We dive into test records and reports - what are the requirements, and why they are important.
AASHTO re:source Q&A Podcast Transcript
Season 3, Episode 2: Records and Reports
Recorded: April 28, 2022
Released: May 17, 2022
Hosts: Brian Johnson, AASHTO Accreditation Program Manager and Kim Swanson, Communications Manager at AASHTO re:source
Note: Please reference AASHTO re:source and AASHTO Accreditation Program policies and procedures online for official guidance on this, and other topics.
Transcribed by Kim Swanson
[Theme music fades in.]
Announcer: Welcome to AASHTO resource Q&A. We’re taking time to discuss construction materials testing and inspection with people in the know. From exploring testing problems and solutions to laboratory best practices and quality management. We’re covering topics important to you. Now, here’s our host, Brian Johnson.
[Theme music fades out.]
Brian: Welcome to AASHTO resource Q&A. I am Brian Johnson.
Kim: And I'm Kim Swanson. What are we talking about today, Brian?
Brian: Today I want to talk about test records and reports. This issue came up recently. Somebody had asked me about, what do we need to actually retain for test records and reports. So. I wanted to talk about that and maybe see if there's something more than just an emailed answer that might be more helpful for other people who also listen to the podcast. So let me start with the R18 requirement.
Brian: In AASHTO R18. There is a section on test records and reports. You have to have a policy on how you produce prepare, check and amend test reports. And you have to identify who's responsible. And then it goes into description of test records. So, it says laboratory shall maintain test records that contain sufficient information to permit verification of any test reports.
Brian: Records pertaining to testing, shall include original observations, calculations, derived data, and an identification of personnel involved in sampling and testing. And then it goes on to say some very specific items that need to be included in reports, in records and traceable to reports. Some you know somehow.
Brian: That is very useful as a guide, not a guide, but a requirement to figure out what needs to be [laughs] to be covered. There's also a records retention section in R18 and that says that they need to be retained for at least five years.
Kim: Five years. So, are there any other, perhaps quality systems, or other standards that would have different records and reports requirements?
Brian: There are actually. And I didn't ask you to ask me that, but the one standard that jumps out at me is, ASTM E329…has a record section also, and in this this is worded in in kind of an interesting way. Where it says that the agency shall establish and maintain a document system to identify, collect, index, access, file, store, maintain, and dispose of management and technical records to suit its particular circumstances and to comply with applicable regulations.
Brian: So, it kind of defers to – Well, there's a lot there, right?
Kim: Yeah, that's a lot to unpack there. Yeah.
Brian: A lot of different actions. But it also says that you know it, it may change – It may vary based on what your requirements are. Now for an AASHTO Accredited laboratory, we have accreditation policies and we have AASHTO R18, so that becomes a reference document that you need to adhere to.
Brian: It also talks about records retention. Right in that section, this is section 11 and E 329, the 2021 version of it, and it says that it has to be records that need to be retained for at least three years. And they need to be legible and include sufficient information to permit satisfactory recapitulation of the inspection. So, if you're talking about an inspection report, so this would be like a, you know, special inspection, building some kind of inspection.
Brian: You have to be able to basically recreate, not copy but like I guess re – Be able to [Kim: Reproduce.] understand exactly what happened.
Brian: In that so [Kim: Oh yeah.] you know there's some sort of like…Recognition of what – you know, recapitulation [laughs] is like you're there's some sort of understanding inherent to that word. Where you have to be able to know what went on [Kim: Hmm-mm.] during that event. It also says they have to be safely stored and retained to prevent damage, deterioration or loss.
Brian: And they shall be held secure and in confidence to the client, unless otherwise authorized by the client or required by law, regulation or valid court order. So, that's an interesting subsection of that as well, and so it gets into quite a few aspects. But one – one thing I find interesting about both of these, is that it really – a lot of times standards won't say why [Kim: Hmm-mm.], they'll just say this needs to be done. But in both AASHTO R18 and E329, it mentions that it has to be… used – like E329 that says you have to be able to have satisfactory recapitulation of the inspection.
Brian: And in R18 it mentions that – it has to have sufficient information to permit verification of any test report. So, that's a dumbed down way to say recapitulate, but it's really the same thing. You've got your rationale right there for why you might want to – have records not just reports, and why you might want to retain them.
Kim: And in addition to those requirements of R18 ,the AAP Procedures Manual, or other – you said E329? [Brian: Yeah.] If your organization or company has their own policy on records retention and records, you have to follow those as well. So with all of that though, that means you have to...
Kim: Follow them all, but also for the records retention you said R18, was five years and then E329 was three years. So clearly you have to keep them for the five – To cover both of those.
Brian: That's right. [Kim: Right?] That's right. Yeah, that comes up a lot and in having a discussion recently, with somebody who is involved in our industry that – just recently involved in this industry. They were kind of confused about why there are so many, uhh overlapping requirements in various standards. And how you know which one is the one [Kim: Mm-hmm.] that rules the other ones, and really it is – you have to look at those limits, right? You have to look at like if there is a…
Brian: Shorter interval or more conservative interval for calibration that you – you would want to do it more frequently than in other standard – you have to go with a more frequent one because you've got a situation where your risk is too high for your one standard to allow it to go on without calibration. That's the one you have to adhere to. For something like records retention you go with the longer one. [Kim: Mm-hmm.] Again, you're looking at what [laughs] –
Brian: How can you conform to one and the other one, and whatever other ones are underlying to that, which often happens. So that's – that’s something to consider as well.
Kim: Yeah. So, when we're talking about this, it obviously I feel like we're talking to the testing laboratories, right, of like the they're having to show their work and being able to keep the records of their work. And not just give test results, but then where do the specifying agencies fall into this and what are they looking for, and how do they make sure that testing laboratories are conforming to this or providing the information that they need? It's just a little confusing in that area. Can you talk about that?
Brian: Yeah, it – it is in in the main point, I think I'd like to get across is that the testing laboratory and the specifier and need to be on the same page about expectations for retention, so...If we're talking about a test record. That could be a bunch of different things. There’s official test records, there's data that's printed out by certain pieces of equipment or data that's stored by other pieces of equipment, maybe electronically.
Brian: Those records’ retention requirements still apply there. And those are records. So, if you've got test points; that is a record. So, one common example that – this actually came up at the technical exchange – there is an ignition of in test AASHTO T308 and there's a printed ticket. And that printed ticket has all of the data points, all of the measurements that are going on – on the balance as that material is being burned off. And that would be something you'd have to retain and one thing that I thought was interesting about the discussion at technical exchange, is that people talked about the different ways they do it.
Brian: Because that is a – it's printed on one of those heat sensitive. [Kim: Ohh uh-huh.] Receipts. [Kim: Hmm-mm.] And you know what happens to those overtime is those. It's like an invisible ink eventually.
Kim: Yeah, I don't like. I don't think that's going to last five years, if that's the policy to keep it, I don't think that's lasting in that form.
Brian: Yeah, it would definitely not last five years. So, what some agencies have done is they've said, OK, well those need to be scanned or though you have to take a picture of those in-store those in your files. And I think that's a great solution and it's one that I had not heard a discussion about, but it can be an issue in some areas. So, I think that that's a – I hope that people who run that test and are listening to this say OK well that's something that we should do, and then all of a sudden, they go back into the records they say where did it go. [Kim: Laughing.] You know, they'll, they'll know. They'll know where the results went. They just did –
Kim: Yeah, I was – I was going to say, have you seen – how have you seen the progression of people storing these? Because I know even since I've been at AASHTO, I know we store our records much differently now than we did when I started 12 years ago. So how have you just noticed what labs are doing to store and maintain these records over the course of the years?
Brian: I remember the first time I saw a big change happen. I don't remember which year, but I remember going to a – a project laboratory as an assessor, so that would be quite a while ago and that laboratory was the first one I had ever seen do everything electronically. So, all the field data was entered onto. I want to say they used palm pilots. [Kim: Wow.] If you – if you even know what that is, uh, at this point or recall what that is. But that was a way that they were able to store that data, submitted electronically, be able to quickly react if there was a change…
Brian: …In the field, that required attention. So, that was great. So, people are doing that. People are – so, you know, are modernizing that approach. And you're seeing some people go straight digital. So, like they will enter the data in from the field and from the laboratory. But I would say that is not the norm. I think the norm is still paper. So people, if you're using paper, you may then send it to a processing person in your facility.
Brian: And they may type it in. But guess what? [Kim: Hmm?] You've got a record at that point. A paper record that needs to be stored. Uh, so in that case, I think what a lot of people do is they put it in a box, or they put it in a folder, which eventually goes into either a bookcase or an old file management system, some kind of like…
Brian: File cabinet? Or maybe it goes into one of those boxes, you know, cardboard boxes [Kim: Those bankers’ boxes.] and they store it up in. Yeah, the bankers’ boxes. And they store it up in the attic of their laboratory, or somewhere else just in case they ever need it.
Kim: So, when does a record become a record? Because I'm just curious about the process of like if you're in the field or in the laboratory and you have the test results, can you then reenter them into like a formal record? Or is the record, is the handwritten record?
Brian: Great question. Because I think this is the area that could cause some conflict, right? So, let's say you're in the field and you're making observations – and this doesn't, whatever the agency says goes, first of all, so like whatever I'm saying right now is not a standard thing. It's not – It doesn't override whatever you're building department has declared is a record. [Kim: laughs.] But I'm just saying if you had. A standard record that you use, but wherever you happen to be at the time – in the well, I'll say in the laboratory because in the field is like a whole different ball game.
Brian: But let's say you happen to be at a bench where your sheet is somewhere else and you need to make the observation because of the time and all you have in front of you is your napkin from Chick-fil-A or McDonald's [laughs] or whatever. Whatever. And you just happen to write a number down on there. It's OK, like as far as we're concerned, it's OK for you to then convey that to your record that you would normally have and throw that napkin out.
Brian: That is a grey area though, that I think an agency and a laboratory or testing firm need to be on the same page with. Is that OK, or do you want that napkin to be included in the official test records? [Kim: Yeah.] If the dot, or the building department, or whoever that – you know, corp of engineers or FAA, whoever the specifying agency says – Yes, in fact, we do want that to be retained then you better retain it.
Brian: And I would not use...Any other language that you see in standards, that I can tell, where that would be explicitly… laid out in in a way that you don't have to retain that. But I think that getting on the same page about the expectation is really important.
Kim: Right. That makes sense because I was thinking as well as I know, I just have horrible handwriting. And so I would feel horrible if I'm writing down test results and be like, OK, I need to rewrite this because that is just for the longevity and readability of this is not going to work. So, I know for me personally, I would – my childlike handwriting would not be what people would want to see on test results that you need to keep for five years, necessarily.
Brian: I feel your pain. I think the word of the day is recapitulate. And if you were trying to recapitulate a meeting, for example, in which I was the note taker, and I was writing the notes down, handwritten good luck. [Kim: Yeah.] You're. You're not going to know what happened. You're not even going to know what the meeting was about.
Kim: [Laughing] I say you're better at that than you think, but I – just looking at my notes for this discussion right now, I mean it's a guess if what I was trying to say, I just wrote it maybe 10 minutes ago, so.
Brian: That's how you know it's bad when you go back and look at your own notes about something and you were there – [Kim: Yeah. ] and you were the [laughing] one who wrote it, and you can't tell what it what it says that is a problem.
Kim: No, it's a weakness of mine. [Laughing] I know that's not an area that I excel in.
Brian: Yeah, I'm always impressed when somebody has really excellent handwriting. We actually have somebody on staff, Sonya Puterbaugh [Kim: Yes! Oh] who I mean, if you see her handwriting, you'll think it was a font on the computer.
Kim: It is gorgeous. It is the best handwriting by far I think I have ever seen in person from like a real person. [Brian: Yeah, for sure.] As opposed to a fake person. I don't know what that is, but.
Brian: [Laughing.] A fictitious person with excellent handwriting.
Kim: Yes, yes. [Laughing.]
Kim: So Brian, with all of this conversation that we had, where do our listeners go from here with this information?
Brian: I think this would be a great topic for a management review, or a separate session of meetings to have with top management because it's not enough to just know for yourself, based on that – like listening to this conversation, it's something that everybody in your organization needs to be on the same page about too. You have to have a system in place. These records need to be stored in a consistent manner.
Brian: There's also, you know, discussion about amendment of reports. You have to know what the policy and procedure is for that, because that data – if you're a testing laboratory, the data is like, that's your job is to produce this data and the data better reflect the facts that were obtained during testing and inspection work. So, the security, the integrity, of those observations is the work product that has to be protected.
Brian: I think it's apparent that it's important to at testing laboratory, but I don't know how much effort unless they're doing a big IT upgrade. How much discussion goes into what those records – you know, how they're retained, what's retained. So, if you're listening to this and you're thinking, well, I don't even know the last time we've even talked about it, maybe it's time to talk about it in your organization and see if there's some things that you can do…To make sure that you are doing it as well as you can.
Kim: So, we've talked about a lot about records and a little bit of our reports, but what about like anything specific just for test reports?
Brian: Oh yeah, there is a lot of information in the standards about test reports. And this is one of those situations where you've got layered requirements. So, in AASHTO R18 there are certain things that need to be on a test report and it's really things that you would expect to see. Such as, you know the data performance, when the sample was received, the name and address of the client or the project.
Brian: The test results. For example, [Both: Laughing.] you know, who’s responsibility for the report. But then, if you want to see the other requirements you might go to the individual test method. So, the individual test method often has a reporting section and it'll say these are the things that need to be reported. And a lot of times in the body of the standard, it will get into what needs to be recorded. So, if it says something that needs to be recorded, that is assumed that that is in the record. But [Kim: So…] there are often not separate record and report sections in a test method.
Kim: So, what's the difference – as someone who does no testing, and don't live in the standards and test methods that as other people do, but what's the difference there of recording and reporting? And it seems like there's a subtle difference. That maybe it's very common if you're in it, but I'm not in it. So, what's the…?
Brian: Yeah, so. So, imagine it like this…The record is your – those are your raw data points. That's all the stuff that goes into making the report, and the report is typically your final report. So, this is what you're sending to your client. [Kim: OK.] They may not want to know all the individual observations. They may want to just know what the outcome is.
Kim: So, your testing firm may only produce the testing report, but the record is showing their work that they're keeping that on file for longer?
Brian: Yeah. Yeah, [Kim: Or did I reverse those…OK.] that's a that's exactly it. And that's what's important to be able to recapitulate…
Kim: The word of the day.
Brian: The work product right, the the report. Uh that it's just like in school when you know, like the kids are in school they're let's say they have math class and there's a question they need to answer it. It's not enough just to write down a number you have to show your work show how you got there. It's the same thing as an adult. So the next time your kid says I'm never going to use this. This doesn't matter you can say hey it does.
Brian: And if you really want to get on their nerves, you'll pull out a standard and show them. [Laughing.]
Kim: I'm sure they'd love that.
Brain: It has a separate records and reports – my kids are – my kids are going to be damaged beyond belief. [Kim: Probably]…but let me get back to reports. So, you can find the report requirements in the standard- the standard test methods. You can also find some really comprehensive, I'd say like the...
Brian: The most comprehensive report section of any standard I know is in ASTM E329. It's so extensive that I've heard a lot of concerns [laughing] by the testing labs about how many things are required, [Kim: Hmm.] and I believe that there is a plan to ballot some changes to this section because it doesn't always work for everybody based on what kind of testing laboratory… laboratory they have. Excuse me.
Brian: But this report thing, it gets more complicated in that you've got a QC laboratory. Let's say you're a quality control laboratory at an aggregate quarry or a hot mix asphalt plant. You may never produce a report for the kind of testing you do, other than maybe you put it on the product description, that goes out with the with the product. I don't, I don't know every state may call it something slightly different. Uh, that whatever the declaration is of the product, will have a lot of these reporting requirements in it. So that's that probably be what we would want to see if we were at a QC laboratory. But customarily they're not putting out reports, you know, when they're doing their daily quality-control tests and checks, they're not going to be producing a report. That would all be records in that case.
Brian: But another thing that can happen is, sometimes the specifier dictates what is going to be included in the report. So, let's say, OK, you're doing this work for us. You need to put it on this form and that would be the form we want to look at during an assessment to see what your report looks like.
Kim: And here I thought asking what's the difference between a record and a report was going to be a silly question, but it turns out that is not a silly question and there is differences and nuances for each one so.
Brian: Yeah, not at all. And these are the, these are the things that I love about our podcast is that you can ask me a question. I'm like, I take for granted that – I just think people know the difference between of record and report, but I promise you, you're not alone. There's going to be somebody who listens to it and say, oh, never really thought about it that way. OK, great. Well, then we our job is done. If we get through to one person, I'm satisfied.
Kim: Yeah, if you are that one person, email us and let us know. [Laughing.]
Brian: [Laughing.] Yeah, let us know. I demand confirmation.
Kim: I would like confirmation that this reached. At least one person that wasn't a silly question and that it was useful to you. That would make me feel better too. [Laughing.]
Brian: That would be good.
Kim: That would be good. So, is there anything else on this – more complicated conversation than I thought it was going to be actually – But do you have any other anything else you want to make sure that we impart, the listeners with?
Brian: Yes, actually the last thing I want to mention is about integrity of records and reports. So I did hint at that a little earlier. But it is so important that people understand what their responsibilities are. As far as how they record data and how they report data. So, I'm talking about the technicians I'm talking about… supervisors. I'm talking about whoever is doing the data entry. People who are communicating with clients. Everybody throughout your organization needs to really understand their responsibilities and the importance of data integrity or record integrity because you don't want to be in a situation where somebody's made not unauthorized change, to the data that is being reported and it cannot be confirmed or recapitulated by any of the resulting records.
Brian: That would be immediately considered to be falsification. And that could lead to all sorts of problems. And it could really ruin your reputation as a testing firm. So, it's important that people understand, like, when you make an amendment, or you do a retest. Let's say you retest, do not just overwrite that data on your original datasheet.
Brian: That is a new test and should be treated as such. Now that may raise a whole bunch of questions as far as how people are storing their data. And again, I would direct you back to the previous conversation about having a conversation with management about how things are being done and what they need to be or how they need to be done… in order to satisfy requirements and maintain the integrity of the data at your company, which would then help your business, your company grow and flourish. So. So that's important too.
Kim: Is there a requirement to have that policy, a policy, and how do you amend reports in your quality management system? Is that a requirement anywhere or is that just best practices to have a quality management system policy on how you amend reports?
Brian: Yeah, it – it is actually in R18. So, in Section 6.8 currently is the section where it talks about test records and reports. The first line says laboratory shall have a document that describes methods used by the laboratory to produce test reports – Or, sorry – to produce test records and to prepare, check and amend test reports.
Kim: So, you want to make sure that…You have that policy, but also that that policy works for you, for you, and that you're following that policy. [Brian: Yep.] So, it's not just having it, it's doing it and checking it and the plan do check act kind of cycle of that.
Brian: That's right. And if people wonder, well, when would I ever amend it? That's report. Well, let's think about this. Let's say that you are – I'm going to throw out a hypothetical scenario. Let's say that your testing firm...Submitted reports to your client and one of the results on the report didn't make any sense. So, like to the point where they wonder what you even tested because the number is so irrelevant to their product or material or whatever is being used that they question the outcome. And then this is where the whole thing kind of happens, right, so.
Brian: Then you go back, and you look at your records, which you have retained, uh [laughing] because of all of the reasons we talked about. And you go back, and you see – Oh well, that's because when we were doing data entry, somebody thought this number was this. But it was that like I thought it was an 8, but it was a 6. And then that's a time where you would amend that test report and you would explain to your client what happened. So, note making a notation on that, like showing what the change was and explaining what the change was really important because years later…
Brian: You're going to want that to be retained in case something goes wrong. And of course that makes me think back to one of our previous ATG chairs – the ATG is our Administrative Task Group, which is like our…
Brian: I what do they call them?… [Kim: Oversight committee.] Jeez, I’m drawing a bank…Oversight committee!
Kim: [Laughing] I just said that 2 seconds ago [Brian: Oh, you did say that?] yes. [Brian: Ohh, I couldn't hear it.]. Continue.
Brian: I'm sorry.[Kim: It’s OK.] So, the ATG, which is our oversight committee, so the former ATG chair would say – well and he was from Mississippi. So, he would start by saying, I'll tell you what. That was, I would always know I was going to get a serious [laughing] explanation when he would tell me. I'll tell you what and also a great way in as far as communication goes is letting people know you're about to tell them something important. Is always a good thing to do. So, like...
Brian: I'm going to tell you something. You know, it's like I OK. I'm. I'm all hers. But he would say it doesn't matter until it matters.
Brian: So, let's say there's a problem down the road all of a sudden that records retention matters a whole lot…because we were able to determine what went wrong. Was it intentional? Was it unintentional? Was it a typo? Was it something worse? It helps determine what went wrong, who was responsible, that information is really, really important in in figuring out not just what went wrong, but how to fix it and how to make sure that things don't go wrong in the future.
Kim: Yeah, because it was all kind of goes into safety, right? Like, that's why you're testing things to make sure that they're appropriate for use, right. Like, if it's the appropriate material to use in that. And that goes back to the safety of the, for the people using the roads or buildings or whatever is going to be built and constructed on that. So it can take a while for something to go wrong. [Laughing.] That's why there's some record records retention policy is, you know, three years, five years, because maybe the project's not going to be done... [Brian: Hmm-mmm.] For another, you know you're testing something at the beginning and to have those a clear picture of what happened, you know, on your end.
Brian: Yeah. And if you're, if you're listening to this and you say, well, I don't want that liability, why is it? Why why don't we have no records retention as the policy? I would say that that's in there because people who don't want to retain anything should not be accredited. [Kim: Laughing.] That, you know, it's important that people who care about quality live it and breathe it and care about doing things the right way. So I doubt anyone listening to this would think that. But there are certainly people out there who would. So it's it's basically to protect the public from people who are intending..to do things the wrong way.
Kim: Yeah. So, I think that covered everything. Is anything else that you want to cover?
Brian: So, I think that's all we have on test records and reports. I can't I. I thought this was going to be about a 10-minute conversation so…[laughing]
Kim: I thought so too. I'm not going to lie. I thought so, too. I mean, we had some tangents in there, but I think we covered everything that needs to be covered. But if you're listening and you still have questions, email us and be happy to follow up with you at an email, but also record another episode about it.
Brian: Absolutely. Thanks for listening, everybody. And we'll see you on the next one.
[Theme music fades in.]
Announcer: Thanks for listening to AASHTO re:source Q&A. If you would like to be a guest or just submit a question, send us an email at email@example.com or call Brian at 240-436-4820. For other related news and content, check out AASHTO re:source's Twitter feed or go to aashtoresource.org.
[Theme music fades out.]