United States
Environmental Protection
Information Resources
EPA 220-N-93-005
Issue Number 26
February 1993

Filing System from page 1
File plans operate on two levels. They guide you in identifying and
arranging the records series in the filing equipment and they guide you
in arranging the document or file folders in the records series. Although
the two are related, there are some differences.
Identifying and Arranging Series
As you completed Steps 1 and 2, you identified and separated out
the non record materials in your file cabinets, and then identified the
records series and matched them to the disposition schedules. The
series is the fundamental building block of the file plan. Identifying
records by series makes it easy to determine what should be filed in
the series and what the retention is. To work most effectively, the
series, disposition schedules, and file plan must be integrated into an
overall file plan structure.
The approach we suggest is to use the draft Agency File Code as
the basic tag to identify each series (See the insert). The file code is
made up of a four letter prefix (e.g. COMM for Committees) and then
the three digit EPA number from the draft records disposition
schedules. The four letter prefix allows you to group related series
of records together and the three digit EPA number allows you to
separate them by disposition. Besides allowing you to easily and briefly
identify each series, the file codes serve to standardize records across
programs and facilitate the exchange of information and the tracking of
Once you've identified the series using the file code, you can begin
grouping those with the same alpha prefix together in your filing
gquipment. Half of the file plan battle is won!
What is a Records Series?
Series are those file units or documents kept together
because they relate to a particular subject or function, result
from the same activity, document a specific type of
transaction, take a particular physical form, or have some
other relationship arising out of their creation, receipt,
maintenance, or use. The series concept is a flexible one,
and programs should be careful to create series by organizing
their documents in ways that facilitate management of the
records throughout their life cycle. $
Arranging the Records
Within the Series
The second stage of the file
plan is to determine how to
arrange the folders or documents
within the series. There are four
basic ways to arrange records
within a series:
~	By date (Chronological).
~	By some assigned number
~	In alphabetical order by
folder title (Alphabetic).
~	According to a code made
up of letters and numbers
These arrangement schemes
are described in the box on page
12. The obvious question is
which one to choose for each
series of records. To decide that
you need to think about how the
records will be used, what
characteristics the staff use to
identify the records, how the
records are requested, and
whether they will be indexed.
Let's look at each of these
issues in turn.
~ How will the records
be used?
If your office is responsible
for permit files and each staff
person is assigned the permits
of a State, it makes sense to
arrange the permits first of all by
State so that each staff person
doesn't have to search the entire
file to find the ones for his or her
State. If on the other hand
permits are assigned to staff in a
Continued on page

random way, some other
srrangements such as permit
number, facility name, facility
number, etc. would be better.
~	What characteristics do the
staff use to refer to the
Continuing with the permit
files example, programs may use
the facility name, the permit
number, or a facility ID such as
the FINDS number to identify
files. Any of these can be used
for the primary classification
scheme, although standardized
numbers such as FINDS may
simplify cross-media analysis.
The best advice is to use
whatever identifier the staff
currently use. There is no
reason to arrange the files by
permit number when the staff
look for them by facility name or
vice versa.
~	How are the records
Perhaps you have a
correspondence series of
outgoing letters signed by various
staff members. There are a
number of ways to arrange the
outgoing letters. If someone
asks you to find a letter, what do
they say? If it's "I wrote a letter..."
maybe the series should be
arranged by author or signer. If
it's "About three weeks ago..."
chronological may be the best
bet. If it's "Didn't we send a letter
to so-and-so..." the arrangement
should be by addressee. Finally
if it's "Have we ever had a letter
asking about..." then a subject
file might be best. Pick the
arrangement that will enable you
to respond to the most requests
The Subject Fi
How often do you hear the request to "Please make a new
folder for this and add it to the subject file." The office "subject file"
is one of the biggest records management problems in EPA. The
typical subject file has the following characteristics, ALL BAD:
~	It contains records, non records and personal papers.
~	It contains records that belong in multiple series.
~	There are no rules or procedures for filing documents.
~	There is no listing of subjects to use when filing new
materials or ways to group related materials.
~	It is never "cut off' so that active and inactive records
are filed together.
Subject files can work, and at the branch or section level they
often make sense. How can you make a good subject file? Here
are some tips.
~	Establish procedures for filing documents and maintaining
the file.
~	Restrict the Subject File to records used for managing and
administering the unit, such as branch or section. File records
about actual work the unit does in appropriate series.
~	Cut off the Subject File periodically and start a new one.
Bring forward only those records that are still active into the
new file.
~	Establish a list of subjects and keep it up to date. Make the
filing designations broad enough that you don't end up making
a new file for every new document. *
most easily. If the series is an important one, you should think about
indexing it to simplify searching in multiple ways.
~ Will the records be Indexed?
If the records will be indexed, the questions are a lot simpler.
Generally modern automated indexes offer a number of search fields,
and the physical arrangement of the records is less important, if the
records will be indexed, the series should be physically arranged in
whatever way makes filing simplest, usually chronologically or
numerically, depending on the type of records.
Continued on paga 12

But What About
The NARA evaluation clearly stated that EPA
should never allow staff to take records home with
them. But what about persons participating in
flexiplace? Can they take records home? Does this
constitute "unlawful removal" of records, a Federal
When asked about this, NARA responded that
the strictures about never taking records home
were aimed primarily at those employees who took
records home to store or hide them. A NARA
spokesperson stated that NARA does not want
to put "roadblocks" in the way of flexiplace
implementation and volunteered that NARA
should revise the wording in some of its
publications to clarify that fact.
At this point there is little in Flexiplace
procedures covering records management issues,
and there is nothing in the records management
manual. Based on discussions with the
Headquarters and Agency flexiplace coordinators,
the following recommendations should be
considered if the question comes up in your
' Records Management1
Goals for FY 93
V			)
During the past three years the
National Records Management
Program (NRMP) has concentrated
on establishing the records
management network, supplying
records managers with guidance
on how to handle the most pressing
records management problems, and
responding to the NARA evaluation
In FY 93 the NRMP is turning its
attention to revising and expanding
Agency records management policy.
Among the priority items are revising
Chapter 10 of the IRM Manual, issuing
interim guidance on filing and file plans,
completing a study of electronic
records management policy needs,
submitting the Agencywide records
disposition schedules for Green Border
Review, and drafting revised schedules
for the remaining Headquarters
programs. *
1)	Records should only be removed for short
periods of time and the volume of records removed
at any one time should be kept to a minimum.
2)	Records should only be removed with the
knowledge and approval of a supervisor.
3)	Document security should be a major
consideration. Many Agency records contain
sensitive information. Generally speaking, if office
procedures prohibit taking certain types of sensitive
records home, those prohibitions apply to flexiplace
as well. When in doubt, if there are no established
procedures, consult with your supervisor or regional
or general counsel concerning whether sensitive
documents can be removed in flexiplace situations,
and if so what kind of precautions need to be taken.

RM Training
Opportunities Beyond
Washington, DC
In most regions, the Federal Records
Centers offer one or more training programs in
records management. The most commonly
taught classes cover files improvement and
records disposition; they are abbreviated
versions of the 2- and 3-day classes taught in
Washington, DC. Some records centers also
offer a two hour briefing titled "Records
Management for Agency Managers" and a half
day introduction to the records center and its
Check with the Accession and Disposition
Branch of your Federal Records Center for
details. Some records centers will do
customized training for your offices on a
reimbursable basis. Again check with your
local records center as to whether it currently
offers this service. $
Retiring Audiovisual
Records to NARA
The Multi Media Division (OCEPA) at
Headquarters has transferred over 60 cubic
feet of videos and other films to the National
Archives. Most films date from the 1980s and
include news reports, speeches, interviews,
press conferences, and documentaries. While
few programs have transferred audiovisual
records to NARA, the process is really quite
EPA has a comprehensive records
disposition schedule that covers most types
of films, photographs, and audiotapes.
Generally pemanent audiovisual records are
transferred directly to the National Archives in
Washington or to the Regional Archives.
Contact Mike Miller, Agency Records Officer,
at 202-260-5911 if you are interested in
determining the proper disposition of
audiovisual records in your custody. #
From the Diary of a Records Manager
It ail started with me doing a
foolish thing; I answered my
phone. The frantic caller, a
fellow records manager said, "I
just got a call from one of the
chemists and he wants to know
where he is supposed to store a
contaminated fish. After he
analyzed it, he froze it in a block
of ice. Now he wants to know
where to store it and for how
First I had to stop laughing.
Then I had to bite my tongue,
because the place I thought of
storing the fish was not very
¦rofessional. I got somewhat
under control and I asked a few
"Ok, this fish has been
analyzed and there is a report,
right?" "Yes, there is a report."
"I'm pretty sure that the report is
the record and the fish can be
destroyed. I know I haven't seen
fish in the records schedules."
"Well, what if there Is litigation?
Do we have to keep the fish as
evidence?" "I don't think so, but
I'll check with headquarters."
My headquarters contact
laughed until she cried. "I can't
wait to pass this one along. I
know what I would tell them to do
with the fish." "Yeah, that was
my initial reaction too; but the
chemist was serious. I don't
think he would appreciate where I
think he can stick the silly thing."
By the next day I had an
electronic mail message. Sure
enough the report was the record
and the fish could be laid to rest.
But all that kept flashing through
my mind was a wall of freezers in
the records center with blocks of
fish staring at me. (The story is
true, only some of the dialogue
has been changed to protect the
guilty.) #

The National Archives has standardized a new design for two of its records
retiring boxes, or "FRC boxes," to maximize overall effectiveness. These are
the boxes used by federal agencies to transfer inactive letter or legal size files
and magnetic tape records to Federal Records Centers.
8 boxes have been re-designed in two distinct sizes with the following
ird features:
A "lock-bottom" style to enhance records security while in transit.
Pre printed instructions for agency use in packing and
labelling the boxes.
increased bursting strength to resist crushing of filled boxes in
transit or while stacked.
Reinforced hand holes on each end to facilitate carrying boxed
records or withdrawing them from shelf storage.
A white exterior surface to enhance readability of annotations
on box exteriors.
Additional information about the boxes is provided in a General Services
Administration (GSA) statement entitled, "Commercial Item Description A-A-
670B." To help facilitate assembly of the new "lock-bottom" style boxes by first-
time users, a simple 5-step graphic entitled "Assembly Instructions" is included
with the statement. The memorandum from the National Archives noted that its
former "oversize" FRC box has been eliminated from the "Commercial Item
Description" because the box is too long and too tall for the standard FRC
service aisles.
GSA expects that the new standard boxes will be available from the normal
sources in Federal Supply Service (FSS) by about mid-February 1993, or as
soon thereafter as the existing stocks are exhausted. At this time the new box
for retiring letter or legal size files is available to those agencies that requisition
from FSS in Stockton, California, under NSN 8115-00-117-8249.
Anyone who did not receive a copy of the National Archives memorandum,
"New Design for Federal Records Center (FRC) Boxes" and the GSA statement,
"Commercial Item Description," can obtain them from Joe Moeltner (contractor),
Records Support, at (202) 260-5272. *
for FRC
INFOACCESS, a forum to provide information and report on progress in information
management across the Agency, is produced by the Information Access Branch of the
Information Management and Services Division, Washington, DC under the direction of
Michael Miller, National Records Management Program Manager. Please send comments
and suggestions to: Mary Hoffman (contractor), Network Coordinator, PM21 IB,
401M Street, SW, Washington, DC 20460. Telephone: (202) 260-7762. Electronic Mail: Hoffman.Mary.

In October 1992, over 140
draft records disposition
schedules covering Agency-wide,
Headquarters-wide, and Regional
records were sent out for
comment. Comments were
requested on all aspects of the
schedules including format
convenience, completeness
of coverage, adequacy of the
dispositions, clarity, correctness,
and usefulness of the
information. Reviewers
were also asked to note any
potential problems in applying the
schedules and to suggest
additional schedule items if
Comments were received from the
Headquarters offices of FMO, PCMO, IMSD,
OSWER, RSCA, and OW; Regions 3,4,5,6,7,9
and 10; as well as EMSL-Las Vegas, HERL-RTP,
ERL-Duluth, and NEIC.
Comments on the format of the schedules were
varied. Some reviewers liked the new format, others
had suggestions for modifying it, and some felt there
were too many pages to look at. Some of the
suggestions for improving the format included:
~	Providing the information in a table format.
~	Including a forms index.
~	Moving the sections around into a different
~	Eliminating either "program" or "applicability"
sections or redefining them.
~	Adding an additional listing of disposition
schedules by series title for ready reference.
Concern was expressed by some reviewers that
the "applicability" section could be a problem
because functions may be performed by different
program offices in the Region, or the Agency may
decide to reorganize.
Comments were received on most of the
individual schedule items. Again, comments were
Comments on
Revised Records
by Sandy York (contractor),
Regional Program Director
for Records Management
varied, and covered all sections
of the schedules, including:
~	Expanding the identifying
~	Increasing or decreasing
retention periods.
~	Changing the disposition or
file break instructions.
~	Adding more cross
referencing and legal
Suggestions were received for consolidating
some of the schedules and adding some new ones
(e.g. Systems Life Cycle Management records). A
number of comments were received asking for
clarification on schedules dealing with projects,
special studies, contracts, and grants. In some
cases, where records were scheduled for
permanent retention, recommendations were made
to keep only portions, of the series permanently.
The NRMP would like to thank the reviewers for
their comments and looks forward to completing the
next step in the process - to study and incorporate
the comments. Some of them will be easy to
incorporate, others will require more thought (e.g.
EPA 214R - "Disposition recommendation: 2-3
cycles because when the Standard Monitoring
Framework is in full use, the disposition does not
permit adequate trend comparisons, especially for
Direct Implementation systems.") And in some
cases, conflicting recommendations were received.
(e.g. EPA 205R - Some reviewers felt draft permits
should be destroyed after approval of the final
permit; others said they shouldn't.)
After the comments are incorporated, schedules
will be prepared for green border review. The
package will include the revised schedules, an
introduction, an explanation of the schedule fields,
and indexes arranged by series number, series title,
program and applicability. *

You all should know that
the best way to get the latest
information on records
management at EPA is
through electronic mail. Mike
Miller, the Agency Records
Officer, regularly sends
information to records
management liaisons through
EPAs' All-in-1 electronic
messaging system. So it is
important to be connected to
the system.
To help Mike - and
everyone else - reach out to
managers working with
RCRA files, a new RCRA
Records Management
Distribution List was
established. The name of the
list is @RCRA.Records. To
use the list just type
"@RCRA.Records" at the
"TO:" prompt on the Message
Header. Then add the text and
send your message.
There are a number of
other records management
distribution lists available on
All-in-1, including the
@SF. Records - Superfund
Records contacts
@Lab.Records - records
managers in EPA laboratories
The Controversy Over
Electronic Mail by Michael L. Miller, IMSD
Electronic mail (email) has been in the news lately. Numerous
articles concerning the White House email records and whether they
should or should not be erased brought what has been a rather
esoteric debate among records managers and archivists to the front
pages of the Washington Post, Federal Computer Week, and New
York Times. The question of whether email messages are actually
Federal records was at the core of the debate.
Email is not specifically mentioned in EPA's records management
manual (Directive 2160), but both it and Chapter 10 of the IRM
Manual (Directive 2100) talk of Agency records "regardless of
medium." At EPA, the medium that carries the message is irrelevant
to the records question. What matters is whether the message
conforms to the definition of an Agency record. If so it must be
retained in some form for the period of time required in the
appropriate records disposition schedule. The retention may be either
in electronic or paper form. In either case the message must be
managed so that it can be preserved, accessed, and used for the life
of the records as stated in the records disposition schedule.
The question is one that deserves detailed study, because the
position the Agency takes can have important ramifications. The
review of electronic records policy issues currently underway will look
carefully at the issues involved. For more information concerning the
policy review contact Mike Miller, Agency Records Officer, at 202-
260-5911 or at Miller.Michael-OIRM on All-in-1. ~
@HQ.Records - records
managers in EPA Headquarters
<5>Maj.Records - principal
records contacts in EPA Regional
To view the names of those
listed on any of the distribution
lists, go to the Distribution Lists
Menu and type "SEL", then the
name of the list, then "R" for
read. You can get to the
Distribution Lists Menu by typing
"DIR DL" at the Electronic
Messaging Menu on All-in-1.
If you have any questions
about the distribution lists for
records management, contact
Mary Hoffman (contractor),
Network Coordinator, at (202)
260-7762; Email box -
Hoffman.Maiy. &

Regional Records Retirement Activity
Congratulations to Regions 3,4, 5, and 6 for their
Total Number of Cubic Feet
records retirement efforts! They retired the most records

of EPA Records

to the Federal Records Centers last year. It is interesting

Retired to Regional

to note that roughly 50% of the total figure was retired by
Federal Records Centers
Superfund programs. Overall Regional offices retired a

for Fiscal Year 1992

total of 9,803 cubic feet (or 12,253 linear feet) of records,

which translates into a cost equivalent (cost avoidance)
in *
Region 3
Philadelphia, PA
ii i.
Region 6
Fort Worth,TX
1,307 5-drawer file cabinets.
Region 5
Chicago, IL
The cost to store these records in EPA office space:
Region 4
Atlanta, GA
Region 1
Boston, MA
Region 7
Kansas City, KS
The same 9,803 cubic feet of records stored at the
Region 9
Los Angeles, CA
Regional Federal Records Centers is costing the Federal
Region 2
New York, NY
Government $15,782.00 annually ($1.61/cft).
Region 10
Seattle, WA

Region 8
Denver, CO
The potential cost savings for EPA:


Total Number of

Cubic Feet for

ALL Regions:

INFOACCESS likes to recognize
records and information management
staff for excellent work in the field of
records management.
Welcome to the Network!
~	Kathy Herrln is the new principal
contact for the Office of Administration
and Resources Management (OARM)
at Headquarters. Katharine Lewis, is
the new alternate OARM-HQ contact.
~	Yvonne Pederson Is the new Region 9
Records Officer.
~	Patricia Lyttle is the new Records
Management Officer for the Office of
Policy, Planning and Evaluation at
~ Manker Harris (contractor), joins the
Regional Records Program in Region 5.
Medals and Awards
We found out that, in December, Region
5 Records Officer, Lynn Calvin, was
awarded a bronze medal for her excellent
work on the Region's "move implementation
team." Lynn also received a medal earlier in
the year [1992] for her work on the move
preparation team. Way to go, Lynnl
Susan Daves (contractor), Librarian for
Removal ARs in Region 9, was recognized
for her continued dedication and professional
service in the preparation of Administrative
Records and the indexing of files. Keep up
the good work. Susanl *


Headquarters Update
HQ Records Management
The Headquarters Records
Management Council met for its
regular monthly meeting on
January 28,1993. Topics of
discussion included the National
Archive's response to EPA's
action plan for records
management, training and
outreach, and Mike Miller's
upcoming presentation at the
March SIRMOs meeting. The
Council heard updates about
records schedules, file plans,
personal papers and electronic
records policy. In addition, some
of the Council members reported
on program activities including an
OPP Document Management
Section Open House scheduled
for April 1st, and an OSWER
workgroup on the disposition of
contractor records. The next
Council meeting is scheduled for
February 25,1993 from 10:00 to
12:00 in the Information
Management and Services
Division conference room
(WSM M2003).
New Files Management Training Scheduled
The National Records Management Program (NRMP) is
sponsoring a new 2-day training workshop to examine the variety of
file plans, discuss the "hows" and "whys" of filing, provide models for
developing appropriate filing systems and assist participants in
resolving their special filing problems.
The training is targeted towards staff responsible for setting up
filing systems, including executive secretaries, administrative officers
and other management personnel.
Training Objectives
Upon completion of this training, participants will:
~	Understand why File Plans are necessary.
~	Understand how a File Plan fits in with the
overall filing system.
~	Understand and be able to discuss the various
types of File Plans.
~	Understand and be able to develop an office File Plan.
~	Identify and select appropriate file equipment
and supplies.
The first session of this new training has been scheduled for
April 1993. It will be held in the EPA Education Center at Waterside
Mall, and the fee for the training is $150. If you have questions about
the training, contact Harold Webster at (202) 260-5912 or Debora
Dorsey, (202) 260-6678.
Revised Records Disposition Schedules
Sandy York (Contractor), Regional Program Director, has
summarized the comments on the revised schedules. Mike Miller is
looking at whether there is a need for a group review of the Agency-
wide, Headquarters-wide and Region-wide schedules, to finalize them
for green border review.

Headquarters and Chemical Libraries
Filing System	"
from page 3
Some Final Tips
1301 Corfetttutk)1

Keep the file plan simple. Let
the records structure themselves
when at all possible. For example
don't make up an alpha-numeric
filing scheme for permits that
already have a number.
The National Records
Management Program (NRMP)
has a useful alpha-numeric filing
plan for basic administrative
records common to most offices.
It works well for Series EPA 110
and other administrative files.
If you have a long series,
consider using color coding for
files or special folders to make
filing simpler.
Have program staff assist in
developing the file plan. They will
have useful suggestions, and
they will feel more positive about
using the file plan if they had a
hand in developing it.
Don't reinvent the wheel.
The NRMP has copies of many
file plans for Headquarters and
Regional offices. One of them
may save you the time of
developing your own. &
There is no one arrangement scheme that is best for all records.
Here are some basic suggestions on the major ones. For more
information consult any records management text book, or contact
Joe Moeltner (contractor) at 202- 260-5272 for a bibliography of what
is available in the records management collection.

ement Schemes
~	Chronological: Arranged by date. Most useful for small files and
for records that have a very short life span so that you can
destroy older materials without difficulty.
~	Numeric: Arranged by number. In its simplest form, a serial
arrangement beginning with the lowest number and proceeding,
but more complex systems can be used for large series. Best for
case files of one type or another, permits, and forms where
numbers have already been assigned.
A Alphabetical: Arranged in alphabetical order from A-Z. This is the
basic arrangement for most subject files. There are books written
on both how to assign the titles that are put in alphabetical order,
and how to alphabetize the folders (Do you file University of
Maryland under "University" or "Maryland?"). Alphabetical subject
files are difficult to manage unless they are very focused, and the
filing and identification of folders is consistent. If you have a folder
that concerns the publication of a Federal Register notice
concerning a regulation on a specific chemical, do you file it under
Federal Register Notice, regulations, or the name of the
chemical? Best used for small files or very consistent ones where
the folder titles are easily determined - e.g. a file of all outgoing
correspondence arranged by addressee.
~	Alpha-numeric: Arranged according to an identifier made up of
letters and number. The file code for records series described in
the insert is an alphanumeric system. Whenever possible the
alphabetic and numeric parts of the identifier should mean
something rather than being arbitrarily assigned. *
12 Months to
Effective Files:
Next Steps
This is the continuation of a 6-step program to effective files. Step 1 was
covered in the October issue of INFOACCESS, Step 2 in the December
issue, and Step 3 has been outlined in this issue. These are the steps that
will be covered in future issues:
Step 4: Develop recordkeeping requirements for corporate
records series (Months 7 & 8).
Step 5: Improve files management via technology, indexing,
and specialized equipment (months 9 & 10).
Step 6: Produce a records management manual (Months 11 & 12). #