United States
Environmental Protection
Agency
Information Resources
Management
(3404)
EPA 220-N-94-003
Issue Number 38
February 1994
&EPA INFO ACCESS
Records Network Communications
¦
In this Issue ...
Two Records Projects in the
Office of Pollution Prevention
and Toxics (OPPT)
p. 3~4
Vital Records and
Disaster Recovery Training
p. 4
A Case Study in Use of
Commercial Storage
p. 5-7
Favorite Records
Management Myths
p. 7
Electronic Records
Management Study Completed
p. 8
Two Programs
Begin Baseline Studies
p. 9
Tip of the Hat
p. 9
Around the Network
p. 10
Messages from the President
and the Attorney General on
the Freedom of Information Act
p. 11
A "Ticklish" Situation
at the Air Docket
p. 11
Headquarters Update
p. 12
Recordkeeping Requirements:
The Next Records Management Frontier
by Michael L. Miller, Agency Records Officer
"Begin with the end in mind."— Stephen R. Covey
Federal records managers can tell program staff how long to store records,
how to file them, what equipment to use, and whether the records warrant
conversion to optical disk or microform. But none of these tactics deal with the
creation phase of the records life cycle, and, as all records managers know, it is
during the creation phase that the major decisions affecting the management of
the records are made.
At one level, program staff are sensitive to the problem. The most frequently
voiced question in records meetings I attend is "How do I know what should be
included in a file?" The simple answer is provided by the quote above from
Stephen R. Covey, author of the popular Seven Habits of Highly Effective
People. Once programs determine why records are being kept and what
purposes they will need to serve over their life, all other questions can be
answered relatively easily.
This is the concept behind "recordkeeping requirements." Effective
recordkeeping requirements (RR) should minimize the number of questions
about what is and is not a record and what should or should not be included in a
file.
According to the Code of Federal Regulations (36 CFR 1222.32),
recordkeeping requirements shall:
(a) Identify and prescribe specific categories of documentary materials to be
systematically created or received and maintained by agency personnel in
the course of their official duties;
(b) Prescribe the use of materials and recordkeeping techniques that ensure the
preservation of records as long as they are needed by the Government;
Recordkeeping Continued on page 2
Printed on Recycled Paper
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Recordkeeping from page i
(c) Prescribe the manner in which
these materials shall be
maintained wherever held;
and
(d) Distinguish records from
nonrecord materials, and with
the approval from the
Archivist of the United States,
prescribe actions for the final
disposition of agency records
when they are no longer
needed for current business.
Although these regulations have
been in place for many years, few
agencies have put together a
comprehensive RR program. The
reason is that, while some of the
requirements can be established
Agency-wide, important
components of a comprehensive
system need to be developed at the
series level.
The enclosed insert "Draft
Framework for Recordkeeping
Requirements at the
Environmental Protection
Agency" provides an overview of
the types of RR that need to be
developed in the Agency, and who
would be responsible for doing so.
The key concept is the layered
approach to implementing RR
within the Agency. Each layer
(level) adds detail and specificity
to the RR for a given type of
records.
Although responsibilities are
frequently overlapping, only three
things need to be done:
1) The Agency must have policy
defining what is a record and
how records must be managed.
2) Programs must develop a
documentation strategy to
identify what types (series) of
records must be maintained to
document the overall work they
do.
3) Programs must decide, within
the parameters set by Agency
policy, what specific documents
must be included in those files,
and how the files will be
managed.
Agency-wide, the main vehicles
for developing RR are policy
manuals, records disposition
schedules, and the Agency-wide
file plan. In fact, most of the
Agency-wide RR are either in
place or in draft.
The new Agency records
disposition schedules provide an
excellent tool for developing
at the series level. The schedules
capture information about basic
file contents and arrangement,
records retention, records location,
file custodians, sensitive
information, and vital records
status. The Agency-wide and
Program Guidance sections can be
used to capture additional RR
information, such as the specific
documents to be retained in an
individual office. The schedules
can be supplemented by file
manuals (see Step 6 in the October
1993 issue of INFO ACCESS) to
provide a complete set of RR.
The concept of recordkeeping
requirements is somewhat new to
EPA and developing a RR strategy
At the program level, the records
disposition schedules should
1 • WVTVlW^/lUg u kJUUIMj
provide the basic framework for the wiu be an iterative process. The
documentation strategy. If files are NRMP welcomes comments on
necessary to the documentation of
the Program's activities, they
should be in the schedule; if files
are not in the schedule, are they
needed at all?
the Draft Framework, and the
issue of RR generally. Please
direct your comments to Mike
Miller, Agency Records Officer,
via telephone (202-260-5911), fax
(202- 260-3923), or All-in-1
(MILLER.MICHAEL-OIRM).O
INFO ACCESS, a forum to provide information and report on progress
in information management across the Agency, is produced by the
Information Access Branch (IAB) of the Information Management and
Services Division (IMSD), Washington, DC, under the direction of
Michael L. Miller, National Records Management Program Manager.
Please send comments and suggestions to: Manker R. Harris (contractor),
Network Coordinator, 3404, EPA National Records Management
Program, 401 M Street, SW, Washington, DC 20460. Telephone:
202-260-5272. Electronic mail: Harris.Manker.
INFO ACCESS
FEBRUARY 1994
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Two Records Projects in the Office of Pollution
Prevention and Toxics (OPPT)
Information Management Division
Initiatives
by Georgianne McDonald, OPPT Records Manager
The Information Management Division (IMD)
took a major step to improve its records management
program by initiating a comprehensive inventory of
its records.
The interrelated problems of paper overgrowth
and fragmented documentation highlighted the need
for IMD to establish an efficient information/records
management system. IMD realized that such a
system does not develop naturally. For example,
addressing the problem of fragmented documentation
takes careful planning and extensive coordination
among all the players. IMD further recognized that
commitment from all levels (especially senior
management) lies at the heart of such a system.
IMD's objectives for having a good records
management system in place became obvious: it was
the logical and practical way to go because it saves—
money, space, time, equipment, and the Division's
records of enduring value.
Like other organizations within EPA, IMD is
facing problems managing records in all media.
For example, IMD is running out of space to store
records and contract dollars for microfiching, and
support and assistance services have been reduced.
In addition, the existing records schedules are
outdated in some cases and do not exist in others.
As a result, the Division could not legally destroy
or retire many of its records. IMD was at a turning
point and began to work to change how it would
manage its records in the future.
In early December 1993, IMD began conducting
an inventory of its records holdings. Currently, there
are three Branches and six Sections within the
Division. Prior to initiating the IMD inventory,
records management training was provided to both
management and support staff. In response, IMD
management has provided their full support,
becoming fully involved and committed to meeting
established milestones. This is an all IMD staff
effort regardless of level in the organization.
IMD's ultimate objective is to put in place a
standardized, uniform, comprehensive records
management system. However, IMD will take a
gradual, step-by-step approach toward achieving its
records management goals. This includes
inventorying, developing file plans, scheduling, and
retiring IMD records. Thus far, IMD actions include
taking not only a Divisional office approach, but a
Program office approach as well. IMD is
coordinating with the Chemical Management
Division in its records effort. Of course, all actions
being taken adhere to Agency policy and directives.
Currently IMD is establishing recordkeeping
requirements and integrating records management
into information systems design and implementation.
IMD set up a work group which is writing new
records schedules (17 new schedules in all), and
scheduling records for permanent transfer to the
Federal Records Center and the National Archives.
The key to the success of this project is the
overwhelming support and commitment of IMD
management and staff. IMD's management
philosophy is to think of records as a resource that
must be wisely managed to ensure information is
available when and where it is needed, at the least
possible cost.
IMD has only begun to scratch the surface. We
will, however, continue on the course that we have
begun even though it is slow, difficult, and uphill. It
has become evident, in just what we have
accomplished thus far, that records management is an
epic opportunity and offers a cooperative solution to
many of IMD's problems.
OPPT Continued on page A
FEBRUARY 1994
3
INFO ACCESS
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OPPT from page 3
Chemical Testing and
Information Branch (CUB)
by Kathy Calvo, Records Manager
OPPT's Chemical Testing and
Information Branch has developed
a records program for managing
its Toxic Substances Control Act
(TSCA) rulemaking files. Section
4 allows EPA to require
manufacturers and processors to
test chemicals and mixtures to
provide EPA with adequate data
on potentially harmful health and
environmental effects.
In October of 1992, CTIB
began to inventory and identify
locations for all chemicals. Since
no standardized filing system had
existed for 15 years, there were
more than 75 5-drawer filing
cabinets of information including
1,000 test reports. Files were
located at Project Manager work
stations in various stages of
"organization."
A standardized file plan was
created for the active as well as
inactive records. The file plan was
structured in accordance with the
TSCA regulatory development
process and EPA-approved records
control schedules. The basic file
structure follows a chronological
sequence of events, and records are
categorized by function. Primary,
secondary, and tertiary topics are
used with related items filed
together similar to a telephone
book. Alphanumeric codes aid in
identifying files.
In April of 1993, using
contractor support, CTIB began
sorting, organizing, and filing
inactive records in accordance will
the file plan. A relative
(alphabetical) index of file plan
subjects and synonyms was created
to aid those using the file plan.
At the close of FY93, CTIB had
sorted and organized 30 file
cabinets of records. Fifty percent
of the records were sent off-site for
storage at the FRC, 30 percent
were recycled (mostly duplicates),
and 20 percent remained on site.
As a result, a total of 24 file
cabinets (80 percent) of records
were eliminated from storage in
CTIB.O
Vital Records and Disaster Recovery Training
by Nancy Yarberry, Records Officer, Region 6
I just finished a two-day training class on vital records and disaster recovery put on by the
Washington office of the National Archives and Records Administration (NARA). NARA is presenting
this new training class at most of its regional offices. Denver was the first, Dallas was second, Kansas
City is coming up soon, San Francisco is on the schedule, and so on ...
The first day was spent on vital records and planning. We learned what vital records really are, how
to go about finding them, whom to talk to, and how to realistically put this information together. We
then discussed how to go about setting up a disaster plan, where to get "good" resources, whom to
"invite" to the planning committee, and what goes into a good plan.
On the second day, we put together an ad hoc plan within each study group, then spent about two
hours at the end of the day dealing with an actual (planned) disaster, locating the vital records and
conducting a recovery (messy but fun). The exercise showed us how important it is to know where and
what is really vital,, what the priority should be, and how poor planning can be the real disaster.
Without a doubt, this was the best class I've taken from our local Federal Records Center (FRC). I
would recommend records officers contact their local FRC and try to attend. It's well worth the $150
NARA charges. A lot of information was presented in a very short period of time and there was some
reading to do outside of class. I know that sometime down the road, all of us will have to address this
subject, and this is a great introduction.
INFO ACCESS iiMll FEBRUARY 1994
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A Case Study in Use of Commercial Storage
Lynn Calvin, Records Officer, Region 5
Well, my first piece of advice on commercial
storage is DON'T but you never would have been
able to convince either me or my management of that
a few years ago. When I first started using it, it
seemed like a life saver, giving me a small degree of
control over the swamp of documents I was sinking
into. The catch is that you feel you have solved
problems, when in fact all you have done is hidden
them or put off dealing with them.
My biggest reservations about commercial storage
are three:
~ It functions as a copout, cheap in a given year, but
expensive over time.
~ You end up not facing and dealing with the issues
raised by the material.
~ It gives people an opportunity to avoid destroying
materials that should be destroyed, and to avoid
shipping to the Federal Records Center (FRC)
material that belongs there.
Commercial storage can be a valuable resource,
but should be approached with extreme care and with
full knowledge of the problems you will encounter if
you become dependent on it. It can be addictive, and
like most addictions, once you get involved, you are
hooked. In Region 5 we made extensive use of it
and have still not fully extricated ourselves from it.
We are down to about 2,500 boxes from a high of
around 11,000.
What Does it Really Cost?
Commercial storage companies charge for various
services, including adding new boxes, pulling and
delivering boxes, returning boxes, and permanently
withdrawing boxes from the facility. Charges in
Chicago were approximately:
~ $2 to put a box in storage
~ $2 per year to store
~ $10 to retrieve and deliver one box with next day
delivery and about $2 per box for additional boxes
on same call
~ $4 for permanent withdrawal (e.g., when you
withdraw them for destruction or transfer to the
FRC)—LOOK AT THIS CAREFULLY, IT IS A
LOT MORE SIGNIFICANT THAN IT SEEMS.
~ $ 1.50 to purchase one box. In our case this is
refunded if we send the box back for storage.
Here is an analysis of what these charges meant to
Region 5. I estimate that from 1986 through 1994
we will have spent well over $200,000 on
commercial storage. It cost us $20,000 a year to
keep our 11,000 plus boxes in storage and another
$25,000 to do reference work with them. Permanent
withdrawal fees total around $44,000. Yes, it was
cheaper than office space, but it wasn't as cheap as
proper disposition—either destruction or retirement
to the FRC.
Moreover, when we decided to convert from
commercial storage to FRC storage, it cost us
roughly $100,000 to pull 2,500 boxes of records,
determine what they were, and prepare and ship them
to the FRC. That's only the contractor costs and
doesn't include all the hours of EPA staff review
time.
There may be times when using commercial
storage rather than FRC storage makes sense. For
instance, you may have a large number of items that
are not eligible for placement in the FRC right now
and you don't want to store them in expensive office
space. However, if the objection to using the FRC is
that material is not accessible as quickly as needed,
commercial storage is not the only alternative. First,
investigate using courier services, Federal Express,
your own vans, or some other method of obtaining
the boxes from the FRC. People rarely really need it
as fast as they claim, and, if they do, somebody can
pick it up.
A Case Study Continued on page 6
FEBRUARY 1994
I
INFO ACCESS
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A Case Study from page 5
Tips for using Commercial Storage
If you decide you do need to use commercial
storage, here are some practical hints to make it more
cost effective.
Pretend you are the FRC—insist that programs
index their material, even if in a very rudimentary
fashion. Under NO circumstances take plain sealed
boxes purporting to hold "policy records about
holidays" (read Christmas decorations).
Use a multiyear contract, not a small purchase.
Otherwise, you have serious procurement hassles
every year. If you start using it more heavily and go
over the $25,000 limit, using multiple vendors or
changing vendors would be a nightmare.
Furthermore, you can't do even small purchases
competitively because of the cost of permanent
withdrawal fees.
Look carefully at, budget for, and include in your
analysis the cost of permanent withdrawal of a box
from storage. This also affects the issue of
procurement of the service. When we first looked at
cleaning out storage, we couldn't afford to close it
out in that fiscal year. It was cheaper to leave it in!
Keep up on permanent withdrawals and circulation
status. Often when you pull the box back, you think
you will be returning it, but you never do. Then you
are paying $.25 a month for an empty space on the
shelf. Over time this really adds up. We found
hundreds of "charged out" boxes when we went to
close out the accounts. The Regional account had
material charged out since 1986 when we closed it
out in 1993. That's more than $20.00 a box.
Buy your own boxes—don't use the commercial
storage company boxes. They are nice boxes and
people use them for all sorts of interim storage. We
ended up running short during a move and used
hundreds of these very expensive boxes for moving
because we had nothing else, but then they were
unusable for commercial storage. Our company had
a seductive "free" box service—there is a $1.50
deposit credited when you put the box back in. But,
lots of them never got back in.
inspect the Storage Facility
Inspection is critical! Inspect the facility, and I
don't mean going on a tour where they show you
nice areas. I had been to the facility when I first got
involved, although the Region was already using that
vendor. It looked fine to me. When I went with the
NARA team, they wanted to look at random boxes of
our records. In the process, we saw broken
windows, plastic sheeting over bays of shelves (leaky
roof), rotting floors (actually wood over concrete
slab—not structurally significant, but disconcerting),
and people eating their lunches.
There is a trade association, the Association of
Commercial Records Centers, with more than 400
members. The Association doesn't regulate or
certify centers, but it has produced a checklist for
evaluating them. Some points from the checklist are
included in the box on page 7.
For more information about the Association of
Commercial Records Centers, contact:
Dave Mattes
Association of Commercial Records Centers
P.O. Box 20518
Raleigh, NC 27619
1-800-336-9793
A Final Note from the NRMP
NARA issued a notice on December 1, 1993, on
cost savings in records storage for FY94. Attached
to the notice is a model computation which can be
used to determine the estimated cost savings in space
and equipment that can be achieved by using the
FRCs. Based on an average cost of $23.04 per cubic
foot to store in active office space and $1.62 per
cubic foot to store at a FRC, Federal agencies can
realize cost savings of $21.42 per cubic foot by using
the FRC. These figures can be used when evaluating
the cost effectiveness of commercial storage.
Contact Manker R. Harris (contractor) at
202-260-5272 for copies of this notice.®
INFO ACCESS K11 FEBRUARY 1994
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The following are some things to investigate
when considering a commercial storage
company.
Are the following services available?
/ Photocopiers or microfilm reader printers
/ Rush or after hours deliveries
/ Fax
/ Packing and shipping
/ Onsite review
/ Detailed billing (so you can set up user charges)
What is the building like?
/ Shell, roof, floors
/ Shelves (steel or steel and particle board)
/ Heating system (oil/gas/electric)
~ Single or multitenant
y Earthquake or floodplain area
What is the security like?
/ Fire system (dry/wet/halon/extinguishers)
/ Zoning
/ No smoking policy
/ Building security (closed circuit TV)
/ Bonded employees
~ Preemployment investigation of employees
/ Perimeter security (fence)
Other issues to consider
~ References
~ Prices
/ Insurance
/ Financial stability
/ Length of time in business
FAVORITE RECORDS
MANAGEMENT MYTHS
In the October issue, we asked records
managers to submit their favorite (or maybe
their least favorite) misconceptions about
records management. Here are the top 10
responses:
1. Office automation (computers) will
reduce the amount of paper we have to
deal with.
2. We can solve all our file space problems
by putting those boxes in commercial
storage.
3. As soon as I send this file to storage (or
destroy it), I'll need it. Or, a favorite
variation—we can't destroy those files,
we'll need them for FOIA requests.
4. That's not a record, it's a computer file.
5. A good spring cleaning (or cleanup day)
is all we need to do for records
disposition.
6. These are my records; it's nobody's
business what I do with them.
7. I don't need to worry about the files—
the secretary or file clerk or somebody
else will take care of them.
8. Alphabetically by subject is good
enough.
9. The recipient is the only one who'll see
my electronic mail message.
10. Anyone can do filing.
FEBRUARY1994
7
INFO ACCESS
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ELECTRONIC RECORDS MANAGEMENT STUDY COMPLETED
During the past nine months, the National Records Management Program (NRMP) sponsored an in depth
study of the Agency's electronic records policy. The study is now complete, and the final deliverable, the
revised "Recommended Framework for Policy Development and Dissemination" has been received.
The overall purpose of the study was to examine Federal requirements, user needs, existing and Agency
policy governing electronic records to determine what changes need to be made to enable the Agency to
maintain its official records in electronic form. Like many other Federal agencies, EPA is attempting to
determine when it is appropriate to retain records solely in electronic form, and how it will do so. The
assumption is that in the future many if not most Agency records will be maintained only electronically.
Before that can be done a number of basic policy issues must be addressed to ensure that the electronic
record will meet all of the Agency's documentation needs including, long-term administrative, audit, and
legal needs. This study defines a policy framework that will:
~ Guide EPA in making the transition from a paper-based system to one in which the automated systems
serve as the official documentation of Agency activities and programs; and
~ Provide a blueprint for the development of an effective system of policies and procedures that meet
Federal requirements and Agency staff needs.
Previous deliverables in this study looked at the Federal regulations and requirements, Agency needs, and
existing policies and developed a matrix showing what our policy needs were in this area. The most recent
deliverable makes recommendations about how the Agency can best organize and disseminate its policy
framework. The 19 specific recommendations fall into four broad categories:
~ Review, consolidate, and simplify Agency policies, procedures, and guidance.
~ Make EPA staff aware of their responsibilities to create adequate and proper documentation of government
activities in any medium.
~ Incorporate electronic records management in Agency IRM planning, budgeting, and review processes.
~ Institute electronic records management in all mission program and IRM activities.
In many cases these recommendations parallel those made concerning IRM and records management
policies generally. Also OIRM and the National Data Processing Division have already undertaken steps to
implement some of the recommendations. The NRMP is now determining how it will implement the
recommendations.
Copies of the report are being sent to all Senior IRM officials, IRM chiefs, and the principal records
management liaisons in the Regions and Headquarters. If you would like to obtain a copy of the study,
contact Manker R. Harris (contractor) at 202-260-5272 or via All-in-1 at HARRIS.MANKER.0
INFO ACCESS
FEBRUARY 1994
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Two Programs Begin Baseline Studies
The Office of Enforcement and Compliance
Assurance (OECA) has joined the Office of
Administration and Resources Management (OARM)
on the list of Headquarters programs currently
conducting baseline records management studies.
The purpose of a baseline study is to identify a
program's records holdings and evaluate the current
effectiveness of the records program. It also serves
as the logical first step for anyone establishing or
expanding a records management program. The
baseline study has four major products:
~ A walkthrough inventory that provides overall
statistical information on the volume of records in
the custody of the program;
~ A detailed inventory, taken at the branch or
section level, that identifies all program records at
the series level;
~ An analytical report, that evaluates the strengths
and weaknesses of the records management
program and recommends improvements;
~ New and revised records disposition schedules,
developed as necessary.
Both OARM and OECA are using the baseline
study as a springboard for developing full action
plans to respond to the National Archives and
Records Administration (NARA) evaluation.
Besides providing the raw material for the action
plans, the baseline studies complete their portion of a
major requirement of the NARA evaluation—the
inventory of all Agency records. OECA also
benefits because the baseline study will assist in
developing a records management program
supporting both the former Office of Enforcement
staff and those being transferred to OECA from other
programs.
The OARM study has been underway since mid-
December and the OECA study began in January.
They serve as a testing ground for procedures that all
programs will be able to use during the Agency-wide
inventory in 1995. At this point, OARM has
developed forms and procedures for the walkthrough
inventory, which other programs may find useful.
If you would like more information on the
baseline studies, you should contact Jim Baca
(OARM) at 202-260-1100, Joan Alcock (OECA) at
202-260-3049, or Mike Miller, National Records
Management Program, at 202-260-591 !.•
Tip of the He*
INFO ACCESS li&es to t&mfo $4 X;
for excellent work in the Ma of records management, of
products, completion of signlfa&t projects, or acknowMgemem of Ageacy awitfik
m Shirley (contractor), ftggiott % along with three other local ARMA
put together the winning submission for the recent award to ft# C&ealer Kansas City
Chapter as the n$w ARJviA Chapter of Ac Ym CmediwiM&se cfcaj«6r).
Barb MacKiamm (contractor), Region 7* has been appointed n the K*s$fts Ms
Historical Records Advisory Board by Governor km Fteaey,
<
FEBRUARY 1994
INFO ACCESS
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Draft Framework for Recordkeeping Requirements
at the Environmental Protection Agency
Level 1 Recordkeeping Requirements
5. Identify broad categories of records necessary to
document Agency activities. Examples:
Purpose: Provide overall framework for
Agency documentation
~ Controlled correspondence 1
~ Schedules of activities
Issued by: National Records Management Program
(OIRM)
~ Rulemaking records/Dockets
~ Administrative records under the APA
How: Agency IRM Policy Manual
Agency Records Management Manual
~ Permits
Agency Records Disposition Schedules
~ Directives
Policy Papers
~ System development documentation
Subjects to Cover:
6. Provide retentions and dispositions
1. Describe Agency responsibilities for
for Agency records.
documenting activities including the
Level 2 Recordkeeping Requirements
recordkeeping requirements program.
2. Define:
Purpose: Provide program specific guidance on the
~ Records
need for recordkeeping requirements, and
~ Non records
what records are needed for program
documentation.
~ Personal papei
Issued by: Assistant and Associate Administrators
3. Provide general overall policy on the
and Regional Administrators
management of records in specific media.
Examples:
How: Program Directive
~ Electronic
Subjects to Cover:
~ Audiovisual
1. Identify specific categories/series of records
~ Cartographic
necessary to document program activities based on
4. Provide general overall policy on the
program needs and program specific legislation.
Examples:
management of certain types of records held/
created Agency-wide. This would be similar to
~ RCRA Permits
that described under Level 3 Recordkeeping
~ Superfund Site Files
Requirements discussed below. Examples:
~ RCRA Docket
~ Electronic mail
~ Office Director files in specific offices
~ Working papers
~ CERCLIS automated system
~ Contract records
2. For records series maintained at multiple locations
~ FOIAs
(e.g., RCRA permit files) resolve issues discussed
~ Contractor-maintained records
in Points 1 and 2 under Level 3 Recordkeeping
~ Dockets
Requirements (below).
National Records Management Program, Information Access Branch
Office of Information Resources Management, U.S. Environmental Protection Agency
EPA 220-N-94-003
February 1994
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Level 3 Recordkeeping Requirements
Issued by: Laboratory, Office and/or
Division Directors
How: Program Directive Records disposition
schedules Program records management
manual
Purpose: Provide specific detailed information
about the management of individual
records series.
Subjects to Cover:
1. Identify the types of documents to be included in
individual files such as those listed in Level 2,
above. Resolve question such as:
~ What documents need to be retained?
~ Which commonly held documents can be
discarded?
~ How should documents be arranged in the file
folder?
~ Should drafts be included?
~ When and how to incorporate email messages,
notes of meetings, telephone memoranda?
~ Whether the records should be divided between
an Official file of primary documentation and a
Working file of supporting documentation?
2. Provide records management guidance in areas
such as:
~ Sensitivity status/access restrictions
~ Vital records status
~ Arrangement schemes for the series
~ File plans
3. Identify files custodians/filing stations.
4. Provide complete records disposition information
This Draft Framework was developed by the National Records Management Program. Please direct your
comments to Mike Miller, Agency Records Officer, via telephone (202-260-5911), fax (202-260-3923), or
All-in-1 (MILLER.MICHAEL-OIRM).
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Around The Network
Region 1
The records and information management staff has
plans underway to enhance the automated SF 135
system previously developed by the NRMP and
Region 7. Phase 1, fixing the "bugs" in the original
system, is nearing completion. For example, problems
using the query function and the header information
field have been corrected, and the ability to sort folders
will soon be available. Phase 2 will continue with
enhancements to the existing fields and additions of
new fields, including those which match developments
in the disposition schedules. Merging the CLP data
records archiving system will also be attempted in the
second phase. The final phase is to put the database on
the VABS, and the software on each of the divisional
file servers with customized help screens, thereby
changing from a PC-based to a LAN-based system.
Region 4
Jim Whittington participated in the National Media
Lab (NML) Review in Reston January 24-26. The
NML asked whether EPA would be interested in
working with them to develop a process to recycle used
magnetic tapes. Currently hundreds of thousands of
tapes are incinerated each year because it's the only way
to assure that classified information is destroyed. The
NML wants to develop a process that does not depend
on incineration and does not produce leachable
byproducts like chrome that might cause trouble in a
landfill.
Region 7
Pat Shirley (contractor) reports that copies of INFO
ACCESS have been sent to Dr. Ibrahim A. Albaddah at
the Institute of Public Administration in Riyadh, Saudi
Arabia. Dr. Albaddah wrote to a member of the
Greater Kansas City Chapter of ARMA asking for any
information the organization was willing to share. Pat
sent a number of EPA and NARA publications. He is
seeking any type of records management information
(e.g., records manuals, disaster plans, filing guides,
etc.). He translates the information for use in his
courses. If you have records management products you
would like to share, send them to:
Cindra Morgan, CRM
City of Lenexa, Records Manager
12350 W. 87th St. Pky.
Lenexa, KS 66215-0888
Pat also reports that she has completed the inventory
of approximately 4,000 linear feet of Environmental
Services Division (ENSV) records. Pat was ably
assisted by the ENSV file custodians. She found the
program files well organized but the administrative files
contained much reference material and outdated
records. Pat provided training on the different
schedules for administrative types of files and observed
that the new draft schedules will help reduce the
quantity maintained on-site. Custodians Barb Jones,
Barbara Nichols, Evelyn Van Goethem and Vonna
Shaw are gearing up for a clean-out of those pesky
admin files.
OSWER
The Office of Solid Waste and Emergency Response
(OSWER) has been conducting an inventory of
Headquarters records. They have been using the draft
Agency file plan (based on the new records disposition
schedules) as the tool for identifying and classifying
records series. Thus far OSWER has identified nearly
50 series. Among the most voluminous are contracts,
studies, correspondence, training records, and regional
oversight and coordination files. One interesting note is
that within each series, OSWER designated the records
as active or inactive. Of the nearly 800 feet of records
inventoried to date, more than 40 percent were
identified as inactive, and eligible for off-site storage.
Office of the Administrator
The Office of the Administrator (OA) has undertaken
a major effort to complete its response to the NARA
evaluation. Although some OA programs had provided
input to OA's action plan, others had not. OA held a
meeting of records liaisons to review records
management laws and responsibilities and to provide
background to assist the offices in developing their
action plans.
INFO ACCESS
FEBRUARY 1994
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Messages from the President and the
Attorney General on the Freedom of Information Act
President Clinton recently sent a
memorandum to all Heads of
Departments and Agencies regarding
the Freedom of Information Act. In
the memorandum, the President talks
about the importance of the Act's
"unique role in strengthening our
democratic form of government." He
also expresses his commitment to
enhance the effectiveness of the Act
as one of the means by which the
public can inform themselves about
their government.
The President asks all agencies to
reexamine their administration of the
Act, to reduce the backlog of
requests, and to be sure they conform
with new guidance on litigation
issued by the Attorney General.
Furthermore, he reaffirms his
commitment to openness and reminds
agencies of their responsibility to not
only respond to FOIA requests, but
also to voluntarily disseminate
information as appropriate and
enhance public access through the use
of electronic information systems.
Attached to the President's memo
is another memorandum from the
Attorney General rescinding the
Department of Justice's (DOJ) 1981
guidelines for the defense of agency
action in FOIA litigation. According
to that memorandum, DOJ will apply
a "presumption of disclosure" and
"will no longer defend an agency's
withholding of information merely
because there is a 'substantial legal
basis' for doing so." In addition, all
pending FOIA cases handled by the
Department will be reviewed in light
of this policy change. DOJ's
litigating attorneys will be working
with general counsels to implement
the new policy on a case-by-case
basis.
The Attorney General goes on to
say DOJ will be doing a complete
review and revision of their FOIA
regulations, regulations relating to the
Privacy Act, all disclosure policies, and
all standard FOIA forms and
correspondence. Each department and
agency is encouraged to conduct a
similar review.
The Attorney General's final point
relates to the problem of backlogs of
FOIA requests, expressing the hope
that agencies can work with DOJ to
reduce backlogs during the coming
year. EPA FOIA staff and the Office
of General Counsel are reviewing these
statements to determine what impact,
if any, they will have on current
Agency policy and procedures, and
what changes are either necessary or
appropriate.
If you are interested in obtaining
copies of these memos, please contact
Manker R. Harris (contractor) at
202-260-5272 or HARRIS.MANKER
on All-in-1. He can provide either a
paper copy or an electronic copy via
All-in-1.0
One of the most common, if not the most common, question to be posed to us working in support of EPA's
Air and Radiation Docket and Information Center is "Can I see the most recent information you have
concerning...?" This question raises an interesting records management dilemma.
When a document is received into the Docket, we strive to update our indices and make it available to the
public as soon as possible. This means filing the documents almost immediately. Filing one document into any
one of the hundreds of dockets can test one's recall when attempting to remember what the most recent document
is. We make the documents available to everyone almost immediately; but when you are speaking of hundreds of
documents and strive to provide rapid turnaround, we can lose sight of what the "most recent" is.
To rectify this "loss of sight" and to facilitate patron requests, we have set up a small tickler file containing
copies of the most-recent documents received into the Docket, broken down by the days of the week (Monday,
Tuesday, etc.). When the five most current files are filled, we empty the first and begin again refilling from the
earliest date, thereby keeping the five most recent days immediately accessible to any patron who will ask "Can I
see the most recent information you have concerning..
A "Ticklish" Situation at the Air Docket
by Joe Moeltner (contractor)
FEBRUARY 1994
11
INFO ACCESS
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