DCHAS-L Discussion List Archive
From: "Smith, George S." <george.smith**At_Symbol_Here**THERMOFISHER.COM>
Subject: Re: [DCHAS-L] EHS Training records retention
Date: January 3, 2013 8:13:02 AM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <751a.12f81f72.3e16da98**At_Symbol_Here**cs.com>
I agree with Monona. Having training records for RTK and HAZCOM may prove invaluable down the line. Also, remember if an MSDS (or SDS) revises you still need to keep the older versions for 30 years after the fact. 30 years is virtually forever.
Sent from my iPhone
George S. Smith III
Thermo Fisher Scientific
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.
Monona
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,
Paul
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