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
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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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•
•
• .
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•
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«
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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
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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
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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
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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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