Hazmat Documentation Life Cycle

Gary asks;

I have a question regarding record keeping for running hazmat items.

How long do we have to keep the signed production order (factory ticket) that verifies our compliance to the test requirements?

My question is not about the certifying lab and the copy of the original hazmat test…..it is about keeping records of a production order that went through our plant and the verification process that we do to be sure it is following the requirements of the certified test.

We have a pretty good handle on our process to run hazmat packaging for our customers. The one question that we are struggling to get a good answer on is how long we have to keep our production copies where we verified the board combination and that the spec was followed and signed off by our operator.

We order board specific to our hazmat test – receive the board in and sign off that the order is ready to be processed based on the testing done and submitted to us by our board supplier. We then send the factory ticket out to production with our signature that the board was correct and production can now process the order. Our operator of the last operation signs off on the factory ticket to indicate that the spec was followed for this hazmat item. We then turn those signed factory tickets back in to the office for filing away.

After a while, we get quite a file full of old factory tickets. I have heard that we need to keep the factory tickets for 1 year, 3 years, etc.

According to our own Hazardous Materials Guide for Corrugated Packaging Manufacturers, on page 26 it states that test reports, and other data, must be maintained as long as the packaging is produced and for at least two years thereafter.

— Ralph

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