Records Management Self Evaluation Guide
EPA 220-B-97-002
June 2001
Introduction [[[ 2
Program Management [[[ 3
A. Program authorization and organization [[[ 3
B. Guidance and Training [[[ 4
C. Internal evaluations [[[ 5
Records Creation and Recordkeeping Requirements [[[ 6
A. Creation of records and adequacy of documentation [[[ 6
B. Contractor records [[[ 6
Records Maintenance [[[ 7
A. General [[[ 7
B. Paper-based Records [[[ 8
Maintenance of Special Records [[[ 8
A. Electronic Records [[[ 9
-------
Introduction
The National Archives and Records Administration (NARA) developed
•''.,-- : ' f • - ' to monitor their records
management programs. This EPA National Records Management Program
(NRMP) Tool Kit is based on that publication and is provided to assist EPA
programs and offices implement the Federal requirement to conduct self-
evaluations as outlined in NARA records management regulations (36 CFR
1220.42).
Using this Self-evaluation Tool Kit will assist EPA programs and offices:
• Make a preliminary assessment of the status of their records
management programs.
• Identify major problems.
• Set priorities for program improvements.
• Assist in the development of their own comprehensive records
management programs.
Other NARA and NRMP publications provide additional details regarding
records creation, maintenance, and disposition policies and procedures.
Relevant publications are available from the NRMP Records Management
Collection.
Although this Tool Kit provides a framework for a general evaluation of a
records management program, programs that wish to conduct a more in-
depth review may add more specific questions based on other records
management publications. Programs may also modify or add questions to
accommodate specialized records and recordkeeping practices. No guide
developed for agency-wide use can replace audit or evaluation activities
tailored to the unique organization and operations of each program.
This Tool Kit is divided into six broad sections. Programs may use the entire
Tool Kit to conduct a comprehensive program review or select sections to
focus on specific areas, such as records disposition or files maintenance. The
Tool Kit consists of a series of questions to be answered either "yes" or "no."
A "yes" answer indicates compliance with NARA records management
regulations and recommended practices.
-------
The term "records liaisons" includes EPA staff at headquarters, regions, field
offices, or laboratories who have responsibility for managing Federal records.
All other terms are defined in NARA records management regulations (36
CFR 1220.14 and 1234.2).
Program Management
An effective EPA records management program requires:
• A clear definition of program objectives, responsibilities, and
authorities;
• Sufficient resources to administer the program;
• Continuing training for staff; and,
• Regular internal evaluations to monitor compliance and program
effectiveness.
The benefits derived from a good records management program include:
• Ready access to records that provide essential evidence of Agency
actions;
• Documentation of the rights of citizens and the actions of federal
officials;
• Economy and improved efficiency through access to complete and
accurate information;
• Avoidance of unnecessary costs for records storage; and,
• Assurance of continuity of operations through preservation of essential
records.
A. Program authorization and organization
Yes
No
Questions
1. Has the program or office formally designated a records
liaison with responsibility for carrying out a records
management program?
2. Does a program directive(s) define the role and
responsibilities of the records liaison and the scope of the
-------
Yes
No
Questions
records management program and provide authority to the
records liaison to conduct an effective program-wide program?
3. Has the program or office formally incorporated its records
management program into the information resources
management program?
4. Does the program or office records liaison provide program
direction to a network of records liaisons in major divisions
throughout the program?
5. Are records management responsibilities included in the
position descriptions for records liaisons?
6. Does the program or office records liaison routinely
communicate with all records liaisons?
7. Are all employees informed of the identity and role of the
records liaisons serving their office?
8. Does the program or office records liaison participate in
planning for new electronic information systems and in major
modifications to existing systems to ensure incorporation of
recordkeeping requirements and records disposition procedures?
Specifically:
a. Is the records liaison involved in the development of
micrographic applications?
b. Is the records liaison involved in the development of
electronic recordkeeping systems, including procurement of
computer equipment?
c. Is the records liaison involved in the development of
document imaging systems?
B. Guidance and Training
-------
Yes
Questions
1. Has the program or office records liaison received training in
Federal and EPA records management regulations, policies, and
procedures?
2. Do records liaisons, secretaries, file clerks, and others with
regular records duties receive training in records maintenance
and filing procedures and records disposition?
3. Is records management guidance received from NRMP, or
other oversight agencies such as NARA, tailored, when
appropriate, to reflect the program or office specific procedures
prior to dissemination to appropriate program or office staff?
4. Does the records liaison brief senior officials and program
administrators on the importance of records management and
records handling responsibilities?
C. Internal evaluations
Yes
No
Questions
1. Does the records liaison periodically evaluate records
management practices?
2. Do these evaluations include electronic records?
3. Are written evaluation reports prepared?
4. Are evaluated programs or offices required to respond to the
evaluation reports promptly?
5. Does the records liaison follow up to determine if offices
implement necessary corrective action or recommendations for
improvements?
-------
Records Creation and Recordkeeping Requirements
Ensuring adequacy of documentation in any information system depends on
the clear articulation of recordkeeping requirements. Recordkeeping
requirements:
• Specify the creation and maintenance of specific records to document agency
operations and activities.
• Facilitate action by agency officials and their successors.
• Permit continuity and consistency in administration.
• Make possible a proper scrutiny by Congress and other duly authorized
agencies.
• Protect the rights of the Government and those affected by its actions.
• Document important meetings and the formulation and implementation of basic
policy and decisions.
A. Creation of records and adequacy of documentation
Yes
No
Questions
1. Has the program or office provided guidance for all employees on
the definition of Federal records and nonrecord materials, including
those created using office automation, and guidance on the ways in
which the records must be managed?
2. Does each program or office have written guidance on what records,
including electronic records, are to be created and maintained and the
format of the official copy?
3. Has the program or office issued guidance and instructions for
documenting policies and decisions, especially those arrived at orally?
4. Has the program or office issued guidance on the record status of
working papers/files and drafts?
5. Has the program or office issued guidance on personal papers?
6. Do program or office procedures require creation of finding aids
such as captions and indexes to facilitate access to individual files or
record items, when appropriate?
B. Contractor records
-------
Yes
Questions
1. Do contracts identify which contractor-created records are Federal
records?
2. Does the program provide contractors with the regulations and
procedures governing Federal records?
3. Particularly when electronic records are involved, do contracts
specify the delivery of background data that may have further value to
the agency in addition to the final product?
4. Do contracts involving development of electronic systems specify
the delivery of systems documentation to the agency along with the
final product?
5. Particularly when electronic records are involved, do contracts
specify the delivery of final products and background data in a format
that is compatible with program records maintenance and retention
guidelines?
6. Are deferred ordering and delivery of data clauses included in
contracts when it is impractical to identify in advance all electronic
data that should be delivered to the Government?
Records Maintenance
Effective and proper management of records ensures that:
• Complete records are maintained.
• Records can be located when needed.
• Records, nonrecord materials, and personal papers are maintained separately.
• Identification and retention of permanent records are facilitated.
Proper records maintenance also contributes to economy of operations by
facilitating records disposition. This section covers general records
maintenance policies and practices, regardless of media, and several aspects
of records maintenance that apply specifically to paper-based records. The
next section specifies additional requirements for special records; i.e.,
records other than traditional paper text.
A. General
-------
Yes
No
Questions
1. Has the program or office established standards and procedures for
classifying, indexing, filing, and retrieving records and made them
available to all employees?
2. Is access to all records, regardless of media, limited to authorized
personnel?
3. Are cutoffs (file breaks) clearly defined and implemented for each
records series?
4. Are permanent series of records identified and maintained
separately from temporary records?
5. Has the program or office established and implemented regulations
or procedures for the storage of confidential business information
(CBI), Privacy Act, and other restricted records?
B. Paper-based Records
Yes
No
Questions
1. Has each office designated official file locations (file stations)?
2. Is a file plan for each series of records maintained at
station?
3. Does each office have procedures for filing, charging
refiling its records?
each file
out, and
4. Are file drawers and folders labeled correctly?
Maintenance of Special Records
Special records are those in formats other than traditional paper text files;
i.e., electronic, audiovisual, cartographic, and architectural records. The
physical properties of the materials used to create microfilm and special
records require additional standards for their maintenance.
-------
A. Electronic Records
1. General
The following questions apply to all electronic information systems that
contain federal records, regardless of media or application.
Yes
Questions
a. Are records in program or office electronic information
systems readily identifiable?
b. Do electronic recordkeeping systems that maintain the official
copy of text documents on electronic media provide indexing or
text search capabilities?
c. Do electronic recordkeeping systems require user
identification codes or passwords to control access and ensure
integrity of the documents?
d. Does the program or office regularly back up electronic
records to safeguard against loss of information due to
equipment malfunction or human error?
e. Does the program or office avoid the use of diskettes for the
exclusive long-term storage of permanent or unscheduled
records?
f. Do electronic recordkeeping systems provide a standard
interchange format, when necessary, to permit the exchange of
electronic documents between agency or program components
using different software/operating systems and the conversion
or migration of documents from one system to another?
g. Does the program or office maintain complete and up-to-date
technical documentation for each electronic information system
that contains Federal records?
h. Does the program or office safeguard and maintain all
software and hardware required to read electronic records
throughout their life?
i. Are procedural controls in place for all electronic
recordkeeping systems (magnetic and imaging) to protect the
integrity of the Federal records and their legal admissibility
under the rules of evidence?
-------
2. Magnetic media
In addition to applying the questions under subsection A-l, Electronic
Records - General, of this section, the following questions should be
discussed to ensure the proper maintenance of records on magnetic media.
Yes
Questions
a. Has the program or office implemented a standard procedure
for external labeling of the contents of diskettes, disks,
magnetic tape reels or cartridges?
b. Are tapes used for permanent and unscheduled records
tested within 6 months prior to use to verify that they are free
of permanent errors?
c. Are tapes used for permanent and unscheduled records
rewound under controlled tension every 3 years?
d. Is an annual statistical sample of tapes used for permanent
and unscheduled records read to identify any loss of data and to
discover and correct the causes of data loss?
e. Are tapes used for permanent and unscheduled records
copied before they are 10 years old onto tested and verified new
tapes?
f. Are magnetic media containing permanent or unscheduled
records stored under recommended temperature and humidity
conditions (between 62 and 68 degrees Fahrenheit and constant
relative humidity between 35 and 45 percent), and is the media
protected from potential exposure to magnetic fields?
3. Office automation applications
In addition to applying the questions of subsection A-l, Electronic Records -
General, of this section, special consideration should be given to electronic
records created using personal computers (electronic mail, word processing
documents, databases, and spreadsheets).
Yes
No
Questions
a. Have all employees using personal computers received
training and guidance in determining record status of documents
that they create with office automation applications?
10
-------
Yes
Questions
b. Has the program or office implemented procedures for
maintaining Federal records created using personal computers in
an official file (hard copy or electronic recordkeeping system)?
c. Are all staff who use computers trained in procedures to avoid
the unintentional loss of records, including techniques for
backing up files and for handling diskettes?
4. Optical Imaging Systems
In addition to applying the questions of subsection A-l, Electronic Records -
General, of this section, the following questions should be used in evaluating
compliance with recordkeeping requirements for optical imaging systems:
Yes
No
Questions
a. Do CD-ROM disks used to store permanent records meet
NARA transfer requirements?
b. Do optical imaging systems conform to NARA policy requiring
the disposition of original records when converting to an optical
digital data disk storage system?
B. Audiovisual Records
Yes
No
Questions
1. Are the original and use copies of audiovisual records
maintained separate from each other?
2. Are finding aids such as indexes, captions, lists of captions,
data sheets, shot lists, continuities, review sheets, and catalogs
(published or unpublished) maintained for all audiovisual
records?
3. Are cross-references to closely related textual records
maintained with audiovisual records?
4. Has the program or office instituted procedures to ensure
that information on permanent or unscheduled magnetic sound
or video media is not erased or overwritten?
5. Does the program or office retain original photographic
images created electronically (digital photography)?
11
-------
Yes
No
Questions
6. Does the program or office maintain originals of permanent
or unscheduled photographs scanned into computer programs?
7. Does the program or office store permanent audiovisual
records, particularly color films and photographs, in
environmentally controlled space (72 degrees Fahrenheit or less
and the relative humidity between 30 and 40 percent)?
C. Cartographic and Architectural Records
Yes
No
Questions
1. Are maps and drawings stored flat in shallow-drawer map
cases rather than folded or rolled?
2. Are permanent maps and drawings stored in acid-free
folders?
3. Are large, heavy atlases and other bound volumes of maps or
drawings stored flat, preferably on roller shelves to facilitate
moving them without damage?
4. Do adequate finding aids such as indexes exist for
cartographic and architectural records?
5. Are cross-references to closely related textual records
maintained with cartographic and architectural records?
D. Micrographic Records
Yes
No
Questions
1. Are records on microform arranged and indexed to permit
ready retrieval of individual documents?
2. Do microforms contain a title header or initial target page
that identifies the records?
3. Are boxes containing microforms individually labeled with the
records series title and date span of the records, and are they
sequentially numbered?
4. Are permanent and temporary records filmed separately?
5. Are silver and nonsilver microforms filed separately?
12
-------
Yes
No
Questions
6. Are silver master microforms of permanent and unscheduled
records inspected every 2 years while these records are in
storage?
Records Disposition
Records disposition is a critical element of records management. EPA's
records disposition program enables programs and offices to dispose of
records that are no longer needed in the office for current agency business.
Only those active records needed for current business should be maintained
in offices. EPA programs and offices should use records schedules to
determine when to destroy records or transfer them to more cost effective
storage in Federal records centers or storage areas. The records disposition
program contributes to economical and efficient agency operations. Clearly
written, up-to-date, and properly implemented comprehensive records
schedules form the basis for a sound records disposition program.
Federal agencies must schedule all Federal records they create or receive.
NARA issues General Records Schedules (GRS) for temporary records
common to most agencies. The General Records Schedules include records
relating to civilian personnel, fiscal accounting, procurement,
communications, printing, and other common functions and certain
nontextual records. These schedules provide disposition authority, so
agencies do not have to schedule those records individually, unless a
deviation from the GRS disposition standard is needed. However, the EPA
has incorporated the information from many of the GRS into the EPA
Records Schedules. The EPA may request authority to apply a disposition
standard different from the GRS by submitting an SF 115, Request for
Records Disposition Authority, along with a justification for the deviation.
Records schedules for Federal records must be approved by NARA before
implementation, and once approved, they are mandatory. EPA must also
request NARA approval for transferring records to any other Federal agency
or donating them to an individual or non-Federal institution. Permanent
electronic, audiovisual, cartographic, and architectural records should be
13
-------
scheduled for transfer to the National Archives as soon as possible because
of their fragility and special preservation needs.
A. Records Schedule Development
Yes
Questions
1. Are records schedules based on inventories of program records? Are
the inventories updated periodically to reflect new records series or
electronic information systems, changes in recordkeeping practices, or
changes in programs resulting from legislative or regulatory changes?
(EPA requires inventories to be conducted at least every three years.)
2. Do program records schedules contain a clear and complete
description of records series that reflects the content and arrangement
of the program's files? Do schedules contain a clear and concise
description of electronic recordkeeping systems that reflects the
purpose, content, sources of information, and outputs?
3. Do the disposition instructions include provisions for:
Cutoffs or file breaks,
Instructions for retiring appropriate hard copy records to Federal
records centers,
Transfer instructions for all records proposed for permanent retention
to the National Archives followed, and
Specific retention periods before final disposition of all records?
4. Are the disposition instructions for electronic records followed that
require the transfer to the National Archives of permanent electronic
records as soon as they become inactive?
5. Do program officials review proposed records schedules relating to
their office or function?
6. Are reviews periodically conducted to identify new records series
and information systems that should be scheduled and changes in
recordkeeping practices that require records schedule revision?
B. Records Schedule Implementation
14
-------
Yes
No
Questions
1. Do the records liaisons monitor implementation of the records
schedules?
2. Does the program or office provide copies of EPA records schedules
to all staff that handle Federal records?
3. Are records destroyed only in accordance with EPA records
schedules?
4. Do file custodians take prompt action to cut off files, destroy records
whose retention periods have expired, and retire eligible records to a
Federal records center (FRC) in accordance with EPA records schedule
provisions?
5. Are permanent records transferred to the National Archives as
provided in the EPA records schedules?
For further information, see NARA publications i ;
/ f~ ^™__™4.,»,_*,™__JL^^
and the > r . ..>-." The National Records
Management Program maintains the • • i >;,-. :'»> Copies can be
obtained from the NRMP and they can be found on the NRMP web page.
Essential Records
An essential records program is intended to assist programs in identifying
and protecting those records essential to continuing their operations under
other than normal business conditions and to protecting the rights of the
Government and those individuals directly affected by its actions.
Yes
No
Questions
1. Has the program assessed potential risks to their essential
records?
2. Is the program familiar with the Agency essential records
policy, authorizing the essential records program and specifying
the responsibilities of various program officials?
3. Has the program designated an essential records point person
to coordinate the program's essential records plan?
15
-------
Yes
No
Questions
4. Has the program identified its essential records, i.e., its
emergency operating records and legal rights records?
5. Does the program periodically review its essential records
plan and update it as necessary?
6. If special media records (such as electronic or microform
records) are designated as essential records, have provisions
been made for access to the equipment needed to use the
records in case of emergency?
For further information, see 36 CFR, Part 1223 - Management of Essential
Records; and the NARA publication, " f ,• ; =r
iii,,, .,..,11 ,," and the NRMP Tool Kit: • Jr; r'
16
------- |