a certificate and/or plate that says their rating. Whatever, it is make sure it ties to a professional organization such as NFPA.

Assuming that the rating is ok, then the answer to the other rooms being rated or file cabinets in the room being rated is, no they do not have to be fire-rated.

Regarding temporary storage. Rule-of-thumb if there are records that will not be completed by the end of the day, i.e., work in progress, like in-process inspections done, but final won't be complete until the next day or later - put them in temporary storage at the end of the day.
Yes, most fire-rated file cabinets do come with a plate inside the drawers showing the NFPA certification, and that would be acceptable. The one particular customer we audited used single vault (room) storage and was not using fire-rated cabinets inside that vault. They did not have any type of certification regarding the fire rating of their vault, thus they didn't meet the record storage requirements of NQA-1 Requirement 17. My understanding is that the vault room has to be fire-rated, not just the vault door.

Regarding work-in-progress records, it would be nice if we could collect all work-in-progress records at the end of every day and file them neatly in our fire-rated temporary storage cabinet, but this is simply not practical in our working environment. We have been audited to NQA-1 over 10 times this past year, and I have yet to have an auditor give us a finding in this area. In our procedure we have written that once a record has been reviewed and approved by the approving authority, it is then considered to be an official QA record and must be kept in our 2-Hour fire-rated cabinet until it is scanned into our records system. I think as long as you write in your procedures your definition for when a record becomes an "official" QA Record, you won't have any problems with most auditors.
 
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