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Governance

05 Document Control and Records

Document FSSMS-GOV-05Stage 1Revision 4Version 0.3.3

Topic pages open on your jurisdiction, and requirements tables show its line. You can change this on any page.

1. Purpose

Documents tell people what the department has decided; records show what it did. Both are evidence of due diligence and both are discoverable. This note sets the document hierarchy, the numbering and version rules, who approves what, how often each kind is reviewed, how documents reach members and how the department knows they were read, how long each record type is kept, and the privacy posture for the records that must never be read by the wrong person. ISO 45001 requires documented information to be controlled for availability, suitability, protection, distribution, access, retrieval, storage, change control and retention (ISO 45001:2018, cl. 7.5). The CFAI model expects documents and procedures reviewed at least every three years and records retained and disposed of under an adopted procedure (CPSE, 2019, criteria CC 9C.3 and 9C.4). The applicable provincial or territorial law requires records and statistics, with minimum retention periods for some record types (J09 Records Retention).

2. Definitions

  • Document: information the department intends people to follow: policy, procedure, operating guideline, safe work procedure, job aid, form template. Controlled by version.
  • Record: evidence of what happened: a completed form, a test certificate, minutes, a report. Controlled by retention; never edited after creation, only corrected by a dated addendum.
  • Controlled copy: the current approved version held in {{Records system}}; every other copy is uncontrolled and says so.
  • Policy: a statement of what the department commits to and who is accountable; approved by the fire chief (or council where the municipality requires).
  • Procedure: how a management or administrative process is carried out, department-wide.
  • Operating guideline (OG): how operations are conducted, with room for judgment; the fire service’s SOG.
  • Safe work procedure (SWP): the step-by-step safe way to perform a specific hazardous task; written with the people who do it.
  • Job aid: a one-page memory aid (checklist, decision card) derived from a procedure or SWP; carries no new requirements.
  • Form: a template that becomes a record when completed.
  • Acknowledgement: a dated, individual confirmation that a member received and read a document.
  • Retention period: the minimum time a record is kept before it may be destroyed under the schedule.
  • Confidential health record: medical, clinical, psychological and exposure-health information about an identifiable member; kept separate from operational records with restricted access.

3. Document hierarchy

Level Type Says Approved by Consulted Stage Example in the package
1 Policy What we commit to; who is accountable Fire chief; OHS policy also signed by the CAO where the municipality is employer of record JOHSC (statutory); union and association; counsel S1 04 Policies
2 Procedure How a department-wide process runs Deputy chief or senior officer responsible for H&S JOHSC where safety content; program team S1 Corrective action handling; document control; reporting
3 Operating guideline How we operate, with judgment Deputy chief, operations, on the program manager’s recommendation JOHSC (formal consultation where safety-sensitive); learning-team session S1 Emergency operations guidelines
4 Safe work procedure The safe way to do this task Program manager, on the team’s recommendation JOHSC (formal consultation); the people who do the task (learning team) S1 06 Safe Work Procedures
5 Job aid The one-page version Program manager None beyond the parent document’s S1 Decon checklist on the apparatus
6 Form Fill this in HSO (safety forms); records custodian (format) Program team S1 09 Forms and Templates

A lower-level document may not contradict a higher one. Where a member finds that it does, that is a hazard report, and the procedure, not the member, is presumed wrong until the program team has looked (Hollnagel, 2014).

4. Numbering scheme

{{Department prefix}}-<TYPE>-<PROGRAM>-<NNN> where TYPE is POL, PRO, OG, SWP, JA or FRM; PROGRAM is a two- or three-letter program code from the register (for example RP respiratory protection, PPE, DEC decontamination, EO emergency operations, TR technical rescue, HW health and wellness, GOV governance); NNN is a sequence within the program. Package documents carry their FSSMS doc_id as the source reference in the header until the department adopts them under its own numbers. The numbering register is one table in {{Records system}}: number, title, type, owner role, approver role, current version, effective date, review date, status, superseded number if any.

5. Version control

  • Versions are v<major>.<minor>. A minor change (wording, a contact, a form field) increments the minor number and is approved by the owner. A major change (a requirement, a step, a role, a threshold) increments the major number and goes through the full approval and consultation route.
  • Drafts are v0.x and are watermarked DRAFT; a draft is never posted as the current version.
  • Every document carries a header with number, title, version, effective date, review date, owner role and approver role, and a change log at the end stating what changed and why (one line per version).
  • Superseded versions are withdrawn from every point of use within five working days of the new effective date and kept in the archive for the retention period of the records made under them, so an old record can be read against the procedure that was current when it was made.
  • One controlled copy, in {{Records system}}; printed copies on apparatus and in stations carry “uncontrolled when printed; check the current version” and a print date, and are replaced on every new version by the station officer, who records the swap.

6. Approval authorities

Action Policy Procedure OG SWP Job aid Form
Draft Policy coordinator or senior officer H&S Owner role Program team Program team with a learning-team session Program team HSO or team
Safety review Senior officer H&S HSO HSO HSO HSO HSO
JOHSC consultation Formal (statutory) Formal where safety content Formal where safety-sensitive Formal Information Information
Union and association review Yes Where terms affected Where terms affected Where terms affected No No
Legal review OHS, Right to Refuse, Records and Privacy, Workplace Violence, Fatigue and any policy with discipline or benefit implications On request On request No No No
Approve Fire chief (and CAO for the OHS policy where required) Deputy chief or senior officer H&S Deputy chief, operations Program manager Program manager HSO
Issue Policy coordinator Policy coordinator Policy coordinator Policy coordinator Program team Records custodian

A document is effective on the date in its header, never on the date it was signed, and the effective date is at least 14 days after issue for any document that requires training, so the training can happen first.

7. Review cycles

Type Scheduled review Unscheduled review triggers
OHS policy Annually, in consultation with the JOHSC; check whether the statute sets this interval (J03 OHS Policy and Program) Change of fire chief; legal change
Other policies 12 months after adoption, then every three years A serious event, near miss or learning review touching the policy; a legal or standard edition change; a JOHSC request; an audit finding
Procedures and OGs 12 months after adoption, then every three years As above; a change in apparatus, equipment, staffing model or service
SWPs 12 months after adoption, then every three years; a learning-team check-in on whether the SWP matches work-as-done at each review Any event involving the task; a routine workaround reported; new equipment for the task
Job aids With the parent document With the parent
Forms Every three years A records system change; an audit finding on data quality
This note and the numbering register Annually Records system change

The review is recorded even where nothing changed (“reviewed, no change, by role, date”). Documents past their review date are listed in the monthly indicator report; a document more than 90 days past review is a register item.

8. Distribution and acknowledgement

  • Distribution. Every new or revised policy, procedure, OG and SWP is issued by a dated change notice (one page: what changed, why, what members must do differently, training required, effective date) to every station and every member through {{Records system}} and the station briefing. Change notices are posted on the station board for 30 days.
  • Acknowledgement. Members acknowledge policies, OGs and SWPs that apply to them individually and by date, in the records system or on a station sign-off sheet entered into it within 10 days. Acknowledgement means “I have read it and know where it is”; competence is shown by training records, not by the signature.
  • Training before effect. Where a document introduces a new task, control or piece of equipment, the training is delivered and recorded before the effective date; the change notice says so.
  • Volunteer stations. Change notices are read at the next training night, with the acknowledgement sheet; the records system shows volunteer acknowledgement rates by station, and the HSO reports them.
  • Availability at the point of use. The current OGs, SWPs and job aids are on every apparatus (mobile device or binder) and in every station; the audit checks a sample against the controlled version.

9. Retention schedule by record type

Minimums; where the applicable statute, regulation, workers’ compensation requirement, municipal records bylaw or collective agreement sets a longer period, the longer applies (J09 Records Retention). Retention runs from the end of the fiscal year in which the record was made unless stated.

Record type Retain for Custodian Access Disposal
Training and competency records (course, date, evaluator, result, certification) Duration of membership plus five years Training division Member; supervisor; training; audit Destroy under the schedule; certifications returned to the member on leaving
Supervisor and JOHSC member training As training records Training division As above As above
Medical and clinical records (evaluations, clearances, fitness assessments, audiometry, immunization, clinical notes) Duration of membership plus 30 years; kept by the provider or occupational health under clinical custody Department physician or occupational health provider; human resources for status only The member; the provider; nobody else without consent or legal authority. The operational record holds only fit, fit with restrictions, not fit, and dates Per health information law
Exposure records (fireground contaminants, chemical, infectious, noise, heat; incident-linked) Duration of membership plus 30 years HSO (exposure register); linked to the health record by member identifier The member (full access to their own); HSO; provider; aggregate only to anyone else Transfer to the member on leaving with a copy retained
Potentially traumatic event exposure reports Duration of membership plus 30 years; confidential route Peer support or clinical adviser under the psychological health program The member; the clinical adviser; counts only to anyone else Per program
Fit test records Duration of membership (the package default; check the minimum the respirator standard and your regulator set on J14 Respiratory Protection, Fit Testing and Breathing Air) HSO Member; HSO; audit Schedule
Workplace inspection records (station, apparatus, equipment, JOHSC) Five years (the package default; check the regulation’s minimum on J15 Equipment Inspection, Ladders and Aerial Devices) HSO; station officer holds the current year Members (posted); JOHSC; audit Schedule
Equipment inspection, test and maintenance records (SCBA, PPE per garment, ladders, hose, pump, aerial, rope, monitors) Life of the item plus five years; PPE garment records retained after retirement for five years Program team; fleet Program team; HSO; audit With the item’s retirement record
Injury, exposure, near-miss and good-catch reports Ten years; permanently where the event involved a fatality, serious injury or a workers’ compensation claim HSO Member (own report); supervisor; HSO; JOHSC (de-identified); audit Schedule
Investigation and learning review reports (tier 1, 2, 3) Ten years; permanently for fatality and serious injury Senior officer responsible for H&S; learning program lead Senior team; JOHSC; regulator as required; members (de-identified learning summary) Schedule
Work refusal records Ten years Senior officer responsible for H&S Member; JOHSC; regulator Schedule
JOHSC agendas, minutes, recommendations, responses, concern log, self-evaluations Ten years JOHSC co-chairs; records custodian Posted minutes to all; full file to the committee, fire chief, regulator Schedule
Audit plans, working papers, reports, category score sheets, register extracts Ten years (three external cycles); interview notes destroyed after the report is accepted Senior officer responsible for H&S Report: per 01 Audit Program distribution; working papers: audit team and the next audit team Schedule; interview notes immediately
Corrective Action Register Permanently as a live register; closed items retained ten years from closure HSO JOHSC; senior team; audit; owners Schedule
Management review packs and decision records Ten years Senior officer responsible for H&S Senior team; JOHSC; audit Schedule
Program team records (charters, minutes, work plans, quarterly updates, appraisals, research, trial reports, budget worksheets) Ten years; appraisals permanently Program manager Senior team; JOHSC; audit Schedule
Hazard profile and risk register Current version live; superseded versions ten years HSO Senior team; program teams; JOHSC; audit Schedule
Policies, procedures, OGs, SWPs (superseded versions) Retention of the longest record made under them (default ten years; 30 years where exposure records depend on them) Policy coordinator Audit; legal Schedule
Statutory reports to the regulator and the workers’ compensation board Permanently Senior officer responsible for H&S; human resources Fire chief; legal; audit None
Incident reports (operational) Per the municipal records bylaw (default ten years) Operations Operations; HSO; learning program Schedule
Culture survey raw data and reports Raw data destroyed after analysis (anonymity); reports ten years Senior officer responsible for H&S Reports: senior team, JOHSC, members (summary) Raw data: on report issue

10. Privacy and freedom-of-information posture

  • Write everything as if it will be disclosed. Safety records are routinely requested in workers’ compensation claims, litigation, regulator proceedings and freedom-of-information requests. Minutes, reports and register entries use roles not names where a name is not needed, describe conditions not characters, and state facts and decisions, not opinions about people.
  • Health information is separate. Medical, clinical, psychological and exposure-health records sit in a separate system or a separate, access-controlled part of the records system under the custody of the provider or occupational health, and never in the operational personnel file. Supervisors see fitness status and restrictions, not diagnoses. The department follows the applicable health information and privacy law (J10 Privacy and Health Information) and the municipality’s privacy program.
  • Learning information is protected. Learning-team write-ups, near-miss reports and learning review narratives are held for learning, de-identified where practicable, and are never the basis for discipline; the Records, Privacy and Health Information policy and the Incident Investigation and Learning program state the firewall and what the department will do if a legal process compels disclosure.
  • Members own their data. A member may see every record about them, obtain a copy of their training, fit test and exposure records at any time and on leaving, and have factual errors corrected by a dated addendum.
  • Freedom of information. The department has a named freedom-of-information contact (municipal), a process for routing requests, and a practice of releasing safety performance information proactively through the annual report, so that requests are rare and unsurprising.

11. Records system requirements

The package is records-system neutral. Whatever the department uses must:

  1. Hold one controlled version of every document with its number, version, dates, owner and approver, and show members the current version only.
  2. Record individual acknowledgements by date and report acknowledgement rates by station and by career or volunteer status.
  3. Hold the Corrective Action Register with every field in Corrective Action Register section 3, report by priority, age and source, and send reminders at plan due, closure due, 30 and 60 days overdue.
  4. Link each exposure report to the member’s exposure register and to the incident, and produce a lifetime exposure summary for the member on request.
  5. Hold equipment records by serial number with inspection, test, cleaning and repair history, and flag items past their interval.
  6. Hold training and certification records by member with expiry flags, and report currency by station.
  7. Keep health information in a separate, access-controlled store with an access log.
  8. Apply the retention schedule with a hold facility for litigation and investigation.
  9. Export every record type in a standard format so the department is never locked in, and so the audit can sample.
  10. Be available at the point of use: on apparatus and at volunteer stations, offline if the network is not.

12. Accountability and closed feedback loop

Element Who How
Owner Senior officer responsible for H&S Accountable for the document system and the retention schedule; the fire chief approves this note
Doer Policy coordinator (numbering register, issue, review tracking); records custodian (retention, disposal, exports); document owners (content, reviews); station officers (point-of-use copies, acknowledgement sheets); provider and HR (health records) Sections 4 to 11
Verifier Internal audit, categories 4 and 6 (Checklist - Procedures and Document Control; Checklist - Records and Information): a sample of point-of-use copies against the controlled version, acknowledgement rates, review dates, retention and health-record separation; the municipal privacy officer on the health-record store Annual
Feedback Documents past review and acknowledgement rates in the monthly indicator report; change notices to every station; members’ access to their own records Monthly
Closure Documents more than 90 days past review, point-of-use copies found out of date, missing acknowledgements and retention breaches are register items Corrective Action Register

Loop test. The audit finds a binder on a volunteer tanker holding a two-year-old SWP for drafting from open water. The same day the station officer replaces it from the controlled version and records the swap; within five working days the item is in the register against the policy coordinator; the fix is a quarterly point-of-use check added to the station inspection form and the change notice route reviewed with the volunteer officers; the crew that used the old SWP hears what changed from their officer at the next training night.

Jurisdiction requirements

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

Topic What to check in your jurisdiction Page
OHS Policy and Program How often the OHS policy must be reviewed and with whom, and what the written program must provide for keeping records and statistics J03 OHS Policy and Program
Written Procedures and Committee Consultation Whether the employer must consult the committee when establishing or reviewing written policies, procedures, plans or codes of practice J06 Written Procedures and Committee Consultation
Records Retention The general record-keeping duty and the minimum retention periods the law sets, including for exposure, health surveillance and medical records J09 Records Retention
Respiratory Protection, Fit Testing and Breathing Air How long fit test and respirator program records must be kept J14 Respiratory Protection, Fit Testing and Breathing Air
Privacy and Health Information Which access-to-information and privacy statute governs municipal records, which health information statute applies, and whether the department or its clinicians are custodians under it J10 Privacy and Health Information
Equipment Inspection, Ladders and Aerial Devices Which equipment a competent person must inspect and how often, and how long inspection and maintenance records must be kept J15 Equipment Inspection, Ladders and Aerial Devices

References

Center for Public Safety Excellence [CPSE]. (2019). Fire and emergency service self-assessment manual (10th ed.). Commission on Fire Accreditation International. https://cpse.org/wp-content/uploads/2019/08/10th-Edition-FESSAM-Strikethrough-Underline-v.4.pdf

Hollnagel, E. (2014). Safety-I and Safety-II: The past and future of safety management. Ashgate.

International Organization for Standardization. (2018). ISO 45001:2018, Occupational health and safety management systems: Requirements with guidance for use. https://www.iso.org/standard/63787.html

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