Managing Working Files
When it comes to describing working files the old saw about art comes to mind:
"/ can't define what it is, but I know it when I see it."
According to the National Archives and
Records Administration (NARA), working files
consist of documents "such as rough notes,
calculations, or drafts assembled or created and
used to prepare or analyze other documents." But
ask most EPA employees, and they will say that
the files in their filing cabinets are their "working
files." So who is right?
The answer is that NARA is right in theory,
and EPA's definition fits far too many offices at
EPA. Why? Because too many EPA programs
have lost the distinction between "official files"
and "working files." One of the biggest challenges
to records management in EPA is to reintroduce
this vital distinction which is fundamental to
effective management of our records. This is
done by developing recordkeeping requirements
for each of the Agency's major programmatic and
administrative files, an initiative that EPA will be
implementing over the next five years.
One function of recordkeeping requirements
is to identify what documents need to be included
in the official file. In fact the easiest way to define
working files is to define official files first. Within
EPA, official records are defined as
... any final product related to administration,
management, enforcement, regulation or
other Agency function and all documentation
necessary to support that document, the
decision trail leading up to it and the actions
that result from it.
Working papers are everything else.
Too many EPA programs
have lost the distinction
between 'official flies"
and 'working files.*
One of the biggest challenges
to records management in EPA
is to reintroduce this vital distinction
which is fundamental
to effective management
of our records.
Why is the working files question important?
As long as they consist only of "rough notes,
calculations, or drafts" working files are not a
major problem. But professional staff frequently
maintain a substantial portion of their project
documentation in "working files."
When working files contain records needed
to document program activities they pose two
problems. If working files are poorly organized
and inscrutable to anyone but the creator (which
they often are) identifying record material to
document program activity is difficult. If staff
mix record and non record materials in one
voluminous "working file" (as they frequently do)
the Agency is forced to manage an even larger
volume of material than is necessary.
National Records Management Program, Information Access Branch
Office of Information Resources Management, U.S. Environmental Protection Agency
EPA220-F-92-016
October 1992
Printed on Recycled Paper
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[ ManagingWorking Files 3
Everyone creates working files and they are
necessary to keep operations running smoothly.
How to manage them is the question. The basic
considerations are to make sure that records
needed to document Agency activity are
separated out from working documents and filed
in official tiles, and that the volume of working
files is kept to a minimum by constant weeding.
Programs often take one of two approaches
to manage working files. The first approach is to
minimize their existence by having staff create an
official file when the action is initiated, and file the
official records and only official records in it. This
is the best solution from a theoretical perspective,
and it works especially well for repetitive actions
where approvals are required, such as the issuing
of permits, travel vouchers, purchase requests, or
the approval of directives.
In other cases, staff retain most or all of the
papers until a specified milestone is reached or
the activity or task is completed. At that time an
off icial file is compiled. This works well when
several individuals are contributing to one product
or result, or when projects are unique. Some
programs also use this approach in compiling
administrative records.
What binds these two approaches together is
that there is an established profile for what types
of documents need to be included in the official
file. Staff then assess the value of their
documents against this benchmark to know
which records in their possession need to be
filed and retained, and which ones can be safely
recyded or destroyed.
What if There Is No Guidance?
Unfortunately not all programs have guidance
on what is to be included in the official file. What
then? Do you have to save everything? No, but
you need to be careful as you sort through the
documents before you. First double check to
make sure that no guidance does exist. If there
is none, develop an approach to the materials
using the general guidelines listed below, and
discuss it with your supervisor, and with counsel
if there is a likelihood of litigation.
(
General Guidelines
Here are some guidelines for handling the
types of documents you frequently find in working
files.
• Record Material: Develop a plan to
organize the materials and file according to
the file plan. If the file is large consult with
your records manager on whether it makes
sense to set up a file for the major documents
and a separate one for supporting materials.
Conllnued on page 4
Supporting Materials and
Working Files
Supporting mat enals are not
workIng files. True supporting
materials are documents that
are necessary to substantiate the
final document or decision trail.
Supporting materials are part of
the official record. atthough they
may be filed separately If volume
warrants.
National Records Management Program
2
October 1992
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( Some Basic Questions and Answers
L Concerning Working Files
Q. Are working files A. As discussed in the article, working files usually contaip a
records? mixture of record and non record materials. Until the holder of
the files separates out and files all records, the working files
themselves must be considered record.
Q. Are working flies the A. No. Personal papers are nonofficial, or private, papers
same as personal relating solely to an individual’s own affairs. Working files,
papers? by definition, relate to Agency business and are not personal
papers. See the August issue of INFOACCESS for more on
personal papers.
Q. Are working papers A. The FOIA does not exclude working files. If there are
subject to the Freedom documents in the files that are exempt from the FOIA under
of Information Act one of its exclusions, those documents may be withheld from
(FOIA)? disclosure. However, the fact that they are working files does
not, in itself, exempt them from disclosure. See the FOIA
Manual (Manual 1550) for more details.
Q. Should working files A. There is no simple answer to this question. As noted in the
be retained past the article, some working file materials can be destroyed when no
close of the project? longer needed. Other portions should be retained for a brief
time, usually 6-12 months after the project is completed, and
then destroyed. Check your records disposition schedule. If
documents are worth retaining for a longer period of time, they
should be kept as part of the official file. If “working files” are to
be retained, they should be pruned of non record material and
organized so that they can be understood by someone other
than the creator. Otherwise there is no reason to keep them
beyond their immediate usefulness. •
National Records Management Program 3 October 1992
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General Guidelines continued
For Further Reading
You may wish to consult the following
• Non Record and Technical Reference publications for information on related issues.
Materials: Extra copies of articles, periodicals,
reports, documents, studies, vendor catalogs, A Basic Apprnach to Improving Your Files.
and similar materials that are needed for [ flyer] June 1992.
convenience or reference but are not part of
the official file. Such items should be EPA Records Management Tools. [ flyer]
destroyed as soon as they are no longer Revised August 1992. EPA 220-F-92-009
needed. INFOACCESS: Records and Library Network
Communications. [ monthly]
• Suspense or Tickler Copies: Extra copies
of documents to remind persons of actions In formation Resources Management Policy
to be completed by a certain date should Manual (2100) - Chapter 10: Records
be destroyed once the action has been Management. November 1987.
completed.
A Practical Guide to Developing Records
• Telephone slips, notes, email messages Disposition Schedules. August 1992.
that are facilitative not substantive in nature EPA 220-F-92-008
(e.g. “Mike, please call Ann about the Records Management Manual (2160), 1984.
project.”). Destroy when no longer needed. Updates in 1986 and 1988.
• Telephone slips, notes, email messages Safeguarding and Disposition of Official
that are substantive in nature. Either retain or Records. EPA Notice 88-1. Environmental
create official documents, such as memos Protection Agency, September 12, 1988.
for the record summarizing substantive
conversations, meetings, telephone calls, 10 Frequently Asked Questions About
and the like, and destroy the notes. Records. [ flyer] August 1992.
EPA 220-F-92-01 0
• Drafts that are not circulated for comment
or review can be destroyed when no longer 10 Quick Ways to Improve Records
needed. Management in Any Office. [ flyer]
August 1992. EPA 220-F-92-01 I
• Drafts that co.ntain only editorial changes
suggested by others can be destroyed when Using the Federal Records Center: A Guide
no longer needed. for Headquarters Staff. July 1991.
EPA/IMSD/91 -004
• Drafts that contain substantive changes
What is a Record? [ poster] February 1992.
need more analysis. If the changes are EPA-220-E-92-001
important, you may wish to retain them as
supporting the documentation. In most cases, What Makes Papers Personal? [ flyer]
however, it is sufficient to summarize the August 1992. EPA 220-F-92-013
comments in a memo for record. In the case
of documents circulated for comment, you Contact the National Records Management
can always keep an original full copy and Program at (202) 260-5272 for copies of
then retain only the annotated pages of the these publications. .
copies with comments. .
National Records Management Program 4 October 1992
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