From: ACTSNYC**At_Symbol_Here**CS.COM
Subject: Re: [DCHAS-L] EHS Training records retention
Date: January 3, 2013 7:59:05 AM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <751a.12f81f72.3e16da98**At_Symbol_Here**>

Since MSDSs on products no longer used must be kept in a dead file for 30 years, I'd throw the training records in there too.  If you have to be able to show employees were or weren't potentially exposed to a particular chemical 30 years ago, perhaps being able to show they were properly trained about it's use wouldn't hurt either. 


In a message dated 1/3/2013 7:11:10 AM Eastern Standard Time, psonnenfeld**At_Symbol_Here**EARTHLINK.NET writes:

If the training includes waste management protocols, I'd recommend a 5-year retention period, consistent with EPA's RCRA record-retention rules. 

Respectfully yours,


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