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OSWER IMS
Revised Draft
January 31, 1939
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INTRODUCTION
w
hat is the Purpose of This Brochure?
This brochure is the first in a series designed to provide each Office of
Solid Waste and Emergency Response (OSWER) Headquarters and
Regional program office with a framework for establishing and man-
aging a Records Management Program. This brochure is neither a
policy directive nor mandatory guidance. It provides practical and
useful information to all levels of program managers and staff who are
trying to gain control over their records.
The information is presented in a question and answer format
organized in four sections: Introduction, Records Management Over-
view, Program Management Activities, and Records System Phases.
This brochure also includes a flowchart of the Program/Systems
Relationship, a list of useful resource materials, and checklists of
critical Records Management Program (referred to as "Program")
activities and Records System (referred to as "System") activities.
W
ho Will Benefit From Reading This Brochure?
Those most likely to benefit are waste management program manag-
ers and staff trying to cope with records management problems:
specifically:
Managers who need to gain control over program records to
improve the efficiency and effectiveness of their operations.
Staff who want to learn techniques to decrease the time they
spend locating records needed to accomplish their day-to-day-
work, to answer requests for information, and to conduct
special record-intensive tasks such as preparing for litigation.
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RECORDSM^MAGEMENT OVERVIEW _ ....
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W
hat is Records Management?
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the right form, in the hands :Qfitir^:Fjghfr people when they need
the lowest possible cost;, 'Kecostls indtideซbut are iwt limited to,
maps, drawings. L and*phojฎgriaphs. anttiare stored: on media sitchra&
paper, microfilm,1 oc?mj3u!ป6r disks-, optical disks,; and Bound- and YidcOj-
tapes. Records management provides a systematic approaeht&Srf
managing an organization's recorded information and establishes
control over records from the time of their creation through retirement
or disposition. This systematic approach and associated controls \
include such tasks as: . '.;> A to ; -r:^;'^ ' < ' -\ r- c, , , / '
r.'ii ' . ' ' .< ^ ..:'- rf .
Organizing records according to uni/brm clossi/icarion systems
and indexing records to ensuge.
that match their search criteria,-
Establishing circulation control procedures to ensure the integ-
rity of records collections.
Concerting records to appropriate storage media, such as optical
disk or microform, to ensure that records are stored in a cost-
effective manner.
Identifying vital records and storing duplicates of them off-site
to preserve the records that are necessary to restore operations
in the event of a disaster.
Establishing special procedures for handling sensitive informa-
tion to protect these records against unauthorized disclosure.
Establishing records retention schedules to .ensure that an
organization keeps only the information it needs, not everything
it can. Inactive records can then be retired or destroyed on a
routine basis.
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RECORDS MANAGEMENT OVERVIEW
VV hat is a Records Management Program?
~
A Records Management Program is a framework to provide broad
A Records
ts as other Agency -
functions, and it.
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RECORDS-MANAGEMENT OVERVIEW
OSWER System Life Cycle Management Guidance (Directive
9028.00)
OSWER Model Prog ram/or Removal Site File Management (Direc-
tive 9360.2-01) , c :c:ฃ.
EPA Records Control Schedules that define the retention period
and disposition fonthe records in each EPA program,
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Most of the external records management requirements are addressed
and interpreted in the EPA internal publications listed above: -^
hat is a Records System and What is its Relationship
to a Records Management Program? '
As stated earlier, a Records Management Program is! a framework for
controlling all records in the Headquarters or Regional program office
where it is established. Within the overall1 Program framework.
individual Records Systems control specific collections oj records.
Each Records System governs a collection of records using a specific set
of record handling procedures and additional tools (e.g., a data base
that manages information about the records). Ideally, a Records
System is defined broadly enough to include all interrelated records
in the waste management program, (e.g.. a Records System consisting
of facility, site and incident records rather than a Records System
consisting of only remedial site records). However, as a practical
matter, in organizational structures, program priorities and the
physical location of records may result in an organization defining
several Records Systems, each consisting of a subset of records, (e.g.
a Records System consisting of RCRA facility records and a Records
System consisting of CERCLA remedial site records).
A Records System may or may not utilize computer-based technologies.
It can be completely manual (e.g., using a paper medium, file folders
and file cabinets, and a handwritten check-out sheet placed near the
file cabinet for circulation control); fully automated (e.g.. using an op-
tical disk storage medium with a full text search and retrieval data
base system): or somewhere in between (e.g., a data base system that
manages information about records in a paper medium).
Daee 4
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*/toM SO
RECORDS MANAGEMENT OVERVIEW
W,
hy Establish a Records Management Program and its
Individual Records Systems?
There are three general reasons for establishing a Records Manage-
ment Program:
_
To promote efficiency to the ;.w$*tea3iart3tgemeiil staffs retrieval of
recorded information, e.g.,:
Programs experience -staff, turnover and projects are reas-
signed. A filing system that everyone can understand and use
will reduce the time andfrustration spent on trying to understand
widely differing personal filing systems.
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Congressional and Freedom conformation Act (FOIA) requests
for information and public inquiries require prompt response.
Program staff2nฃe^^
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RECORDS-MANAGEMENT OVERVIEW
To guarantee compliance with relevant waste management and
records management laws and regulations, e.g.,:
Program managers must comply with laws specific to the
conduct of the waste management program. A Records System
is designed so that legislatively mandated requirements, such as
compilation of the Administrative Record, are met in a manner
requiring minimal cost'and staff time.
Program managers must comply with laws and regulations
specific to records management, such as the Paperwork Reduc-
tion Act of 1980. A Records Management Program builds in the
controls and procedures required to ensure compliance. - "
w
hat are the Levels of Management Responsibility?
Three levels of management involvement are necessary for a success-
ful Records Management Program: Senior level waste management
Program Management, mid-level Records Management Program
Management, and Records System Specialists. Each of the three
levels plays a distinct role with corresponding responsibilities for the
management of the overall Program. However, a single individual can
fill more than one of the three roles. Descriptions of the roles and
responsibilities follow:
Headquarters/Regional Waste Management Division Manager
(senior level)
Role: Overall Program goal setting and oversight
Responsibilities:
Sets and prioritizes objectives of the Program.
Delegates authority for management of the Program by appoint-
ing a mid-level Records Management Program Manager.
Reviews and approves the budget developed by Records Man-
agement Program Manager and secures funding for the Pro-
gram on an annual basis.
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RECORDS MANAGEMENT OVERVIEW
Provides oversight of the Program through establishing a peri-
odic status update process; during this process, assesses
whether the Records Managemenkjjfcogram sufficiently sup-
ports waste management program goals and priorities.
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Approves high-level PrograjT\policies ajid cross-cutting resource
allocations such as space and ADP support for the Program.
Records-Management Program Manager (mid-level)
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RECORDS MANAGEMENT OVERVIEW
Records System Supervisors
Role: Management of the life cycle of the Records System.
Responsibilities:
Establishes a Records System through overseeing the phases of
the System's life cycle.
Provides input info budgeting and scheduling processes and
maintains the budget and schedule set by the Records Manage-
ment Program Manager.
Superuises the Records System staff
Briefs the Records Management Program Manager on the prog-
ress of the Records System and on Systems concerns/cross-
cutting issues, such as Records System procedures and inves-
tigation of records management technologies.
H
ow Can Contractor Support be Used?
Often, EPA staff resources may be insufficient to implement a Records
Management Program. In such cases, contractor support may be
used to:
Supplement the contribution of waste management program
staff members who may not have sufficient time available to
fully plan and define the Records Management Program.
Augment the skills available internally with specialized exper-
tise in Records System development and implementation func-
tions. Specialized skills my be necessary to perform tasks such
as Records System requirements analyses, user surveys, file
structure design, and implementation support.
Provide the Headquarters or Regional program office with long-
term support for the operation and maintenance of individual
Records Systems.
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RECORDS MANAGEMENT OVERVIEW
While contractor resources can be extremely valuable, managers
must carefully plan for maximum utilization. For example, procure-
ment of contractor support is typically a time consuming process; thus
it is desirable that the senior level program management determine
the initial need for contractor support as early as possible. After the
initiaJ need is identified, management should have staff develop a
Statement of Work (SOW) clearly defining the tasks and products
expected of the contractor.
The timing of contractor support also merits careful consideration.
Contractor support is usually most effective during the Records Man-
agement Program Execution to provide technical assistance on activi-
ties associated with individual Records Systems. Since budget re-
strictions typically constrain the extent to which contractor support
may be applied, management should carefully assess internal capa-
bilities in order to identify when outside assistance can be most
beneficial. Management should reassess the need for contractor
support on an ongoing basis during Program Execution and Review
activities.
Finally, the selection of a specific contract vehicle can require research
and coordination. Existing EPA contracts for records management-
related services may be a viable procurement option. If no such
contracts exist, a new procurement action may be required. Procure-
ment aliemotiues may be discussed with OSWER's Information Man-
agement Staff (OSWER IMS) and the Office oj Information Resource
Management (OIRM's) records management staff.
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PROGRAM MANAGEMENT ACTIVITIES
w
hat are Program Management Activities?
The Program Management Activities section presents the general
activities associated with establishing a Records Management
Program. These activities are:
Planning
Execution
Review
Defining Program goals and objectives.
identifying requirements and preparing
the Program Execution and Review Plan.
Placing all of the Program resources into
action, conducting and managing the
Program on a routine basis.
Systematically examining the Program and
recording benefits and shortcomings to
ensure its continued effectiveness.
H
ow does the Planning Process Begin?
Prior to initiating Program Planning. Headquarters or Regional
management will set the agenda of the Records Management Pro-
gram. Specifically:
Senior level management assigns responsibility for the Plan-
ning, Execution and Review of the Records Management
Program - typically to mid-level managers with waste man-
agement program support responsibilities.
Records Management Program Managers prepare a Program
Planning Plan that outlines the methodology, resources and
schedule to be used in establishing the Program.
page 10
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PROGRAM MANAGEMENT ACTIVITIES
w
hot are the Steps to Prepare a Program Plan?
To prepare a Program Plan, the Program Manager works with sen-
ior management to complete the following tasks and incorporate
the results of each into the Program Plan:
Define the problem-The first step in establishing a new program
is to carefully define the problem needing a solution. This step
usually involves management requesting input from staff at
several levels.
Identify objectives and priorities - As with any other program.
management establishes and prioritizes the goals of the Pro-
gram and communicates these priorities to the staff.
Develop policies - Management defines policies that will clearly
guide Program Execution and Review. From these policies.
procedures for each Records System can be developed.
Analyze Program requirements - Management assigns respon-
sibility for researching legal and administrative requirements
and for analyzing the internal organizational requirements of
the Program.
-Assess staffing requirements and assign responsibility Man-
agement determines roles and responsibilities required to es-
tablish and operate a Records Management Program and
approves a staffing plan.
Establish the budget - Management determines and secures a
source of start-up funding for the Program, and develops and
submits annual budgets to operate the Program and its individ-
ual Records Systems.
Set the schedule - Management establishes the time frame for
the Execution of the Program and the development and review
of its Records Systems.
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PROGRAM MANAGEMENT ACTIVITIES
H
Provide oversight - Management establishes a regular evalu-
ation and monitoring process to assess whether the Records
Management Program sufficiently supports waste manage-
ment program goals and priorities.
ow are the Program's Goals and Priorities Established?
Most offices have established means of identifying goals and priorities
for programs. The following activities outline an approach to estab-
lishing the goals of a Records Management Program:
Identify the most significant short-term (e.g., lack of security for
existing records) and long-term problems (e.g., potentially
incomplete documentation for future cost recovery actions).
Identify broad areas of increased organizational effectiveness
and productivity that could be realized if records were better
controlled (e.g., less professional resources dedicated to an-
swering FOIA requests).
Develop a list of goals for achieving solutions to the identified
problems and need for improved effectiveness (e.g., alleviate
danger of record loss or damage).
Prioritize the list of goals by considering the relative importance,
difficulty and time frame projected for attaining each one.
w
hat Types of Program Policies Should Be Set?
Based on the established goals and priorities and the identified
Program requirements, management develops high-level policies.
These policies establish overall standards for the Records Manage-
ment Program. Their stated purpose may be to:
Ensure the program office's complete compltancewith applicable
page 12
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PROGRAM MANAGEMENT ACTIVITIES
laws and regulations.
Guarantee the protection of records that are vital or important to
the mission of the waste management program office.
Improve the efficiency of the waste management program opera-
tion through the organization of the office's records.
Example policies may include:
Record Use - A policy stating that the record copy of all
programmatic records shall be maintained centrally
Record Protection - A policy defining the different categories of
sensitive information and stating that sensitive records shall be
identified at their creation and protected through appropriate
measures throughout their life cycle.
H
low are Records Management Program Requirements
Determined?
A working group of representative waste management program staff
may be formed to analyze Program requirements. The working group
can be successfully supplemented by contractor support for this
activity. The working group's efforts can include the following
activities:
Perform broad reviews of legal and administrative requirements,
for example, esearch the requirements specified in the Agency
guidance documents discussed earlier. OIRM and OSWER IMS
can provide guidance on specific issues that arise.
Conduct a high level records inventory, specifically, perform a
genera] inventory of the waste management program office's
records holdings. Relevant data includes: categories of records
that exist and their location, format (e.g.. maps), physical
condition, volume and rate of growth, sensitivity.
Establish user profiles through conducting interviews with
representative staff. In this way the working group can gain an
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PROGRAM MANAGEMENT ACTIVITIES
and work flows of the waste management program and estab-
lishes the general needs of categories of staff (e.g.. Remedial
Project Managers) who use records. Relevant tasks include
identifying what records the staff use and how they use them.
where the users are physically located in relation to each other
and to the records, and whether or not the needs of any of the
users are in conflict with each other.
Research information integration requirements for existing sys-
tems, for example, by compiling a list of the existing information
systems that may affect the need for and use of records. Any
requirement for integration between these existing systems and
the Records Management Program is identified.
V\A
hat Types of Resources are Required for the
Program?
Staff, space, equipment, and materials are necessary to implement a
Records Management Program. Management cannot establish a firm
budget on the Program level until it develops the individual Records
Systems comprising the Program. However, management is able to
define the type of resources that will be required and to allocate start-
up Program funding. The types of resource needs to be considered are:
Staffing - Skilled Records Management Program management
and staff are necessary to manage the Program and to oversee
the development and implementation of the individual Records
Systems.
Space - Space is necessary for managing and storing the
records. The current and projected space availability directly
influences the types of Records Systems that can be developed
and how quickly they can be implemented.
Equipment/Materials - Equipment such as file shelving, tradi-
tional file cabinets, record filming and scanning equipment.
and computer hardware may be necessary. Supplies such as
folders and labels are often used. The choice of records
management equipment and materials is very much dependent
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PROGRAM MANAGEMENT ACTIVITIES
on the Records Systems that are developed.
Records Management Technologies - Feasible technological
alternatives to paper, such as microform and optical disk.
appropriate computer software, and integrated record stor-
age and retrieval systems are examples of the types of
technologies that can assist in managing records. Specific
technology choices are dependent on the results of analyses
of Program requirements, individual Records Systems re-
quirements, and the costs/benefits of feasible alternatives.
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PROGRAM MANAGEMENT ACTIVITIES
w
hat is the Program Execution Plan?
The Program Execution Plan is a blue print for the Execution and
Review of the Records Management Program, which includes the
individual Records Systems within the Program. It is based on the
information gathering and decision making that occurred during the
Program Planning process. The plan:
Identifies the Records Systems to be developed as pad. of the
Program.
Defines a schedule of the initial tasks and products that will be
produced to develop the Records Systems.
Provides an initial assessment of the resources required for the
development of Records Systems.
Provides initialforecasting tools for developing budget requests.
Outlines internal and external communication and coordination
links.
Provides the framework for periodic review of the Records
Systems.
The most effective Program Execution Plan also includes details on the
Program's goals and priorities, general policy guidelines and require-
ments. These components of the plan provide a framework for
developing each Records System. Management prioritizes the Rec-
ords Systems to be developed, based on resource availability and the
overall priorities of the waste management program.
w
hat Is the Focus of Program Execution?
The primary focus of the Program Execution activity is the creation
and management of the individual Records Systems included in the
Program. All five phases of a Records System's life cycle occur during
the Execution of the Program Through the activities of the System life
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PLANNING
EXECUTION
PROGRAM MANAGEMENT ACTIVITIES
cycle, the resources that were identified and acquired during Program
Planning are utilized.
w
hat Activities Are Included in Program Execution?
The Records Management Program is executed via a set of carefully
planned activities:
Performing ongoing planning and budgeting.
Prouidinp initial staffing for individual Records Systems.
Facilitating integration among the different Records Systems.
Evaluating the overall performance of individual Records Sys-
tems
Conducting assessments of various technologies and planning
for their utilization.
Establishing internal and external coordination and communi-
cation.
Providing expert technical assistance, either internally or through
external consultants.
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PROGRAM MANAGEMENT ACTIVITIES
W
hy Is Program Review Useful?
After Records Systems have been functioning for a period of time, a
regular assessment of overall Records Management Program perform-
ance should be made to determine whether:
Overall Program performance expectations are being met.
Original Program goals and priorities continue to be applicable.
Individual Systems need to be modified or integrated based on
changes in Program requirements.
Policies and procedures in force are effective in providing Pro-
gram direction.
Additional records management automaton technologies can be
cost-effectively employed.
Resources allocated to the Program are adequate.
Staffing levels and mix are appropriate and effective.
Actual Program costs are within budgeted amounts.
Annual budget requests accurately reflect Program requirements
and are being prepared in accordance with applicable Agency
guidelines.
page 18
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RECORDS SYSTEMS PHASES
Wr
hat are the Phases of the Life Cycle of a Records
System?
The steps in creating a Records System parallel the phases and stages
described in OSWER's System Life Cycle Management Guidance.
Directive #9028.00. The Records System Supervisor oversees the
following phases of activity:
Initiation - Identify the records management problem.
Concept - Analyze the problem to produce a high-level, compre-
hensive model of its solution.
Definition and Design - Prepare detailed descriptions of the
requirements of the Records System and a detailed System
design that fulfills those requirements.
Development and Implementation - Build and install the Rec-
ords System.
Operation (including Production, Evaluation and Archiving) -
Make the Records System fully available to the users and
evaluate it. modify it and terminate it as necessary.
Many of the tasks associated with each phase can be successfully
carried out using contractor support. Contractor activities should be
evaluated against the overall goals, budget, and schedule of the
Program Execution Plan.
H
ow is a Records System Initiated?
A Records System is initiated through the preparation of a Project Plan.
The Project Plan for the System serves the same function as the
planning plan developed for the Program. It identifies a records man-
agement problem and describes the methodology and resources to be
used to further the analyze the problem. The purpose of the Initiation
Phase is to identify the records management problem to be solved, with
a focus on the pertinent information, organizations experiencing the
problem, timeframe available for establishing the solution, and overall
value of the solution.
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RECORDS SYSTEMS PHASES
H
low is the Project Plan Put into Action in the Concept
Phase?
The Concept Phase provides a high-level, comprehensive model of the
solution to the records management problem. The following activities
comprise the specific steps of the Concept Phase:
Conduct requirements analyses to determine legal and admin-
istrative, user, functional and performance requirements.
Perform inventory of record collection holdings to compute record
volume, estimate record volume growth, classify the types of
records, and estimate the degree of activity for each record type.
The purpose of this information is to determine how categories
of records are used, how they relate to each other, and how long
they need to be maintained in accessible active and inactive
storage.
Analyze Records System options, including: centralization or
decentralization; storage media (e.g.. microfilm); use of technol-
ogy; and type of space, staff. ADP support, equipment and
resources that are necessary. The identification process in-
cludes cost/benefit analyses of each set of options that meet the
requirements (e.g., one set of options may be a centralized
records storage room for paper records with an accompanying
data base system).
Choose the best Records System, based on the cost/benefit
analyses of the feasible alternatives, and the goals and objec-
tives of the overall Records Management Program.
page 20
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RECORDS SYSTEMS PHASES
tance of each type of record and deciding on the best method of
preservation is the first step toward developing a disaster
recovery plan during the Development and Implementation
Phase.
Record Protection - The Records System Supervisor defines the
System capabilities necessary to prevent theft or intentional
destruction of all records in the System. In addition, specialized
requirements to protect categories of sensitive records (e.g..
enforcement sensitive) are also identified.
Record Retention and Disposition - Operating, administrative.
fiscal, legal and historical requirements all affect the length of
time that records need to be retained. Each type of record
within the Records System needs an individualized retention
(i.e.. how long it should be kept) and disposition (i.e.. when it can
be archived or destroyed) schedule. The retention and disposi-
tion schedules have an impact on the System's cost because
they affect the amount of active and inactive storage that the
System requires. After the schedules are initially established.
they are reviewed and updated periodically.
hat Are the Components of the Records System
Design?
The System Design is based on the overall Concept of the Records
System, and reflects the resource and functional capabilities required
by the System. The Design is of a picture of how the System will work.
The primary components of the Records System design are:
File Structure - Regardless of the level of automation chosen, the
organization of the records is one of the most important
elements of the System. The key to structuring the records is
to consider how they will be used. Most record collections in the
waste management programs are comprised of groups of rec-
ords relating to specific activities (e.g., in the RCRA program.
the permitting activity creates different records than corrective
1: ' 'J
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RECORDS SYSTEMS PHASES
action activity). Since most of the records are used for activity-
specific information, the file structure often mirrors these
activities. Each major section of the file structure is subdivided
into several functional categories (e.g., technical reports and
correspondence). In some cases, these categories may be
divided further depending on the volume and complexity of the
records.
Procedures -To ensure that the Records System fulfills all of the
defined functional capabilities, the Records System Supervisor
develops procedures governing use of the Records System.
Examples of the types of procedures to be developed include:
- File Maintenance - Procedures must be set detailing how the
Records System staff and program staff handle the records
on an ongoing basis.
- File Circulation - How records are checked in and out is
the basis for the file circulation procedures. These proce-
dures define methods for program staff to check out and
return files.
- Non-Standard Records (e.g.. duplicate, draft, oversized
and informal records) - Every Records System requires
procedures to integrate non-standard records into the
Records System.
- Vital Records - Specialized procedures for handling vital
records may need to be established to ensure that these
records are protected from the point of creation onwards.
- Sensitive Information - Special procedures must be estab-
lished for sensitive information (e.g., enforcement sensi-
tive or CBI). A security officer should be identified to
maintain the protocol for access to this information.
Data Base System - If a data base system is chosen, the file
structure is designed in conjunction with the design of the
data base.
page 24
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