EPA Records Management Technical Leaflet #2
A Practical
Guide to
Developing
Records
Disposition
Schedules
One of the most important things stressed by the
National Archives and Records Administration (NARA)
evaluation of EPA's records program was that we
should revise and implement our records disposition
schedules. In fact, all of Section III of the evaluation
was devoted to revising and applying the schedules.
It's the Law
There are a number of laws governing the
estruction. retirement, and archiving of Federal
records. These are covered in a NARA publication
called Federal Records Management. Laws and
Regulations and are summarized in a pocket piece put
out by NARA called Records Management and the
Law. The essence of these laws as they pertain to
destroying, retiring, or archiving records is that:
A record is any document (electronic or
paper) that is produced or received in the
course of conducting Agency business. All
records must have disposition schedules.
All disposition schedules must be approved
by NA RA. Federal employees must comply
with the provisions of all schedules.
Federal employees may destroy Federal
records only in accordance with NARA
approved schedules.
So there is no way around it - your Program MUST
have and use NARA approved records disposition
schedules.
It is entirely possible (although unlikely) that all the
records in your Program are covered by the general
Agency-wide (or HQ-wide or Region-wide) schedules.
Jowever. this must be determined by interviewing the
eople in your Program to find out what kinds of
records they produce and/or receive in the course of
fulfilling their jobs (missions). If there are any types of
records which are UNIQUE to your Program OR DO
NOT fall into one of the categories of records (called
"record series") that already have a disposition
schedule, you will need to develop and obtain approval
for a disposition schedule to cover those record types.
There are Benefits
Although this may sound like just another
bureaucratic hassle, there are real, tangible benefits to
your Program from having and using records
disposition schedules:
First, using realistic records schedules can help
alleviate the problems caused by natural pack rats
who want to keep "everything." The schedules indicate
when records should be thrown out, retired or
archived. They should not be kept in the office longer
than the schedules indicate. This can free up valuable
office space.
Second, using realistic records schedules also
guards against disposing of record material too soon.
Sometimes records are no longer of value to the office
that created or maintained them, but they may still be
valuable to someone else. This type of consideration
is (or should be) incorporated into the schedules when
they are developed by including a sufficiently large
schedule review loop.
Third, using realistic records schedules takes the
guess-work out of cleaning out files at the end of the
year. This saves time on what can be a tedious task.
Finally, using realistic records schedules helps
avoid having to fulfill FOIAs and other requests '
unnecessarily. If requested documents have been
legally dispositioned per the schedules, no one can
hold the former custodian responsible for not having
the documents. In addition to providing valuable legal
protection, this also saves valuable staff time and
resources.
The operative word in the aforementioned benefits
is "realistic," and the only way to make the schedules
realistic is to obtain program staff input during their
development.
So how do you go about developing schedules for
your program's records? As you might expect, this
must be coordinated with the National Records
Management Program (NRMP) within the Information
Management Systems Division (IMSD) of the Office of
Information Resources Management (OIRM). The
NRMP, in turn, is responsible for coordinating with
NARA.
National Records Management Program, Information Access Branch Jury 1994
Information Management and Services Division, U.S. Environmental Protection Agency EPA-220-F-92-008
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Developing Records Schedules
in the Programs - Lessons
Learned
The Office of Solid Waste and Emergency
Response (OSWER) and the NRMP have completed
most of this process for the RCRA and CERCLA
programs. As a result of going through this process.
they have come up with a baker's dozen list of lessons
teamed which should help guide you in developing
effective, realistic schedules for your program:
1. Define the scope
Determine whether to revise schedules for a Program
or a set of organizations (e.g., for the RCRA program
which spans OSW, OWPE, OE and other
organizations or just OSW). Either can work. Doing it
for a set of offices is somewhat easier since there is a
finite, clearly defined universe. However, we chose to
do it for a whole program. We wanted to mirror the
Superfund efforts already underway and, more
importantly, needed to be able to reconcile information
we gathered on custody, official record ownership,
usage, etc. across offices and particularly between
HO and the regions.
2. Obtain top management support first!
The definition of 'lop" should be based on the scope of
schedules you are revising. A variety of approaches
are possible. For example, have the Office SIRMO
(who is ultimately charged with the responsibility of
records management within your Office) write a memo
to top management explaining the necessity and
benefrts-pf revising the schedules. Or you can make a
presentation to top management covering this
information. You may need to make a presentation to
top management's key subordinates first to obtain their
buy-in. Whatever you do, be sure to sell the "benefits"
(such as those mentioned above) to be reaped by top
management and their organization. Lay out the
schedule development plan which would include
identifying interviewees, sending a letter and
information to interviewees, interviewing program
technical staff and management, developing drafts,
and reviewing as described below. Be sure to pin
down when a letter encouraging or requiring
cooperation will go out from top management. (Be
prepared to draft it yourself.)
This Fact Sheet was written by Lisa Jenkins,
Information Management Division,
Office of Solid Waste and Emergency Response.
7 Steps For Developing
Records Disposition Schedules
J1
The following are steps in the records
disposition schedule approval process
(from an NRMP handout circulated at the
Records Management Working Meeting
held in Chicago on June 9-101992).
1) Program develops disposition schedules with
substantive input from technical program staff and
management, or program provides the NRMP with
sufficient information to do so.
2) The NRMP reviews schedules and suggests
changes as necessary.
3) The NRMP returns schedules to program for
approval if changes are made. Program suggests
interested parties to review. All schedules are
approved by at least the AAship in the which the
submitting program is located, Office of General
Council (OGC) and Office of Administration and
Resources Management (OARM).
4) The NRMP circulates schedules for formal
concurrences (Green Border if necessary) by
interested programs.
5) The NRMP submits schedules to National
Archives, if necessary, (i.e., if there are substantive
changes in the title, description, retention or
disposition).
6) The NRMP negotiates changes with the National
Archives and Records Administration (NARA) and EPA
if necessary.
i • •
7) The approved schedules are distributed.
National Records Management Program
July 1994
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3. Get expert records management
contractor assistance
ne advantage to using a contractor is that revising
te schedules then gets established as a formal
project and is more likely to be completed. Using
records management experts will also shorten the
lead time for the project, since experienced
contractors know the right questions to ask and can
pick up on the nuances that spell the difference
between useable and difficult to use schedules. Also
they can provide examples to interviewees on how
similar problems (e.g.. determining retention periods)
have been handled with similar records. Ideally, find a
contractor with a good understanding of your program
and the terminology used in it. This minimizes any
information gaps that could crop up during the
interviews.
4. Use local contractors
Since any program-wide schedule development
project will probably require a lot of interviews, and
since meetings can be cancelled at a moment's notice,
it is helpful to use local contractors. We found it next
to impossible to block out time for an out-of-town
contractor to come in for in-person interviews. This
was unfortunate since an interviewer can gain
valuable information by what they see in an office and
m non-verbal clues that surface during the
erview.
5. Target your interviews
If one thing is the crux of the whole project, this is it!
Work with people targeted by top management (and
records champion(s) within the targeted.
organization(s)) to determine key interviewees.
Usually, the best bets are branch chiefs, section
chiefs, and key technical people in branches or
sections. There is a tendency for people to want to
shove records management down to the next person
on the totem pole. It is important to obtain input from
technical program staff and managers, so don't let
them pass the buck. Keep in mind that there is a
happy medium between interviewees who are too high
up to know sufficient details about the records and
how they are used, and those who are not high
enough up to be familiar with the content, use and
significance of the records. Also, the more people
interviewed, the more contractor hours are expended.
6. Do your homework
in't go into the interviews cold. Do background
osearch to find out as much as you can about the
types of records an organization might have before the
interview. The EPA library can provide such things as
organizational mission statements and organizational
charts, relevant laws, previous records schedules,
program training materials, etc. By understanding
what an organization is charged to do, you will have a
fairly good idea of the types of records it is likely to
produce. Bring a list of potential record series to the
interview to help initiate the conversation.
7. Pick your sources
Be wary of allowing one portion of an organization to
speak for the rest. It is rarely the case that one group
knows what records are produced throughout an
organization, let alone the appropriate retention values
and the significance of each type of record. However,
we did have a case where one division was
responsible for the docket, budget, contracting, and
communications within a whole office. After extensive
research and careful discussions with this one
division, we found that most of the documentation
produced by the office seemed to flow through this
one division. As a result, we did not interview anyone
from any other divisions. Of course, the proof will be
in the implementation and whether additional series
are unearthed after the schedules are in place.
8. Get a champion
Coordinate efforts to obtain interviews with "records
champions" (i.e., advocates) within the targeted
program offices/divisions. People seem to respond
better to others within their own office (especially their
managers) than to those outside their office.
9. Get involved
Don't expect to divorce yourself from the process.
Setting up interviews can be next to impossible if you
rely solely on the contractor conducting the study.
(See note 3). Many people do not return calls to
others outside their organization unless they know the
caller. You'll need to be up to speed on the purpose
and the process for the informal briefings that occur
while setting up interviews as well as for the major
presentations to management. Continue to sell
"benefits" of doing the records schedule revision!
10. Provide interviewees with a few
materials before the interview.
Here are a few examples of materials we found useful:
* A copy of the memo from top management stating
the purpose of the project and why their participation
National Records Management Program
July 1994
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is needed (i.e., why program and technical people
need to be interviewed not just secretaries and
paraprofessionals).
• A straw list of possible series for the program
office/division. A good contractor can prepare this
from organizational charts, mission statements, old
records schedules, laws, regulations, training
materials, etc. pertaining to the program.
* The NRMP diagram "What is a Record?"
Unfortunately, many people at EPA are unaware of
their legal, records management responsibilities and
are unsure of what a record is. This diagram helps
sort out what constitutes official records from what are
personal papers and other non-record material (like
technical reference) so that your interviews can focus
on true records.
• A sample of an old/current records schedule and
sample of a new records schedule. Most people in
EPA have never heard of a records disposition
schedule, much less know it's purpose or what one
looks like. (In fact, most haven't even heard of the
word "disposition.") Note in a cover letter that the
format is changing, and that the new format will
provide more information which will assist us in our
overall records management effort.
Note: It is NOT recommended that you send all the
old/current schedules. They are bulky, and if the pre-
interview package is too thick, your interviewees may
not read ANY of the material. In addition, it could
cause confusion since the old/current schedules are
out of date (and we need fresh thinking on the subject
anyway).
11. In interviews, ask interviewees to
focus on unique, program specific
records that wouldn't be found in other
parts of EPA.
Common materials already covered by schedules
include administrative materials, rulemaking dockets,
policy making materials, contracting records, special
studies, reports to Congress, etc. Be sure to unearth
electronic records as well. Know the schedules that
have already been rewritten in draft form and what will
and won't fit under these series.
The existing drafts can be obtained from the NRMP.
For the unique types of records, ask your
interviewees:
4 For what are the records used? What's their
purpose?
• What laws or regulations form the basis of the
activity that produces the record?
• What other organizations (inside and outside EPA)
use them or have copies?
• Who is or should be responsible for (have custody
or ownership over) the official record.
• A) How long are records active (i.e., needed in the
office).
B) After that, how long do they need to be
infrequently accessed (i.e., less than one retrieval
per FRC-sized box per month).
C) Do they need to be kept permanently (i.e.
greater than 50 years).
[Points B and C will help indicate when and whether
things should be sent to the FRC and/or Archives
respectively.]
• How are the records physically and logically
organized currently?
12. Make sure you leave time for
actually writing the schedules and for
plenty of reviews.
Be sure to separate out Program Specific Guidance
from Agency wide Guidance information for inclusion ii
the appropriate sections on the new schedule format
since NARA will not need the former. Multiple reviews
by the program are extremely important. Although
people may not be used to thinking of their records in
terms of record series and certainly not in terms of
disposition schedule verbiage, they will still be able to
pick up errors and point out missing information when
they review the schedules.
13. When the schedules are ready for
Green Border, make sure to work with the
NRMP.
Keep in mind that the more you have involved the
relevant organizations in preparing the draft schedules
prior to Green Border, the more likely they are to be
approved in that process with few additional revisions.
This goes for the National Records Management
Program (NRMP) as well. Mike Miller, NRMP
Manager, will be happy to review your draft schedules
at any point in the process and give you valuable
feedback. You can contact him at (202) 260-5911,
orondmaihMiller.Michael.OIRM. For further
information contact Manker R. Harris (contractor),
at (202) 260-5272.*
National Records Management Program
July 1994
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