**Index to Comments**

[Respondents who provided answers to the Questions we
provided:]{.underline}

Edwin McCeney, Dept. of Interior, p. 3

Margaret Peppe, Dept. of State, p. 5

Barbara Compton, Cleveland Foundation, pp. 19-20

[Respondents who recommended changes in the order of the
Framework:]{.underline}

Roberta Terkowitz & Mary Rawlings-Milton, IBM, p. 9

(move records center facility regulations to the end)

John Tessler, Dept. of Education, pp. 15-18

(complete re-organization)

Barbara Compton, Cleveland Foundation, pp. 21-22

(use ISO 15489 as the standard for the total records management program)

[Respondents who made comments about specific parts of the
regulations:]{.underline}

Edwin McCeney, Dept. of Interior, pp. 3-4

Margaret Peppe, Dept. of State, pp. 6-8

Sue Silva, Western Area Power Administration, p. 10

Dorothy Green, Dept. of Energy, pp. 10-11

Linda Genovese, Corps of Engineers, pp. 12-14

Barbara Compton, Cleveland Foundation, pp. 20-21

[Respondents who made more general comments:]{.underline}

Fred Graboske, USMC, p. 1

(electronic records)

Retta Graham-Hall, Dept. of Defense, pp. 1-2

(electronic records, training, payments, schedule assurances, file
plans)

Roberta Terkowitz & Mary Rawlings-Milton, IBM, pp. 8-9

(incorporate DoD 5015.2, BPR/ERA)

B. Sachau, citizen, pp. 14-15

(rights of the public)

William Benedon, Benedon & Associates, p. 15

(ISO 15489)

**Agencies/Companies**

From: Graboske GS12 Fred J \<GraboskeFJ@hqmc.usmc.mil\>

To: "'comments@nara.gov'" \<comments@nara.gov\>

Date: 3/23/04 10:47AM

Subject: Proposed regulatory framework for electronic records management

CC: Goodwin Ms Linda B \<GoodwinLB@hqmc.usmc.mil\>

NARA,

In general I approve of your proposal for change. I certainly agree that
the current federal records management regulations need revision. I
recommend that NARA completely re‑think its structure and functions for
dealing with electronic records. These kinds of records age so quickly
that NARA should try to accession them as soon as possible. Marine Corps
operational records are eligible for transfer to NARA after 30 years. 5"
floppies from Operation DESERT STORM can no longer be read, in part
because we have no machine with a port that size and in part because the
software program used to create them can no longer be read.

NARA's creation of partnerships with federal agencies is a good idea. As
an example, in response to an initiative by Deputy Secretary Chu,
components of the DOD are re‑examining and revising their operational
records management plans and policies. This would be an excellent
opportunity for NARA to work with DOD components on the preservation of
the records of Operations ENDURING FREEDOM and IRAQI FREEDOM. These
records document not only an important national experience (war against
terrorism and war in Iraq), but they also will provide the basis for
future claims by veterans. I suggest that NARA consider a pre‑accession
transfer of these electronic records, as described in your proposal. As
Archivist for the Marine Corps I cannot guarantee that you will be able
to read these records 30 years from now.

Respectfully,

Frederick J. Graboske

From: "Graham‑Hall, Retta H., OIG DoD" \<rgraham‑hall@dodig.osd.mil\>

To: "'comments@nara.gov'" \<comments@nara.gov\>

Date: 5/3/04 1:37PM

Subject: ANPR

To Whom it may Concern:

I have reviewed the proposal for changes to the NARA rulemaking and this
is what I think:

Changes are in order and long over due.

Record keeping environment to include:

Web based records ‑ we talk about it, but haven't seen any real guidance
or guidance I understand.

Electronic Document Records Management System/Applications

Include more guidance on electronic records of all types

Training: More training on issues above and certification for Records
Managers within the Federal Government.

Payment & Charges: The new rule making should discuss billing procedures
to customers

(federal agencies) from NARA and discrepancy

resolution in bill from (customer/federal agencies) back to NARA

Records Schedules: Make it a requirement that "**all**" agencies receive
the **concurrence** on any records schedules submissions from their
**Office of General Counsel**.

More on file plans: standardize government wide based on the GRS and an
Alpha‑numeric system vs. a straight numeric system. Instructions and
guidance on creating, deriving, comprising, devising and implementing a
good file plan for an agency.

This is all I can think of right now. If I think of more, I will send
you my additional thoughts.

Retta Graham‑Hall

OIG‑DoD

Records and Forms Manager

400 Army Navy Drive

Arlington, VA 22202

Phone: 703‑604‑9781

Fax: 703‑602‑0294

From: \<Edwin_McCeney@ios.doi.gov\>

To: "Howard Lowell" \<howard.lowell@nara.gov\>

Date: 5/7/04 7:42PM

Subject: Re: NWM 12.2004 Comments on the proposed reorganization of the
regulations for Federal records management

CC: \<sharon_michel@ios.doi.gov\>

Howard,

In general, DOI is in agreement with the intention of this proposed
reorganization. DOI would also submit that critical portions of the
solution have yet to be defined. Representation of records management in
the FEA business process and data model is critical to the success of
this work. From the meeting this week with NARA representatives, DOI is
excited about the potential partnership with NARA and other agencies to
develop a comprehensive and defined records management process, which
includes electronic records.

Below, please find DOI's specific comments and replies to posed
questions.

Please contact me if you have any questions or need further information.

Thank you.

Ed

Edwin J. McCeney

Departmental Records Manager

Department of the Interior

\(202\) 208‑3321

Questions for comment:

What do you think about this proposal? Strongly agree with it.

Do you agree that the current Federal records management regulations
need revision? Yes.

Which regulations do you think need updating, revision, or expansion?

Federal Records, General; Electronic Records; Cartographic Records;
Program Assistance

Are there other records management issues that NARA should address?

-   Capital Planning process. Records Officers sign off on Capital Plans
    (300's) from the GPEA viewpoint ? what about NARA working to require
    records management as an integral part of the 300? For example, if
    the 300 relates to an electronic system then that agency must show
    proof that the system and its records have been scheduled by NARA
    before the 300 will be approved by OMB.

If you think the NARA regulations need to be revised, are there any
priority areas that should be addressed first? Electronic Records, in
general and e‑mail, plus e‑mail records.

Will the proposed reorganization of 36 CFR Chapter XII, Subchapter B,
make the regulations easier to use? Yes

Will consolidating definitions in one section be useful? Yes

How do you see the proposed revision affecting the records management
programs of Federal agencies? The revision will make it easier for
employees to understand Federal records management and records officers
will be able to better implement the mandates.

What further changes would you like to see?

-   Like the definitions all being in one place. Will there be one rule
    in which NARA will talk about all of the NARA forms, i.e., SF‑115,
    SF‑135 and instructions on how to fill them out? Or does NARA intend
    to include appendixes to the appropriate rules that forms related
    to? For example, in scheduling records will a SF‑115 be shown and
    instructions included? In transferring permanent records to NARA
    will there be a SF‑258 and instructions?

-   Where would there be information on affiliated archives and agency
    procedures to apply?

```{=html}
<!-- -->
```
-   Continue to incorporate ISO standards, as appropriate.

COMMENTS:

In Part 1220:

Will information be added about managing records for the new workforce,
i.e., those employees who are authorized to work at sites away from the
office, i.e., home or a telecenter?

Will there be information added on maintenance and use of records while
under court restrictions due to pending litigations?

In section 1220.14 ‑ good inclusion of the ISO records management
elements.

Part 1222.46 ‑ What does 'Recordkeeping requirements of other agencies'
relate to?

Part 1223 ? Current laws speak to Contingency of Operations Planning and
Disaster Recovery, which basically goes hand‑in‑hand with vital records.
How can the Vital Records rule read to ensure that all of this
terminology is included so that agencies better see the correlation with
vital records?

Part 1225.12 and 1225.14 ‑ Are 'Developing" and "Formulating' agency
records schedules significantly different from each other?

Part 1233.22 ‑ Should be in question format.

Part 1235 ? Should there also be information on records subject to
homeland security?

Part 1236 ?

-   Will reference to PKI, E‑signatures, Instant Messaging, and web
    records be added?

-   Will this section discuss managing Federal records on handheld
    devices, i.e., PDA's, blackberries, electronic laboratory notebooks,
    laptops, etc?

-   Will information be added about migrating media through the
    life‑cycle of the record to ensure preservation?

-   Will this section discuss managing electronic records which have
    privacy information in them?

-   Will the electronic mail section discuss doing official work from
    other than government e‑mail systems?

-   Ensure that this section stresses coordination with agency
    information technology staff to better manage electronic records.

Part 1237 ? Will there be mention in this section about vinegar syndrome
and its affect on film and how to deal with it?

Part 1238 ? Will information on the new transfer guidance for digital
photographs be included in this rule?

Part 1231 ? From the title of this it seems to not address records of
agencies whose functions do not get transferred, i.e., the agency is
dissolved. Is that covered in this rule? If so, the title is confusing.

Part 1244 ‑ Not knowing what a 'studies program' is, perhaps an
introduction section would be justified.

From: "Peppe, Margaret G" \<PeppeMG@state.gov\>

To: "'comments@nara.gov'" \<comments@nara.gov\>

Date: 5/10/04 10:05AM

Subject: FW: NWM 12.2004 Comments on the proposed reorganization of the
regulations for Federal records management

CC: Records‑DL \<Records@state.gov\>

UNCLASSIFIED

Subject: Comments ‑ NWM 12.2004 Proposed Reorganization of the
Regulations for Federal Records Management

The U.S. Department of State appreciates the opportunity to comment on
your request NWM 12.2004, Proposed Reorganization of the Regulations for
Federal Records Management. The document was coordinated for review
among Department bureaus/offices including those of the Agency Records
Officer and the Chief, Information Officer.

Should you have any questions you may contact Mr. Cornelius Kelliher of
my staff at (202) 261‑8343 or via email at kellihercv@state.gov.

Margaret G. Peppe

Agency Records Officer

U.S. Department of State

Room 6073, SA‑2

Washington, DC 20037

\(202\) 261‑8327; FAX (202) 663‑2717

Inter/Intra‑net: peppemg@state.gov

"Our mission is to meet the information needs of our customers and the
US Government"

NARA Questions

In response to NARA's series of questions we agree that an update to all
parts of 36 CFR is needed as many parts rely on others to be effective,
so we welcome the NARA proposal to update and reorganize these
regulations in their entirety. It appears that most sections of the
regulations were last updated circa 1999 to 2001, so an update is due.
However, we recognize that with one remaining electronic records
transfer format on which to develop guidance, it makes sense to wait
until all of the guidance produced from the e‑Government initiatives are
completed and adopted. As NARA points out there have been numerous
issuances of new guidance and such guidance needs to be incorporated
into the regulations. When completed records managers, program managers,
and IT personnel, will have the convenience of one principal source from
which to obtain guidance on Federal records management, including
electronic records.

We feel there are elements of the regulations dealing with electronic
records management that urgently require attention, for example, web
records policy and guidance and records management requirements for
electronic information systems. Web guidance has been promised for quite
some time and is badly needed. DoD 5015.2 has proven useful but
consideration should be given to whether DoD 5015.2 becomes the
Government standard or NARA sets forth such requirements as part of the
reorganized regulations.

As NARA has pointed out, this reorganization should result in a updated
set of regulations that are comprehensive and easy to use and
understand.

General Comment

We assume that the updated and reorganized regulations will be published
both electronically and in hard copy. For the hard copy publication we
suggest NARA consider a letter size loose leaf binder format? This
format would provide the convenience of updating only the affected pages
or sections as soon as changes are available for release.

Comments on Outline ‑ Table of Contents

Proposed part 1220.14 Definitions

We think the idea to consolidate definitions from the various points of
36 CFR is a good one. It brings all definitions together in one place.

Does NARA envision introducing topics like content management and
knowledge management and how they play with traditional records
management terms?

Proposed 1222.20 Agency Responsibilities

The current 1222.20 (b) (7) does not include reference ensuring
compliance or approvals for certain OPM and GAO policies and/or
procedures related to official personnel and medical files and certain
accountable officer files. Existing section 1228.22 (f) does mention
obtaining GAO approval for certain records schedule items required under
title 8.

Proposed 1225.14 Formulation of Agency Records Schedules

The proposed outline for this section mirrors the current regulations.
Over the last year or so NARA has conducted analysis and introduced
different approaches to scheduling that NARA feels could offer agencies
some flexibility over current processes. Will the proposed updates to
the regulations authorize such approaches as flexible scheduling and
media neutral schedules?

Proposed 1225.16 Request for Records Disposition Authority

Suggest NARA look at and consider time requirements under 1228.26 (1)
and 1228.26 (2). These situations can require sizeable efforts to write
or rewrite schedules and coordinate internal approvals before submission
to NARA for appraisal and approval. Under such conditions and with
limited resources available in most agencies for the task, the time
frames seem unreasonable. We understand the need to establish some
requirement that these schedules be completed, but in lieu of
unrealistic time requirements, perhaps NARA could require from agencies
an indication that the effort is underway with an estimated completion
date and a simple periodic progress report.

Proposed 1225.18 Scheduling Permanent Records

Existing section 1228.28 (b) (8) (i) specifies that permanent paper
records are usually transferred to the National Archives "within 30
years". With the current E.O. 12958 requirement of systematic review of
classified national security information at 25 years, will the current
30 year requirement remain or will it be changed to 25 years?

Proposed 1225.20 Scheduling of Temporary Records

Existing section 1228.30 (d) discusses GAO approval of program records
(minimum retention 3 years) and certain records related to claims and
demands by or against the Government, etc. It would be useful if the GAO
address for obtaining approvals were added to the CFR reference
currently found in this section.

Proposed part 1227 General Records Schedules

The proposed sections do not include the former 1228.44, Current
Schedules, which would drop the list of current General Records
Schedules numbers and titles. If NARA does not intend to fold the GRS
list into one of the proposed sections we would like to see the section
containing the list of GRS be retained.

Proposed part 1233.22 Transfer to and Storage of Electronic Records in
NARA Records Centers

This is a new section. We suggest that requirements include packaging
information relative to the storage of various electronic media,
including CD‑ROM, or at the very least, include a reference to the NARA
Guide to Records Center Services, which should contain specific
packaging information.

Proposed 1235.20 Electronic Records

Will this section or proposed section 1235.16 Audiovisual Records
incorporate guidance on digital photography?

Proposed 1236 Electronic Records Management

The sections identified as containing information on design and
implementation make reference only to ISO 15489 as a source of guidance.
Does NARA plan to incorporate any of the provisions of DoD 5015.2 into
sections such as 1236.16?

We see no indication in the outline as to where or to what extent NARA
will incorporate policy/guidance related to web records.

We assume that standards related to imaging will include the
identification and use of suitable techniques to establish legibility
and quality control measures.

We also assume the guidance for transfer of e‑mail with attachments will
be incorporated as part of proposed section 1235.20 or 1236.24 or
1236.52 (d) although the outline does not specifically address it.

Part 1237 Audiovisual Records Management

Suggest there be discussion of digital photography in this part on
audiovisual records management. It should discuss the technology, how it
can be used, how to store digital photo's/disks, and quality standards
if applicable. If NARA chooses to discuss digital photography only under
section 1236, Electronic Records, then we would encourage some form of
cross‑referencing between the two parts.

Part 1240 Micrographic Records Management

Subpart E

This subpart indicates "Centralized Micrographic Services" operated by
NARA. Is such a service envisioned for document imaging and if so, where
would the criteria for such service be described?

Does the current centralized micrographic services include the
conversion of micrographic images to a digital format regardless of the
microform format? Where will availability and scope of such service be
described?

May 11, 2004

Regulations Comments Desk (NPOL)

Room 4100, Policy and Communications Staff

National Archives and Records Administration

8601 Adelphi Road

College Park, MD 20740-6001

Attn: 3095-AB16

IBM and its Electronic Records Archives subcontractors are pleased to
have the opportunity to offer our comments on the proposed regulatory
changes for Federal records management issued in the Federal Register,
Volume 69, No. 50, March 15, 2004. We wish to express our strong support
for the proposed changes to the regulatory framework for records
management.

It is the understanding of the IBM Team that the reorganization is based
(at least in part) on the NARA records management redesign that
incorporates the ISO standard into Federal records management. Is it
NARA's intention to included additions, changes or deletions to the
regulations that may result from the Business Process Reengineering
Project and the Electronic Records Archives Project? The IBM Team would
like to recommend that NARA consider these two initiatives and
incorporate the known requirements or allow room in the framework for
these requirements to be added. The outline published in the Federal
Register is unclear in this regard.

The IBM Team has two specific comments on the proposed reorganization:

-   NARA should incorporate into the regulation a specific endorsement
    of the DOD standard 5015.2 or its equivalent as the approved
    approach to electronic recordkeeping and electronic records
    management. We recognize that NARA has endorsed the standard through
    a Memorandum to Agency Records Officers. However, including this
    requirement in the regulations would strengthen the Records
    Officers' arguments as to why these requirements must be
    incorporated in electronic information systems containing records.

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```
-   Move the records center requirements (proposed Part 1234) from their
    current location to the end of the regulations. The current location
    in the text interrupts the record keeping requirements. A more
    logical flow is from transferring temporary records to off-site
    storage to transferring permanent records to NARA. Moving these
    off-site facility requirements would not make the requirements hard
    to find.

The IBM Team would like to thank you again for the opportunity to offer
our thoughts and comments

Sincerely,

**Comments received late**

From: \"Evelin, Sharon\" \<SHARON.EVELIN@hq.doe.gov\>

To: \"John Ellis (John Ellis)\" \<john.ellis@arch2.nara.gov\>

Date: 6/1/04 9:52AM

Subject: FW: Comments ‑ RM Numbered Memo 2004‑02: DOE\'s Response
toNARA\'s Request for Comments\...

John ‑ we are way past the due date for comments ‑‑ but I did receive
these and thought I should pass them along.

se

‑‑‑‑‑ Original Message‑‑‑‑‑

From: ssilva@wapa.gov

Sent: Monday, May 10, 2004 1:06 PM

To: Evelin, Sharon

Cc: Henderson, Toby; Bean, Debra; JOAN JESSEN; Cathy McCartney; Abel
Ramon

Subject: Comments ‑ RM Numbered Memo 2004‑02: DOE\'s Response to NARA\'s
Request for Comments\...

Thank you for the opportunity to comment. The Western Area Power
Administration (Western) is submitting the following comments:

Overall, we agree, and are happy to see the proposed changes to the
current Federal records management regulations, especially the
incorporation of guidance on electronic records management.

It is helpful to have the definitions identified in each Part where they
are applicable. If they are shown in Part 1220, perhaps there could be a
cross reference or Appendix to provide a quick reference as well.

1\. There does not appear to be a cross reference between proposed Part
36 and FOIA and how these regulations are interrelated.

2\. There does not appear to be a reference or proposal for guidance on
online forms management. Will this be incorporated into the proposed
Part 1236, Electronic Records Management?

3\. There does not appear to be a reference or proposal for guidance on
Disaster Recovery.

4\. There does not appear to be a reference to records which need to
have restricted access.

5\. Part 1232 \* Consider changing the Records box design to have a
separate lid. Too much time is exhausted opening and closing box flaps
when dealing with large volumes of records.

Please contact me if you have any questions or need additional
information.

Sue Silva

Western‑wide Records Manager

Western Area Power Administration

\(720\) 962‑7175

**From: **\"Evelin, Sharon\" \<SHARON.EVELIN@hq.doe.gov\>

**To: **\"John Ellis (John Ellis)\" \<john.ellis@arch2.nara.gov\>

**Date: **6/1/04 9:59AM

**Subject: **FW: RM 2004‑02 DOE\'s Response to NARA\'s Request for
Comments on Proposed Reorganization of the Regulations for Federal
RecordsManagement

John ‑ last one.

se

‑‑‑‑‑ Original Message‑‑‑‑‑

From: dorothy‑m.green@srs.gov \[mailto:dorothy‑m.green@srs.gov\]

Sent: Thursday, May 06, 2004 9:13 AM

To: Evelin, Sharon

Subject: RM 2004‑02 DOE\'s Response to NARA\'s Request for Comments on
Proposed Reorganization of the Regulations for Federal Records
Management

1220.14 ‑ Suggest adding definitions for electronic recordkeeping system
and for electronic information system.

General comment:

Subpart C ‑ NARA Evaluation Program, previously 1220.50 Authority 44 USC
Chapter 29 appears to be left out of the proposed outline. Is this
intentional or an oversight?

Will Agencies have an opportunity to comment on the revised outline
including verbage on new subject matter before issuance by NARA?

e‑mail dtd 4/30/04, Green to Evelin ‑ Would still like to get a copy of
the ISO 15489‑1 standard which web site indicates was attached to
RM2002‑14. It will be useful in review of future CFR 36, Chapter X11
revisions.

thank you,

**From: **\"Genovese, Linda C HQ02\"
\<Linda.C.Genovese@HQ02.USACE.ARMY.MIL\>

**To: **\"\'Cheryl.Stadel@nara.gov\'\" \<Cheryl.Stadel@nara.gov\>

**Date: **6/4/04 12:30PM

**Subject: **FW: Federal Register: NARA RIN 3095‑AB16 ‑ Comments
submitted by U.S. Army Corps of Engineers

Cheryl:

Resend.

Linda Genovese

761‑7115

\> ‑‑‑‑‑Original Message‑‑‑‑‑

\> From: Genovese, Linda C HQ02

\> Sent: Friday, May 14, 2004 4:16 PM

\> To: \'comments@nara.gov\'

\> Cc: Troyan, Frank D HQ02; Genovese, Linda C HQ02; Frank, Richard C
HQ02

\> Subject: Federal Register: NARA RIN 3095‑AB16 ‑ Comments submitted by

\> U.S. Army Corps of Engineers

\>

\> Federal Register/Vol. 69, No. 50/Monday, March 15, 2004/Proposed
Rules

\> Attn: RIN 3095‑AB16

\>

\> Federal Records Management: Proposed Regulatory Framework

\> National Archives and Records Administration

\>

\> Advance Notice of Proposed Rulemaking; Request for Comments due on or

\> before 14 May 2004:

\>

\> 36 CFR CHAPTER XII, SUBCHAPTER B, PARTS 1229, 1233, 1236, AND 1238.

\>

\> U.S. Army Corps of Engineers (Record Group 77), a major command
within the

\> Department of the Army, submits the following Comments and
Recommendations

\> in response to the above subject Federal Register notice:

\>

\> QUESTIONS FOR COMMENT: The current Federal records management
regulations

\> need updating and revision. The reorganization of subchapter B does
not

\> appear to reflect the records lifecycle, as proposed. A separate
section

\> of definitions would be useful. To facilitate the management of
records

\> relating to Record Group 77‑Office of the Chief of Engineers, the
U.S.

\> Army Corps of Engineers recommends the following priority areas be

\> addressed first:

\>

\> 1. PART 1229 ‑ EMERGENCY AUTHORIZATION TO DESTROY RECORDS

\>

\> Section 1229.12 ‑ Menaces to human life or health or to property.

\>

\> COMMENT: Records infested with mold, insects, and vermin are a

\> serious threat to human life, health, and property. The time it takes
to

\> process a request and wait for Archivist review and approval to
destroy

\> such records prolongs the exposure of menaces to humans and subjects
the

\> records to further infestation and damage.

\>

\> RECOMMENDATION: Expand menaces to include mold, insects, and

\> vermin, and allow agencies to immediately destroy records infested
with

\> these without prior authorization by the Archivist.

\>

\> 2. PART 1233 ‑ TRANSFER, USE, AND DISPOSITION OF RECORDS IN A NARA

\> RECORDS CENTER

\>

\> Section 1233.22 Transfer to and storage of electronic records in

\> NARA records Centers. \[New\]

\>

\> COMMENT/RECOMMENDATION: Electronic records transfer and storage

\> guidance is needed for all formats.

\>

\> 3. PART 1236 ‑ ELECTRONIC RECORDS MANAGEMENT

\>

\> ISO 15489 Records Management Standard.

\>

\> COMMENT: Access costs to the ISO 15489 documents are prohibitive.

\> In Oct 2002, ANSI offered the Corps of Engineers a three‑year
networking

\> site license for the ISO 15489‑1:2001 and the ISO TR 15489‑2:2001

\> documents entailing an annual license fee of \$1,200.00 per year. PDF

\> copies of the documents were to be provided to load on an internal
server

\> for access by a maximum of 100 with a maximum usage of five
simultaneous

\> users at any one time. Copies could not be given to any party.
Records

\> managers (i.e. authorized employees) could print hard copies as
needed,

\> but they could not be given to any other party. This would prohibit
their

\> dissemination to records coordinators, records holding area managers,
and

\> action officers. Because of these prohibitive costs and access

\> limitations, the Corps is unable to provide relevant ISO documents to
its

\> 50+ records managers to facilitate the integration of this new
standard

\> into its agency‑wide records management program to its fullest
extent.

\>

\> Will access to the ISO 15489 documents be requisite to interpret

\> and/or implement the referenced standards into an agency\'s records

\> management program?

\>

\> RECOMMENDATION: NARA should take into consideration, when

\> incorporating relevant portions of ISO standards, the prohibitive
cost and

\> access limitations by agencies to the ISO 15489 documents.

\>

\> Section 1236.32 ‑ Standards for scanned images. \[New\]

\>

\> COMMENT/RECOMMENDATION: With the high volume of digital scanning

\> projects for legacy paper documents (particularly permanent records)
that

\> is occurring, NARA guidance and technical standards in this area
would be

\> most beneficial.

\>

\> 4. PART 1238 ‑ CARTOGRAPHIC, ARCHITECTURAL, AND AERIAL FILM
MANAGEMENT

\> \[New\]

\>

\> COMMENT: This would be a welcome addition to Federal recordkeeping

\> requirements as the Corps of Engineers (RG 77) generates large
volumes of

\> cartographic, architectural, and aerial film and has thousands more
in

\> records storage.

\>

\> Army aerial film has been unscheduled for the past decade, because

\> managing this format is so problematic. Definitive and reasonable
NARA

\> guidance for aerial film is lacking. NARA records center staff are
not

\> knowledgeable about aerial negative preservation and transfer. NARA

\> records centers do not have suitable facilities to store aerial
negatives.

\> Current NARA practice requires agencies to bear the exorbitant cost
of

\> storing and shipping all permanent aerial negatives (canisters) to
the

\> NARA facility in College Park, MD. This is an unreasonable
expectation.

\>

\> RECOMMENDATION: Definitive aerial film requirements are needed and

\> would be best presented as a separate Subpart C: Aerial Film
Management.

\> NARA staff should have a more definitive knowledge of the management
of

\> this challenging format. NARA records center facilities should
support

\> aerial photographic negative storage. Reasonable preservation and

\> transfer requirements should be drafted to address the backlog of

\> thousands of cans of historic aerial photographic negatives currently
in

\> storage.

\>

\> V/R,

\>

\> Linda C. Genovese

\> USACE Records Program Manager (Federal Records Officer)

\> Corporate Information, CECI‑CA

\> U.S. Army Corps of Engineers (Headquarters)

\> 441 G Street, NW

\> Washington, D.C. 20314‑1000

\> Phone: 202‑761‑7115

\> E‑mail: linda.c.genovese@usace.army.mil

\>

**Public Citizens**

From: jean public \<jeanpublic@yahoo.com\>

To: \<comments@nara.gov\>

Date: 3/20/04 10:26AM

Subject: RIN 3095‑AB16 ‑ National Archives public comment

CC: \<rodney.frelinghuysen@mail.house.gov\>

page 2 comment ‑ where is the goal to make it easier for the "public" or
"taxpayers" to follow regulations. I do not think focussing on federal
agencies and records management contractors and leaving out the public
is fair or equitable.

As a member of the public seeking federal records, I can tell you that I
have been completely ignored in seeking those records and that is
completely wrong.

The paramount interest of the general public in having access to what
happens in government is completely forgotten in this proposal.
Absolutely completely forgotten. And the public comes first.

b\. sachau

15 elm st

florham park nj 07932

From: \<WBenedon@aol.com\>

To: \<cheryl.stadel@NARA.Gov\>

Date: 5/5/04 4:25PM

Subject: NARA Regulations on Federal Records Management

Dear Ms.Stadel‑Bevans: I have reviewed the proposed changes as covered
in the March 15,2004, Federal Register at page 12100. I agree that the
proposed changes make the regulations easier to read, understand, and
use. The materials are better organized (consolidated definitions,
emphasis on lifecycle concept). The guidance on electronic records is of
particular value as more and more records are being generated in that
media. I am particularly pleased with the incorporation of refences to
ISO15489‑1:2001. This very significant standard has not received the
attention and application it should. I hope the private sector of
business will respond in the same manner. NARA has been a major force in
the application of sound business practices for records management in
the private sector as well. The proposed changes will, therefore, have
wide benefits. To respond in plain language principles ‑‑ it is great!

William Benedon, CRM, FAI

Benedon & Associates

From: "Tressler, John" \<John.Tressler@ed.gov\>

To: "Nancy Allard (E‑mail)" \<nancy.allard@nara.gov\>

Date: 5/10/04 1:20PM

Subject: Suggestions in Response to the Federal Register Notice on
Policy Updates

Hi Nancy,

Sorry I was not able to speak with you on Friday, since I was out of
town.

I have taken the Federal Register Notice outline for the new RM policies
and guidance, and put together a restructured outline of how I believe
it would work best from a customer's viewpoint. It just represents my
own quick analysis of what I read in the Notice, and is not an official
ED response at this point. I am sharing it as a member of the ERPWG. I
also am attaching an outline of the current structure, as it appears in
the Federal Register.

Hope it is helpful. Will give you a call shortly.

Thanks.

John

Attached files: \<NARA.Guidance.Update.Structure.suggested.doc\>
\<NARA.Guidance.Update.Structure.current.doc\>

1^st^ Draft -- 5/5/04

Suggested Outline of NARA Proposed Guidance as Published in the Federal
Register 3/15/04

# SECTION I -- FEDERAL RECORDS MANAGEMENT (RM) PROGRAMS

PART 1220\--FEDERAL RECORDS, GENERAL

Subpart A\--General Provisions

Subpart B\--Key Definitions

\[Appendix A: Glossary of Terms \]

Subpart C\--Overview of Federal RM Responsibilities

\-- National Archives and Records Administration's (NARA) Program
Management Role

\-- Other Central-servicing Agency Roles (e.g., GSA, OMB, NIST, "other"
TBD)

\-- Agency Records Management Programs

# SECTION II -- NARA'S RM PROGRAM RESPONSIBILITIES

PART 0000\--RM AWARENESS AND TRAINING

PART 1242\--OTHER NARA PROGRAM ASSISTANCE

PART 1246\--NARA RECORDS MANAGEMENT REPORTING

PART 1229\--EMERGENCY AUTHORIZATION TO DESTROY RECORDS

PART 1230\--DAMAGE TO, ALIENATION, AND UNAUTHORIZED DESTRUCTION OF
RECORDS

PART 1244\--RM PROGRAM EVALUATIONS (formerly Inspections and Studies)

(including reviews of Agency Vital Records Programs and Risk Management)

# SECTION III - OTHER CENTRAL-SERVICING AGENCY RM PROGRAM RESPONSIBILITIES

PART 0000\--GENERAL PROVISIONS

PART 0000\--OFFICE OF MANAGEMENT AND BUDGET (OMB)

PART 0000\--GENERAL SERVICES ADMINISTRATION (GSA)

PART 0000\--NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY (NIST)

PART 0000---OTHER CENTRAL-SERVICING AGENCY ROLES (NOTE: if any)

# SECTION IV -- AGENCY RM PROGRAMMATIC AND OPERATIONAL RESPONSIBILITIES

PART 1223\--MANAGING VITAL RECORDS

Subpart A\--General (include relationship to Contingency Planning)

PART 0000\--INVENTORYING AND SCHEDULING OF OFFICIAL RECORDS

Subpart A\--Conducting Records Inventories

Subpart B\--Scheduling of Records

\--General Records Schedule

\--Agency-Specific Records Schedules

Subpart C\--Implementing Records Schedules

PART 1222\--CREATING, MAINTAINING, AND USING OFFICIAL RECORDS

Subpart A\--General

Subpart B\--Program Requirements

Subpart C\--Agency Recordkeeping Requirements

PART 0000\--TRANSMITTING OFFICIAL RECORDS

Subpart A\--General

Subpart B\--Program Requirements

Subpart C\--Data Integrity, Authentication, and Certification Issues

Subpart D\--Risk Management and Mitigation Issues

PART 1234\--STORING OFFICIAL RECORDS IN APPROVED STORAGE FACILITIES

Subpart A\--General

Subpart B\--Facility Standards

Subpart C\--Handling Deviations from NARA's Facility Standards

Subpart D\--Facility Approval and Inspection Requirements

\[Appendix B: Minimum Security Standards for Level III Federal
Facilities \]

\[Appendix C: Alternative Certified Fire-safety Detection and
Suppression Systems \]

PART 1232\--TRANSFERRING OFFICIAL RECORDS

Subpart A\--Transfer, Use and Disposition of Records in a NARA Records
Center

Subpart B\--Transfer of Records from the Custody of One Executive Agency
to Another

Subpart C\--Transfer of Records to Non-NARA Records Storage Facilities

Subpart D\--Transfer of Permanent and Records to the National Archives
of the United States

Subpart E\--Temporary Loans of Permanent and Unscheduled Records

PART 0000---DISPOSING OF OFFICIAL RECORDS

Subpart A\--General

Subpart B\--Program Requirements

Subpart C\--Agency Recordkeeping Requirements

# SECTION V -- TYPES OF OFFICIAL RECORDS AND THEIR COMMON AND UNIQUE REQUIREMENTS

PART 0000\--OVERVIEW

Subpart A\--General

Subpart B\--Program Requirements

Subpart C\--Standards

Subpart D\--Storage, Use, and Disposition of Records

Subpart E\--Emerging Technology Issues

PART 0000\--PAPER RECORDS

Subpart A\--General

Subpart B\--Program Requirements

Subpart C\--Paper Standards

Subpart D\--Creation, Storage, Use, and Disposition of Paper Records

PART 1236\--ELECTRONIC RECORDS

Subpart A\--General

Subpart B\--Types of Electronic Records

\-- IT Systems

\-- COTS Products

\-- Specialized / Customized Application Systems

\-- Electronic Mail Systems

\-- Government Information on the Internet

\-- Other Systems with Specialized Records Management Requirements

Subpart C\--Program Requirements

Subpart D\--Management of Electronic Records

\-- Creation, Storage, Transmission, Use, and Disposition of Electronic
Records

Subpart E\--Standards for Design and Implementation of an Electronic
Records System

PART 0000\--OTHER TYPES OF OFFICIAL RECORDS

Subpart A\--Audiovisual Records

\-- General

\-- Program Requirements

\-- Audiovisual Standards

\-- Audiovisual Records Management

\-- Records Management Requirements

\-- Creation, Storage, Use, and Disposition of Audiovisual Records

Subpart B\--Cartographic, Architectural, and Aerial Film Records

\-- General

\-- Program Requirements

\-- Standards

\-- Cartographic Records

\-- Architectural Records

\-- Aerial Film Records

\-- Records Management Requirements

\-- Creation, Storage, Use, and Disposition of these Records

Subpart C\--Micrographic Records

\-- General

\-- Program Requirements

\-- Microfilming Standards

\-- Records Management Requirements

\-- Creation, Storage, Use, and Disposition of Microfilm Records

# SECTION VI -- APPENDICES

Appendix A\--Glossary of Terms

\-- Records Management Terms

\-- Information Technology Terms

(NOTE: Include information life-cycle management, Federal Enterprise
Architecture, and IT capital planning terms in both of these)

Appendix B\--Minimum Security Standards for Level III Federal Facilities

Appendix C\--Alternative Certified Fire-safety Detection and Suppression
Systems

From: "Barbara Compton" \<bcompton@clevefdn.org\>

To: \<comments@nara.gov\>

Date: 5/13/04 1:16PM

Subject: \[Docket No: 3095‑AB16\];\[FR Doc: 04‑05625\];\[Page
12100‑12103\]; Records management: Federal proposed regulatory framework

My comments on the proposed regulation are below. I worked as a records
manager for many years for a contractor to a federal agency and remain
interested both as a private citizen and as a professional in the field.
I have also worked with the ISO Standard for the past year and have
presented several seminars to introduce it to many audiences. Thank you
for the opportunity to review and comment on this extremely important
issue.

**QUESTIONS FOR COMMENT:**

**What do you think about this proposal?**

I think the time has finally come to rethink the regulations for
government record keeping. I have been encouraged with the progress that
NARA has made over the last 10 years as they have researched and defined
issues. The time has come to bring all of those experiences together,
use the work of other respected professionals and publish comprehensive
standardized regulations that can be used by NARA agencies and
contractors to those agencies.

**Do you agree that the current Federal records management regulations
need revision?**

Yes because the life cycle of records in all media is not adequately
addressed as a process. The current regulations are too choppy and leave
too much to the imagination and guesswork of agency employees and
contractors. The regulations are difficult for records managers to
interpret which leaves no hope for general employees to sort out the
requirements. There are also significant gaps in the current
regulations.

**Which regulations do you think need updating, revision, or
expansion?**

Every regulation that includes a reference to records management needs
to be addressed. I believe that expanding and improving 36CFR is
necessary and then other CFR's with record requirements should refer the
reader to 36CFR.

**Are there other records management issues that NARA should address?**

It is critical that 36CFR be considered THE regulation for the complete
records management program across the agencies. I believe the perception
is that this CFR only addresses those activities performed by dedicated
record staff, not for the body of agency employees.

NARA should automatically be on the review list for all CFR's that are
written or revised if they in any way refer to records.

Staffing competencies and line item budget requirements should also be
addressed.

**If you think the NARA regulations need to be revised, are there any
priority areas that should be addressed first?**

I would not try to prioritize because it tends to break up the overall
mission. I believe that part of the problem with the current regulations
is that NARA took too narrow a focus on a specific issue(s) and tried to
regulate it without considering the entire scope of records management.
The whole of records management needs to be addressed (not for instance
just electronic records). I realize that this is a pressing issue not
only with the government but word‑wide. However, if you do not have a
foundation for a solid records management program, of which electronic
records are just a piece, you will still fail. It is true that
electronic records are volatile and the number is quickly growing, but
I'm absolutely confident that Federal agencies still create the majority
of their records in other media. And that has to be confronted.

**Will the proposed reorganization of 36CFR chapter XII subchapter B,
make the regulations easier to use?**

This question is difficult to answer without more information.

**Will consolidating definitions in one section be useful?**

Yes, it's always easier to use if like sections are consolidated. It's a
good starting place. I would suggest that you consider definitions from
ISO15489.

**How do you see the proposed revision affecting the records management
programs of Federal agencies?**

The proposed revision should:

Incorporate the management of all federal records in a standardized
process. This process should:

Address the life cycle of records

Address the media differences in life cycle management

Address this requirement as it applies to all federal employees and
contractors

Benefits:

Real cost reduction

Improved documentation of agency activities

Faster decision making and more effective leadership from NARA

**Please specify what further changes you would like to see?**

Reconsider using ISO 15489 as the standard for the total records
management program. A great deal of work has already been completed for
you by known and respected record management professionals. You have
proposed using only a very small piece of the standard in Part1236. Once
again, I see this as a piecemeal effort and an attempt to beef up
electronic record requirements just because they are getting most of the
press attention. Record system characteristics, as written in ISO15489
apply to all systems of records, not just electronic. If you are going
to include this part of the standard why not also use the part that
defines records characteristics. How can you possibly put together a
requirement on record system characteristics if everyone has their own
idea of records characteristics. Trying to pick a small part of the
standard without using the other parts is once again going to give you a
very choppy look at records management programs.

My biggest problem with the suggested changes is that I think you are
placing most of your emphasis on the management of electronic records.
Again, it's a great concern and agencies need direction, but that media
type is a very small part of a comprehensive records management program.

Part 122 Subpart A and B are about policy and responsibility. Section 6
of the ISO Standard certainly applies here and the language is very
useful.

Part 1222 Subpart C addresses the broad spectrum of requirements.
Sections 7, 8 and 9 of the ISO Standard addresses each of your concerns
and provides firm direction to employees.

Part 1224, 1225, 1226, and 1227 ‑ disposition issues are fully covered
in section 8 and 9 of the standard.

I would urge you to reconsider using the standard either in its'
entirety or at the very least as a reference. Picking one very small
part out of the middle of the standard does not give the whole picture.

Barbara Compton CRM

The Cleveland Foundation

bcompton@clevefdn.org

216‑615‑7191