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All companies have documents no matter the size of the company. These documents can be divided into a hierarchy and different laws and regulations apply to the retention and / or review of these documents. General examples of documents would be policies, objectives, manuals, legal documents, and records. Usually only documents that are regarded as records, need to be retained, as such a document is a seen as proof of an action.

ISO 15489-1:2001 defines records as "information created, received, and maintained as evidence and information by an organization or person, in pursuance of legal obligations or in the transaction of business". All records, despite their retention period, must be easy accessible (managed) and kept in a secure, dry and fire proof establishment, either internally (archive room) or externally (commercial storage areas).

The most H&S documents that need to be retained fall under employment records. Legally the following H&S records should be retained:

The COID Act No. 130 of 1993 states that all employee records for time worked, overtime, earnings and payments must be kept for 4 Years.

The OHS Act No. 85 of 1993 states the following retention periods.

Document	Legal reference	Retention
All employee medical surveillance records – base line audiogram included	Noise induced hearing loss Regulations, 2003	40 years
	Lead Regulations, 2001	40 years
	Hazardous Biological Agent Regulations, 2001	40 years
	Asbestos Regulations, 2001	40 years
	HCS Regulations, 1995	30 years
Noise monitoring and all assessments	Noise induced hearing loss Regulations, 2003	40 years
Air monitoring and all assessments	Lead Regulations, 2001	40 years
	Hazardous Biological Agent Regulations, 2001	40 years
	Asbestos Regulations, 2001	40 years
	HCS Regulations, 1995	30 years
All health and safety committee appointments, meeting minutes and recommendations	General Administrative Regulations, 2003	3 years
Records of incidents / accidents	General Administrative Regulations, 2003	3 years

 

Suggestions for the retention of documents would be to keep incident/accident record for at least 10 years and to keep all training records, either in-house or external training for the duration of employment, plus a further 2 years.

All project specific H&S Files are to be kept for at least 3 years after completion of the project. The documentation in these files would consist for example of Section 37.2 appointments of contractors, letters of good standing, appointments of competent supervision with CV’s, method statements, risk assessments, safe work procedures, inductions, toolbox talks, meeting minutes, inspections and audits, fall protection plans, control of HCS, temporary works design and control, emergency procedures and drills, checklists for excavations, PPE, facilities, tools, plant and scaffolding.

In conclusion it is evident that there are very few legal requirements when it comes to the retention of H&S documentation, or records. Companies do however, are required to ensure they are aware of possible client requirements, as stipulated in tenders or H&S specifications. The retention periods of all other H&S documentation or records can be determined by company policy after a proper risk analysis has been completed. After any retention period, all documents or records should be destroyed and disposed of in a responsible, environmentally friendly way, recycling where possible.