Record Retention - NC for keeping records longer than our defined minimum

[el_quixiote]

Hi. Maybe some one could help me.

We had an qs audit an the auditor found that we have retained our quality records more than the minimum requiered and the auditor is documenting this fact as a non-conformancy.

Is that correct. I've read the qs-9000 4.16 clause and in the last sentence states "This periods are considered as minimum".

So, I think I'm not in a non conformancy situation.

Am I wright?

Thanks

 

[Icy Mountain]

What did you document?

Great name el_quixiote. Quality can be a quixotic struggle. Welcome to the Cove!
For example: you wrote in your procedure that you will keep a record for three years, then throw it away. If you keep the record for four years, you have a non-conformance to your system, even if the standard says keep them two years, as a minimum. Correction: write your procedure to say "keep the record three years (as a minimum), then throw it away.

 

[SteelMaiden]

Greetings el_quixiote!

No it is not a nonconformance just because they are kept longer than the minimum retention. The standard states that retention times are minimums. BUT, if keeping the records longer than the minimum (much longer??) starts to create storage problems where you might not be able to access the records or maintain their integrity/legibility then he could write up a nonconformance about your retention periods.

Icy makes a valid point about documenting, even if the standard clearly states that all retention periods shall be considered minimum, if you just make a simple statement saying that all retention times recorded in "such and such document" are considered to be minimum retention times and records will be destroyed, (or whatever) after that time as storage space dictates, they'll never be able to hang you. I don't know what TS says, I was with a QS division and we never had a problem with minimum retention times.

 

[howste]

I've seen this come up before. I think it comes from the fact that the OEMs would prefer to have records destroyed after their required retention periods in order to eliminate any liability.

Example: you are required to maintain records for the life of the part plus one year. In the year after the required retention period, a $$$$$$$ lawsuit comes up against the OEM for some alleged problem. The prosecution lawyers subpeona your records and find that Joe Temporary forgot to do his dimensional checks for a couple of days. They treat this as a smoking gun that the product is defective and they win the case.

BUT, like Icy Mountain said, if you define your retention requirements carefully they shouldn't be able to write it as an nonconformity. Please look at your record retention requirements and make sure that you didn't write them in a way that required you to destroy them after the minimum time.

 

[Wes Bucey]

I've seen this come up before. I think it comes from the fact that the OEMs would prefer to have records destroyed after their required retention periods in order to eliminate any liability.
. . .
BUT, like Icy Mountain said, if you define your retention requirements carefully they shouldn't be able to write it as an nonconformity. Please look at your record retention requirements and make sure that you didn't write them in a way that required you to destroy them after the minimum time.

I disagree about liability reason for discarding documents and records. There are just as many documents and records which would defend a liability question. (Unless, of course, the organization is willfully performing processes which may harm or injure others. In which case, why bother to keep ANY records?)

In my experience, well-run organizations want to discard documents because they are obsolete or no longer have a purpose. Records are a special kind of document which are kept for a variety of reasons (government regulation, customer requirement, historic reference, etc.)

An organization needs to make the same kind of decisions about retaining records (hard copy or computer) as it does about retaining inventory or production equipment.

In my most recent organization, our Quality Manual refers to the process for this :
4.2.4 Control of records

Records may be hard copy or electronic. A record is a special document which holds data generated during the course of performing a process. We control a document by maintaining its integrity against loss or alteration during its useful life. We provide access to a record to all interested parties. We may aggregate data from records into reports or summaries. We may analyze the data contained in a record with a view toward modifying or retaining a process.

We have a documented process to determine which controls over identification, storage, protection, retrieval, retention, disposal shall apply to a specific record.


Does this coincide with Cove members reasoning?

 

[howste]

I disagree about liability reason for discarding documents and records. There are just as many documents and records which would defend a liability question.

What I stated above I have heard from more than one QS-9000 auditor in exactly the context stated by el_quixiote. I personally feel, like you, that records are more likely to help in court rather than hurt.

 

[mshell]

We state in our procedure that we can maintain records longer than the minimum retention period without formal justification and that the purpose for disposition is to free up filing space. As far as the company is concerned, we must keep them for 1 yr. but we could possibly keep them forever if we want.

If the nonconformance was written because of your procedure, then change your procedure and the nonconformance is resolved.

The 1yr is just an example. We do have some that we keep forever!!!

 

[mshell]

This our current QM statement. It directs the auditor to the operational procedure which clearly defines what records we control, responsible party, period, location, doc #, doc name, and disposition.


4.2.4 Control of Records

Records have been established to provide evidence of conformity to requirements and of the effective operation of the quality management system. Controls are established for ensuring that records remain legible, readily identifiable and retrievable.

 

[Gary L. Phillips - 2007]

The idea that I try to get across to a client is for him/her to define how long the retention of a certain record needs to be including customer, industry, and/or regulatory requirements. Once the timeframe for keeping a particular record is identified, the only other concept (retention-wise) deals with the removal or destruction of the record in question. I simply let them know to place a control within their document for control of records which states that once the retention times have been exceeded, records may be distroyed or discarded at the descression of the Records Manager (or whomever is the owner of the records in question: Sales Manager, Production Manager, Director of Human Resources, etc.

This then will allow for retention beyond the criterior established by the organization, and should never create a problem for an assessor. Any creditable auditor worth his salt will accept this...Any auditor who would not I would argue to the death.

 

[SteelWoman]

Agree with all and add that I'd contest the non-conformance. The standard is a "minimum" retention period and ONLY if your procedures say you WILL discard them after that period is it a non-conformity. Ours actually says we "may" discard them, but normally for issues relating to space/storage.