5.3 The Texas Recordkeeping and Retention Map

Why This Section Matters

Retention questions look easy until four plausible numbers appear as answer choices. Texas uses one, two, five, and ten years for four different documents, plus two and five years as label dwell times. The only reliable way through is to attach each number to its rule.

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1. The Master Retention Table

Memory pattern: 1-2-5-10. One year — residential drawings. Two years — service/maintenance/testing records and service labels. Five years — installation inspection forms and inspection/test labels. Ten years (or life of system) — the installation certificate.

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2. Availability for Inspection

Three provisions make records reachable by the state:

1. § 34.616(d): service, maintenance and testing records "must be available for examination by the state fire marshal or the state fire marshal's representative."
2. § 34.617(2): the company's installation certificate copy is retained "for access by the State Fire Marshal's Office."
3. § 34.613(a)(2): every registration application must include written authorization permitting the state fire marshal or a representative "to enter, examine, and inspect any premises, building, room, or establishment used by the applicant while engaged in the business" to determine compliance.

That third item is the consent you give at application time — it is why an SFMO investigator does not need a separate warrant to review your job files during a compliance investigation under § 34.625(a).

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3. Where the Records Must Live

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4. Documents Created at Each Job Stage

PLANNING       -> Signed plans with planner license no. + firm name, address,
                  phone, ACR no.                                (§ 34.619(b))

INSTALLATION   -> Inspection form entries at 3 milestones       (§ 34.618)
                  Installation label INSIDE the panel cover     (§ 34.620)

CERTIFICATION  -> Installation certificate (SF035):             (§ 34.617)
                    original on site
                    AHJ copy within 10 days
                    company copy: life of system or 10 years
                  Record drawings incl. sequence of operation   (§ 34.619(c))

SERVICE        -> Service label, stacked over the previous one  (§ 34.621)
                  Service/maintenance/testing records, 2 years  (§ 34.616(d))

INSPECTION     -> Blue inspection/test label after AHJ
                  acceptance for new systems                    (§ 34.622)

DEFICIENCY     -> Yellow label + written notice, 5 business days (§ 34.623)
                  Red label + oral now / written next business
                  day (inoperable) or 3 business days (fault)   (§ 34.624)

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5. Worked Fact Patterns

Pattern A. An SFMO investigator asks a firm for the installation certificate on a system certified 12 years ago. The firm no longer has it. → Compliant. Section 34.617(2) requires retention for the life of the system or ten years, whichever occurs first. Ten years occurred first.

Pattern B. The same investigator asks for the installation inspection form for a system certified four years ago, and the firm says it was left with the customer. → Non-compliant twice: the form must be kept five years from system certification, and it must be kept at the licensed firm's office.

Pattern C. A firm purges all service tickets after 18 months to save storage. → Non-compliant. Section 34.616(d) requires complete records of all service, maintenance and testing for a minimum of two years, available for examination by the state fire marshal.

Pattern D. A firm installed a monitored system in a single-family home 14 months ago and has kept nothing. → Non-compliant at the time, but the § 34.619(f) obligation runs not less than one year after completion, so a 14-month-old drawing may lawfully have been discarded — provided the firm actually kept it for the first year and made it available to the owner and AHJ on request during that period.

Pattern E. A technician keeps the record drawings in the firm's server and the panel manual folded inside the panel door. → The server copy is fine; the panel storage violates § 34.619(e).