From: 8524828hau**At_Symbol_Here**COMCAST.NET
Subject: Re: [DCHAS-L] EHS Training records retention
Date: January 2, 2013 6:37:22 PM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <AB2FEBFEF318F0499197674BA932AF6006D262FA**At_Symbol_Here**>

I recently retired from one of the multiple "national laboratories" operated by civilian employees under a contract with the U. S. Department of Energy.  In addition to a requirement to operate in accordance with OSHA and all other applicable federal regulations, these national laboratories have a contractual requirement to retain records in accordance with requirements established by the National Archives and Records Administration (NARA).

Based on the NARA requirement, the "training" chapter in the national laboratory's ES&H Manual defines the following requirement for records retention:

"Lesson plans, signed attendance sheets, and completed exams for subjects dealing with hazardous, toxic, or radioactive materials have a retention period of 75 years after the termination/separation of the employee."

In the era of computer-based training, an electronic record of "attendance" and "completion of an exam" with a passing score serves the purpose of printed documents.  Although I have no knowledge about how it is achieved, 75-year retention of retrievable electronic records presumably requires periodic migration of the data in accordance with technological advances.

The extremely long retention time allows the organization to PROVE (even post mortem) that the required training was successfully completed in accordance with the then contemporary regulatory requirements when an employee or former employee (or a former employee's heirs) claims that an illness resulted from occupational exposure.  The employee-specific training requirements are defined by completion of a job hazard questionnaire; that is verified/updated periodically (at least annually), and promptly revised in accordance with (a) changing requirements, and (b) changes in occupational responsibilities and work environments. 

David Haugen


From: "Susan Hadden [JRDUS]" <SHADDEN**At_Symbol_Here**ITS.JNJ.COM>
Sent: Wednesday, January 2, 2013 2:57:36 PM
Subject: Re: [DCHAS-L] EHS Training records retention

I'm looking for information for standards and best practices about records retention for EHS trainings. A quick, casual review of a couple of OSHA standards show 3 years for BBP but nothing on retention for CH2Cl2 or benzene.


I realize OSHA may not have the most up-to-date recommendations and that other agencies (NIOSH, ACGIH, etc) might have more. Maybe even PMA has a recommendation.


Any ideas out there?




Susan Hadden

Senior Occupational Safety Specialist


Janssen Research & Development, LLC

Environmental, Health, Safety & Sustainability

1000 Rt 202, Raritan, NJ 08869

Tel: 908-704-4295, Fax: 908-927-3965

EHS website:

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