Records management governs how quality records, the completed documents that provide objective evidence that quality-affecting activities were performed correctly, are identified, stored, protected, retained, and retrieved. NQA-1 Requirement 17 and 10 CFR 50 Appendix B Criterion XVII establish the requirements. Nuclear QA records are distinct from controlled documents: a procedure is a controlled document, but a completed work order signed off against that procedure is a quality record. Records have retention and protection requirements that reflect their evidentiary function, they may need to be retrieved and examined decades after the work was done, during re-licensing, maintenance planning, or regulatory investigation.
What constitutes a quality record
Not all documents generated in a nuclear program are quality records. A quality record is a completed document that provides objective evidence that a quality-affecting activity was performed, and how it was performed. Examples include completed inspection reports, calibration certificates, weld travellers with inspection sign-offs, non-conformance reports and their dispositions, audit reports, material test reports, supplier certificates of conformance, personnel qualification records, and completed test procedures with recorded results.
A procedure template is a controlled document. A completed procedure with signoffs, recorded measurements, and NCR references is a quality record. This distinction matters because records carry different obligations than documents: they must be retained for defined periods, protected against deterioration, and remain retrievable throughout their retention life.
The quality program must define which documents constitute quality records for each type of activity. A records categorisation matrix, identifying record types, retention periods, storage requirements, and responsible custodians, is a common tool for managing this across a complex program.
Identification, indexing, and retrieval
NQA-1 Requirement 17 requires that quality records be identifiable to the item or activity they relate to. This means records must carry sufficient traceability information, part number, serial number, heat or lot number, work order number, purchase order number, or similar unique identifier, to allow a later reviewer to establish the provenance of the work. Records that cannot be linked to the item or activity they certify provide no quality assurance value.
Retrieval requirements are particularly demanding in nuclear programs. A record that cannot be retrieved within a reasonable timeframe is treated almost equivalently to a missing record by regulators. Retrieval is tested during audits: auditors select completed work orders or procured items and trace the associated quality records, inspection signoffs, calibration status of M&TE used, material certifications, NCRs opened and closed. Programs with good physical storage but poor indexing consistently fail this test.
Retention vs. retrievability: Nuclear QA programs sometimes maintain excellent physical storage but lack the indexing needed to retrieve specific records efficiently. Auditors assess both dimensions: that records exist and that they can be found. A well-organised archival system with no retrieval capability is not compliant. Records management investment should be weighted toward retrieval infrastructure.
Storage, protection, and environmental controls
Quality records must be protected against deterioration, damage, and loss throughout their retention period. For paper records, this means fire protection, appropriate temperature and humidity controls, and protection from water damage. Vital records, those for which loss would be irreplaceable, should be stored in fire-rated facilities or duplicated at geographically separate locations. For electronic records, protection requires validated backup systems, migration planning to prevent format obsolescence, and access controls that prevent unauthorised modification.
Retention periods for nuclear QA records are long by most standards. Records for safety-related components and systems are typically retained for the design life of the facility plus a regulatory notification period, in practice, this often means 40 to 60 years or longer. Programs must plan for this at the outset: paper records stored in non-climate-controlled facilities will deteriorate well before their retention periods expire, and electronic records in proprietary formats may become unreadable as technology evolves.
Some facilities maintain duplicate records at geographically separate locations for records supporting the safety case or the licensing basis. This is considered best practice for records that could not be reconstructed if the primary copy were lost.
Records in supplier relationships and audits
Supplier-generated records, material test reports, inspection records, certificates of conformance, weld maps, must meet the same identification and protection standards as internally generated records. Procurement documents should specify the record requirements as a quality flow-down: what records are required, in what format, by what deadline, and with what traceability information. Suppliers who do not understand what records are required will generate inadequate records, and inadequate records discovered at receipt inspection create delays and potential nonconformances.
Auditors test records availability systematically. The standard technique is to select a sample of completed work orders, procured items, or inspected components and trace the complete set of associated quality records. Missing records, a calibration certificate for M&TE used during inspection, a material certification for a received component, an NCR disposition for a condition noted during fabrication, are findings. Records that exist but cannot be retrieved within the audit window are treated similarly. A robust records management program is one that can satisfy this test across any random sample of work.
Forged Operations keeps every quality record traceable, retrievable, and protected. Automated indexing links records to work orders, items, suppliers, and inspection events. AI identifies missing records before work packages close and flags gaps in supplier documentation during receipt inspection.
References
- American Society of Mechanical Engineers. ASME NQA-1-2022: Quality Assurance Requirements for Nuclear Facility Applications, Requirement 17 — Quality Assurance Records. New York: ASME, 2022.
- U.S. Nuclear Regulatory Commission. "Criterion XVII — Quality Assurance Records." Code of Federal Regulations, 10 CFR 50 Appendix B. Washington, D.C.: NRC.
- CSA Group. CSA N286:12(R2018): Management System Requirements for Nuclear Facilities, Clause 5 — Records and Document Management. Toronto: CSA Group, 2018.
- International Atomic Energy Agency. Safety Standards Series No. GS-G-3.1: Application of the Management System for Facilities and Activities, Section 5 — Documentation and Records. Vienna: IAEA, 2006.