Document a1e1qz4vjyRLkG5p6pjVBzb8y
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
fiPrnONMUMBH
fi&lA DATE
AOE, 1
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME__________________
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
I. CLEAN AIR ACT
A. Permits/Registered Sources
1 .a. Current air permits to construct/operate, including the underlying permit application and support information, key correspondence and compliance schedules. (Include previous permits only when referenced by the cunent permit).
1 .b. Permit reports and basic data supporting permit reports.
[111,112,40 CFR 51 and 52. Also C and D, 160-169,-171-178]
2. Annual Air Permits fees (unless other State requirement)
3. Permit Conformance tests
4. Withdrawn permit applications
5. Registered Sources Grandfathered sources not permitted
Information to register Source Certificates
[111,112,40 CFR 51.165, 52.24, 52.21]
6. Compliance Inspection Records, notice of violation
[114 and 110]
7. Consent Orders/Compliance Agreements
L plus 1
#
6#
2 or as required by local NP law, if longer 6 DR 6 DR
DCT 6 Current Year
6 DCT
For duration of effect on Dow
C0NF10FNT1al
NOTE: Each record wired above Is classified and coded with a proprietary or not classified cod# as folows: NP - Not Classified DR Restricted for use within Dow DC - Dow Confidential DCT - Dow Controlled * -Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006.249
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SFPTtClN NUMBER
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
8. Records of Accidents/Emissions from startups /shutdowns/malfunctions reports to Agency (Except those subject to litigation which will be retained pursuant to $1001 `Claims and Litigation")
[110 and subsections]
B. Air Pollution Surveys (in-house) (Only verifiable data should be maintained)
1. Ambient Air/Meteorological/ Climatological
2. Process emission data [C and D of the Act]
3. Vegetation damage (incidents)
Emission Inventory (Report to State and raw data to support Emission Inventory)
1. Basis for Calculation Methods, when not incorporated in a required record with a different retention
[110]
D. Prevention of Significant Deterioration (PSD) 1. Sources and Emissions for Baseline Determination
[40 CFR 51]
2. Permits, Supporting reports and final permit monitoring
E. Bubble alternative applications/determinations. Emission banking data and determination
[40 CFR 52]
3 NP
10 5 5 10
Until Superseded
DC
NP DC DR NP
L plus 1
L plus 1 5
DR DR
NOTE: Each record named above is classified and coded with a proprietary or not classified cods as folows: NP - Not Classified CONF TDFKjttai
DR Restricted for um within Dow DC. Dow ConMential DCT Dow Controlled # - Subject matter to determine classification
Nl 1
THE DOW CHEMICAL COMPANY
Do 625o
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
terwtij niimrfe
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Prafarrad Storaga RECORD NAME
Mada
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
F. NESHAPS (National Emission Standards for Hazardous Air Pollutants Sources) (Prior to a Titte V Operating Permit)
3
After obtaining a Title V Operating Permit
[112] G. Incineration Test Bums
5 or as specified in the permit, whichever is longer
6 DC
H. State Implementation Plans
NP
Compliance schedules for sources
6
DCT
I. NSPS (New Source Performance Standards) (Prior to Title V Operating Permit)
3
After obtaining a Title V Operating Permit
[111]
J. Documentation of Exemptions
5 or as specified in the permit, whichever is longer
Life of facility plus 5, or 5 after exemption ends whichever is less
K. All records not otherwise specified
3
II. ANALYTICAL AND QUALITY ASSURANCE/QUALITY CONTROL
This section governs the retention of analytical data and QA/QC records which have been generated by or at the request of environmental personnel, and which support the development and verification of the permitted activities of a facility under the various laws and regulations mentioned throughout this schedule.
NOTE: Each record namad abova la dassKted and coded with a proprietary of not classified coda aa lolows: NP Not Classified
OR - Rastridad tor uaa within Dow DC Dow Con*dant>a) DCT Dow Controlled # Subject matt* to detormtna classification
CONFIDENTIAL
THE DOW CHEMICAL COMPANY
DO 006251
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
RPCTIHM NIIMRPG
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
This information may be generated by: Laboratories affiliated with the environmental service units and environmental operations units at a Dow
site; Other Dow laboratories at the site; Outside laboratories under contract to the environmental function.
(Note: Schedule 861 requires that the original copies of all essential laboratory records be maintained in ithera central departmental or central laboratory file location.]
A. ANALYTICAL RECORDS
1. Central Files Originals of all records generated during a sampling and subsequent analysis (includes, but is not limited to: custody documents, photographs, field work sheets, chromatograms, computer printouts, strip chart readouts, calculation sheets lab reports; excludes items mentioned in paragraph A3.)
In accordance with the for purpose within Schedule 861 which the work was done
Examples: Instrument checks and standardization, control charts, check sample results, QC letters and miscellaneous information (ex. refrigerator temperature logs). [A2LA requirements for environmental laboratory accreditation under ISO/IEC Guide 25-1990]
2. Analyst's files
a. Analytical data in progress (analyst's possession)
Until completed
b. Analytical data completed
2 after completion
3. Notebooks/Databooks
See Section 1501
a. Bound notebooks which have been assigned an identification number (includes field logs, laboratory notebooks, research notebooks, instrument maintenance logs, standard prep logs)
50 after being closed out
NOTE: Each record named above is classified and coded with a proprietary of r>ot classified ood* as Mows: NP - Not Classified DR Restricted for usa within Dow DC Dow ConMenfcal DCT -Dow Controlled # Subject matter to determine classification
T DFNTj^t
THE DOW CHEMICAL COMPANY
DO 006252
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
* ENVIRONMENTAL
Preferred Storage RECORD NAME
Medta
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
b.Notebooks dedicated to a specified project or type of analysis (e.g., biomonitoring study, NPDES permit monitoring) which have not been assigned an identification number.
B. QUALITY ASSURANCE/QUALITY CONTROL RECORDS
1. QA/QC documents which support any results reported to a regulatory agency (includes DMR-QA studies).
2. Dow-sponsored inter-laboratory uniformity studies
3. QA audits and assessments of special projects, Dow laboratories, or contract laboratories (Not otherwise regulated)
4. Procedures, Standard Operating Procedures (SOPs), Operating Discipline Documents (ODDs)
a. Current copy
b. Obsolete versions (must be filed separate from current versions)
[ISO/IEC Guide 25-1990 tor accreditation of laboratories]
[A2LA requirements for environmental laboratory accreditation under ISO/IEC Guide 25-1990]
** or as required by regulation or certification authority, if shorter than permanent.
5. Analytical data not associated with permits (Le. drinking water)
III. ANNUAL BUREAU OF THE CENSUS QUESTIONNAIRE RESPONSES
See Paragraph A. 1
See Paragraph A.1 3 after completion See II.A.1.
Until superseded Permanent**
5 F Plus 1
DR
NOTE: Each record named above is classified and coded with a proprietary or not classified code as tofiows: NP Not Classified
OR - Restricted (or use within Dow DC-Dow Confidential DCT -Dow Controlled #-Subject matter to determine classification CONFIDENTIAL
THE DOW CHEMICAL COMPANY
DO 006253
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
B61A
DATE
mE___
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAMEMedia
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
IV. ANNUAL POLLUTION ABATEMENT REPORT (Includes MA-200)
V. COAST GUARD INSPECTION REPORTS
VI. CRITICAL MATERIALS USAGE. REPORTS AND DATA REPORTED TO AGENCY
VII. DOW ENVIRONMENTAL EVALUATIONS
A. U.S. Area Environmental `Assessments' (Pre-1991)(Predecessor to U.S. Area Compliance Audits)
B. U.S. Area Environmental Compliance Audits or Environmental Assessments/Consolidated Audits (Conducted in the plants & operating units of The Dow Chemical Company or subsidiaries by Environmental and Health Regulatory Affairs and/or Environmental Services personnel)
1. Draft Audit Report
2. Final Audit Report
3. Corrective Action Plan(s)
4. Audit Working Papers (includes pre audit questionnaire)
5. Status Reports
6. Follow-up Audit Report
5 - See Section 675
DC
5 NP 10 DR
Destroy Immediately
Destroy Upon Completion of Final Written Report
Until Superseded, Max 5
Until Superseded, Max 5
Upon Receipt of Corrective Action Plan or 6 Months after Destruction of Draft Report whichever comes first
Upon Completion of Corrective Action Plan
Same as Final Report
NOTE: Each record namad above is classified and coded with a proprietary or not classified code as folows: NP- Not Classified
DR - Restricted for use within Dow DC - Dow Confidential DCT-Dow Controlled # - Subject matter to determine classification CONFTDFNTTAl
THE DOW CHEMICAL COMPANY
D0 006254
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SECTION NHMBPP
RfilA
DATE
PAQF 7
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
C. Compliance Improvement Program (Utilized by personnel of Dow operating units to achieve and maintain environmental compliance)
1. Environmental Compliance Checklist
2. Monthly Deficiency Tracking Sheets
3. Monthly Data Plots (Div & Mgt area)
4. Multi-Year Plots
5. Compliance Assessment Findings
6. Compliance Assessment Follow-Up List
D. Dow Audits of External Treatment, Storage, Disposal or Recycle (TSDR) Firms (Audits are completed by Dow Environmental Services or Environmental and Health Regulatory Affairs personnel)
1. Working Papers
E. Due Diligence (Company Authorization Policy Article IX) Audits (These audits can be conducted by Dow Environmental personnel or hired outside contractors under guidance of U.S. Operations, in conjunction with Division and/or Corporate Legal)
This article shall cover all transactions involving real property including but not limited to, gifts; leases, whether Dow is lessor or lessee; sale or purchase transactions; easements; and mergers, acquisitions, or divestitures involving real property assets.
Current Year Current Month Current Year 3 Current Quarter Current Quarter
Until Superseded, max 10
Upon Completion of Report
NOTE: Each recotd named above is classified and coded with a proprietary or not classified code as Mows: NP - Not Classified CONTI DENT TAI
DR-Restricted for use within Dow DC - Dow Confidential DCT Dow Controlled #-Subject matter to determine dassHtaation
THE DOW CHEMICAL COMPANY
DO 006255
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SECTQNHUMBH
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
1. Final Audit Report (notes, records and reports)
2. Due Diligence Reviews Related to Article IX Transactions but no transaction
3. Division Due Diligence Audits (These audits are conducted by Environmental Services personnel for Donations, Easements, Right-Of-Ways, Leases and Licenses. The documentation may contain maps, written reports and background data.)
F. Environmental Review of Contract Manufacturing Facilities (Conducted by Area or Division Environmental and Legal personnel coordination with U.S. Operations. They will review contract manufacturing, blending, formulating and similar operations performed by others for Dow.)
VIII. ENFORCEMENT ACTIONS BY GOVERNMENT AGENCIES (ERA, OSHA, FDA, ETC.)
A. Retain contents relating to enforcement action until case is closed
B. Closed - Resolved/settled (except dispositive documents)
C. Closed - Unresolved (except dispositive documents)
D. Dispositive documents (ie consent decree, finaljudgment, settlement agreement)
IX. ENVIRONMENTAL IMPACT STATEMENTS
Baseline Studies
3 beyond last contract obligation as to Divestiture or contractual benefit if an Acquisition
1
3 beyond last contract obligation as to Divestiture or contractual benefit if an Acquisition.
5
1 4 25
P NP
NOTE: Each record namad abova it classified and coded with a proprietary or not classified cods as (blows: NP Not Classified DR Restricted for um within Dow DC - Dow ConManial DCT - Dow Controlled # - Subject matter to datormina classification
... __. -------------------------------------------------------------
co^tofnttal
THE DOW CHEMICAL COMPANY
oo 006256
DOW RECORDS RETENTION SCHEDULE
______________________________________________________ SFCmflN NUMBcf _____ OBlUA____PAPE __
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
X. ENVIRONMENTAL INCIDENTS/INCIDENT LOG
Citizen complaints/Damage claims/ Investigation reports (internal/extemal)
(Significant citizen complaints, etc. maybe transferred to a claims file for a longer than 5 year retention, See Legal Section 1001/Claims)
For Statistical Reporting of Environmental Incident Data
XI. FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT
A. Pesticide Disposal Records
[40 CFR 169.2(1)]
Name of material, quantity, location and method of disposal
Containers Disposed
The EPA will accept a statement from a responsible firm official describing in general terms the method and location of disposal for containers that are periodically taken to a certain site.
COMMON DOW RECORDS
5 DR See XXIII F
20 DR 20 DR See Section 628
NOTE: Each record named above is dassMled and coded with a proprietary or not daeaitled code as tdows: NP - Not Classified
DR - Restated for use within Dow DC Dow ConMentiai DCT - Dow Controlled - Subject matter to determine classification CONFIDENTIAL
THE DOW CHEMICAL COMPANY
DO 006257
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SECTION NUMBER
fifilA
DATE
AQ 10
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage
CURRENT YEAR PLUS TOTAL
OWNING
RECORD NAMEMediaRETENTION IN YEARS
CODE SECTION
XIII. GROUNDWATER RECORDS Our groundwater records are primarily under RCRA. See RCRA/D/#l/#2. They are also generated under Superfund. See Superfund/CERCLA/#4.
A. Groundwater records include many other records than the analytical results of groundwater samples from the monitoring wells like:
Note: Records retained in order to comply with RCRA and regulations promulgated there under must be reviewed at the purge date to determine whether they must be relabeled and retained to comply with internal Dow policy (on-site or offsite disposal records).
1. Monitoring Wells Inventory, location, number, depth, up or down gradient, well construction.
[40 CFR 264.97(c) & 265.91(a)]
2. Sampling and Analysis Plan Sample preparation, containers, preservation, shipment, chain of custody, elevation of groundwater in well during sampling, analytical methods, quality assurance of methods, accreditation of laboratory.
[40 CFR 264.97(d) & 265.92(a)]
3. Statistical Procedure (Student-ftest) To determine if analytical results exceed background levels or concentration limits.
[40 CFR 264.97(h) & 265.93(b)]
P
Closure plus 5 or Post Closure if necessary
Closure plus 5 or Post Closure if necessary
NOTE: Each record named above is classified and coded wilh a proprietary or not classified code as folowa: NP - Not Classified OR - Restricted for uae within Dow DC - Dow ConMential DCT Dow Controlled t - Subject matter to determine classification CONFIDENTIAL
THE DOW CHEMICAL COMPANY
DO 006258
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
4. Background Concentrations/ Quality Concentration levels of each RCRA hazardous constituent in upgradient monitoring well/s.
[40 CFR 264.92, 264.93, 264.94 and 265.92]
5. Hydrogeological reports for facility and surrounding land/flow and direction of groundwater.
B. Monitoring Programs
1. Interim Status Facilities Ground Water Monitoring (Subpart F) Recordkeeping and reporting (Note: TSR's post-closure time is equal to operational time of unit)
[40 CFR 265.94]
a. Quarterly Reports (1st yr) (Establish initial background concentrations or parameters values for each monitoring well)
[40 CFR 265.91, .92, .94]
b. Annual Report (after 1st yr) Groundwater quality
[40 CFR 265,92(bXd)]
c. Semi-Annual Report Groundwater contamination.
[40 CFR 265.92(b)(3),(d)]
Closure plus 5 or Post Closure if necessary
P
Closure plus 5 (TSR's) or Closure plus PostClosure/minimum 30 (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure/minimum 30 (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
NOTE: Each record named above Is destined And coded with a proprietary or not classified coda as folows: NP Not Classified DR - Restricted for use within Dow DC - Dow Confidential DCT Dow Controlled #-Subject matter to determine classification
Co^tofnt
THE DOW CHEMICAL COMPANY
DO 006259
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
12
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
d. Groundwater Quality Assessment Plan
[40 CFR 265.90(d), 265.93]
e. Annual Report Notice (Informing Reg. Admin, a facility may be affecting groundwater quality)
[40 CFR 265.93(d)(1)]
* Note: B1 records are candidates for retention in B2 when your facility gets its Part B permit.
2. Permitted Facilities Releases from Solid Waste Management
(Subpart F)
Written notification to Reg. Admin, (of significant increase of indicator parameters or hazardous constituents)
Application for permit modification to Reg. Admin, for detection monitoring system
Written demonstration notification
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus PostClosure (Disposal facilities)
CONFTDFNTT At
NOTE: Each record named above is classified and coded with a proprietary or not classified code as Mows: NP- Not Classified DR - ResYicted tor use within Dow DC Dow Conftdenfiai DCT- Dow Controlled #-Subject matter to determine classification
THE DOW CHEMICAL COMPANY
00 006260
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
b. Compliance Monitoring [40 CFR 264.99]
Closure plus 5 (TSR's) or Closure plus Post Closure (Disposal facilities)
Quarterly Compliance Report/Compliance Period (Concentration of hazardous constituents in each compliance point monitoring welt's are meeting groundwater protection standard)
Annual determination of flow and direction of groundwater
Notification of presence of additional hazardous constituents (App Vllf) in compliance point wells {Annually
Closure plus 5 (TSR's) or Closure plus Post Closure (Disposal facilities)
Closure plus 5 (TSR's) or Closure plus Post Closure
(Disposal facilities)
Application for permit modification to establish corrective action program.
Closure plus 5 (TSR's) or Closure plus Post Closure (Disposal facilities)
Written demonstration notification
Closure plus 5 (TSR's) or Closure plus Post Closure (Disposal facilities)
c. Corrective Action Monitoring
[40 CFR 264.100, .101]
Semi-annual report/on effectiveness of corrective action
Closure plus 5 (TSR's) or Closure plus Post Closure (Disposal facilities)
CONFTDFNTTAI.
NOTE: EacTi record named above is classified and coded wrtb a proprietary or not classified code as folows: NP -Not Classified DR - Restricted for um within Dow DC Dow Confidential DCT - Dow Controlled # -Subject matter to determine classification
1
in i
i.
ii
.1 ^ j
--
THE DOW CHEMICAL COMPANY
00 0062M
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
ftprmw NtlMRFF
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Medta
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
Written application for permit modification (When program no longer satisfies requirements)
XIV. IN-PLANT ACCOUNTABILITY
A. Sewer Surveys (water survey)
Permit-related surveys Special surveys
B. Internal sewer permits
C. Incineration/Landfill (Basis for recharge)
XV. INTERNAL REPORTS
(Includes files on specific pollutants and special studies, not filed in CRI)
A. Issue Management Team Minutes
B. Issue Management Team Policy Statements
C. Technical Report Release Approvals
XVI. LANDFILL BURIAL RECORDS (ON SITE DISPOSAL)
Land Disposal Certifications
XVII. MANUALS/DATA BOOKS
A. Emergency Response Manual
B. Standard Industrial Classification Directory (Codes for U.S.A. Operations)
C. Environmental Services Data Books (See Analytical Records II)
Closure plus 5 (TSR's) or Closure plus Post Closure (Disposal facilities)
Lplus 1 3 F plus 1 2
5
DC
DC DR #
3 Until superseded
# DR
5 See Section 661 XVIII
# #
See Section 861 XXIV
Until revised Until revised
DCT
50 DC
CONFIDFNTIAt
NOTE. Each record named above is classified and coded with a proprietary or not classified oode as Mows: NP-Not Classified DR - ResWcted for use within Dow DC - Dow Confidential DCT - Dow Controlled -Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006262
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
qprTlOM NIlMRFf
DATE
pare
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Prefaced Stcxago RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
XVIII. OFF-SITE AND ON-SITE DISPOSAL Landfill Burial Records (on-site disposal)
Records for off-site disposal of hazardous and non-hazardous waste, including contracts, purchase orders, release invoices for purchase orders, manifests or any documents describing the amount, characteristics, methods and/or treatment of those wastes moved off-site (both Dow owned and non-Dow owned)
P P
#
Also see Section 861A XXIV(D.I)
Landfill Tags (Dow Owned Facility)
P
XIX. POLLUTION CONTROL BOND RECORDS
See Section 1551
DR
XX. PROCESS AUTHORIZATION REVIEWS
5
DC
XXI. QUARTERLY ENVIRONMENTAL SEC DISCLOSURE (Background Data)
2
' DR
XXII. RADIATION RECORDS (other than `mixed waste` records under RCRA)
See Section 1502F
#
XXIII. REQUIREMENTS RECORDS
A. 1. Comments to Federal Register Notices Statements before Congress or to the EPA
10 or until rule has been NP promulgated whichever is longer
2.EPA/Contractor Information Request Letters (308/114/3007/ 8(a)ySARA Title III and subsequent Dow correspondence) Original submission retained by E&HRA Data Center
Backup data kept by Divisions
10 or until rule has been NP promulgated whichever is longer
5
B. Logs of informal agreements/ Communications with government agency personnel
C. Biennial Report (See RCRA 2.1)
10 or life of permit/equip., DR whichever is longer
15 CONFIDENTIAL
NOTE: Each racord namad abova is dassrfiad and ooded with a pfopdatary of not cteasifiad ooda as folows: NP - Not CtasaHiad DR -Restricted fcx u* within Dow DC Dow Confidential DCT - Dow Controlled * - Subject mattar to determine classification
THE DOW CHEMICAL COMPANY
DO 006263
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
16
.............
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
D. Documentation of Our Legal Opinions/Interpretations
Annual review to remove obsolete material
Keep opinions as long as they are applicable.
E. Environmental Fines and Penalties (Statistical Data)
10
F. Environmental Incident Data (Monthly, Quarterly, Annual Reports) (also see sections XXVI., A. 1. and XXVI, B.3.) Global incident Reporting Database (GIRD)
5
G. Global Emissions Inventory (GEI) GEI Database Records Documentation of Changes made to database Plant level worksheets, calculations and activity data needed to support
XXIV. RESOURCE CONSERVATION AND RECOVERY ACT
12 12
5
Note: Records retained in order to comply with RCRA and regulations promulgated thereunder must be reviewed at the purge date to determine whether they must be relabeled and retained to comply with CERCLA or internal Dow policy (on site or offsite disposal records.)
A. RCRA Permits/Applications /Modifications
1. RCRA Part A (including all external correspondence & computer files)
2. RCRA Part B (including all external correspondence & computer files)
L plus 5 L plus 5
C^FTDPNTTAt.
NOTE: Each record named above is classified and coded with a prophatary or not classified code as Mows: NP- Not Classified DR-Restricted for use within Dow DC Dow Confidential DCT - Dow Controlled #-Subject matter to determine classification
THE DOW CHEMICAL COMPANY
00 006264
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
fiPfmON NIIMRPP
ARIA
DATE
paof
17
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
- Trial Burn Results
3. State Permit Applications (including all external correspondence & computer files)
4. RCRA Permits
5. State Permits/Notice of Registration
6. Consent Agreements, Compliance Orders, Regulatory Agreements
7. Facility's RCRA Permit Reference File (Candidates for this file are A1-6)
B. Generator Records
1. Manifests
[40 CFR 262.40]
(These manifests become OffSlte/On-Site with permanent retention after 4 yrs under RCRA.) (See XVIII)
2. Quarterly exception reports
[40 CFR, 8262.40{b)]
3. Summary reports to State
4. Biennial reports to EPA
[40 CFR 262.40]
Until superseded L plus 5
L plus 5 L plus 5 For duration of effect on Dow Annual review to keep current. Have division RCRA Reg. Mgr. sign and date yearly.
3
5
3 or as required by law 3
r,ONFtDFN'nAl'
NOTE: Eacfi record named above l classified and coded wtth a proprietary or not classified code as tolows: NP-Not Classified DR - Restricted for use within Dow DC-Dow Confidential DOT Dow Controlled * Subvert matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006265
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
Mhl DATE
PAGE
W
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
5. Training Records
Current Employees Former Employees
6. Inspection Records
7. identification number
[40 CFR 262.12]
8. Hazardous waste export notices
9. Waste analysis reports (may be candidates tor Superfund records/See Superfund/A)
[40 CFR 262.11, 262.50]
Closure 3 after termination 3 P
Expiration plus 3 3
10. Storage/Hazardous Waste
A generator who accumulates waste on-site for over 90 days must also comply with requirements for storage facilities under 265 or 264 [40 CFR 262.34]
11. Land Disposal Restrictions Certifications
3 5
[40 CFR 268.8[a)] C. Transporter Records
1. Manifest [40 CFR 263.22]
2. Discharge notice [40 CFR 263.30]
3 3
3. State permit applications 4. State transporter permits
L plus 3 L plus 3
CONFTDFNTTAL
NOTE: Each record namadabova is dassifiad and oodad with a proprietory or not daaaifiad coda as tolowa: NP - Not Ctassifiad DR -Restricted for usa within Dow DC Dow Conltdantial DCT Dow Controliad - Subject matter to datarmina classification
THE DOW CHEMICAL COMPANY
00 00626>k
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
5. Identification number
[40 CFR 263.11]
Note: A transporter who stores manifested waste at a transfer facility for more than 10 days must also comply with 265 or 264 [40 CFR 263.12]
D. Operator Records
1. Landfills and Surface Impoundments
[40 CFR 264.73, 264.74, 265.73]
a. Description & quantities of hazardous waste received by the facility
[40 CFR 264.73(b)(1), 265.73(b)(1)]
b. Methods and dates of treatment, storage or disposal at the facility
[40 CFR 264.73(b)(1), 265.73<b)(1)]
c. Location of each hazardous waste within the facility & quantity at each location including maps and cell diagrams
[42 USC 9603; 40 CFR 264.73(b)(2), 265.73(b)(2)]
'Note: 1 a,b,c are candidates for permanent retention as per XVI
d.Land Disposal Restrictions Certifications
Closure plus Post-Closure or as specified in Correction Action Program Closure plus PostClosure or as specified in Corrective Action Program
Closure plus PostClosure or as specified in Correction Action Program
Closure plus PostClosure or as specified In Corrective Action Program
5 CONFTDFNTTAt
NOTE: Each reoord named above to da*ifiod and coded with a proprietary or not ctaaaHled code aetolowe: NP-Not Classified DR - Restricted tor um within Dow DC Daw Contdenttel DCT Dow Controttad # Subject matter to determine ctaesHtcaion
THE DOW CHEMICAL COMPANY
DO 006267
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SPrTlOM NUMBER
fifilA
DATE
mL 20
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
MadiaRETENTION IN YEARS
CURRENT YEAR PLUS TOTAL CODE SECTION
OWNING
2. All Treatment, Storage and Disposal Facilities (including Landfills)
a. General Facility Description and Information (Keep track of TSD facilities)
b. Inspection records (mixed waste)
If waste contains radioactive materials
[40 CFR 264.15, .73(6X5), 265.15, .73(b)(5)]
[10 CFR 20.2102a.2]
c. Waste analysis records (waste analysis, waste characterization, etc.)
[40 CFR 264.13, 265.13]
d. Groundwater records (monitoring, hydrogeologic studies)
[40 CFR 264.73(b)(5), 265.73(bX60, .(94)]
e. Training records
Current Employees Former Employees
[40 CFR 264.16]
Closure 3 See Section 1502F
Closure1
P
Closure 3 after termination
CONFTDFNTTAL
NOTE: Each record named above is classified and coded with a proprietary or not classified code as Wtows: NP Not Classified DR - Restricted for use within Dow DC - Dow Confidential DCT - Dow Controlled #-Subject matter to determine dassHScatfon
THE DOW CHEMICAL COMPANY
DO 006268
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
PAHP - DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
f. Preparedness and Prevention Plan
[40 CFR 264 Subpart C, 265 Subpart C]
g. Contingency Plan
[40 CFR 264 Subpart D, 265 Subpart D] (updated annually)
h. Emergency incident reports
i. Integrity assessments (new and existing hazardous waste tanks and associated lines)
j. Biennial Report to EPA After 5 years move to XXIII REG. DEV. (toradditional 10 years)
[40 CFR 264.75, 265.75]
k.Closure Plan
[40 CFR 264.112]
1. Post-closure plans and reports (including post-closure monitoring records)
[40 CFR 264.117(a)(1), 264.118(c), 265.117(a)(l), 265.118(b)]
m. Hazardous Waste Storage
[40 CFR 264.73(b)(1)]
1 These RCRA records are candidates for permanent retention under Section XVIII or VII, E after their useful RCRA retention.
Closure1
Closure1
Closure1 P 5
Closure plus 30/or until superseded Closure plus PostClosure Until no longer relevant
Closure1
CONFTDFN'H^-
NOTE: Each record namad abova is dassifiad and oodad with a propristary or not classified coda as fdows: NP- Not Classified
DR - Rastrictad for usa within Dow DC - Dow Confidential DCT -Dow Controlled - Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006269
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SECTION NUMBER DATE
BASS. 22
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Medfe
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
n. Summary reports to State
o. Records for material sent to reclaimer or recycler
p. Corrective Action/Compliance Plan Correspondence, Corrective Action order, Compliance plan, Analytical data (Candidate for Permit Reference File XXV, A, 7.)
E. Annual Fee/s
F. Financial Assurance (Financial responsibility closure/post closure and sudden and non-sudden accidental occurrences.)
Forms Data
[40 CFR Subpart H of 264 and 265]
G. Notification of Underground Storage Tanks (5/8/86 Regulated substances 101(14) CERCLA and petroleum)
[40 CFR 280.1 -.3]
H. Boilers and Industrial Furnaces Operating Records (permitted units)
[40 CFR 266.102(e)(10]
Operating Records (interim status units)
[40 CFR 266.103(k)]
"'These RCRA records are candidates for permanent retention under Section XVIII or VII, E after their useful RCRA retention.
15 P For duration of effect on Dow1
2 Current plus 1
3 5
P
until closure
until closure
COnftdeNt
tal
NOTE: Each reoord named above is classified and coded wilh a proprietary or not classified oode a* Mows: NP Not Classified DR. Resticted lor use within Dow DC - Dow Confidential DCT - Dow Controlled # Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006270
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
BFCTtnNNtlMBFF
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
Inspections of Direct Transfer Operations
[40 CFR 266.111(e)(3)(iii)]
Residue Management
[40 CFR 112(c)]
Small Quantity Burner Exemption
XXV. SAFE DRINKING WATER ACT
A. Potable Water Records
1. Well logs 2. Plug and Abandon Report
B. Deep Well Injection (Underground Injection Control)
1. Permits 2. Performance and Mechanical 3. Integrity Records 4. Gas Well Records 5. Reports of Spills 6. Baseline Surveys/Impact Studies 7. Plug and Abandon Report 8. Well logs
XXVI. SUPERFUND
A. Comprehensive Environmental Response Compensation, and Liability Act (CERCLA)
1. Reporting to National Response Center
[CERCLA 103,40 CFR 302]
2. Notification of inactive hazardous waste storage, treatment or disposal sites
3
until closure
3
5 P P
P P P 3 10 20 P P
NP
DR DR
NP DR DR NP NP DR DR DR
5 NP 50
CONFIDENTIAL
NOTE: Each record named above la classified and coded with a proprietary or not classified code as Mows: NP- Not Classified
DR Restricted tor use within Dow DC - Dow Confidential DCT- Dow Controlled # Subject matter to determine classification
THE DOW CHEMICAL COMPANY
D0 006271
DOW RECORDS RETENTION SCHEDULE
major function
SFCTION NIJMREF
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Marfa
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
Records specifying location, title or condition of such sites
[CERCLA 103(c)]
Request from EPA for informatiorv'old site
[CERCLA 104(e)]
3. Records specifying the identity, characteristics, quantity, origin or condition (including containerization and previous treatment) of hazardous waste contained or deposited in such sites. (Dow Policy, see Section XVIII.)
[40 CFR 103(d)(8)(A)]
4. Records and documents pertaining to the performance of abatement action pursuant to 106(a), [42 USC 9606(a)], Of CERCLA not covered under other portions of this schedule (e.g., Rl/FS, workplans, administrative orders and associated data and reports, PSAD, ROD, RD, RA.)
SO 50 50
As specified in the order
(Includes groundwater monitoring records.)
5. Petition for delisting the site from NP List Final Summation
50 50
CONFIDENTIAL
NOTE: Each racord namad abova is dasaifiad and codad with a propriatary or not dautfiacl ooda as fohws: NP Not Ctaaaffiad
DR - Rastoctad for uaa within Dow DC - Dow Oonfldattfal DCT Dow Controllod * - Subjact mattar to datormirra ciassificaboo
1111: DOW CHEMICAL COMPANY
DO 006272
DOW RECORDS RETENTION SCHEDULE
major function
nmM DATE
PAQE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
B. Superfund Amendments Reauthorization Act (SARA)
Emergency Planning and Community Right to Know Act (Title til)
1. Emergency Planning Notification [302 of Act]
2. Notification of Identity of Facility Representative
[303 of Act]
3. Emergency Release Notification (Both LEPC and SERC)
[304 of Act]
4. Categorized List of OSHA "Extremely Hazardous Substances or Material Safety Data Sheets
[311 of Act]
S. Emergency and Hazardous Chemical Inventory and Location Form
[312 of the Act]
6. Toxic Chemical Release Inventory Reporting Form R (Including all individual plant activity data to support this annual facility report starting in 1993 with 1987 data)
[40 CFR 372.1Q/313 of Act]
5 5
S
5
5
5* * Exception - All 1988 baseline data should be kept until the year 2000
CONF T DFNTT At
NOTE: Each record named above is classified and coded with a proprietary or not classified code as folow*: NP - Not Classified
DR Restricted for uae within Dow DC - Dow Confidential DCT Dow Controlled # Subject matter to determine ctaaaification
THE DOW CHEMICAL COMPANY
DO 006273
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
7. Trade Secret Substantiation Claims/ Chemical Identity for 303(d)(2) and 303(d)(3), 311, 312, 313
[40 CFR 350]
XXVII. TOXIC SUBSTANCE CONTROL ACT
(For health Issues under TSCA - See Section 861B)
A. Section 6 Polychlorinated Biphenyls (PCB's and PCB Items)
1. In-service or projected for disposal Annual report/supporting records
[40 CFR 761.180(b)]
2. Disposal and Storage Facilities (General Requirements)
Annual document/supporting records
[40 CFR 761.180{b)]
Special records
[40 CFR 761.180(1)]
Inspection by State
1 Years after facility ceases to use or store. 2Years from date of collection of such information. 3Years after facility ceases to store or dispose.
3 after we waive our claim or claim is finally denied
5"' NP
53 NP 53 NP 7
CONFIDFNTTAl
NOTE: E^h record named above is classified and coded with a proprietory or not classified code as Mows: NP-NotCtessifted DR Restricted tor use within Dow DC - Dow Confidential DCT - Dow Controlled # Subject matter to detornvne dassificallon
THE DOW CHEMICAL COMPANY
DO 006274
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
fiPCTIQM NUMBER
DATE
PAOF 27
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
_____________
Preferred Storage
CURRENT YEAR PLUS TOTAL
OWNING
RECORD NAMEMediaRETENTION IN YEARS
CODE SECTION
3. Incineration Facilities
Trial bum results Permit application
[40 CFR 761.180(b)J/[40 CFR 761.180(1)]
Annual document/supporting records
[40 CFR 761.180(b)]
Special records
[40 CFR 761.180(c)]
Inspection by State
4. Landfill Facilities
Annual document/supporting records
[40 CFR 761.180(b)]
Special records
[40 CFR 761.180(f)]
Operating records on water analysis/ burial coordinates
[40 CFR 761.180(d)]
5. PCB Rule 3 Exclusion (Inadvertent Generation)
1 Years after facility ceases to use or store. 2Years from date of collection of such information. 3Years after facility ceases to store or dispose.
53
53 S2 7 P P P 71
DC NP NP
NP NP NP
CONFTDFNTTAl
NOTE; Each record named above is classified and coded with a proprietary or not classified code as tolowe: NP No! Classified DR ResSicted for use within Dow DC - Dow Confidential DCT Dow Controlled * -Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006275
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
gpr-nnu number
ARIA
DAT!
AOL 28
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME_________ _______________________________
CURRENT YEAR PLUS TOTAL
OWNING
MediaRETENTION IN YEARS
CODE SECTION
Supporting records (includes monitoring records and theoretical analyses)
[40 CFR 761.3 and Subpart J])
6. PCB Transformer Inspection and Maintenance records
[40 CFR 761.30(a)]
B. Section 8A
C. Section 8B Site or Plant Inventory lists
D. Pre-Manufacture Notifications (PMN's)
E. Section 8C
F. Section 8D
G. Section 8E
XXVIII. WASTE MINIMIZATION
Dow "WRAP" Program (All supporting data)
Hazardous Waste Generation Reports to Regulators
1. Annual State Reports
2. Federal Biennial Survey Forms WM-Part I, II
3. Toxic Chemical Release Inventory Reporting Form R Section 8 (This is part of a SARA record 313 record)
Wears after facility ceases to use or store. 4Or three years after process ceases, whichever is shorter.
74
31
See Section 861B Until superseded See Section 861B See Section 861B See Section 861B See Section 861B
5
#
5 5
5
confidential.
NOTE: Each record named above Is classified and coded wilh a proprietary or not ctassifiedoode as tolows: NP Not Classified DR - Restricted for use within Dow DC Dow Confidential DCT Dow Controlled # Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006276
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
SjFPTinM niimhef
DATE
PAGE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
XXIX. CLEAN WATER ACT
A. Permits & Applications
1. NPDES/State Permits,
Applications, and associated correspondence
2. Storm Water General Permits
Notice of Intents (NOIs)
3. Discharge Permits/Contract Licenses for Source Dumping Into POTW
4. Dredge and Fill Permits
5. Records of data used to complete applications
[40 CFR 122.21(0) requires a minimum retention of 3 years]
*
Life of current permit plus previous permit
Life of current permit plus previous permit
Life of current permit plus previous permit
Life of current permit plus previous permit
Life of current permit plus previous permit
B. Monitoring Reports
1. Discharge Monitoring Reports
(DMR), State Monitoring Reports, Analytical Reports & Raw Data
Sheets (to support monitoring reports)
Life of permit plus 5
[40 CFR 122.41 (j)(a) requires a
minimum retention of 3 years]
2. POTW Industrial User Monitoring Reports
Life of permit plus 5
[40 CFR 403.12(oX3) requires
a minimum retention of 3
years]
3. Noncompliance Reports and associated correspondence to the Agency
Life of permit plus 5
OONFTDFNTTAI
NOTE: Each record named above le classified and coded with a proprietary or not dasaified code eafolowr NP-Not Classified
DR Restricted for use within Dow DC Dow Confidential DCT Dow Controlled * - Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006277
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Preferred Storage RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
C. Special Studies/Baseline Data
D. Storm Water Pollution Prevention Plans (SWPPPs) 1. Annual site inspection 2. Annual site compliance evaluations 3. Certification of Compliance 4. Noncompliance Reporting 5. SWPPP Amendments/ Modifications
E. Best Management Practices (BMPs) [40 CFR 125]
F. Enforcement Actions (see 861A, VIII) G. Permit Reference Files (candidates
for this file are all prior records for A through F)
H. Fees 1. Daily logs from operations J. CWA 311 Spills
1. Spills (reports to Agency) 2. Other non-superfund spill reports
As long as useful; after 10 requires written authorization
Life of permit plus 5 Life of permit plus 5
Life of permit plus 5 Life of permit plus 5 Life of permit plus 5
Until superseded
Annual review to keep current. Have division CWA Regulatory Manager sign and date yearly 2 3
5 5
confidential
NOTE: Each raoord narrMd abova is dassHrad and cxxlad witt) a propriatary or not dassilwd coda as lolows: NP Not Owsifred DR-RasSictad for usa within Dow DC Dow Confidential DCT Dow Controliad * Sutyect matter to determine ciassihoabon
THE DOW CHEMICAL COMPANY
DO 006278
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
RfilA
DATE
PAPE 31.
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- ENVIRONMENTAL
Protected storage RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNINQ
RETENTION IN YEARS
CODE SECTION
K. Spill Prevention Control & Countermeasure (SPCC) [40CFR 112]
1. SPCC Plan
2. SPCC Inspection Records
3. SPCC Training Records
L. Facility Response Plans [40 CFR 112.20]
While [40 CFR 112.41G)(a)] and [40 CFR 403.12(o)(3)] require a minimum retention of 3 years, discharges may be subject to a citizen suit for 5 years in most jurisdictions.
Until superseded 3 3 Until superseded
CODE INDEX L = Life of Permit P = Permanent A s As specified in Permit F Life of Facility
To ensure 'evergreen status,' this record retention schedule is subject to review at quarterly Environmental Managers meeting.
OONFTDENTTAI
NOTE: Eacti record named above is classified and coded with proprietary or not classified cobs as Mows: NP Not Classified DR - Restricted for um within Dow DC - Dow Confidante! DCT Dow Controlled # -Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006279
DOW RECORDS RETENTION SCHEDULE
PWUOR FUNCTION
Preferred Storage RECORD NAME
Maria
datc
......
CURRENT YEAR PLUS TOTAL
OWNINQ
RETENTION IN YEARS
CODE SECTION
This page was intentionally left blank.
CONFTDFNTrA(
NOTE: Each record named above is classified and coded with a proprietary or not classified cod# as Mows: tP -Not Classified DR Restoeted for use within Dow DC Dow Confidenfcal DCT Dow Controllad # -Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006280
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
RFCTION NUMREI
DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- HEALTH SCIENCES
Preferred Storage RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNINQ
RETENTION IN YEARS
CODE SECTION
1. General
Audits, Guidelines
Audits, Reports
Audit working papers; notes; drafts of final report
Follow-up responses to final report and related correspondence
Certificates of Compliance/Letters of Certification/Listings
Comments, Notices, & Reports to Regulatory Agencies, including back-up data (Submissions file)
FIFRA 6(a), TSCA 8(e) & TSCA 8(c) Committee (Dow) Minutes/Completed Special Projects/Communications
Continuing Guarantees by Dow on our Products
Continuing Guarantees by suppliers on their Products
Data Necessary for Certification in Professional Organizations
Interpretation of Regulations
Lists of regulations, people, chemicals
Product Files: Correspondence Projects Raw Material/Additives - Supplier Information
Until revised
1
Short term; maximum when final report is prepared
File with final report; destroy with final report
2 after product is discontinued
15
1
Duration of guarantee. Where there is no time limit in the guarantee, 1 after product is discontinued, but not more than 7.
1 after purchase is discontinued
7
As long as useful
As long as useful, max until superseded
2 1 after completion Current
CONFIDENTIAL
NOTE: Each raoord namad above is classified and coded with a proprietary or not dassifiad coda as tolowa: NP-Not Claastfiad DR RaaYictad for uaa within Dow DC Dow Confidan&aJ DCT - Dow Controlled < - Subpct matter to detetmirw dassificaton
THE DOW CHEMICAL COMPANY
DO 006281
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
flRIB
DATE
Pine 2
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
HEALTH SCIENCES
Preferred Storage RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
Registrations (Other than FDA, USDA and FIFRA)
All other registrations except those listed below:
Antifreeze Brake Fluid Commercial Fertilizer
Training Materials (must be dated)
Voluntary submittals of information to government agencies (i.e. ATSDR, Agency for Toxic Substances Diseases Registry)
II. FDA/USDA/NSF and Other Groups
Certificates/Certification Listings
National Sanitation Foundation Union of Orthodox Jewish Congregations of America Others
FDA/USDA Files
Government Inspection Reports Drug Master Files Notice of Termination of Product Drug Site Registration Status Letters and Summaries Drug Listings Technical Backup to Support Classification (except for records that already have an established retention schedule)
USDA Approval Letters Petitions for FDA/USDA Approval
* After product is discontinued
3 after registration is canceled 7 7 7 Until Revised 12
2* 2* 2* 2*
1 20* 20* 1 1* 1* 1*
1* 5*
CONFIDENTIAL
NOTE: Each record named above is classified and coded with a proprietary or not classified oode as folows: NP - Not Classified DR Resticted lor use within Dow DC Dow Confidential DCT Dow Controlled # - Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006282
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
cerunN mi imrpe
DATS
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
HEALTH SCIENCES
Preferred Storage RECORD NAME
Madte
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
III. FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA)
Federal FIFRA Registrations
All other registrations
Correspondence on Inactive Registration Submissions
Petitions for FIFRA Approval
* After product is discontinued
IV. OCCUPATIONAL SAFETY AND HEALTH ACT (OSHA)
Records of Inspections, Citations and Resolutions of Citations by Government Agencies
Records of visits by OSHA (Occupational Safety & Health Act) and/or NIOSH (National Institute for Occupational Safety and Health) personnel
Submissions of survey information to OSHA and/or NIOSH
Records of health hazard evaluations by OSHA and/or NIOSH
Other data submissions to NIOSH
V. TOXIC SUBSTANCES CONTROL ACT (TSCA)
TSCA (Toxic Substances Control Act) Correspondence NOC (Not otherwise classified)
8 after registration is canceled 3 after registration is canceled 5 after date of last entry in the file 5*
15 or until superseded
3
10 or until rule has been promulgated whichever is longer 20
10 or until rule has been promulgated whichever is longer
4
CONFTDFNTTAl
NOTE: Each raoord namad abova ia cteasifiad and oodad wrth a proprietary or not olaaaifiad coda as folows: NP - Not Classified
DR - Rastricted for um within Dow DC - Dow Conltdantial DCT Dow Controllad # -Subjact matter to datermlna classification
THE DOW CHEMICAL COMPANY
o0 OOfo^83
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
RfilR
DATE
oanc 4
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- HEALTH SCIENCES
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
VI. TSCA Section 4 Test Rules
Notice of Intent to sponsor testing Request for exemption Notices for exemption on Dow's behalf Test study plan and related correspondence Study reports - Dow sponsored
6*
6* 6*
6*
75 - See Tox Studies, Section 1502D
Study reports - non-Dow sponsored Consent Agreements to Test Contracts to Conduct Testing under Section 4 * after submission of last test data
6*
6* 6*
VII. TSCA Section 5 Premanufacture Notification (PMN), Commercialized
PMN document
15 after submission of COM (See below)
PMN Backup information
5 after date of COM (See below)
Notice of Commencement of Manufacture (COM) and backup
Records of production volume for 3 yrs from date of COM
15 5 after date of COM
Section 5(e) Order Compliance Information
5 unless otherwise specified in the order
Section 5(e) Consent Orders and/or Compliance Agreements
Duration of effect on Dow plus 5
Significant New Use Rule (SNUR) Information (SNURS on non-Dow PMNs)
SNUR Information on Dow PMNs for sections formally part of a 5(e) Order
5 unless otherwise specified in the Rule
5 unless otherwise specified in the Rule
conftofnttai.
NOTE: Each record named above to classified and coded with a proprietory or not classified code as Mows: NP-Not Classified DR - Resticted for use within Dow DC Dow Confidential DCT- Dow Controlled # Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006284
DOW RECORDS RETENTION SCHEDULE
MAJOR function
--------- uttlu____ EASE___ ___ DATE
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- HEALTH SCIENCES
Preferred Storage RECORD NAME
Madia
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
VIII. TSCA Section S Premanufacture Notification (PMN), Not Commercialized
PMN document and all related correspondence in the PMN file
Documentation of amount made, used, distributed, disposed of, & inventoried
Technical Qualifications of R&D Supervisors
Notifications of Risk, including backup and information reviewed to evaluate potential risk to health & environment
IX. TSCA Section 6 PCB Regulations
X. TSCA Section 8(a) CAIR/PAIR Reports
PAIR (Preliminary Assessment Information Rule) (Submissions file)
CAIR (Comprehensive Assessment Information Rule) (Submissions file)
Backup (PAIR/CAIR) - Correspondence and Surveys
Inventory Update Report to EPA
Inventory Update Reports backup information in the Submissions file
Less than 10,000 lbs produced documentation
Computer database (5 data sets)
Documents to Support Potential Inventory Corrections 6(b)
As long as useful
5
S 30
(See Section 861A XXVII)
5
5
5
5 5
5
5 Until accepted by EPA and listed on the Inventory
NOTE: Each record named above is classified and coded with a proprietary or not classified code as folows: NP- Not Classified
DR-Restricted for use within Dow DC - Dow Confidents! DCT - Dow Controlled #-Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006285
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
DATE
6
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
HEALTH SCIENCES
Preferred Storage RECORD NAME
Msdta
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
XI. TSCA Section 8(c) Report of Adverse Reaction File
Report of Significant Adverse Reaction, Occupational, recordable
30
Report of Adverse Reaction, Other, recordable
5
Reports from Computer Log
Short Term
Report of Adverse Reaction, Not Recordable
Short Term
Disposition Letter
As long as useful, Max 1
Review Committee Minutes
As long as useful. Max 1
XII. TSCA Section 8(c) Report of Adverse Reaction Log
Computer entries for filed reports, Employee Health
30
Computer entries for filed reports, Other
5
Computer entries for reports not filed
1
Indexes
Short Term
Statistical Reports
Short Term
XIII. TSCA Section 8(d) Health and Safety Studies
Copies of studies submitted (Submissions file)
5
Lists of studies submitted (Submissions file)
15
Correspondence with EPA (Submissions file)
10
XIV. TSCA Section 8(e) Substantial Risk Notices
Notices to EPA (Submissions file)
5
Committee minutes
10
co^
NOTE: Each record named above i* classified and codad with a proprietary or not ctaaaifSed code as blows; NP-Not Ctassmed OR - Restricted lor uae within Dow DC-Dow ConMential OCT bow Controlled * - Subject matter to determine ciamftoebon
THE DOW CHEMICAL COMPANY
D0 006286
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
'SFntnMMlIMBH ________
ENVIRONMENTAL AND HEALTH REGULATORY AFFAIRS
DECEMBER 1997
- HEALTH SCIENCES
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
Committee Charter/Procedures/Guide
Until Superseded
XV. TSCA Section 12(b) Export Notices
Notices to EPA (Submissions file)
10
Computer log
Until Superseded
XVI. TSCA Section 13 Import Certification
Copies of letters certifying TSCA status
Compliance Certification tetters
5 (kept by originator)
XVII. Dow TSCA Publications
TSCA Handbook, Brochures, Manuals and other guidance documents
Until Superseded
TSCA Newsletter (Questions and guidance documents)
1
CONFIDENTIAL
NOTE: Each record named above is classified and coded with a proprietary or not classified code as fdtowe: NP-Not Classified DR Restricted for use within Dow DC Dow Confidential DCT Dow Controlled - Subject matter to determine dassificabon
THE DOW CHEMICAL COMPANY
DO 006287
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
Preferred Storage RECORD NAME
Madia
ccrTinKi MUM are
DATE
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
This page was intentionally left blank.
CONF1DFNTTA1
NOTE: Ewtfnecord named atoova is classified and eodad with a proprietary or not classified coda as Mows: NP - Not Classified DR-RasYictad for usa within Dow DC - Dow Confidential DCT- Dow Controllad -Subject matter to dalarmina daasification
THE DOW CHEMICAL COMPANY
00 006288
i
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
EXECUTIVE
RECORD NAME
Pretened Storage Madia
DATE
DECEMBER 1997
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS CODE SECTION
KEY CORP/BOSTON EQUISERVE LIMITED PARTNERSHIP
Canceled Stock Certificates Stock Transfer Journals
Stockholders' Meetings: Voted Proxies Workpapers, Ballots, etc. from annual meeting Shareholders of Record Microfiche
MINUTES:
Corporate Board of Director Meeting Minutes
Corporate Executive Committee Minutes
Audit Committee Minutes Compensation Committee Minutes Contributions Committee Minutes Environment, Health and Safety Committee Minutes Finance Committee Minutes Investment Policy Committee Minutes
Public Interest Committee Minutes
6 5 after corporation Is dissolved
2 6
3
DR DR
DR DR
DR
VITAL RECORD Dispose of five years after dissolution of the company VITAL RECORD Dispose of five years after dissolution of the company 40 40 5 5 5 Life of the IPC or any committee succeeding its function + 6
5
DC
DC
DC DC DC DC DC DC
DC
CONFIDENTIAL
NOTE: Eash raoord namad abova Is dassifiad and oodad with proprietary or not classified code as Mows: NP-Not Classified DR. Restricted for use within Dow DC Dow Confidential DCT-Decontrolled #-Subject matter to determine classification
THE DOW CHEMICAL COMPANY
DO 006289
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
Preferred Storage RECORD NAME
Medto
DATE
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
This page was intentionally left blank.
CONFTDFNTTAI.
NOTE: Each record named above is classified and coded wilh a proprietary or not dasoified code as Mows: NP -Not Classified DR Restocted tor uee within Dow DC - Dow Confidential OCT - Dow Controlled *. Subject matter to determine daaaificatton
THE DOW CHEMICAL COMPANY
DO 006290
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
RATION NUMBER
90S
DATE
AS 1
CORPORATE AVIATION
RECORD NAME____________________
DECEMBER 1997
Preferred Storage
I CURRENT YEAR PLUS TOTAL
MadiaRETENTION IN YEARS CODE SECTION
OWNING
Accounting Cost Sheets Invoices - Construction
5
Life of equipment or property + 4
DC DC
Invoices - Purchased Fuel Away Domestic International
Maintenance Supplies and Aircraft Parts Invoice Copy Packing Lists Purchase Orders Quotations Release Forms
Administrative
Pilot Duties and Right Times
Policy Letters
Capital Projects
Active Capital Projects
Authorization Packages
Capital Spending Projections
Specifications
Commercial Travel
Flight Itinerary - Work Copy
Invoice Itinerary
Inplant Records
Refunds
Client Profile
DC 1 3
4 DC
4 Current copy
DC DR
See Sections 825,841, 1441
See Section 501
2
Life of equipment + 4
DC
DC DC DR
6 months 4 4 1 Current
CONFIDENTIAL
NOTE: E*iraoordnamadabova la daaaifiad and oodad with a proprietary or not daaalfiad coda as tolowr NP -Not Classified DR - Restricted for use within Dow DC - Dow Confidental DCT - Dow Controlled Subject matter to deMnnine classification
THE DOW CHEMICAL COMPANY
DO 006291
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
CORPORATE AVIATION
RECORD NAME
Preferred Storage Media
DATE
DECEMBER 1997
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS CODE SECTION
Dow Rights and Car Rental
Aircraft Charter Contracts; Expired (Purchasing)
Schedule Sheets - Dow Form #48010
Car Rental Authorized Rep Cards
Car Rental Company Travel Orders
Car Rental Contracts; Expired (Purchasing)
Rebilling Aircraft Recharge - Ledger Summary Flight Record
Equipment. Operations
Aircraft Maintenance Records
Flight Sheets
General Right Information, Master Copy Form and Computer Tape and Discs
Fuel Farm. Home Fuel
Daily Usage Form Fuel Flowage-airport Fuel Inventory Report Invoice Copy Physical Inventory Form
4 5 Life of card + 1 1 4 1
DC DC NP NP DC DC
As required by FAA regulations
4
4
DC
DC DC
1 1 1 1 1
confidenttal
NOTE: Each record named above ia classified and coded with a proprietary of not classified cod# as tolowr NP - Not Classified DR ResYicted for un within Dow DC - Dow Confidential DCT-Do# Controlled * - Subject metier to determine dassificafion
THE DOW CHEMICAL COMPANY
DO 006292
DOW RECORDS RETENTION SCHEDULE
MAJOR FUNCTION
Q07
DATE
1
EXECUTIVE - DOW CLUB/CUSTOMER ACCOMMODATIONS
DECEMBER 1997
CENTER
Preferred Storage RECORD NAME
Media
CURRENT YEAR PLUS TOTAL
OWNING
RETENTION IN YEARS
CODE SECTION
Dow Club Charges to Club Users (Department's File Copy)
Originals to Accounts Payable Customer Visit History Reservations, Functions and Rooms Schedule Special Menu File WINE Quantity Records Customer Accommodation Center Accounting Rebill Spread Sheet Daily Occupancy Book Daily Operations Report Lease Information
2
5 5 Current copy 2
DC
DC DC
10
2
5
4 after termination of lease
CONFTDFNTTAL
NOTE: Each record named above is dassiliod and coded with a proprietary or not clesaHled coda as Mows: NP - Not Classified DR Restricted for use within Dow DC Dow Confidential DOT - Dow Cootroiied #-Si >hjed (natter to determine dessiticaiion
THE DOW CHEMICAL COMPANY
006203 DO