The form itself
We found no numeric retention period for the permit form in legislation. The general provision requires every record of the health and safety activities carried out at the workplace to be kept, but adds "without prejudice to the periods set in the relevant legislation" and gives no general figure. That is not a gap but a pointer: the period follows from which work the permit covered.
Periods for attached records
| Record | Minimum period | Clock starts |
|---|---|---|
| Records kept in work with carcinogens or mutagens | 40 years | End of exposure |
| Asbestos working time and exposure level records | 40 years | End of exposure to asbestos dust |
| Occupational hygiene measurement, test and analysis records | 10 years | Creation of the record — the floor where no period is set |
| Personal health files | 15 years | The worker leaving employment |
| Periodic inspection reports for work equipment | As long as the equipment is in use | Issue of the report |
A one year difference
The site procedure we measured set retention at 41 years for asbestos and for carcinogen and mutagen work. The regulation says at least 40 years. The difference is not an error but rounding to the safe side; still, a system that does not know where the number came from could round it down to 39 next year. That is why periods are recorded together with the legal reference.
If the activity ends
For carcinogen and mutagen records, if the activity at the workplace ends the records are handed to the provincial social security directorate; for asbestos records they pass to the acquiring undertaking if the workplace is transferred. The clock does not stop when the workplace closes.
What this means in practice
A permit system that does not know which record class a form belongs to cannot know its retention period either. The right arrangement is to attach the permit to the type of work and to derive the retention period from that type — rather than leaving it to a person to choose.