Records Retention Schedule for CNSC
CNSC names this requirement as "Dosimetry records obtained from a CNSC-licensed dosimetry service". The QA manager owns it, alongside the certification scheme rather than replacing it.
The finding auditors record against this document is: Quarterly or annual exposure device maintenance records missing or incomplete. The CNSC does not certify NDT methods. It licenses the company and certifies the person who operates an exposure device. An inspection provider doing industrial radiography needs a Nuclear Substances and Radiation Devices licence covering use type 812, a named Radiation Safety Officer with documented training including a source retrieval course, a radiation protection programme built on ALARA, dosimetry from a CNSC-licensed dosimetry service, an Emergency and Operating Procedures manual, sealed source leak-test and device maintenance records, and certified Exposure Device Operators. On nuclear plant pressure-retaining components the NDE method certification requirement comes from the CSA N285 series and points at CAN/CGSB-48.9712 rather than at any CNSC document.
Source: Verified August 2026 against CNSC published regulatory documents and pages: REGDOC-2.2.3, Personnel Certification, Volume I: Exposure Device Operators, Version 1.1, last modified 19 December 2022, made under the Nuclear Substances and Radiation Devices Regulations pursuant to the Nuclear Safety and Control Act, which references CSA PCP-09, Exposure Device Operator Personnel Certification Guide – Revision 1, published August 2021; REGDOC-1.6.1, Licence Application Guide: Nuclear Substances and Radiation Devices, Version 2.1 (Version 2 superseded Version 1 of October 2015), for use type 812 and the application content; REGDOC-2.5.7, Design, Testing and Performance of Exposure Devices, Version 1.1; REGDOC-2.7.1, Radiation Protection, and REGDOC-2.7.2, Dosimetry, Volumes I and II; Radiation Protection Regulations (SOR/2000-203) for dose limits and the licensed dosimetry service threshold; CNSC "Exposure device operators" and "Certified exposure device operators" pages. The NRCan NDTCB role as qualifying body for the EDO written examination is confirmed on the NRCan NDTCB FAQs page. The Canadian nuclear NDE certification position (CAN/CGSB-48.9712 required, SNT-TC-1A accepted for ASME-stamped components with AIA and licensee agreement) is taken from WNA CORDEL report 2014/003, "Certification of NDE Personnel — Harmonization of International Code Requirements", October 2014, and should be re-checked against the current CSA N285.0 and N285.4 editions (N285.4:23 is the eighth edition) before being relied on contractually.
| Item | What applies | Why it matters |
|---|---|---|
| Regime | Canadian Nuclear Safety Commission licensing and personnel certification for inspection service providers | Enforced by Canadian Nuclear Safety Commission (CNSC), acting under the Nuclear Safety and Control Act and its regulations |
| Document | Records Retention Schedule | how long each record is kept, where, and who can retrieve it during an audit |
| Owner | the QA manager | The signature an auditor traces back |
| Where it is checked | Operate under continuing obligations: dosimetry through a licensed service, leak testing, quarterly and annual device maintenance records, and. | Usually against a sampled job, not in isolation |
| Common failure | An uncertified worker operating an exposure device, or a trainee not under direct supervision and continuous observation | The gap between the manual and the job file |
What must a records retention schedule contain under CNSC?
It has to satisfy CNSC as Canadian Nuclear Safety Commission (CNSC), acting under the Nuclear Safety and Control Act and its regulations enforces it: how long each record is kept, where, and who can retrieve it during an audit. The test is not completeness on paper but traceability — an auditor picks a finished job and works backwards to this document, so anything it claims must be demonstrable on that job.
Who signs the records retention schedule for CNSC?
The QA manager. This regime requires central or third-party certification, so the signature works alongside the scheme rather than substituting for it.
How does a CNSC auditor test this document?
By sampling. They take a completed job, find the technicians and equipment used, and trace each back through this document to the evidence behind it. A document that reads well but cannot survive that trace is the most common finding across every regime, not just this one.
How long must CNSC records be kept?
Exposure Device Operator certification is renewed every five years. Renewal requires documentary evidence of successful completion of the EDO practical examination, and a written examination is additionally required after a significant interruption in work. Since 1 January 2017 only EDO cards issued on or after 1 February 2013 are recognised, and cards must not be expired. The CNSC expects the practical examination to be administered by a certified EDO who administers examinations at an NRCan Authorized Examination Centre, or who has held certification for at least five years, or who has been authorised by their licensed employer to conduct practical examinations. Company licences run for the term stated on the licence and are renewed by application; dose limits for nuclear energy workers under the Radiation Protection Regulations are 50 mSv in a one-year dosimetry period and 100 mSv over five consecutive years, with a licensed dosimetry service required where there is a reasonable probability of exceeding 5 mSv in a year. Retention is set by the regime and by the client contract above it, and the longer of the two governs. Firms that set one retention period for everything and document it fare better at audit than firms tracking different periods per record type and losing track.
Does a generic template satisfy CNSC?
No. A downloaded template describes a generic firm, and the first question an auditor asks is whether the document describes THIS firm — its methods, its equipment, its people, its actual workflow. Templates are a starting structure; the content has to be the firm's own or the trace fails immediately.
What happens if this document is missing at a CNSC audit?
It is a finding, and depending on the regime it can suspend the certificate rather than merely generate a corrective action. The related finding auditors record most often is: An uncertified worker operating an exposure device, or a trainee not under direct supervision and continuous observation
Where this sits in the CNSC evidence pack
- Nuclear Substances and Radiation Devices licence covering use type 812 for industrial radiography
- Completed "Request to Appoint a Radiation Safety Officer" form, with an RSO job description setting out roles, responsibilities, qualifications and authority
- RSO training course certificate and, for use type 812, a source retrieval course training certificate
- Emergency and Operating Procedures (EOP) manual
- Radiation protection programme documentation demonstrating dose control and ALARA
- Dosimetry records obtained from a CNSC-licensed dosimetry service
- Sealed source leak testing records, and quarterly and annual exposure device maintenance records
- Valid CNSC Exposure Device Operator certification cards for every operator, plus training logs for trainees
- Transport package registration and packaging documentation, one registration per certificate number
Personnel certification context
Two separate things, and firms conflate them. Exposure Device Operator certification is central: the CNSC certifies EDOs under the Nuclear Substances and Radiation Devices Regulations, and no person other than a certified EDO, or a trainee acting under the direct supervision and continuous observation of one, may operate an exposure device. No employer written practice substitutes. NDE method certification inside Canadian nuclear work runs to CAN/CGSB-48.9712 for radiographic, ultrasonic, magnetic particle, liquid penetrant and eddy current methods, with one documented carve-out: for ASME-stamped components, SNT-TC-1A qualification has been accepted where the authorized inspection agency and the licensee both agree.
Related: the CNSC overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.