United States
Environmental Protection
Information Resources
EPA 220-N-94-009
Issue Number 44
August 1994
Records Network
Recordkeeping Requirements Project Begins
by Michael L. Miller, Agency Records Officer
In This Issue
Recordkeeping Requirements (RR) will
form the basis of the Agency's records
management program for the next
century, providing the overall context
for file plans, records disposition
schedules, and other familiar records
management tools. The National
Records Management Program
(NRMP) is conducting a study to
develop an Agency recordkeeping
requirements framework that programs
will be able to use to develop detailed
recordkeeping requirements for their
records. As currently conceived the
framework will consist of seven steps:
STEP I: Issue Program Directive
The Agency should issue a directive to
identify the program's objectives
responsibilities, authorities, etc. To
implement this, the NRMP would
amend Chapter 10 of the Agency's IRM
Manual to include this material.
STEP II: Establish Media Specific
Recordkeeping Requirements
The Agency should issue directive(s)
specifying requirements for media such
as electronic, audiovisual, cartographic,
microfilm, image. To implement this,
the NRMP would amend currenj
Agency Records Management Manual
chapters to include necessary
requirements, using the materials
provided in the CFR and the NARA
management guide series as a basis for
the requirements. A second action
would be to include requirements or
references thereto in appropriate media
specific directives (e.g., systems life-
cycle management guide, Agency
microform contracts).
STEP III: Develop Recordkeeping
Requirements for Creating and
Maintaining Common Types of
The Agency should produce RR that
speak to specific forms of
documentation that often cause
confusion. In concert with the Office
of General Counsel and Agency
Programs, the NRMP should develop
listings of types of documents to be
covered such as drafts, memos for the
record, minutes of meetings, notes on
telephone calls. E-mail messages, read
receipts for E-mail messages, and
contractor-maintained records. The RR
should indicate the circumstances
under which such items must be
created and/or maintained.
Page 3
Development of Records
Management Manuals in Region 4
Page 4
Superfund Document
Management System in Region 9
Page 4
Tip of the Hat
Page 5
EPA Responds to
NARA on Vital Records
Page 5
The IRM Poucy Manual is
Page 6
EPA Responds to NARA's
Proposed E-mail Standards
Page 8
Automating Records Management
Page 8
Headquarters Update
Page 9
Around the Records Network
Page 10
Tips for Using the Revised
Records Disposition Schedules
Page 11
Software, continued ...
Page 12
Ask Dr. Records
Page 13
FOIA Issues for Records Managers
Page 14
Records Retention Schedui£s
recordkeeping continued on page 2-3
Printed on Recycled Paper

Recordkeeping from page 1
Since staff frequently think in terms
of types of documents rather than
functions or actions documented, it is
necessary to provide some guidance in
this form. These RR should be
developed for any type of document
that staff find to be "gray areas" where
they need guidance. These RR would
serve as "minimum standards" and
could be strengthened through function
specific RR.
STEP IV: Develop High-Level
Agency Functional
Recordkeeping Requirements
With the help of Program offices the
NRMP should compile listings of
major agency functions and supporting
documentation. As part of this step the
NRMP should review documentation
about Agency functions and develop a
list of primary programmatic functions.
An example might be managing toxic
waste sites, with sub-functions to
include cleaning up the site, recovering
the costs, pursuing litigation, and
keeping the public informed.
The NRMP would use the list to
review records disposition schedules to
determine what records series are
currently being created to support these
functions. The NRMP would then link
records schedules to functions and
annotate schedules to show what
functions they support. If there were
functions for which no records
schedules currently exist, the NRMP
would contact programs to identify
relevant records.
Programs would review the lists of
functions and series to determine
whether any records have been missed.
Together the NRMP and the Programs
would develop a final listing of
functions and the series that the
Agency determines to be necessary to
adequately document those functions.
A key point here is that RR should
be developed for the most important
functions first; in fact, many
operational functions probably won't
need detailed requirements. The
decision on where to begin and how
deep to go should be based on a risk
analysis of administrative, fiscal, and
legal needs for the records.
STEPV: Develop Generic
Guidance for Widely Created
The NRMP should develop generic RR
to ensure that basic types of records
series such as meeting minutes,
dockets, administrative records have
similar RR. These RR serve as the
basis for more detailed program
specific RR. The NRMP and Program
offices should identify series for which
generic RR are appropriate. Examples
would be: dockets, administrative
record files, rulemaking files, permit
files (EPA issued), permit files (EPA
oversight), Scientific Advisory Board
Committee meeting files, program
direction files, and program
management files.
For each of these generic records
series, the NRMP would coordinate
development of a basic set of RR that
would have to be met at this level.
Examples include: retention, a file
plan/organizational structure, guidance
on drafts, guidance on file maintenance
procedures, and document lists to show
mandatory documents that must be
included, documents that may be
included, and documents that should
not be included.
STEP VI: Develop Series-Specific
Recordkeeping Requirements
Programs should ensure that all major
series needed for documentation of
Agency functions have series specific
RR. To do so, programs would develop
listings of series level mandatory RR.
Basic information should include in the
RR would be: name of the series,
function supported, source of
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>

Development of Records Management Manuals in Region 4
by Rosa Dickens (contractor)
The Regional Records Program for
Region IV has been given the task of
establishing and promoting records
management in the Region. One of the
key goals of this program is to create
file structures and write manuals for
the EPA divisions. Unfortunately,
when the present staff came into the
program, a backlog of EPA Programs
wishing to obtain file structures and
manuals had accumulated.
The first task on our agenda was to
establish the purpose the manuals were
to serve—documenting the
organization, maintenance, and
disposition of the EPA Programs'
records. With this in mind, the
contractor responsible for writing the
manuals developed a (hopefully,
foolproof) technique for getting at the
end result—a well written manual that
the EPA Programs can utilize.
requirements (legislation, policy, etc.),
custodian and location of records,
retention and disposition, file plan/
organizational structure, guidance on
drafts if different from Agency,
guidance on files maintenance
procedures and document lists as
described above.
STEP VII: Evaluate the
Effectiveness of the Requirements
The Agency must determine whether
the RR are actually resulting in the
preservation of adequate and proper
The first step in this process is to
meet with the entire unit that will be
receiving the manual and through them
determine the kinds of records created
by their unit and the persons
responsible for the creation of these
records. Once that is accomplished,
individual meetings are held with those
persons to gather more in-depth
information needed to develop a file
structure and to write the manual.
During these meetings a file structure
begins to take shape and the process of
writing the manual commences. By the
time the meetings are completed, a file
structure has been developed, NARA
schedules have been matched with the
records and the manual is well
A draft manual encompassing all
the aforementioned information is
presented to the unit chiefs and other
documentation. As part of the Agency
records management evaluation
program the Agency should
periodically review series and RR to
ensure that adequate and proper
documentation is being created and
As the NRMP identifies Agency
functions that require recordkeeping
requirements, the NRMP will contact
programs for copies of file plans and
other guidance used in creating the
records. The timing of the project is to
have the recordkeeping requirements
designated persons for their review.
Upon the receipt of their comments, it
is determined whether more individual
meetings or clarification is needed and
if not, the task of writing the final
version incorporating all comments and
changes is begun.
The final version of the manual
covers everything from general records
and records handling to the specific
records of the unit and dispositioning
of the records.
Implementation of the
recommendations in the manual will
provide the EPA Programs with a
uniform records system for active,
semi-active and inactive records;
simplified filing instructions; faster
retrieval of records; faster FOIA
response time; better security for CBI
or other sensitive records; and easier
identification of records for records
disposition. ¦
framework developed in time for
implementation following the Agency-
wide inventory. As products are
developed, they will be shared with the
records management network and
comments incorporated. The first
product, the overall project plan, is
now available from Manker R. Harris
at 202-260-5272 or on All-in-1 at
Harris.Manker. Records officers
interested in participating in the project
should contact Mike Miller on
202-260-5911 or on All-in-1 at

Superfund Document Management System in Region 9
EPA Region 9 and OSWER
Information Management are
cooperating in the development and
implementation of the Superfund
Document Management System
(SDMS). SDMS is an automated
imaging/text/index system designed to
meet Superfund site file documentation
and records management needs.
All Regions face a number of
problems related to managing
Superfund site files. Even with high
quality paper filing systems and
electronic indexing, the quantity of
paper is overwhelming. Documents can
be lost or damaged. Sensitive
documents are vulnerable to '
inadvertent disclosure. Documents that
are needed can not always be found
quickly. Multiple users cannot have
simultaneous access to the same
documents. Microfilm provides backup
but is awkward to use and paper
backup is expensive. Information
sharing with responsible parties and the
public is often cumbersome because
multiple copies of important
documents must be produced and
disseminated to many parties.
SDMS relates each document's
Image to its Full Text and Index. Users,
including Remedial Project Managers,
Enforcement Staff, Attorneys, and
Records Management contract
personnel, may search by any word in
the text, any indexed field or a
combination of the two. At the
conclusion of the search the user may
display the actual image and text of the
document, then import either or both
from SDMS into a working document,
such as WordPerfect.
SDMS operates over the Local
Area Networks (LANs) with all
documents accessible at every work
station. SDMS stores hundreds of
thousands of pages on a single 12 inch
optical disk. Paper original pages can
be sent off-site to a Federal Record
Center. Duplicate optical disks can be
stored off-site to provide a complete
backup to meet Vital Records
requirements. Sensitive documents in
the system can be electronically
redacted (blacked out) to allow only
authorized access.
Since pages on optical disks can be
readily converted to paper and has the
potential to be converted easily to
microfilm and CD ROM, we will be
able to distribute the Administrative
Record and/or Site Files to responsible
parties, Public Repositories, or other
"customers" based on their access
capabilities including the "Information
Super Highway."
In late June, Lisa Jenkins and
various members of the SDMS team
contract staff were here in Region 9 to
install the first actual version of the
application, load data converted from
the old indexing system (ImageTrax)
and conduct user training. Training was
conducted for the users including
Project Managers, Enforcement Staff,
Attorneys, and Records Managers
including contract personnel of Labat-
Anderson. Since then, we have been
going through the "discovering and
dissolving the bugs" stage of
implementation. But the application is
coming together and every day both
managers and staff see new ways to
use the system for streamlining and
improving our work processes. We
hope the system will be fully
operational in Region 9 in September,
If you have any questions on the
Region 9 implementation of SDMS
please call Margaret Morkowski in
Region 9 at (415) 744-2364. If you are
interested in exploring implementation
of SDMS in your Region, please
contact Lisa Jenkins of the OSWER
Information Management Staff at
(202) 260-7951 (All-In-One:
Jenkins.Lisa or LanMail: LJenkins on
Tip of the Hat
Joseph Clore is now
the RCRA Records
Manager in Region 2.
Welcome to
Howard McCartney
(contractor), the new Records
Manager in Region 6; to Maria
Korte (contractor), the new
Records Center Manager in
Region 7; Gail Snow (contractor)
the new Records Managerin
Region 8; and William Jetmirifigt
Principal Contact, in OECA at

EPA Responds to NARA on Vital Records
Unlike the proposed standards on
electronic mail (see page 6), the
National Archives and Records
Administration (NARA) proposed
regulations on vital records drew very
little interest—much less than they
should have, given their potential
impact. If implemented, the proposed
regulations would result in three major
1.	The emphasis of the vital records
program would be changed to
providing for protection against
natural disasters as well as civil
defense emergencies. EPA
concurred with the intent of that
2.	Agencies would be required to
duplicate all vital records to ensure
that such records would be given the
special protection needed to prevent
unauthorized loss or removal. EPA
responded that such a requirement
could prove to be very expensive.
And duplication should be
determined by the agency on a case-
by-case basis.
3. The regulations on vital records
would be broadened to require
agencies to plan for the protection
and recovery of all records
effected by a disaster or
emergency. While EPA agreed
with the intent of that change, EPA
felt that the program proposed by
NARA was more elaborate than is
necessary in many cases.
The Agency's comments centered on
three points:
¦ In essence NARA is requiring two
new programs complete with
directives and training, without
demonstrating that they are
necessary for all agencies. EPA
suggested that NARA require
agencies to review their records
management programs with
respect to these issues, but allow
agencies latitude on how to best
address any problems identified.
The specific procedures expressed
in the proposed regulations would
be better provided in a
management guide of potential
best practices to help agencies
comply with the requirements rather
than making them requirements
¦	NARA's requirements for separate
directives, programs, lead officers,
etc., appear to represent a generic
answer to all records management
problems rather than a detailed
understanding of the needs of Federal
agencies in this area.
¦	NARA's requirement that all vital
records relating to rights and interests
of the government or its citizens be
duplicated flies in the face of its own
guidance that agencies analyze how
best to protect their vital records. It is
EPA's position that duplication is not
cost effective in all cases. EPA also
commented that the guidance on
identifying vital records is vague and
should be expanded.
The proposed regulations can be
found in the Federal Register for
Tuesday, May 31, 1994. If you would
like a copy of the Agency's comments
contact Manker R. Harris at 202-260-
5272 or on All-In-1 at Harris.Manker. ¦
The IRM Policy Manual is Now Available on Videotex
by Suzanne Annand, OIRM	_____
The IRM Policy Manual, Directive
2100, is now available on Videotex. It
can be found under the Policies and
Procedures section of the Videotex
menu on All-In-One electronic mail
and on the Value-Added Backbone
Service (VABS). The Uniform
Rulemaking Docket Policy is also
available in the same section. So, next
time you have to take a look at
Chapter 10 and you can't find that
hardcopy of the Manual, just type vtx
at All-in-One's electronic messaging
menu and it's right at your fingertips.
You can also download or print
sections of the documents by using the
All-In-One scratch pad function. ¦

EPA Responds to NARA's Proposed E-mail Standards
The standards for electronic mail (E-
mail) proposed by the National
Archives and Records Administration
(NARA) were the most discussed
regulations NARA has issued in years
EPA responded to NARA with nine
pages of specific comments drawn
from those submitted by a number of
Agency offices. Due to the high level
of interest in this issue, we are
including the text of the letter EPA sent
to NARA concerning the proposed
regulations. For a copy of the nine
pages of specific comments, contact
Manker R. Harris (contractor), at 202-
260-5272 or via All-In-1 at
James J. Hastings, Director
Records Appraisal and Disposition Division
National Archives at College Park
8601 Adelphi Road
College Park, MD 20740-6001
Dear Mr. Hastings:
Enclosed are the Environmental Protection Agency's (EPA) comments on the National Archives and
Records Administration (NARA) proposed standards on electronic mail (E-mail). We are providing both
general and specific comments on this document. I hope you will find them useful in revising the draft
Like others in the Federal government, our Agency is learning to cope with the explosion of electronic
records. We recognize clearly that electronic recordkeeping offers the promise of better documentation of
Agency activities, better access to Agency information by the public, and improved control over our records.
While we appreciate NARA's interest in electronic recordkeeping and look to NARA forguidance in records
issues, we do not feel that the current draft standards are helpful in meeting the challenge of managing E-mail.
We have three main concerns that are detailed in the enclosure. The first is that the proposed standards
in their present form are essentially unnecessary and often confusing. The portion that merits inclusion in
Federal regulations offers nothing not already found in existing NARA regulations, except for the definition
of what constitutes a complete E-mail record. We recommend that the proposed standards be rewritten to
eliminate the obvious repetition and inconsistencies, and be distributed as one of NARA's highly useful
instructional guides.
Second, having such a lengthy regulation covering just E-mail flies in the face of two basic principles of
the reinventing government movement: "rowing" rather than "steering," and being "results oriented." I'll
offer only two examples here:
¦	NARA's existing regulations speak to the need for an agency to create and maintain "adequate and
proper documentation." It is the agency's responsibility to determine how to implement those
regulations, and NARA's to evaluate how well the agency does it. It is also NARA's role to remind
agencies that E-mail messages can meet the definition of a Federal record, and those that do so must
be maintained as records. However, the draft regulation goes beyond that to discuss the details of how
an agency could approach the problems posed by E-mail. We recommend that NARA provide
suggestions on technical approaches to E-mail in guidance documents rather than in its regulations.
¦	Iji:|he case of monitoring E-mail messages, the regulations require establishing a regular process for
checking whether messages have been properly deleted or saved by individual staff. We feel that,
beside* being burdensome and invasive, this requirement is not results-oriented. For NARA, the issue
Ilow individuals manage their E-mail, but whether the agency's records in all media are

sufficiently complete to provide adequate and proper documentation as required. Rather than
focusing on how staff are managing their E-mail, we suggest that NARA provide agencies with
better guidance on overall recordkeeping requirements for records in all media. This would assist
agencies in evaluating whether or not there is need to monitor of E-mail messages or other records
Third, there is the issue of burden and cost. Most obviously there is the cost of conversion to an
electronic recordkeeping system. Although we are stri ving to maintain an increasing portion of our records
electronically, we believe that it is not now cost effective to develop an electronic recordkeeping system
just to handle E-mail. Rough estimates show that to make the many current E-mail systems across our
agency even minimally compliant with the draft standards would cost over $ 10 million, primarily for extra
equipment on our local area networks. Where only 15 percent of our E-mail traffic constitutes Federal
records that need to be kept for more than 90 days (our findings in a small test survey conducted by our
records management staff), it is not cost effective to modify our E-mail systems to operate as recordkeeping
There are other potential burdens as well. The draft regulation can be interpreted to require agencies
to develop separate programs to train staff in managing E-mail records and to monitor E-mail use. This
would be extremely costly, whereas it would be more useful to incorporate E-mail issues into our ongoing
records management training and our internal evaluations of Agency records,
We offer the following four suggestions. NARA should:
1.	Include a definition of E-mail records in NARA's regulations at 36 CFR 1234.2 (Electronic
Records Management, Definitions). The definition should state that E-mail messages that qualify as
Federal records must include sufficient transmission and receipt information to adequately
document their use for current and future needs.
2.	Revise the proposed standards and issue them as a part of NARA's highly successful instructional
guide series.
3.	Work with the General Services Administration, Federal agencies, and vendors to detemiine
functional requirements for E-mail systems that will allow them to operate easily as recordkeeping
systems. To actually contribute to improved recordkeeping, the software development initiative
should address all types of documents, not just E-mail. This will take considerable time to develop,
plus additional time to implement.
4.	Establish a realistic timetable for overall implementation, based on Federal budget cycles.
Like NARA, EPA looks forward to the day when agencies can take advantage of existing and
future technologies to better manage their records and provide greater internal and external access to
Federal information. Agency-wide, we are committed to reducing our use of paper. Managing records
electronically is one key way to do that. Currently, several EPA programs are investigating ways of
maintaining their official records entirely electronically. These projects will help us define
requirements and establish models for future implementation. Based on our experience to date on this
issue, we feel the draft regulations will hurt, not help in making this,transition.
If you have any questions about this response, please contact our Agency Records Officer, Michael
Miller, on (202) 260-5911.
Jonathan Z, Cannon
Assistant Administrator

Headquarters Update
Automating Records
Information supplied by Region 9
and reviewed by Lisa Jenkins, OSWER
OSWER is currently implementing two
computer-aided tools to assist with
referencing the new records
disposition/retention schedules and
records retired to the Federal Records
Center (FRC).
One tool simply uses the
WordPerfect 5.1 files of the new
records schedules and makes them
available to each OSWER Office
Records Contact. The files are
provided on two diskettes in PKZIP
format so they must be PKUNZIPPED
using a PKUNZIP file on the diskette
before they can be used in
WordPerfect. (This is a common
practice for transferring large files).
The Contact may then put the files on
their own PC for their own reference,
or on their Office LAN for "read only"
access by Office staff and
management. WordPerfect's basic full
text "Find" function makes finding
relevant schedules quick and easy.
Although this does not represent a
technological "feat," it is indispensable
allowing the user to narrow in on
applicable schedules without having to
flip through 700 schedules in paper
The second tool is the OSWER
SF13S Database. This database,
accessible through InMagic 7.2
Automating continued on pag* 9
Department of Defense Looks at Electronic Records
The Department of Defense (DOD) is planning for the future of their records
management program. They have developed a model for making the transition to
primarily electronic recordkeeping by the year 2005. Among the steps they plan
to take are several that are familiar to EPA: completely revise and consolidate the
records schedules, develop more standard retention and disposition statements,
and create an overall file plan. One area where DOD has moved well ahead of
other agencies is in developing detailed recordkeeping requirements that all
automated systems will have to meet. They have developed a list of 46
requirements, such as ability to delete records, ability to select records, and ability
to store records throughout their life cycle. One thing that surprised the DOD
research team was that there was document management software on the market
now that would meet 43 of the 46 requirements. For a copy of selected portions of
the report, contact Manker R. Harris at 202-260-5272 or on All-In-1 at
NARA and Microform
The Washington National Records Center which serves the Washington, DC
metro area will start enforcing portions of their regulations concerning the transfer
and inspection of permanent and unscheduled microform. A copy of the letter was
sent to all Headquarters records officers. A copy can be obtained from Manker R.
Harris at 202-260-5272 or on All-In-1 at Harris.Manker. Field offices should
contact their records centers to inquire whether they will be enforcing these
regulations as well.
Information Security Manual Circulated for Comment
A draft information security manual was circulated for comment by the
Information Management and Services Division. The manual covers both
automated and manual systems and provides guidance for developing plans for
identifying and protecting sensitive information. For more information about the
manual, contact Don McGinnis at (202) 260-8671.
Dockets to Accept Electronic CoMMtNfs
EPA is embarking on a pilot project to allow the public to comment on
selected Agency proposed rules published in the Federal Register. The goals of
the pilot, which will run until January, are to determine the feasibility of
accepting electronic comments and develop procedures for doing so effectively.
While public access to Agency information is the driving force, records

Headquarters Update (Cont'd)
management issues are a core concern. Mike Miller, Agency Records Officer, the
members of the Headquarters Docket Work Group, and the Office of General
Counsel are working with John Richards to develop the necessary procedures to
ensure that electronic filing of comments does not affect the integrity of the
dockets' records.
Records Schedule Update
The NRMP has now sent all of the revised schedules in the new format to the
appropriate SIRMOs for review. Programs are expected to review the draft
schedules, make any changes necessary and propose new schedules for records
that are currently unscheduled. As soon as responses are received from the
programs, the NRMP will submit the schedules for Green Border review on a
Program by Program basis.
Around The Records Network
Region 5
Lorraine Kos (contractor), reports that the Superfund records center has
changed a number of filing procedures to include the use of more color coded
filing techniques. Contract files which may cover more than one site have
different colored folders for each site within the contract. In addition, sampling
documents which are part of the Administrative Record are filed in green
accordion files within the organized NPL files. And finally, green tape on folder
tabs is used to distinguish emergency removal and enforcement files which are
being integrated into the organized NPL site files. Use of these various color
coding techniques makes finding specific types of files much easier and quicker.
AWBERC's Records Committee has reviewed its standard operation procedure
on vital records to ensure it complies with agency policy. Records liaisons from
each lab and administrative division are identifying and duplicating vital records
within their areas. Duplicates will be sent to the Dayton Federal Records Center
and an environmentally controlled off-site storage facility. The Dayton FRC does
not accept electronic records so they, along with emergency operating records,
will be sent to the commercial storage facility. Lists of the vital records will be
sent to the Emergency Operations Center in Washington, D.C. via All-in-One.
Automating from page 8
software, provides a mechanism for
storing, retrieving and printing
information about the folder contents
of boxes stored in the Federal Record
Centers (FRCs). The system is used to
capture and print out the official box
content list which is sent with the SF-
135 form when retiring records to the
FRC. The same system is also used to
determine the existence and location of
records in the FRC in response to
information requests and FRC
Reference Requests (OF-1 Is).
At present, the database holds only
those records retired by Labat-
Anderson, Inc. (LAI) staff providing
support to OSWER through an
OSWER-IM Delivery Order from 1992
to 1994. It is currently only accessible
by OSWER-IM and the LAI staff.
Plans are in the works, however, to
include in the database other OSWER
records that have been retired to the
FRC. We are also looking into making
the SF135 database accessible by other
OSWER personnel (particularly in
those offices already utilizing
InMagic—OERR/ERD and OERR/
HSCD) through the network of HQ
We welcome more examples of
records management automation.
Please send your ideas to Manker R.
Harris (contractor), Network
Coordinator, 3404, EPA National
Records Management Program,
401 M Street, SW, Washington,
DC 20460. E-mail: Harris.Manker;
Telephone: (202) 260-5272. ¦

Tips for Using the Revised Records Disposition Schedules
Now that all of EPA's records
disposition schedules have been
converted to the new schedule format
and are moving through the approval
process, we thought it would be helpful
to share answers to some of the most
often asked questions about using the
There are a number of finding aids
available to help you find the specific
schedule you need. Lists are available
which have the schedules arranged by
EPA series number, alphabetically by
series name, by program, and by
applicability (that is, agency-wide,
headquarters, regions, labs, etc.).
If you have Inmagic software in
your office, you can obtain a copy of
the database and search for the
appropriate schedule electronically.
Lists can also be obtained in
WordPerfect format. Some contacts
have found this to be very useful since
they can add and delete or manipulate
the information to meet their own
Information on how to obtain these
finding aids is given at the end of this
When schedules are submitted to the
National Archives, they assign "job
numbers" to each agency. EPA's
assigned numbers begin with NCI-412
or N1—412. The next element of the
number is the fiscal year. The last
element consists of two numbers—the
records schedule submission number
and the item number. For example, NI-
412-94-2/3 means: EPA, FY 94,
submission number 2, item number 3.
Revised schedules submitted to
NARA earlier this year were broken
into 5 groups and assigned the
following job numbers:
N1-412-94-002 Agency-wide
N1 -412-94-003 Superfund program
N1-412-94-004 Regions
N1 -412-94-005 RCRA program
Nl-412-94-006 Headquarters
Once the National Records
Management Program (NRMP)
receives the job numbers, item
numbers can be assigned for each of
the schedules within the groups. For
example, EPA 006A—Program
Management Records, became item no.
3 of group N1-412-94-002 or
I'm familiar with the old
If you are familiar with the old
schedule numbers, there is a cross
reference list available from the NRMP
which you can use to lead you from the
old schedule number to the EPA series
number and the revised schedule
In some cases, the approved
schedule number remains the same
since the disposition has not changed.
If the disposition has been changed
and is yet to be submitted to NARA,
the word "pending" will show up as the
schedule number.
A number of revised schedules
have been submitted to NARA and
they have been assigned new schedule
numbers. The prefix for these
schedules is N1-412-94-. (Program
management files, EPA series number
006A,for example, is N1-412-94-2/3.)
Since all the schedules have not
Once you have found the schedule you
are looking for, check the section
entitled "NARA Schedule No.". If
"Pending" appears, you can not use the
schedule until it has gone through the
approval process and is assigned a new
NARA schedule number.
If a GRS or N1 or NC1 number
appears, you may use the schedule to
retire or dispose of records unless the
prefix is N1-412-94. In the latter case,
you can only retire records to the
Federal Records Centers (and not
destroy them) since they have not
received final approval.
What do i do if i can't find the
It is possible the records series you are
looking for is identified by a different
name or included in a different series

or does not have a schedule. Check
with the NRMP.
Contact your Records Liaison Officer
or the NRMP. The NRMP has two
documents which will help. One is a
Questionnaire for Updating the U.S.
EPA Records Control Schedule and the
other is the Guidelines for Completing
the Records Control Schedule (SF115).
Why is it taking so long to get
Schedules which have had substantial
changes must be approved by both the
agency and the National Archives. This
can be a lengthy process. To prepare
the schedules for the agency's Green
Border Review process, drafts are
prepared and sent to the appropriate
programs for approval. After program
revisions are incorporated, the
schedules are ready for Green Border.
In an effort to speed up the
approval process, the schedules are
submitted to the National Archives at
the same time they are sent out for
Green Border. Mike Miller, the
Agency's Records Officer, also
requests "an unscheduled exception"
from NARA to use the pending
schedules to retire records. That way,
even if it takes some time to obtain
approval, the agency can still retire
records to the Federal Records Centers.
Note, however, that we can not use
them to destroy any records until final
approval is received.
Yes, the schedules are being
maintained in WordPerfect and copies
can be obtained through the NRMP.
Other electronic formats are being
The "Program Office Guidance/
Descriptive Information" section of the
schedule has been designed specifically
so programs can include additional
information to records users. This
section could be used, for example, to
identify custodians not covered in the
Custodial Information section, special
instructions, or other information
useful to program staff.
Paper copies of the records
schedules and finding aids can be
obtained by contacting Manker R.
Harris (contractor), at (202) 260-5272
or Harris.Manker on All-in-1. Contact
Sandy York (contractor), at
(303) 840-0464 or York.Sandy on
All-in-1 for electronic copies or lists
needed for specific purposes. ¦
Software, continued. . .
In the June issue we reported the installation of Versatile software in
Regions 4 and 6. Versatile is software specifically designed for records
management applications. There are a number of other offices where
"generic" or multi-purpose software is used for records management. One
example can be found on page 8 of this issue. Another example is at
AWBERC in Cincinnati. Five different databases have been developed
using dBase II Plus. The main database1 tracks all boxes located in their on-
site storage area, others track boxes destroyed, boxes-Sent to the FRC,
inventories of on-site storage, and box circulation. Databases can be linked
on the box field. Plans include making the databases available on the LANs
so staff can search online.

Ask Dr. Records
A while back you talked about
planners and calendars and when
they are records. Does everyone
have to keep a calendar?
Our research has not found any
Federal or Agency directive that
requires every employee to
maintain a calendar. Whether
employees have to create and
maintain calendars is a records
management issue only in one
respect. Programs must have
adequate and proper
documentation of their activities.
Given that requirement, managers
must decide whether calendars
are mandatory or optional for
their staff.
In the new Agency file plan, the
filing designation for controlled
correspondence is CORR 141 and
the one for general
correspondence is CORR 127.
We prefer GCOR 127 for general
correspondence and CCOR 141
for controlled. Can we use those
designations, or must we use the
ones OIRM supplies?
In the new draft Agency file plan
distributed at the training sessions
in May, the filing designation
such as CORR 141 for controlled
correspondence is made up of
two segments. The number, 141
in this case, refers to the new
Agency records disposition
schedule for controlled
correspondence. The CORR part
is a four letter mnemonic prefix
that is meant to help those filing
remember what the numbers
stand for. The number is
mandatory and cannot be
changed. We are suggesting a
four letter prefix that we feel
from an overall Agency
standpoint makes the most sense,
but they may not for some
offices. Freedom of Information
Act letters are given the prefix
FOIA in the Agency plan, but
some offices may consider it a
type of correspondence and want
to use CORR with the number
034. What four letter prefix you
want to use is up to you,
provided you use the correct
number and you provide an
overall file plan that identifies all
of your filing designations.
The Federal Records Center
requires that all boxes we send
there be full. Yet in some cases,
we may not generate enough
records in a year to fill a box.
What should we do?
This is a very common problem,
at EPA and elsewhere. The first
piece of advice is to contact your
local records officer or records
center to see what that center's
preferences are. Different ones
take different approaches to
resolving this problem. There are
two basic approaches. Option 1:
combine several small series with
the same destruction date or date
for transfer to the Archives in the
same box. Option 2: hold the
records in the office for a longer
period of time until you have a
full box. There may be others. If
so, Dr. Records would love to
hear about them. Filling the
empty part of the box with
newspapers doesn't count as a
suggestion, however.

FOIA Issues for Records Managers
by Brook Sadler (contractor)
At the Records Management Council
Meeting on June 28,1994, Marlyne
Lipfert who specializes in Freedom of
Information Act (FOIA) issues in the
Office of General Counsel (OGC),
spoke about some FOIA concerns with
relevance to records management. She
used the meeting as an opportunity to
both inform records managers of some
of FOIA's procedural requirements and
to elucidate through discussion the
very particular ways in which FOIA
issues are inherently connected to
broader records management issues.
EPA's FOIA records retention
schedules follow the mandatory
retentions specified by the National
Archives and Records Administration
(NARA) in the General Records
Schedules (GRS).
Marlyne noted that it is important to
remember that FOIA files are
maintained by the calendar year rather
than the fiscal year. She explained the
life cycle of a FOIA request beginning
from the time it is logged in by the
Freedom of Information (FOI) Office
and stated that the Agency's records
retention responsibilities begin at that
Each office that plays a part in the
process of responding to the FOIA
request has a role to play in the records
retention process. For example, the
FOI Office is responsible for
maintaining the FOIA control files, the
FOIA reports files, and the FOIA
Administrative Files. Headquarters and
Regional Program offices (also called
action offices) are responsible for
maintaining FOIA request files and the
official file copy of the requested
records. The Office of General Counsel
or the Office of Regional Counsel, as
appropriate, is responsible for
maintaining the FOIA appeals files and
FOiA litigation files.
Marlyne explained the procedures
for responding to FOIA requests and
pointed out areas where records ;
management issues could play an;
important part. One such area is the
nature and extent of the agency s
search for responsive documents For
instance, if the office has a good
records management system in place,
the search method could possibly be as
simple as reviewing indices of records
maintained by that office to identify the
files that might contain responsive
Mike Miller (ISMD) questioned the
nature of search method when an office
has no organized official files. Marlyne
replied that if the responding office has
no organized files, the person searching
for responsive documents would have
to search through all of the files to
locate the responsive documents. When
records responsive to a FOIA request
have been retired to the Federal
Records Center, it is necessary to get
the records back from the Records
Center to respond to the request. This
is another area where a good records
management system is important. If the
records retired to the record center
have been properly indexed, it is much
easier to identify the specific boxes of
records that will need to be recalled.
One last thing that record managers
must always keep in mind is that the
official file copy of the records at issue
in a FOIA request, appeal or litigation
should be disposed of in accordance
with the approved Agency disposition
instruction for the related records or
with the related FOIA request, appeal
or litigation retention schedule,
whichever is later.
For your ease in reference, the
EPA's FOIA Records Retention
Schedules appear on pages 14-15 . If
you have any questions about records
retention issues, please call Mike
Miller at 260-5911. If you have FOIA
questions, you can call Marlyne Lipfert
at 260-5472 or Jeralene Green, the
Agency FOI Officer, at 260-1050. ¦

Records Retention Schedules
Freedom of Information files are maintained by calendar year, and should be
retained in accordance with EPA's Records Control Schedules. The schedules
below are maintained by the Information Management and Services Division.
1. Agency And Regional FOI Offices
a.	FOIA Control Files.
Files maintained for control purposes in responding
to requests, including registers and similar records
listing date, nature, and purpose of request and
name and address of requester.
1.	Registers or listing.
(e.g., log)
Destroy 6 years after date of last entry.
2.	Other files.
Destroy 6 years after final action by the Agency
or after final adjudication by courts, whichever is
b.	FOIA Reports Files.
Recurring reports and one time information
requirements relating to the Agency implementation
of the Freedom of Information Act, including
annual reports to the Congress.
1. Annual reports at Departmental/Agency level.
Permanent. Offer to the National Archives and
Records Administration (NARA) with related
Agency records approved for permanent
retention in Agency records control schedule or
when 15 years old, whichever is sooner.
2. Other reports.
Destroy when 2 years old or sooner if no
longer needed for administrative use.
c. FOIA Administrative Files.
Records relating to the general Agency
implementation of FOIA, including notices,
memoranda, routine correspondence, and related
Destroy when 2 years old or sooner if no longer
needed for administrative use.
2. Headquarters And Regional Program
Offices (Action offices)
a. FOIA Requests files.
Files created in response to requests for
information under the Freedom of Information
Act consisting of the original request, a copy of
the reply thereto, and all related supporting files
which may include official file copy of requested
record or copy thereof.
1) Correspondence and supporting documents
(Excluding the official file copy of the records
requested if filed herein).

Records Retention Schedules (Cont'd)
•	Granting access to all the requested records.
Destroy 2 years after date of reply.
•	Responding to requests for nonexistent
records; to requesters who provide inadequate
descriptions; and to those who fail to pay
agency reproduction fees.
-	Request not appealed.
Destroy 2 years after date of reply.
-	Request appealed.
Destroy 6 years after final determination by
Agency or 3 years after final adjudication
by courts, whichever is later.
•	Denying access to all or part of the records
a.	Request not appealed.
Destroy 6 years after date of reply.
b.	Request appealed.
Destroy 6 years after final determination by
Agency or 3 years after final adjudication
by courts, whichever is later.
2) Official file copy of requested records.
Dispose of in accordance with approved Agency
disposition instruction for the related records, or
with the related FOIA requests, whichever is
3. Office Of General Counsel
(Office Of Regional Counsel)*
a. FOIA Appeals Files.
Files created in responding to administrative
appeals under the FOIA for release of
information denied by the Agency, consisting of
the appellant's letter, a copy of the reply thereto,
and related supporting documents, which may
include the official file copy of records under
appeal or copy thereof.
1)	Correspondence and supporting documents
(Excluding the file copy of the records under
appeal if filed herein).
Destroy 6 years after final determination by
Agency or 3 years after final adjudication by
courts, whichever is later.
2)	Official file copy of records under appeal.
Dispose of in accordance with approved
Agency disposition instruction for the related
record, or with the related FOIA requests,
whichever is later.
* FOIA appeals arising out of a regional denial
under 40 CFR 2.204(d)(1) are transferred by the
Office of General Counsel to the Office of
Regional Counsel. The Regional Counsel's final
confidentiality determination serves as die
Agency's determination on the appeal.









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