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#1 larissaj

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Posted 25 October 2019 - 02:39 PM

Hello,

 

We have documents from like the 90s here in storage buildings. Do I need to do any type of anything when getting a company to shred stuff to about 2010? Maybe even 2015? Per FDA or any other business means. I dont collect much in my office and my boss makes 3 copies for everything. 



#2 SQFconsultant

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Posted 25 October 2019 - 03:07 PM

Shred away!


Kind regards,

 

Glenn Oster
 
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#3 Ryan M.

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Posted 25 October 2019 - 06:21 PM

Keep in mind organic (if you have organic records) requires 5 years of retained records.  

 

If you don't have organic production, and no organic records then you can safely shred up through 2016 records.



#4 Parkz58

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Posted 29 October 2019 - 02:26 PM

The only exception I can think of is anything relating to tax records, in which case you'd want to keep them for at least 7 years.

 

I'm guessing that getting your boss to stop making 3 copies of everything would be akin to pulling polar bear teeth, but wow...if you can get him to stop that, you probably should, even if only for the sake of the poor trees...hahaha



#5 Shabdkaur1

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Posted 29 October 2019 - 03:49 PM

Hi Larissa,

 

Not sure if you would have any of the SDS sheets or information on the chemicals and non--food materials you have used throughout the facility, but those records must be kept for 30 year after you stop using the chemical. Mentioned already are tax related documents and Organic documents. If you have none of that in those piles, then I agree with the SQF Consultant, shred away!

 

Best Regards



#6 Parkz58

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Posted 29 October 2019 - 03:52 PM

Hi Larissa,

 

Not sure if you would have any of the SDS sheets or information on the chemicals and non--food materials you have used throughout the facility, but those records must be kept for 30 year after you stop using the chemical. Mentioned already are tax related documents and Organic documents. If you have none of that in those piles, then I agree with the SQF Consultant, shred away!

 

Best Regards

 

30 years??  I've never heard of such a requirement - can you please point me to where you found this information?



#7 BostonCream

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Posted 29 October 2019 - 04:00 PM

Isn't it the chemical suppliers' responsibility to keep SDS/technical data sheet for each chemical they sell? And as customer, we can download these info from online easily.... Just not sure why would the food manufacturers keep chemical documents for 30 years  :eek_yello:

 

 

Hi Larissa,

 

Not sure if you would have any of the SDS sheets or information on the chemicals and non--food materials you have used throughout the facility, but those records must be kept for 30 year after you stop using the chemical. Mentioned already are tax related documents and Organic documents. If you have none of that in those piles, then I agree with the SQF Consultant, shred away!

 

Best Regards



#8 Ryan M.

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Posted 29 October 2019 - 08:15 PM

For SDS / MSDS sheets it is anyone who is holding / handling the chemicals.  30 years includes any chemicals that have been retired.  There isn't a clear, specific requirement from OSHA, at least that I've found, but it has been the general rule of thumb.  It may be related to California Prop 65 with cancer causing chemicals.

 

You can't always find SDS sheets online, especially if the are old / aged chemicals and the company is out of business or no longer sells that specific chemical.  



#9 Parkz58

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Posted 29 October 2019 - 08:18 PM

Again, I've never heard that, even as a rule of thumb.  Outside of California (I won't even get started on that state), what reason would there be to retain them more than 3 years after use?  If the company that manufactured the chemical has no requirement to keep them, why would we?



#10 SQFconsultant

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Posted 29 October 2019 - 09:07 PM

I was at a juice production facility in Southern NJ a number of years ago doing a general 3rd party audit for a supermarket chain and when I got to the question about records retention the QA Manager said that the company holds onto all printed documentation/records FOREVER!

 

I was only looking for at least 3 years.

 

Looked at her and said, WHY?

 

She said, the owner (who passed away 50 years prior - this is a 150 year old business) said that you never know when you might need something!


Kind regards,

 

Glenn Oster
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | We are International - Accepting all major C-Currencies

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

60% Savings to Ownership/Senior Partners when using C-Currency "XRP" Expires: 04-NOV-20

https://glennosterco...-development-pr
 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
 

#11 Ryan M.

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Posted 30 October 2019 - 01:29 AM

Again, I've never heard that, even as a rule of thumb.  Outside of California (I won't even get started on that state), what reason would there be to retain them more than 3 years after use?  If the company that manufactured the chemical has no requirement to keep them, why would we?

 

They are required.

 

It is for employees, past and present, who have worked at your facility in proximity to the chemicals or with the chemicals.  If those employees develop some illness or health issue that points to that chemical as the possible cause you could find yourself in deep doo doo if you can't provide an SDS or MSDS.  If the manufacturer of that chemical is out of business and you can't get an SDS or MSDS, then what would be your position at that point?

 

Yes, may seem far fetched, but could be reality.  So why not hold onto them?  Even if you scan and file electronically it really doesn't take that much time and effort, or space for the potential of deep doo doo lawsuits and liability.



#12 YNA QA

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Posted 30 October 2019 - 12:35 PM

They are required.

 

It is for employees, past and present, who have worked at your facility in proximity to the chemicals or with the chemicals.  If those employees develop some illness or health issue that points to that chemical as the possible cause you could find yourself in deep doo doo if you can't provide an SDS or MSDS.  If the manufacturer of that chemical is out of business and you can't get an SDS or MSDS, then what would be your position at that point?

 

Yes, may seem far fetched, but could be reality.  So why not hold onto them?  Even if you scan and file electronically it really doesn't take that much time and effort, or space for the potential of deep doo doo lawsuits and liability.

 

 

This is the rationale I have heard in the past as well.  When I've been in charge of SDS sheets, I've kept a binder of current and a binder of old in my office just in case.  As I update, I pull the old versions out of the "current binder" and add to the old binder.



#13 Parkz58

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Posted 30 October 2019 - 01:39 PM

I still would like to see where this is a documented requirement.



#14 YNA QA

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Posted 30 October 2019 - 03:34 PM

I still would like to see where this is a documented requirement.

1910.1020(d)(1)(ii)(B)

Material safety data sheets and paragraph ©(5)(iv) records concerning the identity of a substance or agent need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years(1); and 

https://www.osha.gov.../1910/1910.1020

 

I believe this is where the "30 year" idea is from, in terms of MSDS records retention.  I know when I took my OSHA class recently they stressed keeping old MSDS sheets for 30 years in the event that a previous employee filed a medical complaint, you had the evidence that you did foreclose to them what chemicals they were subjected to and the risks involved.

 

 



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#15 Parkz58

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Posted 30 October 2019 - 04:51 PM

 

1910.1020(d)(1)(ii)(B)

Material safety data sheets and paragraph ©(5)(iv) records concerning the identity of a substance or agent need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years(1); and 

https://www.osha.gov.../1910/1910.1020

 

I believe this is where the "30 year" idea is from, in terms of MSDS records retention.  I know when I took my OSHA class recently they stressed keeping old MSDS sheets for 30 years in the event that a previous employee filed a medical complaint, you had the evidence that you did foreclose to them what chemicals they were subjected to and the risks involved.

 

 

 

Well.  I'll be damned. 

 

Thank you, YNA QA, I never knew that existed.  Which OSHA class did you take, if I may ask?  Sounds like something I need to take.  I handle our OSHA and Safety program here as well.

 

Ryan M., I stand corrected - you were right, good sir.

 

Brian



#16 CMHeywood

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Posted 30 October 2019 - 07:36 PM

From MSDSonline: 

Based upon careful reading of OSHA Standard 29 CFR 1910.1020, and several letters of interpretation, you are not required to keep material safety data sheets, MSDSs, for 30 years.

You are required to keep some record of the identity of the substances or agents to which employees are exposed for 30 years. To that end, OSHA recognizes an MSDS as an acceptable record – and as you will see, MSDS retention may be your easiest recourse.

If you choose not to retain the actual MSDS, then OSHA requires you to have not only a record of the identity (chemical name if known) of the substance or agent, but also information regarding where and when it was used.

 

https://www.msdsonli...s-for-30-years/



#17 Ryan M.

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Posted 30 October 2019 - 08:38 PM

Thank you!

 

 

1910.1020(d)(1)(ii)(B)

Material safety data sheets and paragraph ©(5)(iv) records concerning the identity of a substance or agent need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years(1); and 

https://www.osha.gov.../1910/1910.1020

 

I believe this is where the "30 year" idea is from, in terms of MSDS records retention.  I know when I took my OSHA class recently they stressed keeping old MSDS sheets for 30 years in the event that a previous employee filed a medical complaint, you had the evidence that you did foreclose to them what chemicals they were subjected to and the risks involved.

 

 

 



#18 Ryan M.

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Posted 30 October 2019 - 08:40 PM

No problem.  We all learn on here (at least I hope).

 

Definitely take a course if you are responsible for that area in your facility.  A wrong move with OSHA and your facility / company can be paying very hefty fines.  OSHA doesn't screw around with that stuff.

 

 

Well.  I'll be damned. 

 

Thank you, YNA QA, I never knew that existed.  Which OSHA class did you take, if I may ask?  Sounds like something I need to take.  I handle our OSHA and Safety program here as well.

 

Ryan M., I stand corrected - you were right, good sir.

 

Brian



#19 YNA QA

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Posted 31 October 2019 - 12:35 PM

Well.  I'll be damned. 

 

Thank you, YNA QA, I never knew that existed.  Which OSHA class did you take, if I may ask?  Sounds like something I need to take.  I handle our OSHA and Safety program here as well.

 

Ryan M., I stand corrected - you were right, good sir.

 

Brian

 

I took the entry level 30 hour course.  It was daunting as my background is in Food Safety/Quality but I think most small companies combine it with OSHA as there is minor overlap.

 

Many of the local colleges near us offer quarterly courses.  This was 3 and a half days, and involved a quiz to get the certificate.



#20 mgourley

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Posted 31 October 2019 - 11:19 PM

The 30 year rule is a real thing. Now, who randomly regulated that is the real question.
I'm old enough to know that in a job, a long time ago, we had huge binders of MSDS's of no longer used "materials".

 

And they had a "get rid of date" that was 30 years from the time the material was discontinued in the facility.

 

Marshall

 



#21 BostonCream

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Posted 01 November 2019 - 01:45 PM

Heard from our plant manager (person in charge of site safety) that the 30-year rule also applies in Canada. 



#22 QAGB

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Posted 04 November 2019 - 10:04 PM

I never knew all of this. I'm so glad our Safety Dept. was separate our QA Dept., else I would have been shredding necessary documents unknowingly. Keeping MSDS/SDS on file makes sense, never thought about it from an "exposure over time" view point.



#23 Dr.Khan

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Posted 05 November 2019 - 06:25 AM

Shred almost every thing until 2012






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