Record Retention Requirements for Pipeline Systems.
A discussion that often comes up in training courses surrounds what documents and records need to be kept and for how long.
As you’re probably aware, numerous clauses within the Z662 mandate that some records be kept for the life of the pipeline, while other clauses suggest the company can establish record retention and disposition times under their management system. So which is it? Are records forever or can I shred after 5 years? The Z662 provides both directions depending on what the record is.
“While it can be a bit confusing as some of these clauses include examples of both types of records, there is a relatively simple two question process you can use to determine what to do with the record.”
The first question is who am I? If I am the Company or Operating Company, as defined in the Z662, I am the organization who has care and control of the pipeline and I am responsible for any of the permanent records. If I am a contractor, sub-contractor, supplier or service provider, my responsibility is to ensure that all project records are provided to the Company at the end of work. Disposition of my records, or copies of project records that I have, is then up to my corporate policies and are no longer under the Z662.
The second question belongs to the Company or Operating Company. Does the record pertain specifically to a pipeline system? If the answer to this question is yes, the record is required to be maintained as part of the file for the life of the pipeline. If the record is not pipeline specific, the Company or Operating Company can dispose of the record in accordance with their policies.
Weld Procedure and Welder qualification is a great example of the above. Imagine that:
SuperSafe Pipelines Inc. is an Owner Operator. They engage in a project to build a new pipeline. The design specifies Z245 pipe and components. They develop and qualify Weld Procedure Specification(s) (WPS) for the project. Two company welders are then qualified to the new WPS and assigned to the project. The project requires three welders, so the company enters into a contract with Bob’s Failsafe Welding Ltd. Bob also qualifies to the WPS. When they arrive onsite, Bob and the two company welders are met by the welding inspector for the project. He discusses some of his expectations and verifies that all three welders are qualified to the WPS for the project and that the qualifications are current. Here is the record breakdown:
- Records of the WPS must be retained as part of the permanent pipeline file.</>
- Records of the qualification of the two company welders should be kept for 2 years or until the welders re-qualify to this procedure. (company employed welders are required to re-qualify at least every 2 years)</>
- Records of Bob’s qualification should be kept for 1 year or until he re-qualifies to the procedure. (contract welders are required to re-qualify at least every annually)</>
- Record of the inspector’s verification the welder’s qualifications (all inspection activities need to be recorded) must be retained as part of the permanent pipeline record.</>
The Z662 only mandates that pipeline specific records be kept for the life of the pipeline, however with the electronic storage capabilities we now enjoy, all records could conceivably be kept indefinitely. Never be afraid to go above and beyond the minimum.