NARA wants archiving plans in place by 2002

Agencies will have until 2002 to set polices on preserving e-mail and other electronic
documents deemed to be federal records, the National Archives and Records Administration
said in a recent bulletin.

The bulletin is the first guidance on dealing with such records since federal District
Court Judge Paul L. Friedman ruled in 1997 that NARA’s previous policy was null and
void. That regulation, General Records Schedule 20, let agencies print out electronic
documents and then delete the electronic versions.

NARA Bulletin 99-04, posted on the Web at, provides guidance
on word processing and e-mail documents that remain online after a copy has been stored in
a record-keeping system, whether that record-keeping system stores the documents
electronically or on paper.

Meanwhile, the government is continuing with its appeal of the Friedman ruling.

The new bulletin gives agencies until Feb. 1 to update their records schedules to
include policies for the archiving and destruction of electronic files or to describe how
they plan to complete that task by 2002 if their current policies cannot be changed

The bulletin instructs agencies how to set storage and destruction schedules for
program and administrative records, said Michael Miller, director of NARA’s Modern
Records Programs.

“It’s not how to manage them otherwise. It’s not telling them they have
to move to an electronic record-keeping system,” he said.

Nor does the guidance instruct agencies on the specific format in which documents must
be archived or maintained.

First, agencies must determine the significance of an electronic record and determine
how long a document must be kept, Miller said. Also, agencies need to determine whether
the document must be readily accessible or searchable. They also must consider the costs
of storing records in an electronic record-keeping system, Miller said.

Agencies will need to determine the status of their existing records schedules, Miller
said. That will determine whether the organization can meet the Feb. 1 deadline or will
need to submit a plan for preparing new schedule polices, he said.

Michael Tankersley, senior staff attorney for Public Citizen, a Washington public
interest group that filed the successful lawsuit questioning GRS-20, said the bulletin is
a step in the right direction.

But it has two major flaws, he said. The timetable essentially gives agencies until
2002 to complete their reviews, which will let agencies continue destroying documents
“without anybody reviewing that process,” Tankersley said.

The bulletin does not provide agencies with any guidance about identifying record
systems that might be permanent, and it does not include criteria to determine whether
records need to be maintained electronically, he said.   

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