United States
Environmental Protection
Agency
Information Resources
Management
(PM-211D)
EPA 220-N-93-027
Issue Number 32
August 1993
&ERA INFO ACCESS
Records Network Communications
In this Issue...
Landmark Cases
p. 6
OPPT Tour
p. 8
Revised OMB A-130
p. 10
NARA's Optical
Disk Policy
p. 12
Ask Dr. Records
p. 13
Removal of Agency
documents
p. 14
GRS Transmittal #6
p. 18
Step 5: Applying Technology to
Records Monagement
by Michael L. Miller, Agency Records Officer
People frequently turn to technology because they find that they can't manage
their paper records. Either they are swamped by too much paper on site, or they
can't find the documents they need, or both. By itself, tecnnology cannot fix a
records management problem; technology applications need a lot of research and
planning to be effective. The old saw is true: if you try to automate a records
management mess you will have an automated mess.
However, technology, even simple technology, can make a basically sound
records management system operate better. This article will look briefly at a
number of technological "fixes" and the types of problems they can help remedy.
For more technical guidance on applying technology, I strongly recommend the
new General Services Administration publication, Applying Technology to
Records Systems (see page 3).
Before You Cut the PR ...
There are two steps to take before rushing out to buy any hardware or
software. These steps are equally valid if you are looking to improve a cabinet of
branch correspondence files or the management of millions of Superfund
documents. The scale may be different, but the steps are the same.
First, take the time to study the current situation, diagnosing what the
problems are with the current recordkeeping system, analyzing what needs to be
done to meet those needs, and then planning out what a new system should
accomplish. Second, examine whether a simple change in how you currently do
business can remedy your problem. In many cases improving the manual system
can either solve the problem or at least allow you to focus the technology
application on improving specific aspects of the records system. Examples of
"manual solutions" to records problems are provided below.
However, simple fixes don't always resolve the problem, and in many cases,
such as the Superfund program, the sheer volume of records and the special
problems they pose mandate that the program go beyond a well run manual
system to implement technology solutions.
Continued on page 2
Recycled/Recyclable
Printed with Soy/Canoia Ink on paper that
contains at least 50% recycled fiber

-------
Applying Technology
from page 1
Types of Technology Applications
There are 7 basic types of technology
applications to assist you in managing your records
better:
~	Better filing equipment to improve the storage
and retrieval of records.
~	Document conversion technology such as
optical imaging and microform to reduce the
volume of paper on site and allow more
efficient workflow.
~	Document indexing to allow for retrieval of
records in multiple ways.
~	Document tracking and control systems to
enable you to track documents or folders from
creation to final disposition.
~	Special purpose programs that allow you to
automate specific aspects of records
management such as records disposition
schedules or retiring records to a Federal
records center (FRC).
~	Document access and distribution media
records managers can use to allow staff to
access information electronically.
~	Electronic forms programs to improve
workflow and increase the usability of
information contained on the forms.
ACCESS

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, PM-211B, 401 M Street, SW,
Washington, EXT 20460. Telephone:
(202) 260-7762. Electronic Mail: Hoffman.Mary.
Matching Technology to Problems
Let's look at our two typical records
management problems and see what types of
solutions technology offers.
Too Much Paper!!
Mgnggl S
-------
Applying Technology
to Records Systems:
A Media Guide
As technology continues to expand our
informational horizons and increase its
importance in our working lives, we find more and
more options regarding the way we handle
recorded information. With this increase in
options, there is a corresponding increase in the
number of decisions that must be made regarding
the record media.
Continually engaging in unplanned, costly,
time-consuming and disruptive media
conversions is not the most productive method of
information management. Record systems can
be designed that function effectively throughout
the entire information life cycle. By fully
understanding the available media, necessary
conversions can be planned for as an integral
part of the records system operation and can be
conducted efficiently and economically.
This Media Guide was created by the U.S.
General Services Administration (GSA) to help
Federal agency personnel more fully understand
their media options. It discusses paper,
microform, digital storage, magnetic media,
optical media, and their physical properties and
limitations. There are specific chapters on the
properties of records that affect conversion,
indexing, storage and retrieval, information
capture, and cost considerations. The final three
chapters look at organizational considerations,
matching media to needs, and approving a
change in the medium.
A copy of this publication is being sent to
records liaisons in each Headquarters Program
office, laboratory, Regional office and facility. If
you have any questions regarding technology or
records systems, please contact Michel L. Miller,
Agency Records Officer at (202) 260-5911, or on
AII-in-1 at MILLER.MICHAEL-OIRM. If you would
like to obtain a copy of this publication, please
contact Joe Moeltner (contractor) at (202) 260-
5272, or on AII-in-1 at MOELTNER.JOSEPH. 
-------
Applying Technology from page 4
Special Purpose Programs
There are several areas where automation of one or more phases
of the life cycle can simplify records management tasks. There are
several programs available that Regions can use to develop the
SF-135 form to retire records to the FRC. Using the FRC's Center
Information Processing System (CIPS) simplifies the records retrieval
process. Region 5 and others have put the records disposition
schedules into packages such as InMagic to enable them to print out
customized products tailored to individual program needs. Just having
schedules in WordPerfect allows them to be searched for individual
terms. These relatively low cost systems save a lot of effort and
provide great benefits in terms of improved control over your
information.
Document Distribution
Providing increased access to information isone place where
technology offers a number of options. In looking at the dissemination
of records disposition schedules for example, it is possible to consider
distributing them on diskette, putting them in a relational database,
providing the text online via a bulletin board or videotext in All-in-1, or
supplying them to programs on CD-ROM and loading them onto the
local area network. Individual programs are looking at similar methods
for getting their program specific information out in electronic form.
Workflow
One of the fastest growing areas in records management is to
create, process, and store records electronically without ever going to
paper form, or the processing and storage of documents converted to
electronic forms from paper. We'll look at this questions in the next
issue of INFOACCESS.
Don't Reinvent the Wheel
Most of the records management applications discussed above are
operational in one or more Agency offices. To find out more about
where a specific application is being used, contact Sandy York
(contractor) on (303) 840-0464, or York.Sandy on AII-in-1. *
	
6 Steps to
Better Files
This article is the fifth in a
series of six that form the
steps of a program to effective
files management. Four
previous steps have been
outlined in the records
management issues of
INFOACCESS, between
October 1992 and June 1993.
Reprints of those four
"Step" articles are available in
a flyer format from the
National Records
Management Program
(NRMP).
6 Months to Better Files,
May 1993, EPA220-F-93-
007. [An overview of the
series]
Step 1: Understanding the
Scope of the Problem, May
1993. EPA 220-F-93-008.
Step 2: Conducting a
Records Inventory, May
1993. EPA 220-F-93-009.
Step 3: Developing the
Filing System - The Filing
Structure and File Plan, May
1993. EPA 220-F-93-010.
Step 4: Developing
Recordkeeping
Requirements, July 1993.
EPA 220-F-93-012.
The article outlining Step
6: Producing a Records
Management Manual wilt
appear in the October issue of
INFOACCESS. ~
INFOACCESS Hj||	AUGUST 1993
-------
Headquarters Update
Records Management Council
The Council meeting for July was hosted by the
Office of Pollution Prevention and Toxics, who
conducted a tour and demonstration of their image
processing system, a tour of their Confidential and
Non-Confidential Information Centers, and a
demonstration of their automated document tracking
system. See the article beginning on page 8 for a
description of the tours and demonstrations. The
next Council meeting is scheduled for August 26th,
in IMSD's Conference Room, at 10 am.
CBI Workgroup
The Workgroup that is revising the Agency's
confidentiality regulations at 40 CFR Part 2, Subpart
B is reviewing a second draft of the proposed
revised regulations. Workgroup closure is
scheduled for August 31.
Manuals on CD
The National Records Management Program
(NRMP) is participating in a project to put IRM policy
manuals on CD-ROM. The CD will include several
records management publications such as the
records management manual, the Headquarters
guide to using the FRC, and the Model Regional
Manual.
Regional RM Teleconference
The regular Regional records management
teleconference was held on June 23. Participating
records managers discussed a number of issues,
including timekeeping records, Regional response
to the NARA evaluation, revised records disposition
schedules and records inventories. Mike Miller
asked for volunteers for a workgroup that will
develop inventory-related materials for Agency
records managers. After some discussion about the
workgroup, the Regional Records Officers reported
on the status of work in progress at their sites. The
next teleconference is scheduled for Thursday,
September 2nd at 2:00 pm.
RM Guidance Bibliography
Under the direction of Lisa Jenkins, Records
Officer, OSWER's records management staff have
developed a bibliography of records management
guidance. The bibliography includes file structures,
records center operations manuals, filing systems,
guidance manuals, floor plans, records center
procedures, and microfilm standards.
Records Management Training Available
The NRMP will come to your facility to do
records management training. At this point the
organization requesting training must pay travel
expenses, but training will be tailored to your
specific needs. Mike Miller, Agency Records
Officer, recently completed training sessions for the
Office of Research and Development laboratory in
Athens and the Office of Solid Waste. Training is on
a first come, first serve, basis at this point. Contact
Mike Miller at (202) 260-5911, or
MILLER.MICHAEL-OIRM on AII-in-1 for details.
Headquarters Records Management
Iniatives
The Office of Administration and Resources
Management and the Office of Enforcement have
initiated projects to evaluate their records
management needs using contractor support.
Their statements of work are based on a model
Statement of Work developed by the NRMP. Wc, k
will begin during FY 94. For details contact IV^e
Miller at (202) 260-5911 or MILLER.MICHAE!
OIRM on AII-in-1. *
AUGUST 1993
S
INFOACCESS
-------
Determining
Landmark
Status in
Region 1
During a Regional records management teleconterence held earlier this year,
Yvonne Pederson, Region 9's Records Officer, initiated a discussion about
enforcement action case files. Barbara Callahan (contractor), commented about
the way the Region 1 works with Agency attorneys to determine "landmark
status" for enforcement cases. We asked the Region 1 records management
staff to elaborate on those comments for the network, and they provided the
following description of the process.
Enforcement Action Case Files
The disposition of enforcement action case files is governed by EPA Records
Control Schedule NC1-412-85-20, Item 5. When no legal action or routine legal
action is required for a case, the total retention period for the files is five years
and twenty years respectively; the files are temporary.
But for "landmark status" cases, the files are permanent. After the case is
closed, the files remain in the office for five years, then the files are transferred to
the Federal Records Center (FRC) for another fifteen years, after which the files
are offered to the Regional Archives.
Research into Landmark Status
The Regional records management staff examined a National Archives and
Records Administration (NARA) Disposal Authority Report and other Regional
documents, and spoke to senior officials at the Boston FRC to derive guidance
for Regional staff to follow when assigning landmark status to Regional
enforcement cases. [According to the NARA Disposal Authority Report (08), as
of May 1991, only the Washington National Records Center has scheduled
landmark cases. They used disposition authority NC1-412-85-2/5AB:
administrative law judge (ALJ) case files. All ALJ cases sent to Headquarters
are considered landmark, without further differentiation, but the Regional portion
of an ALJ case is not covered by this.]
Region 1 s Discussion about Landmark Status
A meeting was held on May 4th with a twofold purpose: to establish criteria
for Region 1 attorneys to follow when assigning landmark status to enforcement
case files; and to review the list of case files located in the Regional Office's
Records Center and assign landmark status where appropriate.
Regional records management staff and Office of Regional Counsel staff
participated in the meeting.
The group was of the opinion that the following criteria should be used in the
determination of landmark status:
~	Significantly complicated site with many units and multiple media.
~	Precedent in how the site was treated.
~	New legal territory, that is of historical significance in the
development of the law.
Continued on page 7
INFOACCESS
AUGUST 1993
-------
~	Significant controversy
involved.
~	Whether the case was
taken to the Appeals Court.
~	Attorney "instinct."
~	Enormous sums of money
involved.
~	Great number of parties
involved.
The group also believed that
landmark status would be
infrequently assigned and most
often only after a case was
closed. Also, congressional
inquiry or being cited in Region
1 's Enforcement
Accomplishments Report were
not singular criteria to use. As a
result of the meeting, a number
of cases were designated as
"landmark" cases that will require
permanent retention.
As a followup to the meeting,
the group defined a number of
action items, including the
flagging of case files recently
assigned landmark status;
consolidation of case files lists;
establishing of an annual review
of closed cases with Regional
attorneys at the time the Enforce-
ment
Accomplishments Report is
written; reviewing criteria
considered by other agencies
when assigning landmark status;
and defining part of the file to
include when retiring landmark
status case files. * Contributed
by Barbara Callahan (contractor),
Region 1 Records Management
Coordinator
Tip of the Hat
INFOACCESS likes to recognize records and
information management staff for excellent work in the
field of records management, the development of special
products, completion of significant projects, or
acknowledgement of Agency awards.
Welcome to the Network!
~ Joan Alcock, Office of Enforcement, Headquarters
«• Ellen Hunt, Environmental Research Laboratory,
Duluth, Minnesota
Recognized for Community Service
A few of our colleagues were awarded EPA's Employee
Recognition Award for their community service.
Dot Cook (Office of Pesticide Programs) was recognized
for her work with several organizations in the area,
including House of Ruth and My Sister's Place. She also
teaches fellow employees about cultural diversity.
Brenda Daly (Office of Information Resources
Management) was recognized for her work with Children's
Hospital and the Hospital for Sick Children.
Bessie Hammlel (Office of the Administrator) was
recognized for her coordination of an effort to collect
Christmas gifts for children at St. Ann's Infant Home.
Keep Up the Good Work 11
We tip our hats to Nancy Yarberry and all of the Region 6
records staff who are incorporating records management
requirements in their imaging initiative.
Thanks for the Memories!
We also tip our hats to Mary Hoffman (contractor) who is
leaving after 2 years as editor of INFOACCESS, for all of
her work in making the newsletter what it is. Best of luck!!
AUGUST 1993
7
INFOACCESS
-------
OPPT Hosts HQ RM Council Meeting
Georgianne McDonald, from the Information Management Division of the Office of Pollution Prevention
and Toxics (OPPT), invited the Headquarters Records Management Council to attend a special session of
the monthly Council meeting in OPPT space. Several Council members participated in a tour of OPPTs
Non-Confidential Information Center and demonstrations of its optical disk system and automated document
tracking system.
OTSIPS [Office of Toxic Substances Image
Processing System]
The meeting/tour started next to OPPT's 64-
platter jukebox in OPPT's computer room. Joanne
Martin and Les Smith, OPPTs computer experts,
talked about the system and the importance of their
relationship with the OPPT scientists and
researchers. OPPT chose to develop an optical disk
system for its records because of the volume of
material, especially the documents related to
Pre-Manufacturing Notices, to be managed. They
started scanning Section 5 (TSCA) documents into
the system in September 1991. Approximately
twelve fields are indexed; the case number serves
as the unique identifier in the system.
Scanning Documents
The scanning and quality control is performed in
an adjacent office. Once the documents have been
scanned into the system and quality control has
been completed, the paper copies are boxed and
shipped to the Federal Record Center, to be
disposed according to the Agency's records
disposition schedules. Currently OPPT staff are
rewriting all records disposition schedules to include
the optical records, and they hope to expand the
system to include documents relating to TSCA's
Section 8. Since 1991, OPPT has added several
terminals in its offices for staff to view the
documents, and has produced no microfiche for the
documents added to OTSIPS.
Retrieving Documents
Retrieval of the documents on the system can
be accomplished by menus, including the retrieval
of related documents. These related documents
have been linked logically by reviewers familiar with
the information included in them. It was interesting
to note that the documents are stored on optical
disk but the index values that facilitate searching are
stored on magnetic tape. The workstations
connected to the system have a number of features
to faciliate retrieval and use of the documents,
including boolean logic and wild card characters to
enhance the search process, graphics capabilities,
magnification of all of parts of documents, the ability
to rotate the image on the screen, the ability to
redact parts of the document.
NCIC [Non-Confidential Business
Information Center]
As she walked them through the Non-
Confidential Information Center, Georgianne
McDonald Informed the group that it was "moved" to
the Information Management Division when OPPT
reorganized in 1992. Since the reorganization, IMD
staff have reviewed and revamped the flow of
documents between all sections of TSCA, and are
rewriting records disposition schedules to make
sure that all documents are covered and that the
schedules better reflect the life of the documents.
Continued on page 9
INFOACCESS
3
AUGUST 1993
-------
Georgianne commented that TSCA's complexity is
mirrored by its records; its sections don't interrelate
much. The documents managed by the OPPT
dockets contain information from the 1970's to the
1990's, some of which have been retired to the
Federal Records Center. (See the box on this page
for additional information about TSCA dockets.)
CBIC [Confidential Business
Information Center]
Next Georgianne walked the group to the
Confidential Business Information Center (CBIC),
which is in the basement of the East Tower. The
group was not able to tour inside the Center
because of the sensitivity of the information stored
there. Georgianne and Bette Drury (contractor),
talked to the group just inside the door of the
Center.
The CBIC is composed of the Document
Receipt Office (DRO), the Original File Room
(OFR), and the Document Disposition Unit (DDU).
The DRO forwards time-sensitive documents to the
OPPT staff, who determine the document types.
The OFR is the repository for most of the TSCA
related documents. The CBIC uses two systems to
track the documents it manages, the Document and
Personnel System (DAPS) and the Confidential
Business Information Tracking System (CBITS).
The CBIC works with the Document Control Officers
(DCOs) in the Regions to track documents sent and
received.
Automated Document Tracking System
Les Smith introduced the group to OPPT's
automated document tracking system. He assured
the group that the system does fulfill requirements
for tracking CBI documents. It was developed in
dBase III+, as a PC stand-alone version; a LAN
version would require a great deal of additional
programming. It will be released to the Agency
eventually, after some testing is done.
Continued on page 15
(
OPPT Dockets
)
Since OPPT's reorganization in October
1992, Georgianne McDonald has been
overseeing the management of its dockets,
including the
~	Non-Confidential Business Information
Center (TSCA Sections 5 and 8)
~	Environmental Leadership Program
(ELP)
~	Integrated Risk Information System
(IRIS)
~	Design for the Environment
At a June meeting of the Headquarters
Records Management Council, Georgianne
talked about the dockets, explaining that the
OPPT dockets are more complex than those
managed by some of the other programs.
She said that beginning last October, OPPT
staff have been meeting weekly to review the
management and operations of the dockets,
focusing particularly on the flow of documents
between the sections of TSCA. They produced
flowcharts to document the flow of the
documents and then planned to streamline the
process for automation. This group decided to
convert the documents directly to optical disk,
bypassing storage on microfiche or microfilm.
OPPT is beginning to develop the indexes
needed to access the material for Sections 5
and 8 of TSCA.
As OPPT worked its way through this
process of review and analysis, the staff
received and responded to several requests for
assistance from other program offices,
including the Office of Air and Radiation and
the Office of Water. &
AUGUST 1993
9
INFOACCESS
-------
Records Management and the
Revised OMB Circular A-130
by Michael L. Miller, IMSD
The revised Office of Management and Budget
(OMB) Federal Information Resources Management
(IRM) Circular A-130 (commonly referred to as
A-130) finally became effective on June 125,1993.
A-130 seems to have been in draft (s) forever and
its publications in final form is an important
milestone for records management in the Federal
government. Why? Because one of the reasons for
revising A-130 was "to bring into focus ... areas not
sufficiently emphasized in the original," and one of
those areas is records management.
Records Management and IRM
The revised A-130 now places records
management squarely within the IRM framework,
and stresses the need to manage electronic records
as a federal information resource. The sections of
the revised circular most pertinent to records
managers have been excerpted [See the box on this
page]. However I would like to briefly summarize the
changes here, because many of them consistute a
strengthening of the role of records management in
IRM.
Taking a Closer Look at the Sections
For records managers, the important changes in
A-130 begin in Section 6, Definitions. Because the
circular now explicitly addresses records
management, Section 6 now includes definitions of
"record," "records management," and "information
life cycle." More good news is that OMB has
decided to use the existing definitions of records
and records management from 44 USC 3301 and
2901 (2) respectively.
Section 7, Basic Considerations and
Assumptions, includes a paragraph on the
importance of records management in sound public
resources management. The thrust of this
paragraph is the need for public accountability and
Excerpts from Circular A-130
Revised [June 25,1993]
Section 6 Definitions
h. The term "Information life cycle" means the
stages through which information passes, typically
characteized as creation or collection, processing,
dissemination, use, storage, and disposition.
n. The term "records" means all books, papers,
maps, photographs, machine-readable materials,
or other documentary materials, regardless of
physical form or characteristics, made or received
by an agency of the United States Government
under Federal law or in connection with the
transaction of public business and preserved or
appropriate for preservation by that agency or its
legitimate successor as evidence of the
organization, functions, policies, decisions,
procedures, operations, or other activities of the
government or because of the informational value
of the data in them. Library and museum material
made or acquired and preserved solely for
reference or exhibition purposes, extra copies of
documents preserved only for convenience of
reference, and stocks of publications and of
processed documents are not included. (44 U.S.C.
3301)
o. The term "records management" means the
planning, controlling, directing, organizing, training,
promoting, and other managerial activities involved
with respect to records creation, records
maintenance and use, and records disposition in
order to achieve adequate and proper
documentation of the policies and transactions of
the Federal Government and effective and
economical management of agency operations.
(44 U.S.C. 2901 (2).
INFOACCESS Bi
AUGUST 1993
-------

x
Section 7 Basic Considerations and
Assumptions
h. Systematic attention to the management of
government records is an essential component of
sound public resources management which
ensures public accountability. Together with
records preservation, it protects the government's
historical record and guards the legal and
financial rights of the government and the public.
Section8 Policy- a.Information
Management Policy
1. Information Management Planning.
Agencies shall plan in an integrated manner for
managing information throughout its life cycle.
Agencies shall:
a. Consider, at each stage of the information
life cycle, the effects of decisions and actions on
other stages of the life cycle, particularly those
concerning information dissemination.
j. Record, preserve, and make accessible
sufficient information to ensure the management
and accountability of agency programs, and to
protect the legal and financial rights of the Federal
Government.
k. Incorporate records management and
archival functions into the design, development,
and implementation of information systems.
4. Records Management. Agencies shall:
a. Ensure that records management programs
provide adequate and proper documentation of
agency activities;
Continued on page 12
the role of records in assuring that accountability is
possible. The explicit inclusion of records
management as part of IRM also gives new
meaning to some of the other paragraphs in Section
7, notably the ones on accessibility (7f), privacy
(7g), strategic planning (7i), and information of State
and local governments (7j).
Section 8a, Information Management Policy,
now has an entire subsction (4) on records
management. According to 8a (4), agencies shall
provide adequate and proper documentation of their
activities, ensure the ability to access records
regardless of medium, schedule their records, and
provide training and guidance on records
management responsibilities.
Most records managers will find these to be
familiar requirements, drawn directly from the
National Archives regulations in 36 CFR 12.
Most IRM types rarely read 36 CFR; but they are
familiar with OMB A-130, which allows records
managers an opportunity for closer cooperation.
Finally in Section 9 on responsibilities, OMB
A-130 requires agencies to create, maintain, and
dispose of records according to the Federal
Records Act. In Section 9a (10), the Circular directs
agencies to designate an official with responsibility
for management oversight of agency audiovisual
productions and establish a program for
management of audiovidual productions, facilities,
and activities, in accordance with 36 CFR 1232.4,
the National Archives regulations on audiovisual
records. This change will also serve to strengthen
the role of records managers in the management of
audiovisual records.
A-130 contains a number of other major
changes that will be of interest to records managers.
The entire circular now embodies a new spirit of
promoting access to government information that
may have a major effect of records management
long term. Those who deal with the Privacy Act
information should be sure to review Appendix I of
the Circular, $
AUGUST 1993
INFOACCESS
-------
OMB Excerpts
from page 11
b. Ensure the ability to access
records regardless of the form
or medium;
C. In a timely fashion,
establish, and obtain the
approval of the Archivist of the
United States for, retention
schedules for Federal records;
and
d. Provide training and
guidance as appropriate to all
agency officials and
employees and contractors
regarding their Federal
records management
responsibilities.
Section 9 Assignment of
Responsibilities
a. Ail Federal Agencies. The
head of each agency shall :
6. Create, maintain, and
dispose of a record of agency
activities in accordance with
the Federal Records Act of
1950, as amended.
10. Designate an office
with responsibility for
management oversight of
agency audiovisual
productions and establish an
appropriate program for the
management of audiovisual
productions, facilities, and
activities in conformance with
the requirements contained at
36 CFR 1232.4. *
Media Coverage of NARA's
Optical Disk Policy
There has been much discussion in the information community
about the National Archives and Records Administration's (NARA)
policy regarding the storage of information on optical disk. In response
to an article that appeared in the June 15 issue of Federal Computer
Week entitled, "NARA extends Non-Optical Policy," Trudy Huskamp
Peterson, Acting Archivist of the United States, outlined three aspects
of NARA's continuing reevaluation of its optical disk policy in a letter to
the editor. She briefly described three developments in NARA's plan
for an electronic archives of the 21st century:
~	The Center for Electronic Records will soon formally
announce that it will accession records in CD-ROM
formats used by the Government Printing Office (GPO).
With a limited number of formats, the Center believes it
can manage the problem of converting the data as the
format becomes obsolete.
~	The Center is working to expand options for electronic
data transfers to include file transfer over networks. This
has a number of advantages for NARA and agencies,
including the elimination of problems with incompatibility
between the media used by the agencies and that used
for storage at NARA. Electronic transfer will allow NARA
to write directly to its storage medium without physically
handling the magnetic tapes or other media currently
received. This also means that the National Archives
will not limit the storage devices agencies choose, as
long as the open transfer standards are observed.
~	This fall, the National Archives plans to release
guidelines for the use of digital imaging and optical
media storage technologies in the Federal Government.
The report, which is based on fifteen in-depth case-studies,
a review of industry trends and standards activities,
addresses critical records management and archives
issues that digital imaging and optical media applications
should take into account.
Dr. Peterson also notes that this does not say that optical disks as
an approved archival storage medium, rather it says that the "rapid
obsolescence of new information technologies makes any designation
as archival transitory." She then says that NARA believes that
Continued on page 16
INFOACCESS
AUGUST 1993
-------
Ask Dr. Records
This is a brand new column for INFOACCESS. We asked Agency records
managers to send us brief records management questions that could be
answered in 25 words or less. These are the first questions submitted by EPA
records managers, and the answers provided by Dr. Records.
Question:
According to 36 CFR 1222.48 (e), all data
created for Government use are considered
Federal records, but can the contractor keep a
copy of records they turn over to us (Agency
records managers)? If so, how do we ensure that
the contractors retained copy does not end up in
the wrong hands?
Answer:
Contractors may keep a copy of the records
they turn over to the Agency. Those would not be
Agency records but their own copies. If there is a
problem with allowing access to any copies they
retain, that should be covered in the contract or
statement of work.
Question:
What is the impact/meaning of the National
Archives and Records Administration (NARA)
Final Rule from the Federal Register for May 28,
1992 (pp. 22331-22434) involving the Privacy Act
and the transfer of records.
Answer:
The NARA rule concerns scheduling records
and not transfer to the Federal records center.
EPA is required to publish a notice in the Federal
Register concerning each system of records
covered by the Privacy Act. If EPA then sends a
records disposition schedule (Form SF-115) to
NARA to approve the disposition of those
records, the Agency must provide the Privacy Act
System number on the SF-115S. Under current
procedures, the National Records Management
Program (NRMP) is the only organization that
sends NARA SF-115. If your program wants to
schedule records from a Privacy Act system,
notify the NRMP and we will locate the system
number and include it on the SF-115.
Dr. Records had a few questions left over this month, and he Is researcNng
their answers for the next Ask Dr. Records column. Dr. Records Is also
Interested in answering your questions, so please send them to Dr. Records
in care of Mike Miller, IMSD, PM-211D; email box Miller. Michael-OIRM.
AUGUST 1993
13
INFOACCESS
-------
Have You Seen This GAP Publication?
In July, 1989, the United
States General Accounting Office
(GAO) published a report in
response to requests from the
House Government Operations
Subcommittee on Government
Information, Justice, and
Agriculture and the Senate
Governmental Affairs
Subcommittee on Federal
Services, Post Office, and Civil
Service to examine various
questions about the legality of
senior agency officials removing
federal records upon leaving
office.
This report responds to the
questions raised and presents
additional information about the
files of officials who could have
been leaving office with a change
of administrations. When leaving
office, some cabinet members
took documents related to official
government business. In many
cases, the former cabinet
members included these
documents in collections of
"personal papers," which were
later placed into public or private
archives. Some collections
included hundreds of thousands
of items.
Are They Federal Records?
The report found that the
legality of removing documents
or papers, which is the subject of
this report, largely depends on
whether they are federal
"records," federal "nonrecord
materials," or "personal papers."
Federal records are legally
defined as documentary
materials that 1) are made or
received by an agency under
Federal law or in the course of
public business and 2) have been
preserved or are appropriate for
Federal
Records:
Removal of
Agency
Documents by
Senior Officials
Upon Leaving
Office
preservation as evidence of an
agency's activities or because of
the value of the information that
they contain. Copies and other
federal documentary materials
that do not meet the criteria for
records status are commonly
referred to as nonrecord
materials. Personal papers
relate only to an individual's
private affairs and not to agency
business.
What Does the Law Say?
The Federal Records Act of
1950 and the Records Disposal
Act of 1943 are two of the
government's primary records
management laws.
Responsibility for records
management oversight is shared
by the National Archives and
Records Administration (NARA);
the General Services
Administration (GSA); and the
Office of Management and
Budget (OMB). Individual
agencies, however, remain
primarily responsible for
managing their own records.
Several laws may relate to
the removal of papers by agency
officials. The Federal Records
Act and the Records Disposal Act
govern the removal of papers if
they consist of federal records,
but not if the documents consist
of federal nonrecord materials or
purely personal papers. The
definition of records specifically
excludes, among other things,
"extra copies of documents
preserved only for convenience
or reference." Consequently, the
records laws do not prohibit
removing such copies.
Criminal laws also govern
1) the removal of federal
documentary materials, generally
excluding extra copies, and 2)
the theft of federal documentary
materials, including extra copies.
In addition, most major federal
agencies have rules or policies
governing the removal of papers
by agency officials.
Applying the Law
The applicability of the
Federal Records and Disposal
Acts to an official's removal of
documents or papers depends
upon whether or not the materials
in question qualify as records
under the definition provided in
the Disposal Act. The Federal
Records and Disposal Acts do
not govern the removal of
nonrecord materials, including
extra copies of records made for
convenience or reference, or
personal papers. Aside from the
exclusion for extra copies, the
determination as to whether a
document or paper is a record
depends not on its status as an
original or copy, but instead on
whether it was made or received
Continued on page 15
INFOACCESS
14
AUGUST 1993
-------
by an agency under federal law or in the course of
official business, and is deemed appropriate for
preservation. Senior agency officials who have
agency permission can, therefore, legally take such
nonrecord materials with them upon leaving office.
For Additional Information, please see:
EPA Ethics Advisory 89-2, Disposition of
Federal Records and Personal Papers,
January 18,1989.
EPA Notice 88-1, Safeguarding and
Disposition of Official Records,
September 12,1993.
EPA Records Management Technical Leaflet
#3, A Practical Guide to Personal Papers,
December 1992. EPA 220-F-92-019.
Federal Records Management: Laws and
Regulations, National Archives and Records
Administration, Office of Records Administration,
1993.
NARA Bulletin 93-2, Proper Disposition of
Federal Records and Personal Papers,
November 13,1992.
Personal Papers of Executive Branch
Officials: A Management Guide [Management
Guide Series], National Archives and Records
Administration, Office of Records
Administration, 1992.
What Makes Papers Personal? [flyer] National
Records Management Program, Information
Access Branch, Office of Information Resources
Management, August 1992. EPA 220-F-92-013.
We hope that you will find the information in this
report useful in advising staff about their
responsibilities for maintaining the integrity of EPA's
records. If you have any questions regarding
personal papers, please contact Michael L. Miller,
Agency Records Officer, at (202) 260-5911, or on
AII-in-1 at Miller.Michael-OIRM. If you would like to
obtain a copy of any of the publications listed above,
please contact Joe Moeltner (contractor) at (202)
260-5272, or on AII-in-1 at MoeltnerJoseph. *
Contributed by Joseph Moeltner (contractor),
Records Management Support, NRMP.
		
OPPT from page 7
The main menu of the system offers access to
the Receipt Log, Inventory Log, and Files
Maintenance menus, and allows the user to
search by disposition and records control
numbers, transfer records between active and
inactive status, and create reports. Les described
a number of useful features available on the
system, including:
~	Mandatory data entry on many fields to
ensure that appropriate information is
recorded.
~	A field to record an auditor's visit or review.
/ String search capability.
/ Description field that can be used in a
variety of ways; OPPT uses it for tracking.
~	Ability to reactivate files designated
"inactive."
In response to a question about system
capabilities, Les commented that it could be used
with bar coding equipment, if some modifications
were made to the program. He also said that
OPPT will work with the Regional records
managers to improve the system. They are
planning to look at the possibility of integrating the
automated SF-135 system developed by AMS
into the automated document tracking system.
Concluding the Tour and Demo
Georgianne concluded the tour and
demonstration by talking about OPPT's plans to
enhance its image processing system by including
the material from the dockets, and incorporating
materials from other sections of TSCA.
Georgianne also talked about her preparations for
a briefing on records management for Mark
Greenwood, Director of OPPT. #
V	—J
AUGUST 1993
15
INFOACCESS
-------
Around the Records Network
This section of INFOACCESS is used to report on upcoming meetings and projects
currently underway in the Regions, Laboratories, and Headquarters. The INFOACCESS
staff would like to encourage all records management staff at the Agency to share news
and information about current projects with the INFOACCESS readers. Anyone with
contributions for this column can contact Mary Hoffman (contractor), Network
Coordinator, at (202) 260-7762 or at Hoffman.Mary on AII-in-1.
Region Ill's RM Activities
Region III has developed a workgroup to create
a records management manual. The manual will
be a supplement to the Agency's Records
Management manual and will describe records
management procedures pertaining to the Region III
office. Also, the Region III records management
directive is being reviewed. It should be approved
by mid-September.
Beginning in FY 94, Region Ill's records
management staff will begin systematic records
management training for secretarial staff. One
division will be scheduled each month until all
divisions have been covered. The training course
will cover cleanup procedures, storing and retrieving
records at the FRC, the Region's alternate storage,
and other records management procedures.
Cleaning & Dusting in Region 5
Records management staff in Region 5 have
instituted a new practice of cleaning and dusting all
boxes of records entering the building from
commercial storage. A recent monitoring of air
quality in the records work area on the 12th floor
showed an extremely high amount of dust. Staff
determined that the dust was probably related to
boxes that had been shipped from a commercial
storage facility to the Regional office. To resolve this
situation, the staff took all the boxes that had come
from commercial storage to the loading dock. There
the staff dusted and vacuumed all the boxes, and
their contents, removing as much dust as possible,
and then repacked the material into FRC boxes.
The boxes were then taken back to the 12th floor
work area. Later in tho week, the work area was
completely dusted and the carpets were cleaned.
The monitors were used again to check the dust
level, and it was found to be acceptable.
Since then, when new boxes arrive from the com-
mercial storage facility, the documents are removed
from the boxes on the loading dock, dusted and
vacuumed, and then taken to the 12th floor.
Imaging in Region 6
Nancy Yarberry shared some insights into
Region 6's imaging activities during a recent
Regional records management teleconference.
According to Nancy, their grant system has been
loaded onto optical disk, and staff are starting alpha
and beta training. They have begun to meet with the
permits staff to work out the details for adding the
permit information to the system. Some of the
issues they are discussing include the disposition of
paper records after the conversion, management of
the optical disks, indexing and scanning.
P-Mail in Region 9
Yvonne Pederson has been distributing
information about records management issues via
electronic mail to Regional staff on a monthly basis.
In her first message, Yvonne introduced herself
and the Regional records program. Subsequent
messages have discussed the unauthorized
removal or destruction of records, how to use the
Federal records center, records held by contractors
and their responsibilities, and the newly established
Records Management Task Force and the EPA
Records Management Program. Yvonne is working
on her next message, which will cover file cut-offs.
This has been a successful effort for Yvonne,
inspiring numerous responses and questions from
Regional staff.
Continued on page 17
INFOACCESS
AUGUST 1993
-------
Diary of a Records Manager
In the three spare minutes I had
last month, I began considering
some of the "Mysteries of Life." You
know... Where have all the paper
clips gone? Why does the copy
machine go belly-up 15 minutes
before the giant project is
completed? Why is the missing file
in the box at the bottom of the stack
(and of course in the last of the 5
stacks)? Where are the missing
records carts, step stools, etc?
For over 3 months I've had a
records cart missing in action. What
is someone doing with a records
cart? Have they taken the wire
baskets home to keep a new litter of
puppies? Is the cart being used as a
portable plant stand? Maybe there
is a worm hole that only appears
when a cart is left alone. It appears,
transports the cart to a different
world and in 200 years a space
explorer will discover the "Land of
the Missing Office Equipment."
Has anyone ever found a missing
file in the top box of the stack? Of
course there is something worse
than looking through a bunch of
boxes before finding a missing file.
Its the person who does the V-8 slap
to the head and says "Oh, I
remember now, we put that file in the
boss' safe/secretary's desk/other
hiding place for safekeeping." You
grin and he walks off happy that the
missing file has been found. You
		
^%Vv ""s•.'¦V
Where x
W Have Is]
¦ All the H
PPIl	JP*§i
ML Paper Clips M
HL Gone?
are in the meantime sitting in a circle
of boxes, all open, grinning because
you are imagining incredibly painful
methods of torture!
Anthropomorphism or not, copy
machines know when the current
project is critical. Do they break at
the beginning of a project when you
have a half of a chance to recover?
Nooo, they throw a tantrum when
you are minutes away from being
complete. Maybe they know that
you are congratulating yourself on
another disaster averted. Under the
listing of 'smug' in the dictionary is a
picture of a copy machine with a
paper jam.
Disappearing paper clips are not
a mystery. I can explain disappear-
ing paper clips and excess hangers.
Paper clips are a pre-mutated form
of a wire hanger! Paper clips secret
themselves away in pockets, hems
of skirts and pants, etc. Then when
you reach home and put your
clothes in the closet or hamper, they
slither out. Like lemmings they are
genetically programmed, only paper
clips collect in the darkest corner of
your closet. When the number of
paper clips reaches the critical level,
they begin to mutate. They meld
together and form a hanger. If you
open your closet door during the
process, you disrupt it and a bent,
mangled hanger is formed. That's
why you never can find a paper clip
when you need it and why there are
always hangers on the floor in the
back of your closet.
A peer reviewed this article and
had some comments. So, more on
the paper clip/hanger mystery!
There certainly must be some
relationship between paper clips and
hangers. Down in my dank
basement where I have the washer,
I can start out with no paper clips
visible but with enough hangers for
all the clothes I'm going to wash.
Somehow... mysteriously...by the
time I'm pulling stuff out to hang up
to dry, I have too few hangers but a
pile of paper clips at the bottom of
the interior wash tub. Transcycle
mutation? Rinsecycle mutation?
I vote for rinsecycle mutation. A
Around the Network from page 16
Training Region 10 Staff
Fern Honore (contractor) has been busy in the
Region 10 office in Seattle training program staff
about "how to create a complete record." Each of
her training sessions is tailored to a specific
audience, each with unique records, and each
includes a presentation on how to document
policy, procedure and decision making in the
office. Fern's advice about determining if
something is a record or not, is that "if you act on it,
it is a record." She goes on to explain that most of
what crosses a person's desk is technical reference
material which does not have to be kept
So far she has briefed staff in the Office of the
Assistant Regional Administrator, the Office of
Policy Planning &Evaluation, the Comptroller's
Office, and the Administrative Management Branch.
Fern always tries to include the file custodians in her
briefings, the filing experts in each office.

AUGUST 1993
INFOACCESS
-------
a General Records Schedules
Transmittal #6
The National Records Management Program (NRMP) recently
received copies of General Records Schedules Transmittal #6, dated
May 17,1993, and is distributing it to agency records managers for
incorporation into their GRS binders.
The National Archives and Records Administration issues the GRS
to provide disposal authorization for records common to several or all
agencies of the Federal government. GRS items cover an estimated
one-third of the total volume of records created by Federal agencies.
Agency records managers should use the GRS to supplement EPA's
own records schedules in determining the dispositions for a wide range
of administrative records.
A complete set of the GRS includes five earlier transmittals plus
the most recent one, #6.
~	Transmittal No.1 (August 10,1988) distributed the basic set of
GRS chapters now in use. You can identify this revised version
because its pages are dated June 1988 and it has a blue cover.
~	Transmittal #2 (October 30,1989) included numerous
corrections to the Transmittal #1 package.
~	Transmittal #3 (February 22,1991) included several
modifications to exising disposal authorizations and a new item
covering passports.
~	Transmittal #4 (April 24,1992) discussed a change to GRS 2.
~	Transmittal #5 (July 9,1992) added a revised page that was
inadvertantly omitted from Transmittal #4.
~	Transmittal #6 (May 17,1993) contains a revision of the
General Introduction and makes additions, revisions, and
corrections to several schedules and to the indexes.
Additional copies of all of the transmittals can be obtained from
your local Federal Records Center, or by calling Joe Moeltner
(contractor) at (202) 260-5272.
Contact Mike Miller, Agency Records Officer, at (202) 260-5911,
with any questions concerning the transmittals or specific General
Records Schedule items, is
GRS on Disk
The General Records
Schedules are now
available on disk from
Joe Moeltner (contractor),
Headquarters Records
Support. If you are
Interested In obtaining
copies of the GRS on disk,
contact Joe at (202) 260-
5272.
Optical Disk from
page 12
national and international
digital information technology
standards, which provide
update migration paths ro
new media, devices, and
software, offer the most
effective long-term solution to
technology obsolescence.
NARA is actively
participating in the work of
several ANSI and ISO
standards groups that are
addressing digital medial and
related information
technology issues.
Establishment of the
standards will be neither
easy nor swift, but NARA is
committed to their
development, adoption and
use. #
INFOACCESS BBl	AUGUST 1993
-------
-------