EPA220-F-92-014
           Response to the
    National Archives and Records
Administration (NARA) Evaluation of
EPA's Records Management Program
              ftttfe
                 July 1992

        National Records Management Program
            Information Access Branch
      Office of Information Resources Management
        U.S. Environmental Protection Agency
               401 M Street, SW
             Washington, DC 20460

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     sr., f
       *>
                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON, D.C. 20460
                                       JUL -1  1992
                                                              OFFICE OF
                                                            ADMINISTRATION
                                                            AND RESOUCES
                                                             MANAGEMENT
Mr. James  W.  Moore
Assistant  Archivist  for  Records
  Administration
National Archives and  Records
  Administration
Washington, D.C.  20408

Dear Mr. Moore:

     This  letter transmits  the Environmental  Protection
Agency's  (EPA's) response to the  National  Archives and
Records Administration (NARA) evaluation of EPA's records
management program.  We  appreciate  the  effort of the NARA
staff  in conducting  the  evaluation  as well as their offers of
continued  support for  our program as we begin implementing
the recommendations.   We look forward to working together to
resolve the issues identified in  the evaluation.

     Our response package consists  of three parts: the
Executive  Summary, which provides an overview of our
implementation strategy; the Agency's Recommendation and
Actions Matrix, which  provides actions  and milestones for
each recommendation; and individual Implementation Plans for
each major Headquarters  program,  Regional  Office,  Laboratory,
and field  facility.  Since  many of  the  recommendations
concern how Agency policy is implemented,  these  program
implementation plans are in many  ways the  most important part
of the package.  A few programs are still  preparing their
plans and those will be  forwarded to you as soon as they are
completed.

     Overall, we agree with the recommendations  in the
evaluation.  They are  consistent  with our  own findings and
provide us with a framework for improving  our records
management program.    In a  few instances,  we  do  have concerns
about implementing the recommendations  on  an  Agency-wide
basis.   We have presented our interpretation  of  how the

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                           -  2  -
 recommendations  should  be  implemented' in the Executive  •
 Summary.   We  would be pleased  to discuss our approaches  after
 you  have  reviewed our response package.

      Our  goal is to  have  the  recommendations implemented in
 most  Agency programs by the end of FY95.  As you will note in
 the  attached  action plans, many of the recommendations either
 have  been  or  are being  addressed.  To date, we have made the
 most  progress in implementing  the recommendations concerning
 communication, policy,  and awareness which were implemented
 by our Office of Information Resources Management.

      Other recommendations will require extensive fact
 finding,  consultation,  and coordination within the Agency and
 will  take  longer to resolve.  The approach we have taken for
 those recommendations is to provide a detailed set of
 milestones for FY93, and general goals for future years.
 Specific  steps to meet  the goals will then be completed  on
 an annual  basis.

      I recognize the importance that a strong records
 management program plays in the efficient operation of the
 Agency's management of  its information.  A key recommendation
 in your report is to improve the communication of records
 management responsibilities to all employees.  To show my
 support of the effort,  I will use the evaluation report  as an
 opportunity to remind all staff of their role in the Agency's
 records management program.

      We look  forward to your comments on our implementation
 plans, both the  Agency-wide plan and the individual program
 plans.  We view  these plans as living documents,  subject  to
 revision and  refinement based on your comments and our
 experience, in implementing the recommendations.   If you have
 any questions, please contact Michael Miller,  Agency Records
 Officer,  on (202) 260-5911.
                             Sincerely,
                             Alvin Pe'sachowitz,  Director
                             Office of Information Resources
                               Management
Attachments

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                   ; ^  ^ \ ^'   % ^ ••         ,.      •--.•-•?
                  Executive Summary
      This report provides a response to the evaluation performed by the
National Archives and Records Administration (NARA) of the Environmental
Protection Agency's (EPA's) records management program during Fiscal Year
(FY)1990. Overall, EPA finds the report to be an accurate depiction of the
challenges that the Agency's records management program is facing and is in
agreement with the recommendations provided by NARA for addressing these
challenges.

      More specifically, NARA provided EPA with 36 recommendations which
cross the records management spectrum.  For the purposes of facilitating a
response to the report, EPA has classified these recommendations into five
categories:

      •     Overall Program Management - Those recommendations addressing
            program-wide issues, such as advocating establishment of a records
            management liaison network.

      •     Creation and Maintenance - Those recommendations that address the
            creation of a record or the process of maintaining that record at the
            Agency.

      •     Records Disposition - Those recommendations that suggest
            improvements in the process of retiring or disposing of .records.

      •     Specific Categories - This category includes all recommendations that
            address specific categories of records, such as Superfund or
            contractor records.

      •     Electronic and other Nontextual Records - Recommendations that
            address records created in an electronic, audiovisual, or other
            nontextual format.

      Addressing and implementing recommendations in each of these areas
will require long-term changes and improvements in EPA's records management
program. Implementing these improvements will require EPA to take actions in
three primary areas:

      •     Improving Policy and Guidance - This area involves the need for
            either updating or issuing new records management policy and/or
            guidance.

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 Executive Summary
       •     Communicating Policy and Regulations Clearly - Actions in this area
             require the communication of existing policies or regulations either
             to specific parties or throughout the Agency.

       •     Improving Operational Performance - Actions in this category are
             targeted at improving operations in the records management arena.

The graphic on the following pages illustrates, for each of N ARA's
recommendations, the areas in which actions will need to be taken.

       The Office of Information Resources Management (OIRM) within EPA,
more specifically, the National Records Management Program (NRMP) will
provide leadership in carrying out many of these recommendations through its
primary responsibilities of planning, issuing policy and guidance,
communicating requirements, conducting performance evaluations and reviews,
and providing technical assistance and training. Actual implementation of these
recommendations will be the responsibility of program and other administrative
offices throughout Headquarters, the Regions, and the Laboratories due to the
need to improve operations and to establish new functions and programs.

       OIRM  is drafting a revised basic policy statement and developing new
policy directives to clarify roles and responsibilities and address the issues set
forth in the NARA report, as well as those regulations mandated by other Federal
agencies. Additionally, an Agency-wide series of guidance manuals will be
issued by OIRM. Based on Agency policy, they will provide additional direction
and a framework for implementing required Federal regulations, and N ARA's
recommendations.

       As an additional effort to communicate records management
requirements, and specifically discuss the recommendations set forth in the
NARA report, OIRM held a working meeting attended by 35 records
management officers in Chicago. OIRM, along with the records management
officers, reviewed all phases of the NARA report and discussed the need for
cooperation and understanding program priorities when implementing the
recommendations.  To follow-up on feedback received at the meeting, OIRM will
be issuing basic records management guidance to support Headquarters',
regional and laboratory efforts to initiate activities pursuant to the NARA report.

      All recommendations are targeted for completion prior to/or during FY
1995.  In fact, many recommendations have been addressed already through
corrective actions taken at EPA. Others are targeted for near-term
implementation based on feasibility in the short term and their ability to effect
significant improvement within EPA's records management program. The
remaining recommendations will be implemented over the next several years as
is feasible and appropriate.

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                                           Response to NARA Evaluation
Summary of Implementation Approach
      In each of the five recommendations categories, EPA is planning to take
specific actions to address the issues raised in the NARA report. A summary of
these actions, by recommendations category, is presented below along with a
discussion of the responsible office and a time table for undertaking the
particular action.  A matrix, which discusses specific actions relative to each
recommendation, is contained in the next section.

      Overall Program Management

            Eight recommendations were placed in the Overall Program
      Management area. These recommendations involve increasing
      communication amongst records managers in the Agency, establishing
      accountability for records functions, enhancing training, and
      implementing regular internal evaluations.  Addressing these
      recommendations will require EPA to take actions in three areas:
      improving policy and guidance (1 recommendation), communicating
      policy and regulations clearly (5 recommendations), and improving
      operational performance (4 recommendations).

            OIRM will be the lead office for all of the recommendations
      requiring policy improvement and clearer communication.  The Office of
      Research and Development combined with the Assistant Administrators
      (AAs), Regional Administrators (RAs), and  the Lab Directors will be
      accountable for recommendations requiring operational improvements.

            With respect to four of these recommendations, EPA  has already
      taken actions to address the relevant issue.  Specifically, OIRM has
      developed a records management liaison network that increases lines of
      communication at Headquarters and the Regions (recommendations 1-1,
      1-5, and 1-8).  Additionally, OIRM has carried out its plans to develop and
      offer formal records management training courses as specified in the
      report (recommendation 1-6) and has expanded records management
      briefings for senior staff (recommendation 1-8).  The recommendations
      will be implemented over time beginning in FY 1992 with targeted
      completion dates during or before FY 1995.  However, we would like to
      clarify our interpretation of recommendation 1-3 concerning the need for a
      full time employee (FTE) which  we take to mean an Agency employee and
      not a contractor.  Although Agency programs are increasingly turning to
      FTE  to staff such positions, the process is a gradual one.  Some programs
      may choose initially to staff the position with adequately qualified
      contractors supervised by Delivery Order Project Officers experienced in
      records management issues. We find this an acceptable alternative to an
      FTE, given the scarcity of Agency resources.

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RECOMMENDATIONS OVERVIEW
Categories
of
Recommendations
t. OVERALL PROGRAM
1-1 Increase headquarters and regional lines
of communication
1 -2 Establish oversight for laboratories
1-3 Establish trained full time records officers in
every major EPA office
1 -4 Appoint local officers at all sites with
sufficient time
1 -5 Develop active records liaison network
1 -6 Carry out plans for training courses
1 -7 Implement a program of regular internal
evaluations
1-8 Expand briefings for senior staff
2. RECORDS CREATION AND
MAINTENANCE
2-1 Provide basic recordkeeping requirements
for EPA
2-2 Develop recordkeeping requirements
for specific programs based on Superfund
practices
2-3 Use these requirements to monitor mission
critical programs
2-4 Review case filing procedures
2-5 Make mandatory the administrative systems
file classification system
2-6 Inform and designate program offices of file
station requirements
2-7 Eliminate personal filing systems and
duplicate records
2-8 Implement file cutoffs for manageability
2-9 Examine policy on storage to ensure
maximum use of the FRCs
2-10 Implement an Agency wide vital records
program
Actions for Improvement
Improve Communicate Improve
Policy Policy and Operational
or Guidance Requirements Performance
More Clearly







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RECOMMENDATIONS OVERVIEW
Categories
of
Recommendations
1 RECORDS DISPOSITION
3-1 Inventory records, revise schedules and
identify custodian, particularly for
permanent records
3-2 Organize schedules into a comprehensive
records manual
3-3 Review revised schedules annually
3-4 Conduct campaign to apply these
schedules
3-5 Inform employees of policy and law on
disposition
3-6 Re-examine Green Border for schedule
approval
4. SPECIFIC RECORDS
4-1 Re-examine schedules for Superfund
records
4-2 Continue to consider alternate storage
media
4-3 Develop more rigorous case file
requirements for NPL
4-4 Inspect all facilities housing Superfund
site files
4-5 Increase EPA oversight of Superfund
records program
4-6 Develop Agencywide strategy for
oversight of records managed by
contractors
5. ELECTRONtC AND OTHER NONTEXTUAL
RECORDS
5-1 Revise and expand existing electronic
- record guidance
5-2 Take recommended steps to improve
disposition of electronic records
5-3 Include electronic record guidance in
training
5-4 Issue and implement a policy affirming
disposabilrty of paper records once
microfilmed
5-5 Inventory audiovisual records
5-6 Develop program for managing audiovisual
records
Actions for Improvement
Improve Communicate Improve
Policy Policy and Operational
or Guidance Requirements Performance
More Clearly






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Executive Summary
      Program managers have the final responsibility in determining the best
      way to utilize both contract staff and FTE to accomplish their mission, so
      that how, and how quickly, this recommendation is implemented, will
      vary from program to program.

      Records Creation and Maintenance

            Ten recommendations fall into this category. These
      recommendations suggest the need for:

            •      Additional guidance on recordkeeping and storage
                  requirements

            •      Communication of records creation and maintenance
                  policies

            •      Mandatory use of guidelines

            •      Implementation of vital records program procedures.

      To implement these recommendations, actions will need to be taken in the
      areas of improving policy and guidance (5 recommendations), enhancing
      communications (4 recommendations), and improving operational
      performance (5 recommendations).

            OIRM will be the lead office for creating and issuing Agency-wide
      policy and guidance and for communicating this policy and guidance,
      where appropriate. As discussed in recommendations 2-4 and 2-5, OIRM
      will provide some general guidelines for filing procedures and
      classification systems, (i.e., using 'ENF as an Agency-wide code for
      enforcement files) in order to streamline operations and accommodate
      record retrieval.  However, due to the diversity of Agency activities and
      unique filing needs and records maintained in individual offices, each
      program will be responsible for developing more detailed guidelines on
      their own filing procedures and classification systems. The AAs, RAs, and
      Lab Directors will develop the necessary program-specific guidance and
      improve current operational practices, including identifying and
      maintaining vital records and measuring overall progress against
      requirements.

           These recommendations will also be implemented over the next
      several years.  In FY1992, EPA will address the recommendations
      requiring Agency-wide policy. In FY 1993, program-specific policy will be
      developed, and policies will be communicated. During FYs 1994 and
      1995, implementation of the operational improvements will be

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                                      Response to NARA Evaluation
 emphasized, particularly with respect to improving records creation and
 maintenance in preparation for the 1995 Headquarters move.

 Records Disposition

      The Records Disposition category has 6 recommendations which
 focus on inventorying records, revising disposition schedules, and
 encouraging use of the disposition schedules. A further recommendation
 suggests examination of ways to improve the schedule review and
 approval process.  Addressing these recommendations will require EPA to
 improve policy and guidance (1 recommendation), to communicate policy
 and guidance clearly (4 recommendations), and to improve operational
 performance (3 recommendations).

      With respect to issues requiring policy and enhanced Agency-wide
 communication, OIRM will be the lead office. Program-specific
 communications as well as implementing other operational improvements
 will be the primary responsibility of the AAs, RAs, and Lab Directors.

      OIRM has developed the basic steps to address these
 recommendations, which include: surveying records, revising schedules
 in a new format, reviewing schedules and adding additional items, and
 finally, inventorying records using revised schedules, which allow the
 addition of additional items if needed. These recommended activities will
 need to occur in a logical progression beginning in FY 1992 with  an
 examination of the schedule review and approval process. The remaining
 recommendations will be addressed in sequential order starting with the
 records inventory, followed by revision, communication, and
 implementation of the schedules occurring in FY 1993 through FY 1995.

 Specific Records

      The Specific Records category includes six recommendations.
These recommendations focus on improvements to Superfund records
maintenance and disposition practices as well as oversight of contractor
records. To address these recommendations, EPA will need to improve
policy and guidance (1 recommendation) and enhance operational
performance (5 recommendations).

      With the exception of development of an Agency-wide strategy,
which is OIRM's responsibility, all recommendations in this category
require the leadership of the Office of Solid Waste and Emergency
Response (OSWER).

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Executive Summary
            Many of these recommendations are either already being addressed
      or can be addressed in the short term. For example, the potential of
      alternate storage media is already being examined in the Superfund
      Program. All other recommendations requiring improvements in
      operational performance are targeted for implementation in FY1992. The
      recommendation to encourage initiation of a program to inspect all
      facilities housing Superfund site files is targeted for FY 1993.

      Electronic and other Nontextual Records

            Seven recommendations fall into this category. These
      recommendations highlight the need for additional guidance on electronic
      records, revised disposition schedules, training on electronic records, and
      creation of a program for managing audiovisual records.  Implementation
      of these recommendations will require EPA to take action to: improve
      policy and guidance, enhance communications, improve operational
      performance, and establish new programs.

            OIRM will provide leadership in all areas related to electronic
      records with the assistance of the AAs, RAs, and Lab Directors when
      addressing disposition of electronic records. OIRM plans on conducting
      the disposition and scheduling of electronic records in a three phased
      approach beginning with the major information systems identified by the
      NAP A project and GSA. Next, information systems sponsored by
      Headquarters programs will be scheduled in conjunction with their
      textual records.  Finally, the regionally based systems will be scheduled.
      EPA's Office of Communications, Education, and Public Affairs (OCEPA),
      which already provides the Agency with audiovisual expertise, will  serve
      as the lead for inventorying audiovisual records and developing a new
      program to manage these records.

            These recommendations are also targeted for implementation in the
      near term due to their potential for effecting significant improvements in
      the current management of these records. The policy issues will be
      addressed beginning in FY 1992, followed by the inventory, and the
      development of training and new programs. As with all other
      recommendations, those in this category are targeted for complete
      implementation by FY 1995.

Overall Implementation Approach

      The previous section provided a summary of how EPA plans to address
NARA's recommendations, the office that is accountable for implementation, and
the time frame involved. The matrices contained in the next section provide
further detail on the specific actions planned for each recommendation, and any
                                   8

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                                             Response to NARA Evaluation
already completed actions that address the recommendation. Additionally, the
matrices indicate the overall Agency goals and a target implementation date for
each activity. When applicable, OIRM requirements for Headquarters, Regions,
and Laboratories have also been included with their target implementation dates.
The target implementation, or completion dates have been estimated on a
quarterly basis through FY1993. During the third quarter of FY 1993, the
planned implementation dates for FY 1994 and 1995 will be adjusted to reflect a
quarterly schedule. Finally, attached to the matrices are the specific
implementation plans that were submitted to OIRM by Headquarters, Regions,
and Laboratories. These plans are the original, unaltered submissions, and some
contain more detail than others. This is due to the varying lengths of time
individual offices have been engaged in records management practices. In the
event that some action plans have not been received by OIRM prior to
submission of this response, they will be sent to NARA under a separate cover
following their receipt.

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                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
  QVERAtll RRQQBWMiiMANAGEMENT
 1-1
Increase records management contact between
headquarters and regional records management, head-
quarters records management and program offices, and
regional records management and regional program
offices. Regular and systematic lines of communication,
both written and oral, need to be established for providing
current information on agency initiatives and activities in
records management, supplying the most current NARA
and agency guidance, and receiving feedback on
problems encountered in implementation. The purpose
is to ensure that:

 a. all EPA records managers are aware of current records
   management policies, procedures, and regulations.
OIRM has established a program
and network to improve
communication. Will also be
carried out in relation  to
recommendation 1 -5.

OIRM:
Established records network
in Regions

Established network in HQ and
holding bi-monthly meetings; will
be held monthly in September

Established network in Field
Offices and Laboratories

Transmitted copies of all
policies, procedures, and
regulations to primary
contacts in all major programs

Held Agencywide and HQ
records management meetings
in FY 91 and FY 92

Established bi-monthly Records
Management newsletter
                   FY92
                    FY91
                    FY92
                                                                                                            FY92
                                                                                                            FY92
                                                                                                            FY92
                                                                                                            FY92
                                                         10

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                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-1
Increase records management contact between
headquarters and regional records management, head-
quarters records management and program offices, and
regional records management and regional program
offices. Regular and systematic lines of communication,
both written and oral, need to be established for providing
current information on agency initiatives and activities in
records management, supplying the most current NARA
and agency guidance, and receiving feedback on
problems encountered in implementation. The purpose
is to ensure that:

 b.  all EPA program offices are aware of and comply with
    records management policies, procedures, and regula-
    tions as they pertain to their respective program records.
OIRM con't.
Established weekly messages
for primary contacts in all
programs to provide
updates on records management
issues

Established bi-monthly teleconfer-
ences with Regional and field
offices

HEADQUARTERS:
All programs must establish a
plan for making their personnel
aware of policies, procedures
and regulations; compliance will
be discussed in recommenda-
tion 1-7

See attached plans

REGIONS:

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached plans
  3rd QTR
   FY93
                    FY92
                    FY92
                                                         1 1

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                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-2
Establish mechanisms to ensure that the provisions of
recommendation 2-1 b are implemented at all EPA,
laboratories. The laboratories must receive regular
records management oversight and guidance similar to
other EPA components. For research and development
laboratories that are not under the jurisdiction of the
regional offices, active oversight must come from
headquarters.  Because laboratories are often not
co-located with other facilities, special efforts must be
made by records management officers to establish
regular oral and written contacts with the laboratories
and to provide on-site support as necessary.
ORD to improve operational
performance

OIRM:
Identified records contacts
in labs and field offices

Providing records management
guidance and procedural
materials

ORD:

ORD must respond-
See attached plans
                                                        REGIONS:

                                                        Regions must respond for ESD-
                                                        See attached plans
                                                        LABORATORIES:

                                                        All labs must respond-
                                                        See attached plans
   FY93
                                                                                            FY93
                                    FY93
                    FY92
                    FY92
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                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-3
All regional records management officer positions should be
made full time to ensure proper oversight of the agency's
records management program. Ultimately, there should be a
trained, full-time records officer in every region and in major
program offices such as Assistant Administrators Offices, the
General Council, and the Inspector General. Because these
staff members will have substantive documentation respon-
sibilities and will be responsible for training, evaluations,
assistance with the system development and other related
activities, they need to be people with appropriate skills and
seniority.
AAs and RAs to improve
operational performance.
To be completed over time,
showing continual improvement.
Will be caried out in relation to
recommendation 1 -4.

OIRM:
Guidance on staffing contained in
Regional Records Management
Procedures Manual

OSWER and OIRM
conducting a study on
records management positions

Additional guidance on
staffing to be produced

OIRM to work with OSWER on
position description

HEADQUARTERS:

All programs must respond-
See attached plans

REGIONS:

All regions must respond-
See attached plans
  FY95
                                                                                          2nd QTR
                                                                                            FY93

                                                                                           3rd QTR
                                                                                            FY93
                                                                                            FY95
                                                                                            FY95
                    FY92
                                                                                                             FY92
                                                         13

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                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-4
Implement the instructions of Chapter 1 of the Records
Management Manual, paragraph 10 a(2) by appointing local
records management officers at all sites throughout the
agency.  In accordance with this regulation, these records
management officers must have appropriate status
(grade and position) and sufficient time to devote to
the program.
AAs, RAs, and Lab Directors to
improve operational performance.
To be completed over time,
showing continual improvement.
Will be carried out in rela-
tion to recommendation 1-3.

OIRM:
OIRM to issue policy directives
and guidance clarifying roles
and responsibilities; to be
implemented by Headquarters,
Regions and Laboratories

Interim  guidance to be issued

Policy directive to be  issued

Individuals have been
nominated for positions

Programs provided guidance
on determining positions

HEADQUARTERS:
Individuals have been
nominated for positions

Positions to be brought into
compliance with regulations

All programs'must respond-
See attached plans

  14
  FY95
                                                                                            FY93
                                                                                           IStQTR
                                                                                            FY93
                                                                                           IStQTR
                                                                                            FY94
                                                                                            FY95
                                                                                                             FY92
                                                                                                             FY92
                                                                                                             FY92

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                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1 -4 cont.
Implement the instructions of Chapter 1 of the Records
Management Manual, paragraph 10 a(2) by appointing local
records management officers at all sites throughout the
agency.  In accordance with this regulation, these records
management officers must have appropriate status
(grade and position)  and sufficient time to devote to
the program.
REGIONS:
Individuals have been
nominated for positions

Positions to be brought into
compliance with regulations

All regions must respond-
See attached plans

LABORATORIES:
Individuals have been
nominated for positions

Positions to be brought into
compliance with regulations

All labs must respond-
See attached plans
  FY95
                                                                                           FY95
                   FY92
                                                                                                            FY92
                                                         15

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                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-5
After implementing recommendation 1-4, develop an
active records liaison network to assist records
management officers in administering the program
by coordinating local records management activities.
OIRM has established a
network to improve
communications and
coordination. Will be carried
out in relation to
recommendation 1-1.

OIRM:
See recommendation 1-1 for
actual steps

HEADQUARTERS:
AA offices shall designate
liaisons at office level

AA offices shall designate
liaisons at division level

All programs must respond-
See attached plans

REGIONS:
Regions shall designate
liaisons at division level

Regions shall designate
liaisons at branch level

All regions must respond-
See attached plans

LABORATORIES:
All labs must respond-
See attached plans	
  16
                   FY92
                                                                                         IStQTR
                                                                                          FY93

                                                                                         4th QTR
                                                                                          FY93
                                                                                         1st QTR
                                                                                          FY93

                                                                                         4th QTR
                                                                                          FY93

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                                        Recommendation and Action Matrix
                   Recommendation
           Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
 1-6
In addition to continuing to make use of courses provided
by NARA, carry out the current plans to develop and
offer a formal series of records management training
courses for all employees with records-related respon-
sibilities including records management officers and
liaisons at all levels as well as records custodians.  The
courses, which can be developed internally or on
contract, should be given on a regular schedule both
at headquarters and in the regions and should be
tailored to meet the specific records maintenance and
disposition issues faced by EPA headquarters, regional
offices  and other special'facilities such as laboratories.
The courses need to provide  information about the
management of non-textual material such as electronic
and audiovisual records as well as textual records.
OIRM is implementing
training plans

OIRM:
General course on records
management fundamentals,
and records retirement provided

Course on file plans and filing
to be developed

Electronic records course
to be developed

Non-textual records
course

Training to be offered at
Agency-wide conferences
beginning FY 93
 2nd QTR
   FY93

 2nd QTR
   FY93

 2nd QTR
   FY94

 3rd QTR
   FY93
                    FY91
                                                           17

-------
                                       Recommendation, and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-7
Implement a program of regular internal records and
information evaluations as required by Chapter 1 of the
Records Management Manual, paragraph I0c(l)c.
Evaluations, broken down by offices, regions, and/or
programs, should be done on a rotating basis, so that
all major components are evaluated on a three to five
year cycle. Staff knowledgeable about and involved in
the creation and management of electronic and audio-
visual records need to be included, as appropriate, on
the evaluation teams. The evaluation process should
include specific recommendations and mechanisms for
follow-up to ensure that these recommendations are
implemented.
Evaluation program
will follow Chapter 1
Records Manage-
ment Manual. To be
completed over time
in context of established
responsibilities.
Actions will be tied to
other existing management
reviews such as GSA
Triennual Review and OMB
Productivity Improvement
Initiatives. Will be carried
out in relation to
recommendation 2-3.

OIRM:
Develop policy framework for
evaluation

Develop basic guidance for an
evaluation program

Test pilot program
                                                        Begin regular cycle of evaluations

                                                        HEADQUARTERS:
                                                        All programs must respond-
                                                        See attached plans
   FY94
  4th QTR
   FY92

  3rd QTR
   FY93

  1st QTR
   FY94

  3rd QTR
   FY94
                                                         18

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-7cont.
Implement a program of regular internal records and
information evaluations as required by Chapter 1 of the
Records Management Manual, paragraph 10c(1)c.
Evaluations, broken down by offices, regions, and/or
programs, should be done on a rotating basis, so that
all major components are evaluated on a three to five
year cycle. Staff knowledgeable about and involved in
the creation and management of electronic and audio-
visual records need to be included, as appropriate, on
the evaluation teams. The evaluation process should
include specific recommendations and mechanisms for
follow-up to ensure that these recommendations are
implemented.
REGIONS:

All regions must respond-
See attached plans
LABORATORIES:

All labs must respond-
See attached plans
                                                         19

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 1-8
Continue and expand the practice of offering records
management briefings for all senior officials and
program managers.  The briefings should be offered
in the field as well as headquarters.  They should focus
on the records responsibilities of managers, the legal
requirements that records management programs are
designed to meet, and the considerable benefits to the
agency and to individual programs of effective and
efficient records management.
OIRM and selected AAs,
RAs, and Lab Directors have
instituted ongoing briefings.

OIRM:
Eight Regions and Cincinnati
briefed in 1991 and 1992

Senior IRM Officials at HQ
briefed in 1992; will continue

Individual programs are being
briefed on an ongoing basis
about one every month

HEADQUARTERS:
Each program is to institute
a program of regular management
briefings
See attached plans

REGIONS:
Each office is to institute
a program of regular management
briefings

See attached plans

LABORATORIES:
Each unit is to institute
a program of regular management
briefings   	

See attached plans	
 20
                                                                                           3rd QTR
                                                                                            FY93
                                                                                          3rd QTR
                                                                                            FY93
                   FY92
                   forward
                    FY92
                    FY92
                   forward

                    FY92
                   forward

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
2. RECORDS CREATION AND MAINTENANCE
 2-1
Develop at headquarters and disseminate throughout the
agency basic recordkeeping requirements for EPA.
These requirements should incorporate the guidance
provided by NARA, modified for the specific needs and
situation in EPA. The guidance should cover the
following areas:

 a. specific instructions on the management of special
   records. (NARA guidance for audiovisual records is
   found at 36 CFR Part 1232; for micrographics at
   Part 1230 and for electronic records at Part 1234.)

 b. a fuller explication of the definition of record and
   of non-record material, along with guidance on
   applying these definitions within EPA. (NARA
   guidance on identifying Federal records is found at
   36 CFR 1222.34.)

 c. instructions on identifying personal papers, directed
   specifically toward senior agency officials and
   scientists and other researchers. (NARA guidance
   on identifying personal papers is found at 1222.36.)
OIRM to revise Record
Management Manual.
Will be carried out in relation
to recommendations 2-7, 5-1
and 5-4.

OIRM:
OIRM newsletter, INFO ACCESS,
contains issues on special
records
Draft completed FY 92; review
in process

Fuller guidance to be issued
Devoted issue of INFO ACCESS
newsletter to personal papers

Willl issue basic policy statement
on personal papaers

Will use materials currently being
drafted by NARA and modify to
meet Agency needs

Headquarters, Regions and Labs
to disseminate,information
within 6 months of receipt
 FY 93-94
  3rd QTR
   FY93

   FY94
  1st QTR
   FY93

  3rd QTR
   FY93
                    FY92
                    FY92
                                                          21

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
2-2
Based on the recordkeeping requirements in place for
the Superfund program, develop recordkeeping
requirements for other EPA programs and record
systems to ensure adequate documentation for both
immediate and longer term purposes. The first priority
should be ensuring that creation and maintenance of
records that protect the financial, legal, and other rights
of the Government and of persons directly affected by
its actions.
AAs, RAs, and Lab Directors
to issue guidance. To be
completed over time. Will
be carried out in relation
to recommendation 5-1.

OIRM:
Will meet with NARA to obtain
guidance on recordkeeping
requirements

Will issue guidance on
developing recordkeeping
requirements

Will develop a basic list of series
warrenting requirements

HEADQUARTERS:
Programs to identify
appropriate records series and
then establish timeframe for
accomplishment.

Programs to develop
requirements

All programs must respond-
See attached plans
   FY93
  forward
 .4th QTR
   FY92
                                                                                          1st QTR
                                                                                           FY93
                                                                                          3rd QTR
                                                                                           FY93
                                                         22

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
        Improvement
 Planned
Completed
  Actual
Completed
2-2 cont.
Based on the recordkeeping requirements in place for
the Superfund program, develop recordkeeping
requirements for other EPA programs and record
systems to ensure adequate documentation for both
immediate and longer term purposes. The first priority
should be ensuring that creation and maintenance of
records that protect the financial, legal, and other rights
of the Government and of persons directly affected by
its actions.
REGIONS:

All regions must respond-
See attached plans
LABORATORIES:

All labs must respond-
See attached plans
                                                        23

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 2-3
As part of EPA's internal evaluation program, use these
recordkeeping requirements as a tool for monitoring
mission critical programs to ensure that all necessary
records are created, and that they  are properly
controlled and protected.
AAs, RAs, and Lab Directors
to monitor mission critical
programs through eveluation.
To be completed over time.
Can be carried out in relation
to recommendation 1-7.
                                                      HEADQUARTERS:

                                                      Programs will comply
                                                      See attached plans
                                                      REGIONS:

                                                      Regions will comply
                                                      See attached plans
                                                      LABORATORIES:

                                                      Labs will comply
                                                      See attached plans
  FY93
  forward
                                   FY94
                                   FY94
                                   FY94
                                                       24

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
  Planned
 Completed
  Actual
Completed
 2-4
Review agency case filing procedures. Begin with a
single category of case file, for example, permit files.
Determine how the various types of permit files are
maintained in each region. Based on this review,
develop and enforce uniform procedures for creating
and maintaining the various categories and types of case files.
AAs, RAs, and Lab Directors
to improve operational
performance. To be
completed over time.

OIRM:
In conjunction with programs,
will determine whether procedures
should be developed on an
Agency-wide or on a
program-by-program basis

HEADQUARTERS:
Programs should identify
appropriate files and
then establish timeframe for
accomplishment

See attached plans

REGIONS:
Regions should identify
appropriate files and
then establish timeframe for
accomplishment

See attached plans

LABORATORIES:
Labs should identify
appropriate files and
then establish timeframe for
accomplishment

See attached plans	
 25
FY 93 onward
                                                                                          1 st QTR
                                                                                           FY93

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 2-5
Amend current agency policy on the subject file
classifcation system for administrative records to
make its use mandatory. Update the system as
necessary to include all administrative records created
and maintained by the Agency.
OIRM to issue guidance.
Actions taken should
assure proper disposition
of duplicate records and
promote HQ move.

OIRM:
Will make decision on adequacy
of system as it now stands

Revise system as needed
                                                       Issue decision as Agency policy
 FY 93-94
 :1StQTR
   FY93


 3rd QTR
   FY93


 3rd QTR
   FY94
                                                        26

-------
                                       Recommendation and Action Matrix
                   Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 2-6
Inform all program offices of the requirements to
establish standardized file stations for the filing of
official records, and to designate file custodians who
are responsible for the operation of the file stations
(Chapter 7, paragraphs 2 and 3, Records Management
Manual). Inform all employees that under no
circumstances are agency records to be taken home or
similarly filed outside of approved agency storage
space.
OIRM to communicate policy
and requirements more
clearly.

OIRM:
Communications will be made
through INFO ACCESS
newsletter

Requirements will be included
in Records Management Manual
revision

OIRM to issue policy directives
and guidance clarifying filing
requirements and roles and
responsibilities; to be
implemented by Headquarters,
Regional and Laboratory offices
                                                        Interim guidance to be issued
                                                        Policy directive to be issued
   FY94
  4th QTR
   FY92
                                                                                           FY 93-94
                                                                                            FY93
                                   1st QTR
                                    FY93

                                   1st QTR
                                    FY94
                                                         27  '

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
2-6 cont.
Inform all program offices of the requirements to
establish standardized file stations for the filing of
official records, and to designate file custodians who
are responsible for the operation of the file stations
(Chapter 7, paragraphs 2 and 3, Records Management
Manual). Inform all employees that under no
circumstances are agency records to be taken home or
similarly filed outside of approved agency storage
space.
HEADQUARTERS:

Programs will comply-
See attached plans
REGIONS:

Regions will comply-
See attached plans
                                                       LABORATORIES:

                                                       Labs willcomply-
                                                       See attached plans
                                                        28

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
2-7
Eliminate personal filing systems for agency records and
generally discontinue the practice of maintaining
excessive duplicate records merely for convenience.
AAs, RAs, and Lab Directors
to improve operational
performance. Actions to
precede HQ move in FY 95.
Will be carried out in relation
to recommendation 2-1.

OIRM:
Determine whether additional
policy or procedures are needed

OIRM to issue policy directives
and guidance clarifying filing
requirements and roles and
responsibilities; to be
implemented by Headquarters,
Regional and Laboratory offices

Interim guidance to be issued
                                                       Policy directive to be issued

                                                       HEADQUARTERS:
                                                       Programs must respond-
                                                       See attached plans

                                                       REGIONS:
                                                       Regions must respond-
                                                       See attached plans

                                                       LABORATORIES:
                                                       Labs must respond-
                                                       See attached plans	
                                                         29
 FY 93-94
                                                                                          4th QTR
                                                                                           FY92

                                                                                           FY93
  1st QTR
   FY93

  1st QTR
   FY94

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
2-8
Implement appropriate file cut-offs to keep files at a
manageable level. Ensure that both headquarters and
field offices receive and implement guidance on proper
filing techniques, including separately filing permanent
and temporary records series and not intermixing non-
record material such as reference works and vendor
brochures, with agency files.
AAs, RAs, and Lab Directors
to communiate policy and
requirements more clearly.

OIRM:
Guidance issued in Model
Regional Records Management
Manual

OIRM to issue policy directives
clarifying filing
requirements and roles and
responsibilities; to be
implemented by Headquarters,
Regional and Laboratory offices

Interim guidance to be issued
                                                       Policy directive to be issued
                                                       HEADQUARTERS:
                                                       Programs must respond-
                                                       See attached plans

                                                       REGIONS:
                                                       Regions must respond-
                                                       See attached plans

                                                       LABORATORIES:
                                                       Labs must re'spond-
                                                       See attached plans

                                                      ~30
  FY94
  forward
                                                                                           FY93
  1SIQTR
   FY93

  IstQTR
   FY94
                   FY92

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 2-9
Examine agency policy regarding use of commercial
storage space and the general problem of interim storage
of records to ensure maximum use of;the FRCs, which
provide storage to EPA at no cost. Better controls agency-
wide along with a more rigorous enforcement of agency
files management and disposition procedures may
eliminate the need for some of this space and save the
agency money. Transferring permanent records as soon
as possible to FRCs is an important means of protecting
them and ensuring their long-term protection.
OIRM to issue policy
and guidance. Will be
carried out in relation to
recommendation 4-4.

OIRM:
Programs will be encouraged
to use FRC storage

Brochures issued which
explain how to use the FRC

Examine policy as part of Records
Policy Review

OIRM to issue policy directives
and guidance on the use of FRCs
and related roles and
responsibilities; to be
implemented by Headquarters,
Regional and Laboratory offices
                                                        Interim guidance to be issued
                                                        Policy directive to be issued
  FY93
   FY92
                                                                                            FY93
                                                                                            FY93
                                   IStQTR
                                    FY93

                                   IStQTR
                                    FY94
                    FY92
                                                         31

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
2-9 cont.
Examine agency policy regarding use of commercial
storage space and the general problem of interim storage
of records to ensure maximum use of the FRCs. which
provide storage to EPA at no cost. Better controls agency-
wide along with a more rigorous enforcement of agency
files management and disposition procedures may
eliminate the need for some of this space and save the
agency money. Transferring permanent records as soon
as possible to FRCs is an important means of protecting
them and ensuring their long-term protection.
HEADQUARTERS:
Training on retiring records
instuted at Headquarters
Programs must comply-
See attached plans

REGIONS:

Regions must comply-
See attached plans
                                                      LABORATORIES:

                                                      Labs must comply-
                                                      See attached plans
                   FY92
                                                       32

-------
                                       Recommendation and Action Matrix
                   Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
2-10
Implement fully the instructions of Chapter 4 of the
Records Management Manual to develop and maintain an
agency-wide program for the protection of vital records.
Steps to be taken include:
 a. identify the records that fall under the two categories
   of vital records. Keep the volume of records at a
   manageable level.

 b. determine the appropriate storage sites, and consider
   the use of Federal Records Centers. Emergency
   operating records need to be available as needed or in
   the vicinity of emergency operating centers; rights
   and interest records require protection but do not
   have to be near these emergency centers.

 c. review the program annually. It should be simple and
   concise and avoid, in so far as possible, complex
   procedures. The plan should take into account that
   during an emergency those who use the records may
   not be the same as those who refer to them under
   normal circumstances.
AAs, RAs, and Lab Directors
to improve vital records
program as indicated in the
Records Management Manual.

OIRM:
Review and revise as needed,
Headquarters guidance on
storage of vital records

Will provide guidance to programs
on identifying vital records

HEADQUARTERS:
Must conduct record retirement
procedures and categorize
vital records
All programs must respond-
See attached plans

REGIONS:
Must conduct record retirement
procedures and categorize
vital records
All regions must respond-
See attached plans

LABORATORIES:
Must conduct record retirement
procedures and categorize
vital records
All labs must respond-
See attached plans
 FY 93-95
                                                                                            1st QTR
                                                                                             FY94
  4th QTR
   FY93
   FY94
  forward
   FY94
  forward
                                                                                             FY94
                                                                                            forward
                                                          33

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
3.  RECORDS DISPOSITION
 3-1
Inventory of all EPA program office records, as required
by 36 CFR §1228.12(a), and revise the Records
Schedules in order to provide complete coverage for all
records created and maintained by the agency.
Headquarters and field records managers need to cooperate
in this effort. Specifically identify in the records
schedules the program office or function having custodial
responsibility for the records, particularly for permanent
series.
AAs, RAs, and Lab Directors
to improve schedules over time.
Will be carried out in relation
to recommendation 3-3 and 4-4.

OIRM:
Memo to be drafted, requiring
the scheduling of Headquarters
records

Memo to be drafted, requiring
the scheduling  of laboratory
records

Memo to be drafted, requiring
the scheduling of field office
records

100 schedule items revised

Complete internal review
and submit to NARA

HEADQUARTERS:
Inventories will be conducted
in each program

Inventory begun in Superfund
FY92

Inventory begun in RCRA FY 92

All programs must respond-
See attached plans	
 34
 FY 93-95
  IstQTR
   FY93
                                                                                          2nd QTR
                                                                                           FY93
                                                                                          3rd QTR
                                                                                            FY93
                                                                                          2nd QTR
                                                                                            FY93
                                                                                            FY93
                                                                                            FY93
                                                                                                           3rd QTR
                                                                                                              92

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 3-1 cont.
Inventory of all EPA program office records, as required
by 36 CFR §1228.12(a), and revise the Records
Schedules in order to provide complete coverage for all
records created and  maintained by the agency.
Headquarters and field records managers need to cooperate
in this effort. Specifically identify in the records
schedules the program office or function having custodial
responsibility for the  records, particularly for permanent
series.
REGIONS:
Inventories will be conducted
in each program

Inventory begun in Superfund
in Regions, FY 91

Overall inventory begun in
Regions FY 92

Draft schedules to be
completed

Internal review completed
and sent to NARA

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached plans
                  2nd QTR
                    FY92
 2nd QTR
   FY93

  1st QTR
   FY93

  3rd QTR
   FY93
                                                         35

-------
                                       Recommendation and Action Matrix
                   Recommendation
            Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
 3-2
Organize these revised schedules into a format that
serves as a comprehensive records manual.  It should
allow clear and easy access to disposition information
and be easy for program offices to interpret and apply.
The manual should include indexes - alphabetically,
functionally, and by name or form for example - to
simplify its use. The complexity of EPA schedules
and the need for them to be widely and easily available
throughout the agency to a variety of uses strongly
suggests the use of automated techniques for maintaining
and disseminating schedule information.
 OIRM is establishing an
 automated records
 disposition program to
 facilitate development,
 revision and management
 of schedules. Selected
 implementation of pilot
 has begun.

 OIRM:
 Format is prepared and mission
 needs analysis is completed

. Distribution methods are in place

 Schedule organization completed
 and approved by NARA

 Schedule format reviewed
 by Agency-wide officers

 Begin adding schedules in
 manual format as completed

 Determine appropriate automated
 format and system to be used
   FY95
   FY92


   FY92

   FY92
                                                                                             FY92
                                                                                            forward

                                                                                           2nd QTR
                                                                                             FY93
                                                                                                              FY92
                                                         36

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 3-3
Review the revised Records Schedules annually to ensure
that they are kept current, accurately reflect program
office needs, and meet all statutory requirements.  Both
headquarters and the regions need to be closely involved
in this review process.
Ms, RAs, and Lab Directors
to improve operational
performance. Conducted in
conjunction with recommendation
3-1 •.

OIRM:
Guidance has been issued for
regions

Guidance to be issued at
Headquarters

Clarifications issued by OIRM
to be implemented by
Headquarters, Regional
and Laboratory offices

Determine best procedure for
implementing annual review
at Agency-wide meeting

HEADQUARTERS:
All programs must respond-
See attached plans

REGIONS:
All regions must respond-
See attached plans

LABORATORIES:
All labs must- respond-
See attached plans

  37
   FY93
  ongoing
                                                                                         IstQTR
                                                                                          FY93

                                                                                          FY93
                                                                                         3rd QTR
                                                                                          FY93
                                                                                                           FY92

-------
                                       Recommendation and Action Matrix
                   Recommendation
           Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
 3-4
Once accurate and usable schedules are in place, conduct
an agency-wide campaign to apply these schedules to
the large volume of records currently in EPA custody.
In the tradition of agency clean-up campaigns, dispose
of records in EPA office space no longer needed or transfer
them to a Federal Records Centers. Unlike some of these
previous campaigns, this must be done in accordance
with approved authorities.  Similarly, review the records
in commercial storage space to identify those that can
either be destroyed or moved into Federal Record
Centers, as discussed in Chapter 2. Carefully identify
and segregate permanent materials wherever located
and transfer those no longer needed for current
business to NARA.
AAs, RAs, and Lab Directors
to communicate policy and
requirements more clearly
and to establish operational
priorities for disposition of
records on a routine basis.

OIRM:
Need basic directive on storing
records

OIRM to issue policy directive
and guidance clarifying
procedures for updating
schedules; to be implemented
by Headquarters, Regional
and Laboratory offices
                                                        HEADQUARTERS:
                                                        Interim clean-ups are being
                                                        conducted as programs move

                                                        Systematic procedure will be
                                                        in place following the inventory

                                                        All programs must respond-
                                                        See attached plans

                                                        REGIONS:
                                                        All regions musi respond-
                                                        See attached plans

                                                        LABORATORIES:
                                                        All labs must respond-
                                                        See attached plans	
                                                         38
  FY95
  IStQTR
   FY93

   FY93
                                ongoing through
                                   HQ move

                                     FY95
                                    forward

-------
                                     Recommendation and Action Matrix
                  Recommendation
           Actions
             for
        Improvement
 Planned
Completed
  Actual
Completed
3-5
Inform all employees that to dispose of agency records
in any manner inconsistent with the agency Records
Schedules or the General  Records Schedules is a
violation of agency policy and Federal law.
AAs, RAs, and Lab Directors
to communicate policy and
requirements mere clearly.

OIRM:
OIRM/OARM to issue memo
informing employees and records
management responsibilities

Will issue information to
employees and records
managers on an on-going
basis through newsletters,
brochures, and other publications

HEADQUARTERS:

All programs must respond-
See attached plans
                                                      REGIONS:

                                                      All regions must respond-
                                                      See attached plans
                                                      LABORATORIES:

                                                      All labs must respond-
                                                      See attached plans
                                                       39
  FY93
                                                                                        IstQTR
                                                                                        FY93
                                                                                      begin FY 92,
                                                                                    continue in  FY 93

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 3-6
Re-examine the agency's "Green Border" process of
approving records disposition schedules to determine
if the process can be made more efficient and involve
fewer delays.
OIRM to clarify FIRMR and
policy requirements that
permit streamlined review
and approval of disposition
schedules as internal
directives.

OIRM:
Will be conducted as part of a
general review of procedures; to
submit and approve schedules
per policy review

Meet with Agency records
officers to discuss review process
and receive feedback

Review policy and FIRMR
requirements

Draft position papers on  "Green
Border" review and discuss with
MOD and OGC

Include procedures in revised
records management manual
and circulate for official approval
   FY93
                                                                                           1SIQTR
                                                                                            FY93

                                                                                          2nd QTR
                                                                                            FY93
                                                                                                            Jun-92
                                                         40

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                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             tor
         Improvement
 Planned
Completed
  Actual
Completed
4: SPECIAL RECORDS
 4-1
Re-examine the agency's Record Schedules as they relate
to Superfund records.

 a. Distinguish between the Administrative Record and
   the NPL Site Files.  Both need long term retention,
   but only one may actually be a permanent record
   to be eventually transferred to the custody of the
   National Archives.

 b. Review the dispositions of all Superfund related
   records. The paper generated by this program is
   voluminous and it may be possible that some of it
   does not merit permanent or prolonged temporary
   retention.
OSWER to continue
improvements in operational
performance.

OIRM:
Complete internal review of
Headquarters and regional
schedules

Completed schedules will be
referred to NARA for approval
once internal review is finished

OIRM to assist OSWER as
necessary in determining
records value

OIRM/OSWER completed
guidance on identifying OSWER
records

HEADQUARTERS:
Headquarters Superfund
records examination in process
All programs must respond-
See attached plans

REGIONS:
Regional Superfund records
schedule examination completed
All regions rnustrespond-
See attached plans

 41
   FY93
  IStQTR
   FY93
 3rd QTR
   FY93
  ongoing
                                                                                         4th QTR
                                                                                          FY92
                                                                                                           FY92
                                                                                                           FY92

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                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 4-2
Continue to consider alternative methods of records
storage and retrieval to diminish the impact of a fast
growing volume of records.  Effectively carrying this
out is contingent on the previous recommendation
because the disposition of the records is an important
factor in determining an appropriate storage medium.
OSWER to continue
improvements in operational
performance. Will be carried out
in relation to recommendation
5-4.

OIRM:
OIRM to work with OSWER to
identify alternative storage
materials that conform to Federal
records management
regulations

OSWER:

See attached plans
  FY92
                                                                                           FY92
                                                                                           forward
                                                         42

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                                     Recommendation and Action Matrix
                  Recommendation
           Actions
             for
        Improvement
 Planned
Completed
  Actual
Completed
4-3
Develop more rigorous case file requirements for the
NPL site file to ensure that only one copy of all
appropriate documents and reports is included in the file.
OSWER to continue
improvements in operational
performance.
                                                      OIRM:
                                                      OIRM to work with OSWER to
                                                      develop more rigorous case
                                                      filing requirements that conform
                                                      to Federal records management
                                                      regulations
                                                      OSWER:

                                                      See attached plans
                                   FY92
                                  forward
                                                       43

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                                       Recommendation and Action Matrix
                   Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
4-4
Inspect all facilities housing Superfund site files. Upgrade
them as necessary to meet the facility standards of 36 CFR
§1228.222.  To prevent deterioration, permanent paper
records that will be retained for long periods of time in
agency storage need to be maintained in environmentally
controlled areas. Special protection must also be provided
for any audiovisual or microfilm records.  (For NARA
regulations in these areas, see recommendation 3-1 a.)
OSWER to improve operational
performance. Will be
carried out in relation to
recommendations 3-1
and 2-9.
                                                        OIRM:
                                                        OIRM to work with OSWER when
                                                        inspecting facilities housing
                                                        Superfund site files
                                                        OSWER:

                                                        See attached plans
                                    FY92
                                   forward
                                                         44

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                                     Recommendation and Action Matrix
                  Recommendation
           Actions
             for
        Improvement
 Planned
Completed
  Actual
Completed
4-5
Increase EPA records staff oversight of the Superfund
records management program to ensure consistency
in and better assess contractor performance, as well as
to help guarantee program continuity.
OSWER to continue to
ensure adherence to
Agency guidelines for
contractor performance.
                                                      OSWER:

                                                      See attached plans
                                                       45

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                                       Recommendation and Action Matrix
                   Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
4-6
Develop an agencywide strategy that establishes
oversight for records created or maintained by
contractors on behalf of the agency by involving records
management personnel in the contracting process whenever
program documentation is a deliverable item or the
contract is for records management.

a. Identify and impose specific contractor requirements
   for the creation, maintenance and use, and disposition
   of records.

b. Include standard language in all contracts that
   specifically identifies document contents for programs
   in which contractors produce agency records.
c. As part of the agency internal evaluation program,
   monitor contractor recordkeeping practices to ensure
   compliance with agency and Federal Regulations.

 d.  Inspect contractor-run storage facilities periodically
    to ensure conformance with the facility standards of
    36 CFR § 1228.222. Upgrade the facilities as necessary.
OARM to issue guidance.
OIRM:
Pilot study will be commenced
with OWPE and OSWER/IMS

Proposed solution will be reached;
process begun 3rd QTR 92

Solution will be implemented

Expand solution for Superfund
to Agency-wide programs

HEADQUARTERS:

All programs must respond-
See attached plans

REGIONS:

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached plans
 FY 93-94
   FY92
 2nd QTR
   FY93

   FY94

   FY94
  forward
                                                         46

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                                        Recommendation and Action Matrix
                   Recommendation
           Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
151 EllECTOONIG AN&NONIEXmJAl RECORDS
 5-1
 Revise and expand the guidance for creation, maintenance
 and use, and disposition of electronic records already in
 place to make it more complete and current. In particular,
 incorporate, as appropriate and in a form applicable to
 EPA, the guidance in NARA's regulations on electronic
 recordkeeping, found at 36 CFR 1234, and in NARA's
 handbook on Managing Electronic Records. Ensure that
 records maintained on all types of systems - microcomputers,
 local area networks, minicomputers, and main-frame
 computers - are included. As part of the EPA directive
 system, this guidance should be disseminated to all
 records managers and  administrators and IRM staff, both
 in headquarters and the field. Clear assignment of
 responsibility for developing and maintaining documentation
 for electronic records should be included in the directive.
OIRM to issue Model
Records Management
Operating Procedures and
to revise the Records
Management Manual.
Will be carried out in relation
to recommendation 2-1, 2-2,
and 5-2.

OIRM:
Issued Model Records
Management Guidance

Initiated review of all Agency
policy including electronic
records to determine policy
needs

Distributed 36 CFR 1234 to all
programs

April issue of INFO ACCESS
newsletter discussed
36 CFR 1234 and other issues

OIRM to develop EPA specific
electronic records policy in
conjunction with NDPD

OIRM/NDPD to circulate policy
for review	
   FY94
                                                                                            3rd QTR
                                                                                             FY93
                                                                                            1st QTR
                                                                                             FY94
                    FY92
                    FY92
                                                                                                              FY92
                                                                                                              FY92
                                                          47

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                                       Recommendation and Action Matrix
                   Recommendation
           Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
 5-1
Revise and expand the guidance for creation, maintenance
and use, and disposition of electronic records already in
place to make it more complete and current. In particular,
incorporate, as appropriate and in a form applicable to
EPA, the guidance in NARA's regulations on electronic
recordkeeping, found at 36 CFR 1234, and in NARA's
handbook on Managing Electronic Records. Ensure that
records maintained on all types of systems - microcomputers,
local area networks, minicomputers, and main-frame
computers - are included.  As part of the EPA directive
system, this guidance should be disseminated to all
records managers and administrators and IRM staff, both
in headquarters and the field. Clear assignment of
responsibility for developing  and maintaining documentation
for electronic records should be included in the directive.
OIRM cont.
OIRM to issue policy directives
and guidance clarifying
procedures for electronic records
life cycle, and related roles;
to be implemented by
Headquarters, Regional
and Laboratory offices
HEADQUARTERS:

All programs must respond-
See attached plans

REGIONS:

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached plans
   FY93
                                                          48

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                                        Recommendation and Action Matrix
                   Recommendation
           Actions
              for
         Improvement
 Planned
Completed
  Actual
Completed
 5-2
Take the following steps to improve the disposition of
electronic records:
   Develop a comprehensive and up-to-date inventory
   of all electronic records and systems of records,
   using the Information Systems Inventory as a
   starting point. The inventory should include information
   about the documentation for electronic records.
 b. As the first step in scheduling the unscheduled
   electronic information, identify what is potentially
   permanent or requires long-term retention and
   formally schedule the disposition. It may be appropriate,
   in determining permanent retention, to focus on
   specific types of information and data segments, rather
   than specific datafiles or even databases. Once
   permanent and long-term retention electronic records
   have been scheduled, schedule those program records
   not covered by the General Records Schedule.
OARM, AAs, RAs, and
Lab Directors to improve
operational performance
over time.

OIRM:
OIRM to work with programs
to schedule all unscheduled
data series in ISI during FY 93-94

Programs are to cooperate
in providing information

OIRM will schedule those records
highlighted in NAPA II report

OIRM will schedule the remaining
electronic systems program-
by-program in conjunction with
scheduling of textual files

OIRM to schedule regionally
based systems following
completion of Headquarters
systems
   FY95
   FY94
  IstQTR
   FY93

 2nd QTR
   FY93
  forward
   FY94
                                                           49

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                                       Recommendation and Action Matrix
                  Recommendation
            Actions
              for
         Improvement
  Planned
 Completed
  Actual
Completed
5-2
c.  For those electronic records already scheduled as
   permanent, primarily older series created on mainframes,
   determine their current status and identify the
   corresponding documentation. One approach would
   involve working backwards from data stored at NCC
   in Research Triangle Park, identifying what corresponds
   to the scheduled items and going to the users responsible
   for the data to locate documentation.

d.  Involve the expanded headquarters records management
   staff in the planning of new electronic records  systems or
   when existing systems are modified in order to ensure that
   appropriate records maintenance and disposition proced-
   ures are built in at the earliest stages. The involvement of
   records managers in the system design will not only
   ensure that records management requirements are met;
   it will also result in a more efficient and effective system.

e.  Based on clearly assigned responsibilities, ensure
   that all necessary and appropriate documentation for
   electronic records is created and maintained according
   to NARA and EPA  requirements. As part of the
   evaluation program, regularly review this documentation,
   with particular attention to those systems requiring
   permanent or long-term retention.
OIRM cont.
Programs have started process
for related data files

OARM will notify custodians
who will carry out objectives

NDPD has issued guidance on
"archiving" data which requires
scheduling of all data stored off-
line at RTP

OIRM working to establish
records management check-off
list as part of project to revise life
cycle guidance. Records
Manager is part of work group.

Implementation will follow
assignment of responsibilities
(Also see response to
recommendation 5-1)

HEADQUARTERS:
All programs must respond-
See attached plans

REGIONS:
All regions must respond-
See attached plans

LABORATORIES:
All labs mustrespond
See attached plans

  50
  ongoing,
 beginning in
FY 92 through
    FY95
    FY94
                     FY92

-------
                                       Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
  Planned
 Completed
  Actual
Completed
5-3
Include segments on managing electronic records in agency
records management training sessions. In addition, develop
presentations for IRM officials and program staff responsible
for electronic records systems that provide information
on their responsibilities in relationship to electronic
records, particularly in terms of building in maintenance
and disposition at the system development phase, and of
creating and maintaining appropriate documentation.
OIRM to communicate policy
and requirements more
clearly.

OIRM:
Will develop a half day
training session on electronic
records management to be
included in Agency training
cycle

Will produce special issue
of INFO ACCESS newsletter to
communicate responsibilities to
major IRM officials, system
managers, and records staff

Will determine best method
of communicating information
to IRM officials and program staff

Will to develop products to
communicate message

HEADQUARTERS:
All programs must respond-
See attached plans

REGIONS:
All regions must respond-
See attached plans

LABORATORIES:
All labs must respond
See attached plans	
  51
FY 93 onward
   FY93
                                                                                           Apr-92
                                                                                            FY92
                                                                                            FY93

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                                     Recommendation and Action Matrix
                  Recommendation
           Actions
             for
        Improvement
 Planned
Completed
  Actual
Completed
5-4
Issue and implement a policy affirming the disposability of
paper records once they have been microfilmed and
verified according to appropriate EPA and NARA
specifications. Permanent records must be filmed
according to the standards in 36 CFR 1232.
OIRM to issue policy and
guidance. Will be carried out
in relation to recommendation
2-1 and 4-2.

OIRM:
OIRM to issue policy;
programs to respond on
implementation

OIRM to issue memo on
disposability

OIRM to include disposability of
paper after microfilming in revised
records management manual

HEADQUARTERS:

All programs must respond-
See attached plans

REGIONS:

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached'plahs
                                                       52
  IstQTR
  FY93
                                                                                       2nd QTR
                                                                                        FY93

                                                                                       4th QTR
                                                                                        FY93

-------
                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 5-5
Inventory audiovisual records in the custody of EPA with
a special emphasis on locating all series of permanent
records. Establish specific dispositons for the series
identified. Records that are at least ten years old should be
reviewed for transfer to the Archives as soon as possible.
Guidance for identifying permanent as opposed to temporary
audiovisual records can be found in NARA's handbook
Managing Audiovisual Records.
OCEPA to improve
operational performance.
OIRM:
OIRM to support OCEPA in
inventorying audiovisual
records

OIRM to develop revised draft
schedules to cover all audio-
visual records

HEADQUARTERS:

All programs must respond-
See attached plans

REGIONS:

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached plans
  FY93
                                                                                         3rd QTR
                                                                                          FY93
                                                        53

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                                      Recommendation and Action Matrix
                  Recommendation
           Actions
             for
         Improvement
 Planned
Completed
  Actual
Completed
 5-6
Develop a program for managing audiovisual records, based
on implementing the guidance established by EPA as
described in recommendation 2-1 a. Once older permanent
audiovisual records have been transferred to the National
Archives, the agency priority should be establishing
appropriate storage and environmental controls for the
permanent records remaining in EPA custody in order to
ensure their long-term preservation, and implementing a
program of regular transfers.  An evaluation of audiovisual
records management across the Federal government and
specific recommendations for improving these programs
can be found in NARA's recently published The Manage-
ment of Audiovisual Records in Federal Agencies:
A General Report.
OCEPA to improve program
management.
OIRM:
OIRM to cooperate with OCEPA
in developing program
HEADQUARTERS:

All programs must respond-
See attached plans

REGIONS:

All regions must respond-
See attached plans

LABORATORIES:

All labs must respond-
See attached plans
 FY 93-94
                                                        54

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