How long do we need to keep maintenance logs/records/annual preventative maintenance records? We have kept records since we opened in 1998.
Thank you for your question. The UHMS HBO2 safety committee can provide information to assist you in answering your question, but the ultimate responsibility for these types of questions rests with the medical director and safety director of your facility.
The answer to your question may be varied, and we suggest that you work closely with your Authority having Jurisdiction (AHJ) and internal resources available in your facility to make this determination. These may include facility administration, Quality Control, Risk Management, Safety, Information Management, compliance and clinical engineering departments. The National Fire Protection Association glossary of terms defines the AHJ as “An organization, office, or individual responsible for enforcing the requirements of a code, or for approving equipment, materials, an installation, or a procedure.” There is more than one AHJ that would have interest in the records kept. Examples of possible AHJs would include: NFPA, ASME (PVHO-1 and PVHO-2), UHMS, FDA, TJC, OSHA, CMS, State specific Department of Health, Local Fire Authority, Interest specific Insurance Carriers/Underwriters, and institutionally imposed standards.
It is important to know that many standards only have the force of law if recognized by a governmental agency with authority in your area. The others are only enforceable if agreed to by the institution, for example insurance carrier/underwriter rules.
There are valid legal reasons for and against maintaining records beyond 7 years. Legal liability for keeping records past a determined time should be discussed with those responsible for the risk management of your facility. The Joint Commission has typically asked for preventive maintenance history and service history up to 3 years, while other regulatory agencies may go back a little further in time. Other areas (such as pediatric, neonatal, labor and delivery, or maternity) expect records to be kept for 21 years. And in some cases, facilities will retain records indefinitely.
The code references listed below reflect several examples of specific regulations regarding record retention:
• ASME PVHO-2-2016, Section 1 General, 1-4 PVHO and PVHO systems documentation, “The owner shall be responsible for maintaining the following documentation for the service life of the PVHO and PVHO systems:
(a) documentation required by ASME PVHO-1, section 1, General Requirements
(b) documentation generated during inspection, maintenance, repairs, and modifications
(c) documentation related to operational procedures and manuals”
• NFPA-25, 2017 ed. 4.3.4 “As-built system installation drawings, hydraulic calculations, original acceptance test records, and device manufacturer's data sheets shall be retained for the life of the system.”
• NFPA-25 2017 ed. 4.3.5 “Subsequent records shall be retained for a period of 1 year after the next inspection, test, or maintenance of that type required by the standard.”
The reference document listed below may be beneficial in determining your needs, and is intended for information purposes only:
ACEC Risk Management Committee and NSPE Professional Liability Committee, “DOCUMENT RETENTION GUIDELINES,” 2016
The UHMS Safety Committee
Neither the Undersea and Hyperbaric Medical Society (UHMS) staff nor its members are able to provide medical diagnosis or recommend equipment over the internet. If you have medical concerns about hyperbaric medicine you need to be evaluated by a doctor licensed to practice medicine in your locale, who can provide you professional recommendations for hyperbaric medicine based upon your condition. The responsibility of approving the use of equipment resides with the physician and safety director of the facility. Information provided on this forum is for general educational purposes only. It is not intended to replace the advice of your own health care practitioner and you should not rely upon it as though it were specific medical advice given to you personally.