Record Retention Pitfalls 12/21
A recent interaction with one of our clients regarding their official AISC Audit shed some light on Record Retention Pitfalls -- basically an issue that was brought to our attention during the client’s audit.
The AISC Audit Agenda called for the auditee to have the last two years of audit reports and CARs available for the auditor. The exact wording was:
“You are required to have last year’s audit report and CARs from the previous two years available at the opening meeting. If you do not maintain these records a corrective action can be written to the management review in the case of a standard audit or to the question on non-conformance / quality control program in the checklist questions.”
Say what?
So we first checked to see if a new auditing policy had been issued. Nope, none released. Then we looked within the Certification Standards and found no specific requirement for the certified company to retain these records as required in the aforementioned agenda. Perhaps it’s in Element 9, Record Retention? No two year retention time requirement there.
While it makes sense to retain at least the previous year’s audit report and any CARs issued for the purpose of the Management Review meeting discussion; it may not make sense for your organization to keep records beyond your company’s record retention policy.
The AISC Requirement for record retention is “Shall be at least long enough to permit evaluation of the records during the course of the project construction unless a longer period is required by contract or government regulation, and not less than the duration of any warranty provided by the fabricator.” These records (QMC audit reports and CARS) are not project specific, but the evaluation cycle should be at least since the previous event. So one year until the next audit to permit evaluation of the implementation of plans and actions.
Always remember: Chapter & Verse; show me in the Standard where & what the requirement is. If an auditor can’t show you the requirement, it probably doesn’t exist.
So what is the takeaway from this?
The AISC Audit Agenda called for the auditee to have the last two years of audit reports and CARs available for the auditor. The exact wording was:
“You are required to have last year’s audit report and CARs from the previous two years available at the opening meeting. If you do not maintain these records a corrective action can be written to the management review in the case of a standard audit or to the question on non-conformance / quality control program in the checklist questions.”
Say what?
So we first checked to see if a new auditing policy had been issued. Nope, none released. Then we looked within the Certification Standards and found no specific requirement for the certified company to retain these records as required in the aforementioned agenda. Perhaps it’s in Element 9, Record Retention? No two year retention time requirement there.
While it makes sense to retain at least the previous year’s audit report and any CARs issued for the purpose of the Management Review meeting discussion; it may not make sense for your organization to keep records beyond your company’s record retention policy.
The AISC Requirement for record retention is “Shall be at least long enough to permit evaluation of the records during the course of the project construction unless a longer period is required by contract or government regulation, and not less than the duration of any warranty provided by the fabricator.” These records (QMC audit reports and CARS) are not project specific, but the evaluation cycle should be at least since the previous event. So one year until the next audit to permit evaluation of the implementation of plans and actions.
Always remember: Chapter & Verse; show me in the Standard where & what the requirement is. If an auditor can’t show you the requirement, it probably doesn’t exist.
So what is the takeaway from this?
Keep your CAR documents and AISC Audit Reports for two years if you take no issue with this requirement. If you take exception to changing the requirements of the Certification Program without issuing an Audit Policy or re-issuing the Standard after public commentary, let the AISC Certification Committee know how you feel.