HAS9002 02 - Powered Industrial Trucks (PIT) and Aerial Lifts 11
HAS9002 02 - Powered Industrial Trucks (PIT) and Aerial Lifts 11
HAS9002 02 - Powered Industrial Trucks (PIT) and Aerial Lifts 11
02
Powered Industrial Trucks (PIT) and Aerial Lifts
1. Purpose
The purpose of this procedure is to prevent personal injury to operators and nearby pedestrians and to prevent
property damage resulting from the use of Powered Industrial Trucks (PIT) and Aerial Lifts, by ensuring correct
equipment specification, maintenance, operation and operator training are in place.
2. Scope
This procedure applies to all areas of Warehouse where PIT’s (including pedestrian controlled pallet trucks) and
Aerial Platforms are in use. This policy is not intended to cover new construction, which is outlined in the Design–In
Safety Policy, but rather to cover inspection and maintenance criteria for existing structures and equipment.
Each location is responsible for complying with the legal requirements currently in force in their country. This
procedure sets out the minimum requirement that are applicable in all Warehouse. Where local regulations are more
stringent than this procedure, then the local regulation will supersede this procedure.
3. References
3.1. Internal
WW EHS Standards:
EU EHS Standards and Procedures -
Other Published References:
3.2. External
PIT manufacturer manual instructions
EN 1175-1:1998+A1:2010 - Safety of industrial trucks. Electrical requirements. General requirements for battery
powered trucks
EN 16307-1:2013+A1:2015 - Industrial trucks. Safety requirements and verification. Supplementary
requirements for self-propelled industrial trucks, other than driverless trucks, variable-reach trucks and burden-
carrier trucks
EN 16307-5:2013 - Industrial trucks. Safety requirements and verification. Supplementary requirements for
pedestrian-propelled trucks
Created: Jan 2019
Date of Last Revision: Jan 2019
1 Next Revision Planned: Jan 2020
EU EHS Procedure | HAS9002.02
Powered Industrial Trucks (PIT) and Aerial Lifts
EN 16307-6:2014 - Industrial trucks. Safety requirements and verification. Supplementary requirements for
burden and personnel carriers
EN 1726-2:2000 - Safety of industrial trucks. Self-propelled trucks up to and including 10000 kg capacity and
industrial tractors with a drawbar pull up to and including 20000 N. Additional requirements for trucks with
elevating operator position and trucks specifically designed to travel with elevated loads
EN ISO 3691-1:2015 - Industrial trucks. Safety requirements and verification. Self-propelled industrial trucks,
other than driverless trucks, variable-reach trucks and burden-carrier trucks
EN ISO 3691-5:2015 - Industrial trucks. Safety requirements and verification. Pedestrian-propelled trucks
EN ISO 3691-6:2015 - Industrial trucks. Safety requirements and verification. Burden and personnel carriers
ISO 13564-1:2012. Powered industrial trucks. Test methods for verification of visibility. Sit-on and stand-on
operator trucks and variable-reach trucks up to and including 10 t capacity
ISO 22915-1:2016 - Industrial trucks - Verification of stability - Part 1: General
ISO 6055:2004 - Industrial trucks — Overhead guards — Specification and testing
ISO 6292:2008 - Powered industrial trucks and tractors. Brake performance and component strength
EN 12053:2001+A1:2008 - Safety of industrial trucks. Test methods for measuring noise emissions
EN 12895:2015 - Industrial trucks. Electromagnetic compatibility
Acronym Description
TUG Tow truck
STACKER Electric pedestrian stacker
RT Reach truck
OP Order picker
Turret truck PIT dedicated for VNA
PIT Operator training External/Internal theoretical and practical training on how to safety drive PIT
PIT Leaders training Familiarization training for all supervisors of PIT drivers
Aerial Lift Any vehicle-mounted device, telescoping or articulating, or both, which is used to position
personnel, including extensible boom platforms, aerial ladders, articulating boom platforms,
vertical towers, scissor lift.
Rabbit / Turtle Function The rabbit / turtle switch allows the operator to quickly set speed and performance profiles
to suit conditions.
Dep. Manager
EHS Manager
Ops. Manager
HR Manager
Procurement
Committee /
Tasks / Activities
Associate
Manager
Sr. Ops.
General
EHS
6. Procedure
6.1. General PIT requirements
PIT/ Aerial Lifts must only be operated according to the manufacturer’s manual which must be kept on site by the
RME department. Modifications and additions that may affect the capacity and safe operation of PIT/Aerial Lifts
must not be performed without the manufacturer’s prior written approval. Upon approval, the rated capacity,
operation and maintenance instruction plates, tags, or decals must be modified accordingly. Nameplates and markings
must be in place and maintained in a legible condition. The manufacturer identification nameplate must contain load
capacity.
The RME Department must maintain an inventory of all PITs and Aerial Lifts currently in use within the FC,
including Power Pallet Trucks. All PITs must be numbered and have at least two visual identifiers, with the number
present on both sides of the PIT.
Each site must have a dedicated and segregated area for repairs to be carried out in. Only contractors qualified and
trained to repair PIT/Aerial Lifts may perform repairs and adjustment. Contractors intending on performing work on
PIT/Aerial lifts will be assigned a RME liaison who will oversee the work conducted by the contractor. It is strictly
not permitted for any Warehouse employee to perform repairs and adjustments to PIT fleet equipment. Where a
contractor is required to undertake a High Risk Operation (HRO) in order to perform the work, then HAS9005.13 –
High Risk Operation and Permit to Work procedure must be implemented.
PIT maximum speed must be limited to 6km/h (this does not apply to PIT that are dedicated to operate in VNA aisles
where their speed can be increased to a maximum of 12km/h due to wire guidance, which will be subject to the
outcome of a risk assessment conducted by the FC). Only adjusted types of PIT are to be operated in the Yard and
any other area outside the FC. PIT maximum speed must be limited to 6km/h and 4km/h for Powered Pump Pallet
Trucks.
Pedestrians are allowed in VNA aisles subject to the outcome of a risk assessments conducted by the FC.
Specific, and stricter safety rules regarding PIT/Aerial Lifts may be defined by each FC, in the specific details
contained in SLLS 17033 concerning VNA aisles and pedestrians.
corrective/mitigation actions; and/or whenever there is a change that could affect risk on site i.e. new/modified
procedure, equipment, task, layout change, and or regulation (whichever occurs soonest).
All PIT/Aerial Lift operators must possess the required certifications and be trained and authorized by employer or a
person designated by an employer prior to operating any PIT.
Operators must possess and be able to present their Warehouse PIT Operator badge at all times during operation of
PIT and Aerial Lift. PIT badge can’t cover associate badge at any time. If an associate does not possess the PIT
badge, a one-day license can be issued to the operator after checking by safety team, if all required documentation is
in place.
They do require the full internal PIT training, the medical pre-checks shall be done in compliance with local law
regulations. Contractors are required to be appropriately trained and certified by their employer to the appropriate
national standard with copies of this training and certification to be given to Warehouse . The Warehouse Point of
Contact (PoC) for the contractor is responsible to notify the need of internal training session to Learning department.
The Learning department will provide training for contractors if all required documentation is given to Warehouse.
Only contractors who have been given permission via contract to operate Warehouse PIT equipment are permitted to
operate them (for example, MITIE, Crown). All other contractors must provide their own PIT equipment necessary
to complete activities on site.
6.4.1.1
Upon completion of a pre-use inspection, the operator must complete the pre-operational checklist and use the
sign-in system. Each FC have to implement WEBTOOL system. Each department must identify a storage
location for the completed pre-start inspection forms. The pre-operational checklist must be kept in the vehicle
at all times or be easy to find and presented. The historical pre-checklist have to be retained for a minimum of
six (6) months in area defined by local team.
Where any safety defects are found they must be marked on the pre-operational checklist, as well as in the sign-
in system, if one is in place. Operators must mark the defected PIT/Aerial Lift and then the RME Department
must be notified. Under no circumstances must PIT with identified defects be operated.
RME will ‘tag’ the PIT/Aerial Lift as “Out of Service” and apply LOTO until repairs or improvements can be
made.
6
6.4
6.4.1
6.4.2
6
6.5
6.6.3. Key/Code control
Only authorized and trained PIT operators shall be allowed access to PIT keys or PIT cards. Physical key/card
controls shall be implemented where training or administrative controls prove ineffective as defined by any
unauthorized access.
Permission in Fleet Management system to drive PIT have to base on list of authorized PIT drivers from L&D.
A central PIT key locker will be available within the FC. Location to be decided by the FC. There can be a
number of lockers controlling keys assigned to different areas if required for operational reasons. Each Area
Manager (AM) or designated lead who requires PIT drivers will issue PIT keys to their PIT drivers as required.
To issue keys, the AM is to visually check the driver’s PIT badge and check the truck type and expiry date is
valid before signing out the key. Each key issued, is to be signed out using the PIT Key Issue Log by both the
AM and the PIT driver. The driver is to sign the key back in upon completion of use.
Where a vehicle key is lost or broken, raise a trouble ticket with engineering to obtain a replacement.
Fall protection equipment must be inspected pre-use daily by the operator. PPE have to be without any visual
damages, the inspection timeframe have to be visible and up-to-date. Annual inspections are to be completed by
an authorized company. A fall protection equipment register, including annual re-inspection dates, is to be kept
by local non-inventory department, or other departments if agreed locally within the FC.
PIT/Aerial Lift must come to a complete stop in a safe location before the use of a phone or radio.
Operators must use the horn at the end of every aisle, intersections, blind corners and when exiting trailers
and swap bodies.
In areas where Aerial Lifts or Elevating Devices do not usually operate, operators must segregate the area to
a minimum of 6 meters exclusion zone using the visual signage (ex. cones and white/red tape).
In pallet racking areas where no barrier exists between adjacent pallet racks a visual (lights pointing 6m
distance installed on the not movable part of PIT and floor marking within the area to facilitate recognition
of the 6m distance) and/or audible (sounding the horn) notification must be used to warn pedestrians in
adjacent aisles when storing or retrieving pallets from elevated pallet racking.
When vision is obstructed, the operator must travel with the load trailing. Otherwise, a spotter is required
and the operator is to proceed slowly and with caution.
Overtaking any kind of PITs, Aerial Lifts or pedestrians is banned. It is only possible to pass when PIT,
Aerial Lift or a pedestrian are stationary and the passage does not interfere with the movement from the
opposite direction.
Overtaking in the high rack aisled is forbidden, unless site has a specific risk assessment which permits this.
The PIT operator must look in the direction of travel at all times.
The PIT operator must slow down for wet and slippery floors.
Speed must be reduced during turning.
PIT must only be used for specific work related tasks. PIT must not be used for personal transportation or
horseplay. A passenger must never be carried on the forks or load.
Under no circumstances are PIT allowed outside during inclement weather (e.g. ice, rain or snow)
PIT operators must wear a seatbelt where one is present on the equipment.
Trash, corrugate, or any other material must not be stored on the overhead guard of a PIT.
PIT must not be used as a towing or push device, unless appropriate attachments are fitted for this intended
purpose.
Persons must not stand or walk under the elevated forks or a platform, even when a load is not being
carried.
PIT must not be left unattended with the engine running, power on or with keys in the ignition without the
operator in the immediate area.
PIT traveling in high rack aisles must drive single file and have at least 6 meters between equipment.
Tailgating is prohibited.
Sites must strictly enforce a no smoking policy in a refuelling or battery charging area.
Hooking, wrapping cables or chains around the mast of the equipment to pull objects is strictly prohibited.
Minimum distance to be observed between PITs are as followed:
6m – in the high rack area
3m – on the main PIT lanes
2m – on the docks, in the buffers and in the charging station area
Note - Distances can be stricter based on the results of site risk assessments.
Created: Jan 2019
Date of Last Revision: Jan 2019
8 Next Revision Planned: Jan 2020
EU EHS Procedure | HAS9002.02
Powered Industrial Trucks (PIT) and Aerial Lifts
Written instructions are to be created within the site and must include at least the following requirements:
Respect of the implemented traffic visual display,
Maintain the access to the emergency exits which must be permanently free of any obstacle.
No handling of equipment without formal authorization.
No obstruction of traffic routes and more generally no blocking of the traffic flow.
No parking (even for a short time) out of the specially dedicated and identified areas.
It is forbidden for pedestrians (except for previously established service reasons) to enter manoeuvring
areas
As much as possible, these instructions are to be written under understandable pictograms to avoid
language barrier (for example: multiplicity of the heavy trucks driver’s languages).
PIT must not travel with forks or load in front unless the PIT is designed to travel with forks first (e.g. Sit down
forklift) or when positioning, entering a staging lane / drop zone or loading and unloading a trailer. Traveling or
turning while the operator, forks, or load are elevated is prohibited (with the exception of positioning a load or
pallet and operating in VNA). PIT equipment in transit must keep forks to 10 - 15cm from the ground.
The act of ‘snowploughing’ is strictly prohibited. Snowploughing is defined as using a PIT to push pallets or
materials on the ground without the operator having a clear view of their path or having complete control to
steer or stop the materials e.g., pushing pallets along the floor to reduce the space between them. Similarly,
operating PIT in two directions at the same time is prohibited i.e. ‘roller-coasting’, ‘air-plaining’ or ‘drifting’ are
common terms for this behaviour. (Exception: This is permitted on Order Pickers and Turret trucks while on
wire guidance). All instances of snowploughing, roller-coasting/air-plaining/drifting must be reported I&M
application as a PIT event and corrective actions must be documented in ATS, including disciplinary actions for
the PIT operator in accordance with the EU Safety Code of Conduct.
6.6.7. Parking
When PIT/Aerial Lift is not in use it must be parked in designated PIT parking areas, marked in accordance
with the FC Safety Signage Standard. When parking PIT, operators must safely lower the load, turn off the
power and apply the parking brake if one is present. Where PIT equipment cannot be parked in a designated
parking area ensure forks are lowered to the ground and covered (e.g. with a pallet and safety cone)
In emergency situations (evacuation etc.) PIT should be parked immediately, not blocking an escape route
and keys should left in vehicle to allow emergency services to move equipment if required. RME will keep
master card for PIT equipped with fleet management system.
Transporting product or totes (without a pallet) on the forks of PIT equipment is not allowed. Product and
totes must be placed on a pallet first.
When transporting pallets, all items must be secured with shrink wrap (minimum three layer of shrink wrap)
or at least two pieces of banding. (Exception: When transporting empty stacked totes at floor level banding
is required).
When transporting a stack of pallets this must only be done using PIT with operator protection guards. The
height of transported pallets must not exceed the height of the protective bar.
Pedestrian restricted areas must be clearly visualized (ex. VNA aisles). Only people with a service need are
authorised to enter these areas.
Based on the traffic plan and a risk analysis, the site shall install collective safety equipment allowing secure
pedestrian and vehicle traffic on site. Recommended are:
Anti-slipping surfaces;
Barriers or obstacles separating the various flows (notably the pedestrians and equipment or vehicles ones)
Traffic lights,
Mirrors at intersections,
Based on the traffic plan, the site must defines its own traffic rules resulting in:
Implementation of adapted visual signposting,
Written instructions completing the signposting.
If PIT incident occurs, the PIT must be marked with the defective label and signed off in the system if one is in
place and marked as “involved in incident”. All PIT incidents must be reported immediately without exception.
If any safety defect(s) occurred during the operation of the PIT, they must be marked with defective label and
marked in the system accordingly and the same process followed as outlined in 6.5.1 above regarding the
escalation to RME and the action that RME must take to LOTO the vehicle and arrange inspection/repairs. If
PIT equipment is involved in a collision, even if there is no obvious visual sign of damage, a report must be
obtained from the supplier to confirm that the equipment is safe to be returned into operation.
6.6.11.Maintenance
Only trained and qualified persons may inspect, maintain or repair a PIT. PIT must be kept clean at all times so
it is easier to identify worn or defective parts. Detailed records of every inspection, service, maintenance, repair
and modification must be retained by RME throughout the whole time the truck is in use within the FC.
Only trained personnel (authorized PIT operators) are authorized to perform battery charging activities as well
as electrolyte backing. Battery charging activities must only be performed at the designated locations provided
for this purpose, which have good ventilation and where suitable means are available to counter the electrical
risk.
Operators must:
Strictly adhere to the posted instructions. All signs have to be in compliance with FC Safety Signage
Standard. Minimum signage in the area should be
Smoking forbidden
Warning signs - corrosive substances
Required PPE
Emergency shower
Explosion zone – if needed, explosion protection analysis
Never ignite a naked flame close to a charging equipment,
Never discharge a battery by more than stated in manufacturer manual of the battery,
Check that the battery lead connections are clean and well-greased,
Never leave tools or metal parts on the battery or at proximity during the loading, and
Always shut down the battery loader at the end of the loading/charging activity
The distance from combustible materials should be min 2m,
Charging cable can’t lying on the floor. Hangers for charging cables are recommended.
For dry-charge batteries or batteries with gel, the charging must be realized at the end of each shift. You should
always follow with manual of battery manufacturer
If possible, use single point watering as shown on diagram below to minimalize risk of acid splashes.
Operators must:
Always wear the required PPE in accordance with section 6.7.5 (below) and ‘HAS9002.01 – Personal
Protective Equipment (PPE)’
Strictly adhere to posted instructions,
Conduct the electrolyte refilling in accordance with the instructions,
Wipe up any electrolyte spillages immediately and dispose of spill materials appropriately
Picture 6 – Single fill watering system.
The FC RME team must routinely validate the proper functioning of the safety shower and eye washes made
available in the area
If the pocket cannot be eliminated, provide ventilation in these areas and ensure there are no ignition sources in
these areas. The floor of the battery charging room shall be resistant and impenetrable to the electrolyte
(acid/alkali). Follow battery charger manufacturer's recommendations for safe operation and ventilation
requirements.
Open flames are strictly forbidden in the battery charging area. Therefore, never permit sparks, open flames, hot
works or lit cigarettes near a battery charging area. The size of the classified area where hydrogen could be
present should be determined by conducting a risk assessment based on local requirements and is dependent on
the dimensions of the charging area, the hydrogen release rate and the availability and type of ventilation. Post
clearly visible signs to prevent open flames in the vicinity of the battery charging area.
Batteries operate at their optimum at room temperature. This is the recommended temperature for battery
charging. Keep battery cap vents clear. If the released hydrogen is not vented, it can build up pressure and burst
a cell. Also when charging batteries ensure that the vent caps are in place to avoid the potential of spray of
electrolyte.
Avoid arcing at the battery. Therefore avoid the use of metal tools, which could accidentally be placed across
the battery, causing a short circuit. Use only insulating tools in the battery charging area and avoid the use of
larger metal objects such as aluminium ladders or scaffolding tubes, which pose the same short-circuit risk.
There shall be touch protection for all active parts at voltages > 50 volts DC with insulation, covers or shrouds
and distances.
Operators shall be trained about the hazards associated with batteries and battery charging.
Proper water levels in the battery cells must be maintained. Batteries can be topped up with distilled or
demineralized water. When lifting a battery, use an approved lifting beam. This beam has a non-conducting
barrier between the two hooks, which prevents short circuiting.
battery cleaning, other cleaning agents may result in buildup of static or may damage the battery cases.
Responsible for cleaning batteries is external company providing service for PIT.
In case of a spill, Operations management and RME must be informed immediately and spill removal to be
handled according to local instructions only by trained personnel. Spill instances must be recorded I&M
application as a Spill/Release Event.
6.8. Audits
6.9. Safety Incident; Property Damage; Power Outage and Emergency Situation Reporting
6.9.1. Safety Incidents or Property Damages
The PIT/Aerial Lift Operator is responsible for reporting all safety incidents, damage to merchandise, equipment
or stationary objects immediately to their Manager. If involved in an incident the following steps must be
followed without exception:
1.
2.
3.
4.
5.
6.
6.1.
6.2.
6.3.
6.4.
6.5.
6.6.
Do not move the equipment (unless an unsafe situation requires movement of PIT) and notify manager
immediately.
Shutdown PIT immediately and leave everything as it came to rest.
If PIT has come into contact with a pedestrian and they are trapped by the equipment - do not move the
equipment and immediately contact first aid response provision or Emergency Medical Services (EMS).
Only move PIT if there are no trapped persons or something is being spilled or leaking (water lines,
sprinkler system) then use extreme caution and move slowly to a safe location.
1.
2.
3.
4.
Created: Jan 2019
Date of Last Revision: Jan 2019
15 Next Revision Planned: Jan 2020
EU EHS Procedure | HAS9002.02
Powered Industrial Trucks (PIT) and Aerial Lifts
5.
6.
6.9
6.9.2 Emergency Events
Further to, and in accordance with’, in the event of:
Power outage, the use of PIT equipment must cease. Operators will lower forks, move to a safe area and
outside of any designated pedestrian path, and leave the work lights on. Equipment operated in VNA will
be moved outside of VNA if it is safe to do so.
Fire Alarm/ Site Evacuation, the PIT operator will lower forks, park in an area not to block any emergency
exit routes, turn off and leave PIT/Aerial Platform with keys inside the ignition and go outside through the
nearest exit.
Fall (including partial fall) from elevated work platforms such as order picker, turret truck, scissor lift or
other aerial lift, the site fall rescue plan will be initiated. Equipment must be taken out of service until it is
deemed safe to use again by the manufacturer (subject to any restrictions on use imposed by the EHS team,
Legal, and regulatory and law enforcement authorities).
Tip over, associates will be trained on how to respond. Always follow the operator’s manual guidance on
such an event.
Battery Acid Spill, refer to site Emergency Action Plan to properly clean the affected area.
Incapacitating Injury/Unconsciousness of a Person at height and/or PIT/Aerial Lift struck at height, the
RME team are the principle point of contact and must be contacted without delay to responsibly lower the
equipment safely etc.
6.9.3 Reporting
In addition to the reporting obligations noted above and in the Global EHS Incident Reporting and Investigation
Standard, all injuries and events must be reported without exception.
The investigation should start immediately and end within 2 weeks. After recommendation from EHS Department
and Legal confirmation, HR department should prepare the final document which is delivered together with Area
Manager to Associates. Learning will organize any retraining accordingly.
Where a person has been involved in a PIT / Aerial Lift incident where there is either injury to people, damage
to equipment or product - the driver’s PIT authorization to drive badge must be immediately removed pending
the outcome of the investigation (the badge must be submitted to the EHS team).
The supervising manager must immediately commence an incident investigation. If during the initial incident
investigation the investigating manager finds that an associate’s conduct is below standard, then the
investigating manager should recommend to HR that a conduct investigation is required. The incident
investigation should not determine the outcome of this but merely state that a conduct investigation is
recommended. The investigating manager should then liaise with HR to commence this separate conduct
investigation. The incident investigation documentation then becomes part of the conduct investigation and is
separate.
The scene of the incident must be photographed prior to any movement of PIT / Aerial Lift. The PIT Pre-Use
Inspection check sheet must be attached to the incident investigation for review and retention. The investigating
manager must arrange for the vehicle to be moved to a safe location, if possible depending upon the
circumstances of the incident. Facilities Department to be informed of the issue and a request for a maintenance
visit and inspection report made.
7. Contractor Management
Establish a program for managing contractors who are authorized to operate PIT to ensure they are competent prior to
operating the equipment. The facility/operation is responsible for ensuring they are competent through training and
evaluation on the use of the specific type of PIT. If a contractor is operating a PIT at the facility that is owned and under
the control of the contract company, the contractor shall follow the facility operation and safety requirements.
Independent RME contractors are permitted to use Warehouse equipment if they have completed and present the
documentation:
Contractor acknowledgment (release of liability and site EHS rules)
Contractor pre-task checklist and risk assessment or safe work method statement
Provide evidence of their training to RME and H&S
Driving license acc local law requirements
Warehouse internal training
Work permit
Provide evidence of their training to RME
Carry out a pre-use check.
8. Training
8.1 Training Documentation and Retention
FC Learning in cooperation with the EHS department must establish the site’s PIT training and certification program
to ensure it meets the requirements of this policy and EU laws and regulations. Electronic training records that
include the course name or code, the trainee’s name, the date, and the trainer’s name must be retained.
Documented training records, including certificates, must be maintained for the whole length of the trainee’s
employment, and 5 years after the termination. Based on local requirements each FC to establish the place
(department) and method of storing the documentation (electronic or paper version).
there is no PIT trainer on site, the EHS team will carry out the awareness session). PIT Operator Audits can be
carried out by any person who has completed this awareness session or is an appropriately trained PIT operator
(e.g. Area Managers (AMs), EHS team, leads, Learning associates). Refresher training is due annually. Second
part must be completed in KNET session.
PIT Trainers must complete training sessions for EHS teams where necessary to enable them to complete the
PIT Supervisor Awareness Training. The details are presented in Table one.
3.
4.
5.
6.
7.
8.
8.1.
8.2.
8.3.
8.4.
8.5.
8.6.
9. Documented Information
At a minimum, the following records shall be kept on file for the time period specified unless country specific regulations
require a longer retention period.
10. Appendixes