98-19469. Electronic Records Work Group Draft Report; Comments Requested  

  • [Federal Register Volume 63, Number 139 (Tuesday, July 21, 1998)]
    [Notices]
    [Pages 39202-39207]
    From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
    [FR Doc No: 98-19469]
    
    
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    NATIONAL ARCHIVES AND RECORDS ADMINISTRATION
    
    
    Electronic Records Work Group Draft Report; Comments Requested
    
    AGENCY: National Archives and Records Administration (NARA).
    
    ACTION: Request for comment.
    
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    SUMMARY: This notice contains a working draft of the Electronic Records 
    Work Group's proposed report to the Archivist outlining the Work 
    Group's recommendations and the effort that went into developing the 
    recommendations and implementation strategy. This draft has been 
    modified slightly from the June draft that was posted on the Web and 
    sent to agencies for review. This draft reflects the Work Group's 
    decisions to use the term ``electronic source record'' to describe the 
    records created using office automation applications and to place the 
    discussion of program and administrative records, formerly in draft 
    Appendix B, in the introductions to draft Appendixes C and D where they 
    are most pertinent. For purposes of this review, we have not changed 
    the Appendix designations that were used in the June draft and have, 
    therefore, reserved Appendix B for a discussion in the final report of 
    the public and Federal comments received on the draft products.
    
    DATES: Comments must be received on or before August 20, 1998.
    
    ADDRESSES: Comments may be sent electronically to the e-mail address 
    grs20@arch2.nara.gov>. We ask that lengthy attachments be sent in 
    ASCII, WordPerfect 5.1/5.2, or MS Word 6.0 format. If you do not have 
    access to e-mail, comments may be mailed to Electronic Records Work 
    Group (NPOL), Room 4100, 8601 Adelphi Rd., College Park, MD 20740-6001, 
    or faxed to 301-713-7270.
    
    FOR FURTHER INFORMATION CONTACT: Michael Miller at 301-713-7110, ext. 
    229.
    
    SUPPLEMENTARY INFORMATION: The draft report appears at the end of this 
    notice.
    
        Dated: July 16, 1998.
    Lewis J. Bellardo,
    Deputy Archivist of the United States.
    
    Draft Electronic Records Work Group Report to the Archivist of the 
    United States
    
    Table of Contents
    
    Executive Summary
    Introduction
    Work Group Approach
    Recommendations of the Electronic Records Work Group
    Rejected Options
    Future Steps
    Appendix A--Electronic Records Work Group membership
    Appendix B--[Reserved]
    Appendix C--Proposal for developing agency records schedules that 
    include office automation records
    Appendix D--Proposal to revise the entire GRS to cover all formats 
    of the administrative records included therein
    Appendix E--Proposed General Records Schedule, Information 
    Technology Records
    
    Executive Summary
    
        The Electronic Records Work Group (Work Group) is an interagency 
    group formed by the Archivist of the United States on November 21, 
    1997, to review the 1995 version of General Records Schedule (GRS) 20, 
    which was declared null and void by the U.S. District Court for the 
    District of Columbia. (That ruling is on appeal.) Specifically, the 
    Work Group was asked to identify appropriate areas for revision, 
    explore alternatives for authorizing disposition of electronic records, 
    identify methods and techniques that are available with current 
    technology to manage and provide access to electronic records, and 
    recommend practical solutions for the scheduling and disposition of 
    electronic records. The Archivist also gave the Work Group several 
    guiding principles and policies, including: program records should not 
    be scheduled in the GRS, electronic records should be scheduled as 
    series, and solutions must be workable.
        The Work Group membership was drawn from staff of the National 
    Archives and Records Administration (NARA) and other Federal agencies 
    with records management and/or electronic records expertise under the 
    oversight of Deputy Archivist Lewis Bellardo. Michael Miller, the 
    Director of NARA's Modern Records Programs, serves as the group leader. 
    In addition, electronic records management experts from state archives 
    and records programs, the National Archives of Canada, academia, and 
    records management consulting firms serve as consultants to the Work 
    Group on a pro bono basis.
        In conducting its review and developing the recommendations 
    contained in this report, the Work Group aggressively sought input from 
    Federal agencies, other interested
    
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    individuals and groups, and the general public. In addition to the 
    public meetings held on December 19, 1997, and January 29, April 7, and 
    May 18, 1998, NARA maintained a web page devoted to the work of the 
    Electronic Records Work Group (http://www.nara.gov/records/grs20/); 
    published public notices in the Federal Register; sent memos to Federal 
    agency records officers asking for their comments at various points in 
    the process; solicited comments from subscribers to the Archives 
    Listserv and Records Management Listserv; and invited comments from 
    professional organizations, such as the American Historical Association 
    (AHA), Organization of American Historians (OAH), Society of American 
    Archivists (SAA), National Association of Government Archives and 
    Records Administrators (NAGARA), Association of Records Managers and 
    Administrators International (ARMA), and the National Coordinating 
    Committee for the Promotion of History, and from other individuals with 
    an interest or expertise in electronic records.
        By March 1998 the group had drafted a number of options to be 
    explored to replace GRS 20 disposition authorities, including 
    authorities for the deletion of program and administrative electronic 
    mail and word processing records, and for system maintenance and 
    operations records. The group also explored options for electronic 
    maintenance of electronic source records (records that remain in word 
    processing and electronic mail and other office automation systems 
    after a record has been produced for incorporation into an agency 
    recordkeeping system) on an interim basis prior to the installation of 
    proper electronic recordkeeping capability. After carefully considering 
    the public and consultant comments on the preliminary options, the Work 
    Group determined that there was only one feasible alternative approach 
    to GRS 20, and that was to schedule the records at the series level.
        The two other options initially proposed as possible approaches for 
    managing electronic source records generated with electronic mail and 
    word processing software were found to have significant flaws. Both 
    options (to establish a uniform minimum retention period or to develop 
    retention standards based on an individual's position in the agency's 
    hierarchy) failed to meet requirements for the proper maintenance of 
    records. Neither provided for proper organization or categorization of 
    records to facilitate access. In both cases, disposition appeared to be 
    based on factors other than business needs. The group could not 
    identify supplemental measures that could be taken in conjunction with 
    either of these options to make them useful.
        The Work Group, therefore, recommends to the Archivist of the 
    United States a three-part approach for scheduling the electronic 
    source records that previously were authorized for disposal under GRS 
    20, items 13, 14, and 15. The Work Group's recommendations also address 
    other concerns with the 1995 edition of GRS 20, i.e., authorization for 
    the disposition of electronic source records produced with other office 
    automation systems such as presentation software and electronic 
    calendaring software, and authorization for the disposal of electronic 
    records that correspond to the records covered in GRS 1-16, 18 and 23.
         First, agencies must schedule their program and unique 
    administrative records in all formats. As part of its report, the Work 
    Group proposes an implementation strategy to assist Federal agencies 
    and NARA in accomplishing this task.
         Second, the Work Group recommends that NARA modify 
    General Records Schedules (GRS) 1-16, 18, and 23 to authorize the 
    deletion of electronic source records, including those generated with 
    office automation systems, that correspond to administrative records 
    covered by those GRS, after a recordkeeping copy has been produced.
         Third, the Work Group recommends that NARA develop a 
    new General Records Schedule that covers only systems administration 
    (or systems management) and operations records, such as files related 
    to system use and maintenance, backup tapes, and other records (e.g., 
    system user access records) used in managing information systems 
    throughout their life cycle. This new GRS would cover records in all 
    media.
    
    The Work Group originally conducted a preliminary review of issues 
    facing agencies that want to move toward electronic recordkeeping, but 
    determined that working simultaneously on the scheduling approach and 
    the electronic recordkeeping approach was not feasible given the 
    deadlines and the complexity of electronic recordkeeping issues that 
    need to be studied. The Work Group recommends that the Archivist 
    establish a follow-on group that continues to work on electronic 
    recordkeeping. This follow-on group should recommend guidance on 
    electronic recordkeeping for Federal agencies.
    
    Introduction
    
        The Archivist of the United States established an interagency 
    Electronic Records Work Group on November 21, 1997. In his charge to 
    the Work Group, the Archivist asked the group to:
         Review the current version of General Records Schedule 
    (GRS) 20;
         Identify appropriate areas for revision;
         Explore alternatives for authorizing disposition of 
    electronic records;
         Identify methods and techniques that are available with 
    current technology to manage and provide access to electronic records; 
    and
         Recommend practical solutions for the scheduling and 
    disposition of electronic records.
        The Work Group was asked to develop and weigh advantages of various 
    options and assess the practicality and feasibility of each in light of 
    the availability of electronic records management tools and other 
    resources. The Archivist asked the Work Group to keep in mind the 
    following working assumptions in performing its work:
         General records schedules should focus on 
    administrative ``housekeeping'' records, not program records, and there 
    should be guidance in place to distinguish between them.
         Records may be transferred from one medium to another; 
    however, key information about those records must be preserved as part 
    of the transfer process.
         Electronic records should be scheduled as series, not 
    classes of media.
         Solutions to electronic records challenges must be 
    workable and be something agencies can and will use.
    
        The Work Group membership was drawn from NARA staff and 
    representatives of other Federal agencies with records management and/
    or electronic records expertise under the oversight of Deputy Archivist 
    Lewis Bellardo. Michael Miller, the Director of NARA's Modern Records 
    Programs, serves as the group leader. In addition, electronic records 
    management experts from state archives and records programs, the 
    National Archives of Canada, academia, and records management 
    consulting firms serve as consultants to the Work Group on a pro bono 
    basis. A list of the Work Group members and consultants is provided in 
    Appendix A to this report.
        Throughout this report, the term ``electronic source record'' has 
    been used to describe the electronic record that resides on an agency's 
    electronic mail, word processing, or other office
    
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    automation systems, i.e., the ``copy'' that formerly was authorized for 
    disposal by GRS 20 after a recordkeeping copy was produced. This report 
    addresses the disposition of the electronic records which are the 
    sources of the records filed in the agency's recordkeeping system. 
    Therefore these records are designated as ``electronic source 
    records.'' Agencies need to recognize that records created using word 
    processing, e-mail and other software on office automation systems must 
    be scheduled according to the same requirements which apply to all 
    records. NARA will authorize the disposal of electronic source records 
    in office automation systems only when copies of these records have 
    been captured in a recordkeeping system.
        A main thrust of this report is to provide guidance and techniques 
    to agencies for scheduling electronic source records that are created 
    using word processing, electronic mail, and other end-user software. 
    These records typically are stored in desktop and laptop computer 
    systems and in networked servers. In the modern Federal office 
    environment, most staff members are provided with generic software 
    tools, such as word processing and e-mail, which they use to generate 
    electronic records related to their work, regardless of the nature of 
    the work. These records need to be filed in a recordkeeping system so 
    that they will be retrievable with other related records such as 
    attachments, the corresponding incoming or outgoing record, and, if 
    part of a case file, the forms and other records that comprise that 
    file. The complete files, and individual records within them, need to 
    be accessible to other staff members who need them in the course of 
    their work and in response to inquiries from the public. Failure to 
    place electronic records generated as electronic mail messages, word 
    processing files, and other office automation products in a 
    recordkeeping system will result in files which are incomplete or 
    unreliable. Consequently, these electronic source records must be 
    copied to a recordkeeping system established by the agency for 
    maintenance, use, and disposition.
        However, even after these records are placed in a recordkeeping 
    system, a record remains on the originating system. These electronic 
    source records, like other Federal records, can be destroyed (deleted 
    from the office automation system) only with NARA's authorization. The 
    Work Group proposes that NARA revise the GRS to provide governmentwide 
    authorization for the disposition of electronic source records used to 
    create the types of records covered by GRS 1-16, 18, and 23. Agencies 
    must obtain authorization for disposition of all other electronic 
    source records by submitting a schedule (Standard Form 115) to NARA.
        The Work Group considered using terms other than ``electronic 
    source record'' but found them problematical. Some readers saw 
    ``electronic copy'' as implying nonrecord status. The term ``version'' 
    is often used to distinguish between a paper record and the same record 
    in electronic form. However, ``version'' is frequently used to describe 
    a record that is an iteration of an earlier or later record. Hence, 
    ``version control'' may be a feature of a document management or 
    electronic recordkeeping system, to distinguish between the first 
    record produced and later variants of the same record.
        Conversely, the Work Group chose not to use the term ``duplicate'' 
    because that term implies an exact match which may not exist. The 
    electronic source record that resides in an individual's word 
    processing directory or electronic mail box would be a duplicate of the 
    record in the recordkeeping system only if the recordkeeping system 
    were electronic and if all of the metadata produced by the word 
    processing or electronic mail utility were transferred to the 
    recordkeeping system. Because so many agencies are still maintaining 
    paper files as their recordkeeping systems, use of the term 
    ``duplicate'' would be inappropriate.
    
    Work Group Approach
    
        In conducting its review and developing the recommendation and 
    products contained in this report, the Work Group made special efforts 
    to engage the Federal community and the public in discussion of 
    possible alternatives to the 1995 General Records Schedule 20, and to 
    keep them informed of the Work Group's activities. A GRS 20 web page on 
    NARA's Internet web site at http://www.nara.gov/records/grs20/>, and a 
    special e-mail address (grs20@arch2.nara.gov) was established. Posted 
    on that web page were documents for public comment, meeting notices and 
    agendas, summaries of public meetings, and other background materials 
    relating to the Work Group and the Public Citizen v. Carlin litigation. 
    Notices of public meetings and information about documents for public 
    comment were published in the Federal Register. Information and 
    requests for comment also were provided to Federal agency records 
    officers through NARA memos and to subscribers of the Archives Listserv 
    and Records Management Listserv through electronic messages.
        The Work Group's first public meeting was held on December 19, 
    1997, at NARA's Archives II facility in College Park, MD, with one 
    member and several consultants participating by teleconference. The 
    purpose of the meeting was to bring the members of the Electronic 
    Records Work Group and consultants together to outline the tasks and to 
    answer questions concerning the logistics of the Work Group. The Work 
    Group and consultants received a set of detailed preliminary issues 
    proposed for discussion and other background materials. The list of 
    preliminary issues was posted on the GRS 20 Page and also published for 
    public comment in the Federal Register on December 24. Comments were 
    received from Work Group members and consultants and a Federal agency 
    contractor by the January 9, 1998, deadline. In an effort to obtain 
    wider input on the list of issues and options the Work Group should 
    consider, a second public meeting was held on January 29, 1998, at the 
    National Archives Building in Washington, DC. More than 70 Federal 
    agency staff and interested members of the public attended. Two Federal 
    employees provided formal remarks, and a number of individuals, most 
    from Federal agencies, made comments from the audience.
        Immediately following the public meeting on January 29 and 
    continuing on February 9, 1998, the NARA members and Federal members of 
    the Electronic Records Work Group held working sessions at the National 
    Archives Building in Washington, DC, to discuss alternatives for GRS 
    20. The members discussed the framework in which they were working, 
    ranging from the goals of the group to the current status of electronic 
    records management in the Federal government. The members also 
    discussed the comments submitted by members of the public and 
    brainstormed on possible alternatives to GRS 20. From these comments 
    and ideas, the Work Group developed three possible short-term 
    approaches for scheduling electronic records for further analysis and 
    review. These were described in the March 12, 1998, paper ``Preliminary 
    Options for Replacing GRS 20.'' The Work Group's consultants, who had 
    reviewed a draft of the paper, were asked to provide their views on 
    enabling requirements and related issues for specific options, and to 
    comment on any other aspect of the paper. Work Group members also 
    developed comments on specific options.
        The Preliminary Options paper laid out three options. The first 
    option, based on a traditional approach to
    
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    scheduling records by series, had three complementary sections for 
    scheduling program and administrative records, revising GRS 20 to cover 
    only systems records, and revising the remaining GRS to provide 
    disposal authority for source records not needed for recordkeeping. The 
    second and third options offered alternative interim approaches for 
    handling the disposition of electronic source records that remain on 
    electronic mail and word processing systems. Option 2 involved saving 
    electronic source records for a specific minimum period of time and 
    option 3 proposed saving the electronic source records created or 
    received by individuals holding specific positions within an 
    organization.
        Public input on the options paper and suggestions for additional 
    approaches were sought in a variety of ways. The paper was posted on 
    the GRS 20 Page as http://www.nara.gov/records/grs20/opt312.html> on 
    March 14, and a notice announcing the availability of the paper and 
    requesting comments was published in the Federal Register on March 19, 
    1998. NARA sent a memo to Federal agency records officers and 
    information management officials on March 13 (NWM 06-98) inviting 
    comments on the paper. Announcements were sent to the Archives Listserv 
    and Records Management Listserv, and messages were sent by e-mail or 
    fax to individuals interested in electronic records issues and to 
    professional organizations, including the American Historical 
    Association (AHA), Organization of American Historians (OAH), Society 
    of American Archivists (SAA), National Association of Government 
    Archivists and Records Administrators (NAGARA), Association of Records 
    Managers and Administrators International (ARMA), and the National 
    Coordinating Committee for the Promotion of History. Comments were 
    requested by March 31.
        Public comments were received from eight individuals and the Small 
    Agency Council Records Officers Committee. None suggested additional 
    approaches although several commented on aspects of the entire GRS and 
    on GRS 20 coverage. Option 1 was generally preferred.
        Most of the Work Group's consultants submitted comments on all of 
    the options and issues. No other short term options were identified. 
    Several comments offered other approaches to appraising records (a 
    systems or macro approach, the Canadian model, the Pittsburgh Project 
    ``warrant'' concept). Given the time frame that the Work Group had to 
    develop its recommendations, these approaches were not pursued; 
    however, they deserve further review later. The consultants found 
    options 2 and 3 problematic.
        Copies of all of the comments received were circulated to the 
    Federal members of the Work Group and to the consultants prior to an 
    all-day public meeting on April 7 at the Office of Thrift Supervision 
    Amphitheater in Washington, DC. All but two Work Group members attended 
    the meeting, as did five of the 8 consultants. The meeting was called 
    specifically to receive comments from the ERWG's consultants on the 
    March 12, 1998, Options Paper, but the meeting was opened to the public 
    and approximately ten persons observed all or part of the meeting. Most 
    of the consultant comments and discussion focused on Option 1, and they 
    agreed that options 2 and 3 lacked merit. No additional options were 
    identified.
        The Work Group met in a working session on April 17 to evaluate 
    further the written comments and discussions at the April 7 meeting and 
    to make assignments for developing products to implement Option 1. 
    Several consultants were asked to contribute to those products and 
    other consultant and agency/public comments were incorporated in the 
    approaches where feasible. A fourth public meeting was held on May 18, 
    1998, at the National Archives Building in Washington, DC, to brief 
    Federal agencies and the public on Work Group's progress and to obtain 
    public comments and questions. In addition to the Federal Register 
    notice and memo to records officers and IRM officials announcing the 
    meeting, invitations were sent to the Chief Information Officers (CIO) 
    Council, plaintiffs in the Public Citizen versus Carlin litigation, and 
    other organizations and individuals. More than 200 people attended the 
    meeting and provided a number of comments and questions.
        As the Work Group discussed in the May 18 public meeting, the 
    report and its appendixes were sent to Federal agencies for comment in 
    June and a copy of the report, without the appendixes, was posted on 
    the GRS 20 Page at that time. The Federal members of the Work Group met 
    on July 13 to discuss changes and clarifications needed in the report 
    and appendixes that would be published in the Federal Register for 
    public and formal Federal agency comment the week of July 20. The Work 
    Group and its consultants will review the comments received and prepare 
    a final report and implementation plan to the Archivist of the United 
    States in time for his review and approval before September 30, 1998.
    
    Recommendations of the Electronic Records Work Group
    
        The Electronic Records Work Group recommends to the Archivist of 
    the United States that NARA take the following actions to replace the 
    1995 General Records Schedule 20:
        1. NARA should instruct agencies to schedule their program and 
    unique administrative records in all formats.
        On March 10, 1998, NARA issued such instructions in NARA Bulletin 
    98-02, Disposition of Electronic Records, for new and revised series 
    that are submitted to NARA for approval. NARA should issue instructions 
    for scheduling the electronic source records generated with office 
    automation systems that were authorized for disposal under the 1995 GRS 
    20.
        If the scheduling process to replace the disposition authority 
    formerly provided by GRS 20 is to move ahead expeditiously, it is 
    essential that the process must both minimize the burden on Federal 
    agencies as much as possible and continue to provide the public an 
    opportunity to comment on the proposed schedules through the usual 
    Federal Register process. In carrying out the proposed scheduling 
    process, agencies must perform a series-based review of their 
    schedules, NARA must appraise proposed dispositions on a series basis, 
    and the public must have the opportunity to comment on proposed 
    dispositions on a series basis. However, the Work Group does not 
    believe that it is necessary, at this time, for agencies to submit 
    individual schedule items for these electronic source records series by 
    series. As agency records schedules are revised or amended, the 
    disposition authorities for these electronic source records will be 
    integrated into the agency disposition manual at the series level.
        The Work Group has developed Appendix C to facilitate 
    implementation of this recommendation. Appendix C proposes guidance to 
    agencies on how to develop records disposition schedules to replace the 
    dispositions formerly provided by GRS 20 and outlines in a general 
    manner how those proposed schedules will be processed by NARA.
        2. NARA should modify General Records Schedules (GRS) 1-16, 18, and 
    23 to authorize the deletion of source records corresponding to the 
    administrative records covered by those GRS that are not needed for 
    recordkeeping purposes, after a recordkeeping copy has been produced.
    
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        Proposed language and a discussion of the recommendation is 
    provided in Appendix D, along with definitions of ``program records'' 
    and ``administrative records.'' The definitions should be added to the 
    general records management definitions in NARA regulations at 36 CFR 
    1220.14, and where appropriate in other NARA records management 
    guidance.
        3. NARA should revise GRS 20 disposition authorities to cover only 
    systems administration (or systems management) and operations records, 
    such as files related to system use and maintenance; backup tapes; and 
    other records (e.g., system user access records) used in managing 
    information systems throughout their life cycle. The new schedule 
    should cover only administrative records, but should cover them in all 
    media.
        A proposed draft general records schedule is provided in Appendix 
    E. This draft has been modeled after the New York State Archives and 
    Records Administration (SARA) General Administrative Schedule's section 
    on Electronic Data Processing, but adapted to reflect the mandatory 
    nature of the General Records Schedules. (The New York General 
    Administrative Schedule is advisory and provides minimum retention 
    periods.) The New York SARA approach was developed with the assistance 
    of the State government data processing community. The Work Group 
    emphasizes that this draft revised general records schedule will need 
    to be reviewed carefully by Federal agency CIO's and their information 
    technology (IT) organizations to ensure that it accurately describes 
    Federal IT records and includes only temporary administrative records 
    that can be scheduled by a common disposition authority in a GRS.
    
    Rejected Options
    
        In early deliberations, the Electronic Records Work Group 
    considered two other options for maintaining electronic source records 
    used to generate some or all program records.
        Those options, numbers 2 and 3 in the Preliminary Options Paper 
    dated March 12, 1998, were:
         Establish a uniform minimum retention period for 
    electronic records currently covered by GRS 20, items 13 and 14
         Develop retention standards for electronic records 
    currently covered by GRS 20, items 13 and 14, based on an individual's 
    position in agency hierarchy
        These options were proposed as possible approaches for maintaining 
    electronic source records of all or some of the most important agency 
    program records created or maintained on e-mail and word processing 
    systems. In discussing these two options, Work Group members came to 
    the conclusion that they were significantly flawed. Both options failed 
    to meet requirements for the proper maintenance of records. Neither 
    provided for proper organization or categorization of records to 
    facilitate access. In both cases, disposition appeared to be based on 
    factors other than business needs. (Business needs refers to an 
    agency's need to conduct its business, maintain a record of its 
    essential activities and decisions for its own use, support oversight 
    and audit of those activities, and permit appropriate public access.) 
    The Work Group could not identify supplemental measures that could be 
    taken in conjunction with either of these options to make them useful.
        A significant concern with both approaches was that they might be 
    viewed by agencies and the public as a satisfactory interim way to 
    manage records electronically until the agencies have fully functioning 
    electronic recordkeeping systems. Such electronic collections of mail 
    and word processing records are incomplete, without proper 
    recordkeeping organization, and unindexed. Moreover, they lack the 
    context of the related documentation filed in the recordkeeping system. 
    Access to such collections is limited to full text search, which has 
    the dual drawbacks of finding many irrelevant documents and missing key 
    documents that may not contain the word(s) used in the query.
        An additional concern with option 2 was that some agencies may 
    believe that this option could be implemented by retaining backup tapes 
    for a minimum period of time. As stated in NARA regulations (36 CFR 
    1234.24(c)) and guidance (the 1995 Agency Recordkeeping Requirements: A 
    Management Guide), backup tapes should not be used for recordkeeping 
    purposes for a variety of reasons. One compelling reason is that 
    records on backup tapes are not readily accessible to agency staff 
    members. While necessary for disaster recovery, backup tapes are not 
    useful for day-to-day agency operations.
        The proposed option 3, to retain electronic source records 
    generated with mail and word processing systems based on organizational 
    position, was a variation of rejected option 2 and seemed to be based 
    on archaic archival and records management theory. Work Group members 
    and other NARA staff believe that setting retention periods based on 
    hierarchical placement would not produce useful results. At one time, 
    appraisal theory assumed that records of high level officials were 
    generally more valuable than records in lower level offices, as 
    significant program decisions are reached at the higher levels. Over 
    many years, NARA has found that in many agencies much of the 
    documentation of policy development and justification is maintained at 
    lower-level program offices of an agency. Currently, appraisal of 
    Federal records is conducted by assessing the documentation patterns in 
    agencies and identifying the most valuable records based on function 
    and recordkeeping practices, as well as content.
        Finally, Work Group members recommended against these options 
    because implementation of either would drain records and information 
    management resources from more productive efforts to control agency 
    records properly, including long-term plans to move toward electronic 
    recordkeeping.
        In conclusion, the Electronic Records Work Group, after careful 
    deliberation, rejected options 2 and 3 in the Preliminary Options Paper 
    dated March 12, 1998, as unworthy to be included in the recommendations 
    to the Archivist.
    
    Future Steps
    
        This report of the Electronic Records Work Group addresses the 
    recordkeeping practices of most agencies, which are still primarily 
    paper-based. However, business needs and technology advances will lead 
    agencies to electronic recordkeeping over time. The many Federal 
    initiatives for electronic commerce and the reliance on computer 
    technology to create the records that document government business are 
    examples of the forces moving most agencies in this direction. NARA 
    must provide guidance to agencies on sound policies and techniques for 
    managing electronic records and for implementing electronic 
    recordkeeping systems.
        The Work Group recommends that the Archivist establish a follow-on 
    group to look at the electronic recordkeeping issue and to make 
    recommendations in that area. The follow-on group should begin as soon 
    as possible and build on the work done by this Work Group. The Work 
    Group suggests that the Archivist should set a relatively short time 
    frame for submitting these electronic recordkeeping recommendations.
    
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    Appendix A: Electronic Records Work Group Membership
    
    Members--National Archives And Records Administration
    
    Lewis J. Bellardo, Deputy Archivist of the United States
    Michael L. Miller, Director, Modern Records Programs
    Nancy Allard, Policy and Communications Staff
    Mark Giguere, Modern Records Programs
    Jean Keeting, Modern Records Programs
    Miriam Nisbet, Special Counsel for Information Policy
    Susan Sallaway, Information Resources Policy and Projects Division
    Kenneth Thibodeau, Director, Electronic Records Programs
    
    Members--Other Federal Agencies
    
    Edward Barrese, Records Officer, Federal Deposit Insurance 
    Corporation
    Maya Bernstein, Office of Information and Regulatory Affairs, Office 
    of Management and Budget
    Elizabeth Behal, Departmental Records Officer, U. S. Department of 
    Agriculture
    Christopher L. Olsen, Chief, Records Classification and Management, 
    Records Classification and Management Group, Office of Information 
    Management, Central Intelligence Agency
    Dan Hocking, Computer Scientist, Army Research Laboratory
    Eleanor Melamed, Department of Energy
    Alan Proctor, CIO Council Liaison, Department of the Treasury
    Catherine Teti, Director for Records Management and Information 
    Policy, Office of Thrift Supervision
    
    Non-Federal Expert Consultants
    
    Rick Barry, Barry Associates
    Luciana Duranti, University of British Columbia
    Bruce Evans, Nuclear Information and Records Management Association 
    (NIRMA)
    Margaret L. Hedstrom, University of Michigan
    James Henderson, State Archivist, Maine
    Alan Kowlowitz, New York State Archives and Records Administration
    John McDonald, National Archives of Canada
    Charles Robb, Kentucky Department for Library and Archives
    Robert Williams, Cohasset Associates
    
    Appendix B [Reserved]
    
    Appendix C--Proposal for Developing Agency Records Schedules That 
    Include Office Automation Records
    
        Note: See the second document published in this Part V of the 
    Federal Register.
    
    Appendix D--Proposal To Revise the Entire GRS TO Cover All Formats 
    of the Administrative Records Included Therein
    
        Note: See the third document published in this Part V of the 
    Federal Register.
    
    Appendix E--Proposed General Records Sechedule, Information 
    Technology Records
    
        Note: See the fourth document published in this Part V of the 
    Federal Register.
    
    [FR Doc. 98-19469 Filed 7-20-98; 8:45 am]
    BILLING CODE 7515-01-P
    
    
    

Document Information

Published:
07/21/1998
Department:
National Archives and Records Administration
Entry Type:
Notice
Action:
Request for comment.
Document Number:
98-19469
Dates:
Comments must be received on or before August 20, 1998.
Pages:
39202-39207 (6 pages)
PDF File:
98-19469.pdf