NARA: Agencies must set own records policies

The burden of determining whether an electronic document must be preserved as a record
will fall to agencies, a senior National Archives and Records Administration official said
last week.

Much to the frustration of many agencies, NARA is not likely to establish regulations
for identifying among the masses of online data what is or is not a record, said Michael
L. Miller, director of NARA’s Modern Records Program.

“Will we be telling agencies they need to implement an electronic management
archiving system? The answer to that is no,” Miller said.

Instead, he said, NARA will tell agencies to review their systems and information
requirements based on their ability to determine what documents are records and must be

“No one size fits all with electronic records, any more than it did with paper
records,” Miller said.

NARA has never instructed agencies on what paper records need to be stored or what
kinds of folders to use, he said. Along those same lines, electronic archiving needs to be
done within the agency, Miller said at a Washington seminar sponsored by the Digital
Government Institute.

The comments fall short of what many agencies have been seeking from NARA. During the
forum, Jeff Greenhut, a contractor working for the Energy Department, voiced a common
frustration among agency systems managers in one short phrase: “I have a problem

The frustration is understandable, Miller said. NARA is rethinking its policy and
guidance on archiving from the ground up, Miller said, but the agency is working under the
premise of the Hippocratic oath: First, do no harm.

There are other issues that slow policy development, Miller said. One is the effort to
consolidate and find consensus among various administrative positions. NARA must
coordinate policies from the Office of Management and Budget, the Justice Department and
the General Services Administration, he said.

NARA must also deal with constantly changing technologies. And any policy must address
litigation and long-term preservation issues, he said.

To deal with some of the concerns, NARA has created the Fast Track Guidance Development

Through this effort, NARA will provide guidance to agencies with immediate needs. Fast
Track is a follow-on to the Electronic Records Workgroup, which NARA formed after the
federal courts ruled that printing and then deleting electronic records was not sufficient
to ensure a record’s appropriate preservation.

NARA has not fully defined how it will use the Fast Track program. But Miller said
agency officials generally agree that the program will respond to questions from agencies
that must deal with specific documents and to questions that it can answer relatively
quickly, Miller said.

“We envision that we’ll be putting up guidance as things change, and
we’ve learned that things change very quickly,” he said.

Meanwhile, NARA has issued revised General Records Schedules, which authorize the
disposal by agencies of records regardless of their format.

NARA also has drafted a bulletin to guide agencies on how long to keep electronic
copies of records for documents that were previously covered by GRS-20. A federal district
court judge in 1997 voided GRS-20, which had allowed agencies to delete electronic records
if a paper copy had been saved.

The government appealed the judge’s ruling; a decision is pending. Miller said
NARA wants to issue a final version of the new schedule later this year.

NARA is also drafting a new GRS for administrative records that document the management
of information technology.

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