Keep each training record for the period required by its applicable rule and your documented retention policy. There is no single number of years for a manufacturing plant's whole register. Record the jurisdiction, the requirement and the event that starts each period; a training date, record-preparation date and end of exposure are different events.
This guide covers selected US federal OSHA general-industry provisions in 29 CFR 1910, FDA's food CGMP and preventive-controls rule in 21 CFR 117 for food plants, and Canada Labour Code Part II / Canada Occupational Health and Safety Regulations (COHSR) examples for federally regulated workplaces only. Most Canadian plants are provincially regulated. In Ontario, O. Reg. 297/13 requires employers to maintain a record of the basic awareness training and of working-at-heights training and to make a training record available to an inspector on request, but neither the regulation nor the Occupational Health and Safety Act sets a period for keeping these records. The three-year working-at-heights validity is a retraining interval, not a retention period. Other provinces set their own rules. State-plan states, construction under 29 CFR 1926, SQF, BRCGS, FSSC 22000, customers and insurers may set their own periods. None is assigned a number here.
- Start with the applicable rule and record type, not one blanket number for every course.
- OSHA bloodborne pathogens training records: three years from the training date.
- FDA food training records required by 21 CFR 117.4(d): at least two years after the record was prepared.
- A refresher or certificate-validity interval is not a record-retention period.
- Give the documented retention policy an owner and preserve the evidence behind each decision.
US federal general-industry and food-rule examples
| Training record and provision | Period and starting event |
|---|---|
| Bloodborne pathogens training29 CFR 1910.1030(h)(2)(ii) | 3 years from the date on which the training occurred. |
| Lockout/tagout employee training certification29 CFR 1910.147(c)(7)(iv) | The cited paragraph requires certification with each employee's name and training dates; it states no retention period. |
| Powered industrial truck operator training and evaluation certification29 CFR 1910.178(l)(6) | The cited paragraph requires certification with the operator's name, training date, evaluation date and trainer/evaluator identity; it states no retention period. |
| Food hygiene and food safety training records required by 21 CFR 117.4(d)21 CFR 117.4(d) and 117.315(a)(1) | At least 2 years after the date the records were prepared, retained at the plant or facility. See the storage options in section 117.315(c) below. |
Section 117.315(c) permits offsite storage of these records if they can be retrieved and provided onsite within 24 hours of a request for official review, and treats electronic records that are accessible from an onsite location as onsite.
“No period stated” describes only the cited training-certification paragraph. It does not mean the record can be discarded or that no other obligation applies. Read the OSHA records overview, lockout/tagout records guide and forklift records guide for the evidence each training provision addresses.
Canada: federal workplace examples
These COHSR examples apply only where the COHSR applies: federally regulated employment under Canada Labour Code section 123, except the employment that COHSR section 1.4 excludes (for example ships, and trains or aircraft in operation). Do not apply them automatically to a provincially regulated plant or treat them as a universal WHMIS certificate expiry.
| Federal record and provision | Period and starting event |
|---|---|
| Hazardous-substance education and trainingCOHSR 10.15 | Two years after the employee ceases to handle or be exposed to the hazardous substance, or is no longer likely to handle or be exposed to it, or ceases to install, operate, maintain or repair the assembly of pipes. |
| Motorized materials handling equipment operator instruction/training under 14.23(1)COHSR 14.23(4) | For as long as the operator remains in the employer's employment. |
| Emergency warden, deputy emergency warden and monitor instruction/training under 17.8(1)COHSR 17.8(2) | Two years from the date the instruction or training is provided, kept in the workplace to which it applies. |
| Employee training under the hazard prevention programCOHSR 19.6(5) | Two years after the employee ceases to be exposed to a hazard. |
The WHMIS training records guide explains why workplace jurisdiction matters. For Ontario work, confirm the applicable provincial rules before deciding the schedule; a course-validity period is not a retention decision.
Keep the retention decision separate from training status
A refresher, evaluation, inspection or certificate-validity interval is not a deletion date. Do not borrow a period from injury logs, exposure or medical records, payroll records or a different FDA rule. For ISO-related competence evidence, consult the ISO 9001 and ISO 45001 guides without assuming a retention period from either. Set a documented retention schedule with an owner who records the source, covered records, starting event and review decision.
For each course, retain the evidence needed to understand the completion and any assessment. Keep the record policy distinct from the recurrence schedule that drives the next assignment, and check retrieval during your audit preparation.
What TrainGrid keeps, exports and deletes
Records are kept while the organization has an account. You can export any time during the subscription and for 30 days after it ends. When an organization is deleted, its records are removed from production systems within 30 days; encrypted backups age out on a 90-day window. Archived employees keep their full training history. Permanent employee deletion is available only for employees with no history. The account, export and deletion periods above are described in our Privacy Policy and data protection page; the employee archive and delete rules are in the user guide. None of these choose your organization's retention policy.