I would suggest checking the FERC requirements for retention, especially for
long term retention. Check: CFR 125.3(21) and/or CFR 225.3(3)(a & b)
which I believe still uses LOF life of Facility + XXX. Using permanent and
the plant closes would indicate you still would be required to retained even
if you didn't own the facility. The citations maybe changed but was
reflected correctly a year + ago. Lots of good retention requirements for
electric/gas in the citations.
Robert W. Dalton, CRM
Dalton Consulting
253-229-4555
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Young, Stephanie
Sent: Tuesday, November 18, 2014 11:29 AM
To: [log in to unmask]
Subject: Re: NERC/ FERC Retention Question - requirements vs audit needs
Hi Amy:
> My concern is this: we are being told that we need to keep most items 7
years even if they don't have a 7 year retention based on state or federal
rules because they may come up in the scope of NERC/ FERC audits.
Unfortunately, I can't speak to NERC/FERC requirements, but I share your
concerns. For example, DCAA is one of our auditors and they are 8 years
behind in conducting their audits. Couple years ago, each department at my
company determined their retention schedules. Many erred on side of caution
by having audit-based retentions (e.g., "Audit Complete", "10Y after Final
Rates Determined", etc.) that exceed regulations (like FAR 4.7). However,
this has caused other issues: (1) the burden to keep and provide records
beyond what is required, and (2) extra man-hours spent tracking things down
for audits due to lack of a unified understanding of when "Audit Complete"
or "Final Rates Determined" occurred.
We recently kicked off an IG program to start addressing various issues
which include how to better disseminate audit complete, final payment, etc.,
but our main records concern is how to comply with regulations, keep what is
needed for audits and defensibly destroy/delete the rest to minimize
exposure risk?
I'm new to Records Management and would greatly appreciate guidance on this
topic from the list as well.
Best,
Steph
Stephanie Young, MSLS
Ball Aerospace
Boulder, CO
303-335-4479
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