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EHS Recordkeeping Requirements

Accountability and Evidence
What are the EHS Recordkeeping Requirements
Scope
Electronic Records
Programming of Planned Disposal
How to use the EHS Recordkeeping Requirements
Terminology Used in the EHS Recordkeeping Requirements
Responsibility for Implementing EHS Recordkeeping Requirements
Destruction Authorisation, Notification and Methods
Transfer of Records
Amendment and Updating

For detailed information on record types, essential records for most offices, collecting and user data (Hazards) etc see :

Records Management Policy and Procedures Manual  Chapter 10: EHS Recordkeeping Requirements  http://www.unimelb.edu.au/records/unimelb-only/pdf/chapter_10.pdf

 

Accountability and Evidence

Established under Statute, The University of Melbourne is a public institution and accountable to parliament for its actions.

Documenting business activity by making transactional records, and capturing them into recordkeeping systems, provides a basis of organisational accountability. A record comprises recorded information in any form, including data in computer systems, created, received and maintained by the University in the transaction of business activities or the conduct of affairs and retained as evidence of such activity. Inadequate records and recordkeeping can contribute to failures to meet accountability and other organisational requirements.

Recordkeeping encompasses:

• allocating recordkeeping responsibilities; and
• the creation of records in the course of business activity; and
• the design, implementation and operation of records systems; and
• determining confidentiality status and related access levels; and
• the management of records as current records and as archives.

There are various legislative requirements in the areas of Occupational Health and Safety which require specific records to be created and retained. The Occupational Health & Safety Act 1985 requires that records be created and maintained relating to the health & safety of employees, proof of training made available to employees, records of supervision, health monitoring & conditions monitoring as well as proof of the work of the Occupational Health & Safety Committee and action taken to eliminate health risks on-site and on entering & leaving the workplace.

 

What are the EHS recordkeeping requirements?

The EHS Recordkeeping Requirements is intended to cover operational records created, received and maintained within University departments' (related to Environmental Health & Safety). The records covered by this document include both paper and electronic formats.

The EHS Recordkeeping Requirements is a document issued by the University which lists various classes of records and specifies their recordkeeping requirements. It is not a list of file titles. It is designed to cater for the needs of all departments within the University to satisfy the requirements of SafetyMAP and Environmental Health & Safety audits. It only addresses records at a departmental level. The Risk Management Office (which has University wide responsibility for Environmental Health & Safety) has separate guidelines which govern their recordkeeping activities. Responsibility for records creation and maintenance, confidentiality determinations and access levels are intergral parts of a viable EHS recordkeeping system; just as legal, administrative, financial and accountability requirements and purposes are taken into consideration when determining the retention periods for the records of those systems.

The aim of the EHS Recordkeeping Requirements is to provide continuing instruction to all staff concerning:

• staff positions which have EHS recordkeeping responsibilities
• records which have restricted access requirements;
• records which have been identified as having continuing value;
• records which are considered to be of temporary value and therefore can be destroyed as soon as there is no longer any administrative use;
• records to be transfered to Records Services when they are no longer required for administrative use by staff.

This ensures:

• effective creation and maintenance of EHS records
• records shall be legible, identifiable and traceable to the activity, product or service involved;
• appropriate levels of access to the records
• consistent, lawful and timely disposal of records;
• that papers retained in the office environment are kept to a necessary minimum by discarding periodically those deemed temporary and;
• that records are retained for administrative, legal, financial and archival requirements

The EHS Recordkeeping Requirements has been developed from information gathered from, and in consultation with:

Risk Management Office
University Solicitor
Internal Auditor
University Archivist
The Faculty of Engineering
The Royal Children's Hospital
The School of Chemistry
Property & Buildings
University Secretary
Risk Management Australia

Note - not all EHS record types must be created & maintained by every department. Each department can select which EHS record types are relevant to their particular situation. The EHS Recordkeeping Requirements is extremely broad for the reason that The University of Melbourne work environments are so varied & thus the full range of EHS record types needed to be included.

 

Scope

The EHS Recordkeeping Requirements is intended to cover operational records created, received and maintained within each University department related to Environmental Health & Safety. The records covered by this document include both paper and electronic formats.

The EHS Recordkeeping Requirements has been developed to deal with current and future records created within the University departments.

 

Electronic Records

While the management of paper-based records relating to an activity is often handled satisfactorily, the related electronic records are often neglected because the records are "invisible". Legislation requiring the retention of records does not distinguish between paper and electronic records.

In relation to electronic records, the appraisal of systems to identify records of continuing value should be undertaken during the system design, upgrade or review. Recordkeeping requirements and preferred methods of 'archiving' should be identified, documented and incorporated into systems management. Further information is available from Records Services on extensions 46996, 44225 or 46405.

Storage

Electronic records should be securely maintained to prevent unauthorised access, destruction, alteration or removal. Storage media and related technologies and practices for maintaining electronic records must be specified, designed, operated and maintained in such a way that records cannot be altered.

All documents should be stored on a networked drive and suitable security and backup measures should be implemented.

Websites which document departmental EHS policy and procedures should be updated regularly to ensure currency. A copy of each revision of a departmental website must be maintained to provide evidence of aforesaid policy and procedures which operated at particular points in time. Records Services can be contacted for further advice on the control of web-based documents.

The Risk Management Office's website (a major reference source for most University departments) is the responsibility of the Risk Management Office to maintain.

 

Programming of Planned Disposal

To ensure effective control of non-current EHS records and to facilitate optimum use of storage space, disposal action should be programmed as an annual activity. It should be conducted at a time when staff resources are available to undertake either destruction or transfer of records to Records Services.

 

How to use the EHS Recordkeeping Requirements

Departments are required to identify, maintain and dispose of EHS records under their control. EHS records are identified from records generated by the use of EHSM procedures and the various classes of records detailed in the EHS Recordkeeping Requirements.

The entries in the EHS Recordkeeping Requirements are arranged by function or subject. Within each function or subject group activities or records are listed. The position with recordkeeping responsibility for the particular record is identified, together with any access & confidentiality conditions. The disposal action that can be taken is specified. This indicates how long records are to be retained by the department before being destroyed or transferred to Records Services. The retention period specified is the minimum requirement. Records can be retained for longer if the Department believes this is necessary.

 

Terminology Used in the EHS Recordkeeping Requirements

Term	Definition
Entry No.	This is a sequential reference number which has been linked to the record subjects.
Record Type	The records are initially listed by broad subject/function, and then further defined into activity types within each subject/function.
Responsibility: Creation/Maintenance	Departmental responsibility for recordkeeping is attributed to the position which has the task of ensuring the creation of the records. If the person in this nominated position chooses to delegate the responsibility for maintaining the records to another position within the department, the official responsibility still resides with the initial position identified by the EHS Recordkeeping Requirements.
Confidentiality & Access	If the records contain material of a personal nature relating to an individual employee, they have a confidential rating. Not all confidential records contain personal information. Some other confidential records may be classified as such due to University Management regarding their content as being potentially harmful to unauthorized persons. This will mean that they will have restricted access. Restricted Access records should only be made available to the Departmental Manager & the employee concerned. Records belonging to this category should be housed separately to the remainder of the EHS records. They should be maintained in a very secure environment. If the records contain no personal details they should be able to be accessed by all departmental employees. Such records will be on Open Access. All record types, whether their access level be restricted or open, should be maintained in a lockable office environment. They are part of the University's Environmental Management System, and as such, should be protected from unauthorised access by non-departmental persons.
Retention Period	This indicates how long records are to be retained by the department before being destroyed or transferred to Records Services. This column uses an expression "Destroy when superseded", which means that the records can be destroyed when new versions are created . It also uses the term "Destroy if administrative use has ceased", which means that the records identified can be destroyed when they are no longer needed.
End Custody	This indicates the department as being responsible for the records destruction, or instructs the department to transfer the records to Records Services for longer term retention.
Authoritative Source	This column specifies the University office responsible for maintaining the authoritative record within the University. The University office nominated in this column has responsibility for maintaining the record until it is destroyed or transferred to Records Services. Departments like the Risk Management Office (RMO) & Human Resources retain these records in accordance with their own separate legislative, financial, administrative and archival obligations.

To Identify The Retention Period :

1. Check the index for the function, activity or subject;
2. Turn to the appropriate disposal class and identify the relevant activity or record type;
3. Ensure appropriate recordkeeping responsibilities and access levels are met;
4. Identify the retention period;
5. Carry out the disposal action.

It is important not to try to force a file or record to fit a particular record type if there is not an appropriate record type listed in the EHS Recordkeeping Requirements. A list should be made of these types of records, as the EHS Recordkeeping Requirements may need updating or alteration. If you are unable to find an appropriate record type, you should seek assistance from the Risk Management Office.

 

Responsibility for Implementing EHS Recordkeeping Requirements

The Head of Department or delegate (Committee Secretary, Safety Officer, Purchasing Officer, Contract Supervisor, Building Emergency Controller, System Administrator, Website Administrator, First Aid Officer, Environmental Officer or Radiation Safety Officer) is responsible to ensure compliance with the EHS Recordkeeping Requirements.

Supervisors are responsible to ensure that staff adequately document EHS processes.

All staff and students are responsible for completion of appropriate documents to record their EHS practices.

 

Destruction Authorisation, Notification and Methods

There are broadly two classes of EHS records authorised for destruction which require different methods of disposal:

• restricted access or confidential
• open access or normal routine

Restricted Access or Confidential records contain information about individuals, information given in confidence or records related to investigations. These sensitive records should be shredded or placed into confidential wheelie bins. The security provided by the shredding of records depends on how fine the paper is shredded. For highly sensitive records, cross shredding may be necessary. If the records have been shredded, then they may be placed in the white paper recycling bins which have been issued to all departments.

• Confidential wheelie bins can be obtained by contacting the Manager, Cleaning Services on x48221. The Cleaning Services has a list of a number of contractors which provide secure destruction services. The confidential wheelie bins, which are lockable, are provided to your department and then collected by the contractor for appropriate destruction. The Manager, Cleaning Services will advise of the cost to the department for this service.

Open Access or Normal Routine records can be destroyed using the usual methods of white paper recycling. records can be destroyed using the usual methods of white paper recycling.

• Records Services recommends that a list of all records destroyed in accordance with the EHS Recordkeeping Requirements, be retained within the office filing system, as reference.

 

Transfer of Records

Once records have been classified by the EHS Recordkeeping Requirements as permanent Departments should notify Records Services (x46996, x44225, x46405) prior to listing and boxing for transfer to Records Services.

Records Services will provide archive boxes and Transferring Records to Intermediate Storage instructions.

 

Amendment and Updating

The EHS Recordkeeping Requirements is a reflection of current practice and procedures. Consequently it will need to be updated on a regular basis as the types of records being created by the University will alter over time. Retention periods may need to be altered due to legislative change and additions to the EHS Recordkeeping Requirements may need to be made due to new activities or changes which effect the types of records created and their retention periods.

Suggested inclusions, amendments and reviews of retention periods should be referred to the Risk Management Office.

The EHS Recordkeeping Requirements will be regularly reviewed to ensure that it complies with current practice.

For further information on EHS see the Risk Management Office homepage.

 

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