NATIONAL 

ARCHIVES AND 

RECORDS 

ADMINISTRATION

Actions Needed to 

Ensure Facilities That 

Store Federal Records 

Meet Standards

Report to Congressional Requesters

September 2013

GAO-13-668

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-668, a report to 

congressional requesters

NATIONAL ARCHIVES AND RECORDS 

ADMINISTRATION 

Actions Needed to Ensure Facilities That Store 

Federal Records Meet Standards

Why GAO Did This Study

NARA manages the Federal Records 

Centers Program, which is to ensure 

the storage and preservation of federal 

records, including paper, photographic, 

audio, video, and film. Records storage 

facilities are required to meet certain 

minimum structural, environmental, 

property, and life safety standards set 

forth in federal regulations. 

GAO was requested to conduct a study 

of key aspects of the program. GAO’s 

objectives were to (1) determine the 

types of facilities agencies use to store 

federal records and the extent to which 

NARA’s data on agencies’ use of 

storage facilities are complete, (2) 

evaluate the extent to which NARA has 

determined these facilities to be 

compliant with standards in 36 C.F.R. 

Part 1234, (3) determine what actions 

NARA has taken to minimize damage 

to records in federal records centers

and the extent to which it documents 

such efforts, and (4) determine how 

NARA determines storage fees and 

whether fees differ among facilities. To 

do so, GAO obtained, analyzed, and 

corroborated documentation on 

records storage facilities, identified and 

compared records storage fees, and 

interviewed NARA officials. 

What GAO Recommends

GAO recommends that NARA 

(1) obtain complete data on where 

agencies are storing records, 

(2) develop a schedule to bring 

noncompliant storage areas into 

compliance with 36 C.F.R. Part 1234, 

and (3) establish a requirement to 

document the results of efforts to 

minimize damage to federal records. 

NARA concurred with the 

recommendations.

What GAO Found

Agencies are to store federal records in three types of facilities: 

• Federal records centers: The National Archives and Records 

Administration (NARA) operates 18 federal records centers that are 

comprised of 24 facilities (buildings) located across the United States. Each 

facility includes storage areas, referred to as bays. 

• Agency records centers: Agencies also establish and operate records 

centers for storing their own records. As of May 2013, NARA had identified 

18 agency records centers that were operated by 6 agencies or offices. 

• Commercial records storage facilities: Agencies also use private sector 

commercial facilities. As of May 2013, agencies reported that 12 vendors 

provided 22 facilities, which were used by 11 agencies.

These facilities notwithstanding, NARA does not know where all agencies are 

storing records. NARA has solicited data from agencies about their use of 

agency records centers and commercial records storage facilities, but not all 

agencies have submitted data. Further, the data agencies submitted—mostly 

from 2008 and 2009—are now outdated. As a result, NARA cannot be assured 

that all agencies are using one of the three types of authorized facilities. 

NARA determined that 20 of its 24 federal records center facilities were fully 

compliant with 36 C.F.R. Part 1234 because all of their bays satisfied the 

regulation; of the remaining 4, 2 facilities with inadequate shelving were partially 

compliant, 1 facility with insufficient protections against pipe leaks was not 

compliant, and the remaining facility was to be replaced. As of July 2013, NARA

had plans to bring these 4 facilities into full compliance, but did not have a 

schedule for completing the plans at 2 of the facilities. As a result, NARA does 

not have a basis for determining progress toward correcting deficiencies in those 

facilities that do not yet fully meet the standards. Also, while NARA had approved 

10 agency records centers and 22 commercial records storage facilities, it has 

inspected 1 of 18 agency records centers and 13 commercial records storage 

facilities. Until NARA completes planned inspections of all remaining facilities, it 

cannot be reasonably assured that agencies are storing records in facilities that 

meet standards. 

To facilitate the protection of federal records from permanent damage, NARA

had generally taken steps consistent with a checklist it requires federal records 

centers to follow when incidents (e.g., roof or sprinkler leaks) occur. However, it 

did not always document the results of its efforts to minimize damage because 

the checklist does not include a step for doing so. Specifically, of the 55 incidents 

that occurred from January 2009 through March 2013, NARA provided 

documentation about the final outcome for 46 incidents. For the remaining 9 

incidents, it could not provide documentation that included the final results of its 

efforts. Without a process that includes documenting the results of its efforts, 

NARA is not positioned to fully report on the effectiveness of its actions to 

minimize damage to federal records and to provide a third party with information 

to validate the results of its efforts. 

Storage fees are determined by NARA’s Federal Records Centers Program and 

the Office of the Chief Financial Officer using the existing fee schedule, expense 

projections, and workload projections. The storage fees charged by NARA in 

fiscal year 2013 were comparable to fees charged by commercial vendors in that 

same time frame. For example, NARA’s fee of $0.23 per cubic foot was higher 

than fees charged by two vendors and lower than fees charged by two other 

vendors. 

View GAO-13-668. For more information, 

contact Valerie Melvin at (202) 512-6304 or 

melvinv@gao.gov.
Page i GAO-13-668 Federal Records Centers Program

Letter 1 

Background 2

Federal Records Are to Be Stored in Three Types of Facilities; 

NARA Does Not Have Reliable Data about All Agencies’ Use of 

Records Storage Facilities 7

NARA Has Approved Almost All of Its Federal Records Centers as 

Compliant with Applicable Standards, but It Has Not Inspected 

and Validated the Majority of Agency and Commercial Records 

Facilities 12

NARA Has Taken Steps to Minimize Permanent Damage to 

Records in Federal Records Centers, but Does Not Always Track 

the Results of Its Efforts 16

Federal Record Centers Storage Fees Are Developed Annually and 

Are Comparable to Commercial Vendors’ Fees 19

Conclusions 20

Recommendations for Executive Action 21

Agency Comments 22

Appendix I Objectives, Scope, and Methodology 23

Appendix II Comments from NARA 26

Appendix III GAO Contact and Staff Acknowledgments 27

Tables

Table 1: Major NARA Offices, Missions, and Staffing 3

Table 2: NARA-Operated Federal Records Centers, Related 

Facilities, and Number of Bays, as of May 2013 7

Table 3: Federal Agencies that Operate Records Storage Facilities, 

as of May 2013 9

Table 4: Federal Entities Use of Commercial Records Storage 

Facilities, as of May 2013 10

Table 5: Status of Compliance of Each Federal Records Center 

Facility, as of January 2013 13

Table 6: Comparison of Federal Records Centers and Commercial 

Vendors’ Storage Fees from the GSA Schedule 20

Contents 
Page ii GAO-13-668 Federal Records Centers Program

Figure

Figure 1: Simplified Depiction of NARA Organization Showing 

Placement of the Federal Records Centers Program 4

Abbreviations

CFR Code of Federal Regulations

FTE full-time equivalent

GSA General Services Administration 

NARA National Archives and Records Administration

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-668 Federal Records Centers Program

441 G St. N.W.

Washington, DC 20548

September 10, 2013

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security 

 and Governmental Affairs

United States Senate

The Honorable Robert P. Casey, Jr.

United States Senate

The National Archives and Records Administration (NARA) manages the 

Federal Records Centers Program, which is to ensure the storage and 

preservation of federal records, including paper, electronic, photographic, 

audio, video, and film. Records storage facilities are required to comply 

with regulations (i.e., 36 C.F.R. Part 1234) that specify certain minimum 

structural, environmental, property, and life safety standards that facilities 

must meet in order to minimize damage to the records. NARA operates 

records storage facilities on a reimbursable fee-for-service basis by 

charging fees to federal agencies for storing records in the facilities.

At your request, we conducted a study of key aspects of the Federal 

Records Centers Program. Our specific objectives were to (1) determine 

the types of facilities agencies use to store federal records and the extent 

to which NARA’s data on agencies’ use of storage facilities are complete, 

(2) evaluate the extent to which NARA has determined these facilities to 

be compliant with standards in 36 C.F.R. Part 1234, (3) determine what 

actions NARA has taken to minimize damage to records in federal 

records centers and the extent to which it documents such efforts, and (4) 

determine how NARA determines storage fees and whether fees differ 

among facilities.

To accomplish the objectives, we obtained and reviewed documentation 

identifying facilities that federal agencies use to store records. We then 

corroborated the lists of facilities through analysis of other documentation, 

such as compliance memoranda and inspection schedules, and through 

interviews with NARA officials. In addition, we obtained and reviewed 

documentation, such as NARA’s central registry of approved facilities that 

discussed the characteristics of each identified records storage facility. 

We analyzed information describing NARA’s assessment of each facility 

 
 

Page 2 GAO-13-668 Federal Records Centers Program

in comparison to applicable standards in 36 C.F.R. Part 1234. These 

information sources included compliance checklist documentation and 

official NARA documentation supporting approval of the facility. We also 

interviewed NARA officials regarding certification documentation. Further, 

we interviewed NARA officials to identify what actions NARA has taken to 

minimize damage to records in federal records centers and corroborated 

the officials’ statements with available documentation pertaining to 

records storage and management. We also interviewed officials from 

companies that operate commercial records storage facilities that NARA 

has approved for use by federal agencies to gain their perspectives on 

storing records for federal agencies. Finally, we obtained and analyzed 

documentation from the NARA Federal Records Centers Program and 

General Services Administration (GSA) schedules1

We conducted this performance audit from November 2012 to September 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. Appendix I provides 

further details on our objectives, scope, and methodology.

that identified and 

discussed records storage fees. We then compared fees among the 

records storage facilities.

NARA’s mission is to safeguard and preserve the records of the U.S. 

government, ensuring that the people can discover, use, and learn from 

this documentary heritage. In this way, NARA is to ensure continuing 

access to the essential documentation of the rights of American citizens 

and the actions of their government.

In carrying out this mission, NARA (among other things) is to provide 

guidance and assistance to federal officials on the management of 

records; determine the retention and disposition of records; store agency 

records in federal records centers from which agencies can retrieve them; 

receive, preserve, and make available permanently valuable federal and 

 

1

Under the GSA schedules program, GSA establishes long-term, governmentwide 

contracts for commercially available goods and services, under which federal agencies 

can issue orders.

Background 
 

Page 3 GAO-13-668 Federal Records Centers Program

presidential records in archives; and centrally file and publish federal laws 

and administrative regulations, the President’s official orders, and the 

structure, functions, and activities of federal agencies through the daily 

Federal Register. Table 1 summarizes NARA’s organizations, their 

missions, and the levels of staff in each (expressed as full-time 

equivalent—FTE).

Table 1: Major NARA Offices, Missions, and Staffing

Organization Mission FTEa

Office of the Archivist, 

staff offices, and 

independent offices

Plans, develops, administers, and oversees NARA programs and functions. 220

Office of Chief Operating 

Officer

Provides operational leadership across six program offices: (1) Office of the Federal Register, 

(2) Agency Services, (3) Research Services, (4) Legislative Archives, Presidential Libraries, and 

Museum Services, (5) Information Services, and (6) Business Support Services to ensure 

agencywide support and accountability to NARA’s internal customers.

15

Agency Services Leads NARA’s efforts to service the records management needs of federal agencies and provides 

coordination between records management and the Federal Records Centers Program.

1,359

Office of the Federal 

Register

Informs citizens of their rights and obligations by providing ready access to the official text of 

federal laws, presidential documents, administrative regulations and notices, and descriptions of 

federal organizations, programs, and activities.

56

Research Services Provides services to customers who access NARA’s accessioned federal records and manages 

archival and preservation-related functions.

592

Legislative Archives, 

Presidential Libraries, 

and Museum Services

Leads NARA’s national education and exhibit programs and administers the Center for Legislative 

Archives and the Presidential Libraries system.

497

Information Services Leads NARA’s information technology projects and programs and develops information systems 

and tools to help customers locate NARA’s record holdings.

104

Business Support 

Services 

Provides customer service to NARA units and is led by an executive reporting to the Chief 

Operating Officer.

180

Total 3,023

Source: GAO analysis of information provided by NARA.

a

NARA staffing levels as of April 2013.

NARA’s Agency Services group includes the Federal Records Centers 

Program, with approximately 1,100 FTE. The placement of this program 

within the larger NARA organization is depicted in figure 1.2

 

2

Organizationally, NARA’s responsibilities under 36 C.F.R. Part 1234 are handled by two 

different offices, Agency Services (where management of both the Federal Records 

Centers and Records Management programs reside) and Business Support Services 

(where the responsibility for inspection and facility approvals are managed). 
 

Page 4 GAO-13-668 Federal Records Centers Program

Figure 1: Simplified Depiction of NARA Organization Showing Placement of the Federal Records Centers Program

In carrying out its responsibilities to store and archive federal records 

under the Federal Records Act and its implementing regulations, the 

Federal Records Centers Program provides storage facilities for federal 

agencies. Specifically, chapters 21, 29, and 31 of title 44 of the United 

States Code,3

 

3

44 U.S.C. §§ 2104(a), 2904, 2907, 3102 and 3103. 

and Parts 1232 and 1234 of title 36 of the Code of Federal 

Regulations authorize NARA to establish, maintain, and operate records 

centers for federal agencies. Further, 36 C.F.R. Part 1234 Subparts B, C, 

and D describe facility standards related to quality, effectiveness, 

durability, and safety; the handling of deviations from NARA’s facility 

standards; and facility approval and inspection requirements. These 

standards are applicable to all records storage facilities that federal 

agencies use to store, service, and dispose of records. To carry out these 

responsibilities, NARA developed an internal policy directive that outlines 
 

Page 5 GAO-13-668 Federal Records Centers Program

the procedures its officials should use to ensure the compliance of 

records storage facilities.4

36 C.F.R. Part 1234 also includes provisions allowing NARA to grant 

waivers from meeting the standards set forth in the regulations for records 

storage facilities. In these instances, waivers are allowed when the 

storage systems, methods, or devices are demonstrated to have facility 

standards that are equivalent or superior to 36 C.F.R. Part 1234

standards for quality, strength, fire resistance, effectiveness, durability, 

and safety, among other things. Underground facilities may obtain 

waivers from regulatory requirements that pertain to the roofs of 

aboveground facilities. Agencies can request a waiver by providing:

• a statement identifying the 36 C.F.R. Part 1234 provision for which the 

waiver is requested, in addition to a description of the proposed 

alternative, and an explanation of how it is equivalent or superior to 

the NARA requirement; and

• supporting documentation demonstrating that the alternative does not 

provide less protection for federal records than what is required by the 

36 C.F.R. Part 1234 standard, which may include certifications from a 

licensed fire protection engineer or a structural or civil engineer, as 

appropriate; reports of independent testing; reports of computer 

modeling; and/or other relevant information.

According to 36 C.F.R. Part 1234, NARA is to review the waiver request 

and supporting documentation, and in some circumstances, consult with 

the appropriate industry body or qualified experts, such as a firesuppression specialist, before making a determination. If NARA is in 

agreement with the proposed waiver and the supporting documentation, it 

is to grant the waiver and notify the requesting agency. However, if NARA 

evaluates the waiver request and the supporting documentation 

unfavorably, it is not to approve the waiver.

The Federal Records Centers Program is financed through a revolving 

fund, which in fiscal year 2012 earned revenue totaling approximately 

$185 million. Revenues for the fund are generated from the fees that 

NARA charges federal agencies for storing, servicing, and ultimately 

 

4

NARA, Review of Records Storage Facilities, NARA 1310 Policy Directive (May 22, 

2008). 
 

Page 6 GAO-13-668 Federal Records Centers Program

disposing of temporary federal records on their behalf, based on a 

standard fee schedule. NARA develops the fees annually for the 

upcoming fiscal year.

In November 2011, a presidential memorandum on managing 

government records was issued to the heads of executive departments 

and agencies. The purpose of the memorandum was to begin an 

executive branch-wide effort to reform records management policies and 

practices and to develop a 21st-century framework for the management 

of government records. Specifically, the memorandum stated, among 

other things, that all agencies were required to designate a Senior 

Agency Official to oversee a review of their records management 

program. The Senior Agency Official would be responsible for 

coordinating with the Agency Records Officer and appropriate agency 

officials to ensure the agency’s compliance with records management 

statues and regulations.

In January 2012 and March 2012, NARA’s Inspector General reported on 

one of NARA’s federal records centers, the Washington National Records 

Center, and found that it had numerous weaknesses.5

 

5

NARA Inspector General, Audit of the Management of Records at the Washington 

National Records Center; OIG Audit Report No. 12-02, Report 1 of 2 (Washington, D.C.: 

Jan. 3, 2012); and Audit of the Management of Records at the Washington National 

Records Center; OIG Audit Report No. 12-05 Report 2 of 2 (Washington, D.C.: Mar. 27, 

2012).

For example, the 

Inspector General reported that formalized procedures were not in place 

to properly track and resolve problems with records received, stored, or 

removed from the center; documented procedures did not exist for many 

of the center’s operations; and periodic inventories of the records held at 

the center were not conducted. In order to address the weaknesses cited 

above, the Inspector General made recommendations, which included 

developing a problem resolution process and mechanism for tracking all 

problems at the center until they are resolved, ensuring a formal tracking 

mechanism is implemented for new records received, and ensuring a 

systematic and repeatable process is in place to perform periodic 

inventories of the records held at the Washington National Records 

Center.

NARA’s Inspector General 

Previously Reported on 

Federal Records Centers 

Challenges
 

Page 7 GAO-13-668 Federal Records Centers Program

NARA concurred with these recommendations and began taking actions 

to address them. Specifically, the Archivist ordered all federal records 

centers operated by NARA to assess their operations during a 1-day 

stand down. In addition, NARA officials stated that they established a 

Washington National Records Center oversight group to ensure that the 

center leadership participated in plans, actions, and results related to 

resolving record storage issues. However, as of May 2013, NARA was in 

the process of addressing the recommendations.

Federal agencies are to store records in three types of facilities: federal 

records centers that are managed by NARA, agency records centers, and 

commercial records storage facilities. Each of these types of facilities is 

authorized by 36 C.F.R. Part 1234, which also requires agencies to notify 

NARA when they use agency records centers or commercial facilities to 

store federal records. While NARA is aware of the extent to which 

agencies use the federal records centers that it manages, its awareness 

of the extent to which agencies’ use their own and commercial records 

storage facilities is incomplete.

As of May 2013, NARA manages 18 federal records centers located 

across the United States. These centers consist of a total of 24 facilities 

where records are actually stored. Each facility includes storage areas, 

which NARA refers to as bays. (According to NARA, the typical bay is 

approximately the size of a football field.) Collectively, the facilities 

provide a total of 162 bays that are used by approximately 200 entities. 

Table 2 provides a listing of NARA’s federal records centers and their 

related facilities, and the number of bays at each facility.

Table 2: NARA-Operated Federal Records Centers, Related Facilities, and Number of Bays, as of May 2013 

 

Federal records 

centers Facility City, State Number of bays

(1) Pittsfield (1) Pittsfield Pittsfield, Massachusetts 3 

(2) Boston (2) Boston - Waltham Waltham, Massachusetts 4 

(3) Philadelphia (3) Philadelphia - Townsend Road Philadelphia, Pennsylvania 7 

(4) Atlanta (4) Atlanta- Ellenwood Ellenwood, Georgia 7 

(5) Chicago (5) Chicago

(6) Great Lakes Palletized Facility

Chicago, Illinois

North Chicago, Illinois

4 

3 

Federal Records Are 

to Be Stored in Three 

Types of Facilities; 

NARA Does Not Have 

Reliable Data about 

All Agencies’ Use of 

Records Storage 

Facilities

NARA Federal Records 

Centers 
 

Page 8 GAO-13-668 Federal Records Centers Program

 

Federal records 

centers Facility City, State Number of bays

(6) Dayton (7) Dayton Building 2 

(8) Dayton Building 3

(9) Dayton Building 4

(10) Dayton Palletized Facility

Dayton, Ohio

Dayton, Ohio

Dayton, Ohio

Fairfield, Ohio

4 

5 

5 

4 

(7) Kingsridge (11) Kingsridge Dayton, Ohio 5 

(8) Lenexa (12) Lenexa Lenexa, Kansas 16

(9) Lee’s Summit (13) Lee’s Summit Lee’s Summit, Missouri 17

(10) Kansas City (14) Kansas City - Subtropolis Kansas City, Missouri 1 

(11) Ft. Worth (15) Ft. Worth - Building 9

(16) Ft. Worth - John Burgess

Ft. Worth, Texas

Ft. Worth, Texas

2 

5 

(12) Denver (17) Denver - Broomfield Broomfield, Colorado 4 

(13) Riverside (18) Riverside Perris, California 4 

(14) San Francisco (19) San Francisco San Bruno, California 7 

(15) Seattle (20) Seattle

(21) Anchorage

Seattle, Washington

Anchorage, Alaska

8 

1 

(16) St. Louisa (22) National Personnel Records Center - 

Archives Drive

St. Louis, Missouri 15

(17) St. Louisb (23) National Personnel Records Center 

Annex - Valmeyer

Valmeyer, Illinois 11

(18) Suitland (24) Washington National Records Center Suitland, Maryland 20

Source: GAO analysis of information provided by NARA.

a

Military Personnel Records Center

b

Civilian Personnel Records Center

In addition to the federal records centers that NARA operates, agencies 

also are authorized to establish and operate their own centers for storing 

records. As of May 2013, NARA had identified 18 records centers that 

were being operated by six federal agencies or offices: the Department of 

Energy, the Department of Veterans Affairs, the Federal Bureau of 

Investigation, the National Geospatial-Intelligence Agency, the National 

Reconnaissance Office, and the Transportation Security Administration’s 

Office of Law Enforcement – Federal Marshal Records Center. These 

agencies varied in the number of storage facilities that they operated—

ranging from 7 at the Federal Bureau of Investigation to 1 facility at each 

of three other agencies (the Department of Veterans Affairs, the National 

Reconnaissance Office, and the Transportation Security Administration’s 

Office of Law Enforcement). Table 3 identifies the number of records 

storage facilities operated by each of the agencies.

Agency Records Centers
 

Page 9 GAO-13-668 Federal Records Centers Program

Table 3: Federal Agencies that Operate Records Storage Facilities, as of May 2013

Agency

Number of 

facilities

Department of Energy 6 

Department of Veterans Affairs 1 

Federal Bureau of Investigation 7 

National Geospatial-Intelligence Agency 2 

National Reconnaissance Office 1 

Transportation Security Administration’s Office of Law 

Enforcement – Federal Marshal Records Center

1 

Total 18

Source: GAO analysis of information provided by NARA.

Federal agencies are also authorized to use private sector commercial 

facilities for records storage, retrieval, and disposition. As of May 2013, 

agencies reported to NARA that 22 such facilities, operated by 12 

vendors, are under contract with and provide storage services for 11 

federal agencies or entities. These federal agencies or offices are the 

Bureau of Public Debt, Centers for Medicare and Medicaid Services, 

Commodities Futures Trading Commission, Department of Veterans 

Affairs, Environmental Protection Agency, Federal Aviation 

Administration, Federal Energy Regulatory Commission, Federal Public 

Defender, Naval Sea Systems Command, United States Customs and 

Border Protection, and the United States International Trade Commission. 

Table 4 identifies each vendor and their facilities that provide records 

storage services to federal agencies.

Commercial Storage 

Facilities
 

Page 10 GAO-13-668 Federal Records Centers Program

Table 4: Federal Entities Use of Commercial Records Storage Facilities, as of May 

2013

Vendor

Number of 

vendor facilities

Federal entity using commercial 

facility

Archive Corporation 1 • Department of Veterans Affairs

Armor Industries 1 • Department of Veterans Affairs

Augusta Data Storage 1 • Centers for Medicare and Medicaid 

Services 

DataSavers 1 • Centers for Medicare and Medicaid 

Services 

Diversified Information 

Technologies, Inc.

7 • Centers for Medicare and Medicaid 

Services 

• Department of Veterans Affairs

• United States International Trade 

Commission

• Environmental Protection Agency

• United States Customs and Border 

Protection

InfoResources 

Incorporated

1 • Department of Veterans Affairs

Iron Mountain 5 • Centers for Medicare and Medicaid 

Services 

• Department of Veterans Affairs

• Environmental Protection Agency

• Commodity Futures Trading

Commission

• Federal Energy Regulatory 

Commission

• Federal Public Defender

• Naval Sea Systems Command

Professional Data 

Storage and Delivery, 

Incorporated

1 • Department of Veterans Affairs

Records Imaging and 

Storage

1 • Bureau of the Public Debt

Riverbend

Government Benefits 

Records Center

1 • Centers for Medicare and Medicaid 

Services 

Safesite 1 • Department of Veterans Affairs

• Federal Aviation Administration

Sourcecorp Deliverex 1 • Department of Veterans Affairs

Source: GAO analysis of information provided by NARA.
 

Page 11 GAO-13-668 Federal Records Centers Program

To determine whether all agencies were storing their records in one of the 

three types of allowable facilities, NARA collected data and compiled a 

database of agencies and the records storage facilities that they use. 

Specifically, in 2008, NARA officials sent letters to agencies’ records 

managers that asked them to provide a list of all records storage facilities 

used. Subsequently, NARA sought to obtain information about where 

agencies were storing their records by sending follow-up letters and by 

including a question regarding the storage of federal records in a 

voluntary annual survey of agencies’ records management practices. 

However, the database was unreliable because it did not include 

complete, current, and valid data. Specifically, NARA’s database of 

agencies’ records storage facilities included a reporting status for about 

260 agencies, but did not have a date associated for when 47 of these 

agencies reported. Additionally, the data were derived primarily from 

information agencies submitted to NARA in 2008 and 2009, thereby 

rendering it outdated. Also, the self-reported nature of agencies’ data 

raised questions about the validity of the data they provided.

NARA officials responsible for determining where agencies store records 

acknowledged that the data about agencies’ and the records storage 

facilities they use are incomplete, outdated, and of questionable validity. 

The officials attributed this situation to agencies’ not reporting data to 

NARA because they were unfamiliar with the 36 C.F.R. Part 1234 

requirement to notify NARA when they use agency records centers or 

commercial facilities to store federal records, as well as NARA having 

insufficient staff to ensure that all agencies report the required data, keep 

the data current, and verify the data agencies provide.

NARA officials responsible for communicating records storage 

requirements to agencies stated that the Senior Agency Officials for 

records could provide NARA with points of contact that can help identify 

all the facilities where agencies store their records.6 Nevertheless, until 

NARA ensures that it has complete, current, and valid data on agencies’ 

records storage facilities, it cannot be certain that agencies are using one 

of the three types of authorized facilities.

 

6

We did not confirm whether agencies have designated these Senior Agency Officials for 

records. 
 

Page 12 GAO-13-668 Federal Records Centers Program

In carrying out its responsibilities to store and archive federal records, 

Title 44 of the United States Code7 authorizes NARA to establish, 

maintain, and operate records centers for federal agencies; approve 

agency records centers; and promulgate standards, procedures, and 

guidelines to federal agencies with respect to the storage of their records 

in commercial records storage facilities. Regulations implementing the 

statute, at 36 C.F.R. Part 1234, specify the minimum structural, 

environmental, property, and life-safety standards that a records storage 

facility must meet when the facility is used for the storage of federal 

records. For example, facilities must be designed in accordance with the 

applicable national, regional, state, or local building codes to provide 

protection from building collapse or failure of essential equipment. 

Further, a floor load limit must be established for the records storage area 

by a licensed structural engineer, and the facility must be 5 feet above 

and 100 feet from any 100-year flood plain areas, or be protected by an 

appropriate flood wall that conforms to local or regional building codes. In 

addition, NARA’s Review of Records Storage Facilities policy directive 

outlines the procedures for NARA to ensure records centers comply with 

36 C.F.R. Part 1234 specifications. Specifically, the directive requires 

NARA to conduct inspections of its federal records centers and agencies’ 

records centers to validate those facilities as compliant. In addition, 36 

C.F.R. Part 1234 requires that agencies ensure that their own or NARA 

officials have the right to inspect commercial records storage facilities for 

compliance with the facility requirements. If a commercial facility fails an 

inspection, federal agencies that store records at the facility are required 

to bring the facility into compliance with the standards within 6 months or 

to transfer their documents to a compliant facility within 18 months. 

Standard practices in program management call for documenting the 

scope of a project as well as milestones and time frames for timely 

completion and implementation of repairs or transfers to ensure results 

are achieved.8

NARA conducted inspections of 23 of its 24 federal records center 

facilities from February 2005 through January 2013 and determined that 

20 of the facilities were compliant with 36 C.F.R. Part 1234. It also 

determined that 2 facilities were partially compliant because they included 

 

7

44 U.S.C. §§ 2104(a), 2904, 2907, 3102, and 3103. 

8

The Project Management Institute, The Standard for Program Management © (Newtown 

Square, Pa., 2006).

NARA Has Approved 

Almost All of Its 

Federal Records 

Centers as Compliant 

with Applicable 

Standards, but It Has 

Not Inspected and 

Validated the Majority 

of Agency and 

Commercial Records 

Facilities
 

Page 13 GAO-13-668 Federal Records Centers Program

at least 1 storage bay that did not satisfy the regulation. Specifically, 

NARA found that 2 of the 16 bays at the Lenexa, Kansas facility and 6 of 

the 17 bays at the Lee’s Summit, Missouri facility were noncompliant 

because they included shelves that were determined to be too weak to 

meet the load requirements for records storage shelving and racking 

systems. Further, it found that all 7 bays at the San Francisco, California 

records center were noncompliant because, contrary to the regulation, 

there were pipes (other than sprinkler pipes) that ran through the records 

storage areas which lacked supplemental protective measures such as 

drip pans.9

Table 5: Status of Compliance of Each Federal Records Center Facility, as of 

January 2013 

The remaining facility consisting of 1 bay at the Anchorage, 

Alaska center was not inspected; however, NARA had considered the 

facility to be noncompliant and had planned to relocate the records being 

stored there. Table 5 summarizes the compliance status of each federal

records center facility.

Facility

Number of 

noncompliant bays Compliance

(1) Pittsfield 0 of 3 ●

(2) Boston - Waltham 0 of 4 ●

(3) Philadelphia - Townsend Road 0 of 7 ●

(4) Atlanta- Ellenwood 0 of 7 ●

(5) Chicago

(6) Great Lakes Palletized Facility

0 of 4

0 of 3

●

●

(7) Dayton Building 2

(8) Dayton Building 3

(9) Dayton Building 4

(10) Dayton Palletized Facility

0 of 4

0 of 5

0 of 5

0 of 4

●

●

●

●

(11) Kingsridge 0 of 5 ●

(12) Lenexa 2 of 16 ◐

(13) Lee’s Summit 6 of 17 ◐

(14) Kansas City - Subtropolis 0 of 1 ●

(15) Ft. Worth - Building 9

(16) Ft. Worth - John Burgess

0 of 2

0 of 5

●

●

 

9

According to NARA officials, the San Francisco facility was constructed prior to the 

establishment of the requirement for supplemental protective measures for pipes that run 

through records storage areas. 
 

Page 14 GAO-13-668 Federal Records Centers Program

Facility

Number of 

noncompliant bays Compliance

(17) Denver - Broomfield 0 of 4 ●

(18) Riverside 0 of 4 ●

(19) San Francisco 7 of 7 ○

(20) Seattle 0 of 8 ●

(21) Anchorage 1 of 1 ○

(22) National Personnel Records 

Center - Archives Drive

0 of 15 ●

(23) National Personnel Records 

Center Annex - Valmeyer

0 of 11 ●

(24) Washington National Records 

Center

0 of 20 ●

Key:

●- The facility’s bays were determined by NARA to be compliant.

◐- The facility had bays that were determined by NARA to be compliant and bays that were 

determined by NARA to be noncompliant.

○- The facility’s bays were determined by NARA to be noncompliant.

Source: GAO analysis of NARA documentation.

As of July 2013, NARA indicated that it had plans to address the 

deficiencies at the noncompliant federal records centers, although it had 

not established schedules for doing so at the San Francisco and 

Anchorage facilities. For example, to correct the shelving at the Lenexa 

and Lee’s Summit facilities, NARA had plans to contract for a detailed 

inspection of the existing shelving, prepare a report identifying necessary 

repairs, and then conduct the repairs and/or replacement of the 

noncompliant shelves. It expected to award a contract for this work in 

August 2013 and to complete the work within the following 6 months. In 

addition, NARA officials responsible for facility compliance had developed 

a plan for corrective actions at the San Francisco facility. This plan calls 

for the installation of water sensing cables and protective drip pans and 

guttering to provide supplemental protection of pipes that run through 

records storage areas. However, the plan does not include a schedule for 

completing these tasks consistent with standard practices for program 

management. NARA officials responsible for facility compliance attributed 

the lack of a schedule to uncertainty about the availability of funding and 

personnel resources to execute the plan. Further, NARA facility managers 

developed plans to replace the existing Anchorage, Alaska facility with a 

newly constructed facility. However, NARA did not have a schedule for 

completing the construction because it had not secured funding to 

construct the new facility.
 

Page 15 GAO-13-668 Federal Records Centers Program

While NARA has stated that it plans to bring all of its federal records 

center facilities into compliance with applicable regulations, the agency 

has not established a schedule for doing so at all facilities. Thus, although 

NARA has determined that the vast majority of the space (i.e., bays) in 

which its facilities store records is fully compliant with applicable 

standards, NARA has not established a basis for tracking and reporting

progress toward resolving deficiencies at all of its facilities that do not yet 

fully meet the standards.

Agencies must obtain approval from NARA to store federal records at 

their own or a commercial records storage facility and, to do so, must 

provide documentation to show that the facility satisfies the requirements 

of 36 C.F.R. Part 1234.10

NARA has approved 10 of the 18 agency facilities that agencies have 

reported using. According to NARA officials, the remaining 8 centers were 

not approved because the agencies that operate them did not provide 

NARA with sufficient documentation to support approval. NARA has 

approved all 22 identified commercial facilities.

After a facility is approved, agencies are able to 

store federal records at the facility and an inspection may be conducted to 

ensure that the facility meets the requirements of the standard. According 

to NARA officials responsible for determining facility compliance, 

inspections have been an important means of determining whether 

facilities are in fact compliant with the requirements.

However, of the 10 approved agency records centers, 1 had been 

inspected; and of the 22 approved commercial facilities, 13 had been 

inspected (1 inspection was deemed unfavorable and the facility was 

removed from the approved list). For the 9 agency records centers and 10 

commercial facilities that had not been inspected, NARA provided a 

schedule for doing so. According to this schedule, NARA plans to inspect 

4 facilities per fiscal year from fiscal years 2014 through 2017, with the 

remaining 3 facilities scheduled for inspection in fiscal year 2018. For the 

commercial facilities, NARA had scheduled all 10 of the remaining 

facilities, with the last of these inspections planned in fiscal year 2017. 

 

10Requirements for NARA’s approval of agency records centers are set out in 36 C.F.R. §

1234.30. This regulation also requires that an agency ensure and provide documentation 

to NARA that a commercial records storage facility in which the agency stores its records 

complies with the 36 C.F.R. Part 1234 requirements. 

NARA Has Not Inspected 

and Validated Compliance 

for the Majority of Agency 

and Commercial Records 

Storage Facilities
 

Page 16 GAO-13-668 Federal Records Centers Program

Until all facilities are inspected, NARA cannot be reasonably assured that 

agencies are storing federal records in facilities that comply with 

standards, thus increasing the risk that these records will be damaged.

In keeping with NARA’s mission to safeguard and preserve the records of 

the U.S. government, the agency has a process in place to handle 

incidents in which records could potentially become damaged at its 

federal records centers. In particular, NARA requires its federal records 

centers to follow the Emergency First Response for NARA Records 

checklist to facilitate the protection of federal records from further impact 

and/or permanent damage when an incident occurs. As part of the 

agency’s 1561 directive,11 the checklist requires (1) notification and 

immediate actions, such as notifying management; (2) an initial response, 

including steps to take if water damage occurs; and (3) damaged records 

response operations, including the requirement to document NARA’s 

immediate response to incidents in an after-action report and a general 

requirement to provide a report after completing follow-up activities. 

Additionally, internal control standards specify, among other things, the 

need for significant events to be clearly documented.

12

In addition to the checklist requirements, NARA’s Chief Operating Officer 

told us about specific steps NARA is to take when boxes of records get 

wet. For example, based on the volume of records that are involved and 

available resources, boxes are to be air dried and stored in an onsite 

freezer or in freezer trucks to minimize the growth of mold and prevent or 

reduce potential damage to records. Boxes of records are then to be 

individually removed, treated, and dried, or sent to a contractor that can 

freeze dry various types of records. NARA is also to use in-house 

restoration services, such as industrial fans, for incidents that are 

considered minor. For major incidents (where affected records are not 

expected to be available to the agency that owns them for more than 48 

hours), NARA’s process indicates that it will work with a contractor for 

drying services.

 

11This directive was established for records emergency preparedness and recovery in 

NARA facilities. 

12GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

NARA Has Taken 

Steps to Minimize 

Permanent Damage to 

Records in Federal 

Records Centers, but 

Does Not Always 

Track the Results of 

Its Efforts
 

Page 17 GAO-13-668 Federal Records Centers Program

NARA generally followed its process to prevent damage to records when 

incidents occurred. Documentation that we reviewed for 55 incidents that 

NARA reported as occurring from January 2009 through March 2013 

indicated that the agency had taken steps consistent with its Emergency 

First Response for NARA Records checklist.13

Specifically, at the Washington National Records Center:

For example, NARA 

provided documentation of steps taken to handle incidents at the

Washington National Records Center and at the National Personnel 

Records Center in Valmeyer, Illinois from March 2011 through August 

2012.

• A roof leak incident in March 2011 impacted 47 cubic feet of records 

stored at the center. According to NARA’s documentation, 2 cubic feet 

of records were placed on drying racks and dried, 3 cubic feet of 

records were reboxed, and the remaining records were air dried in 

their original boxes.

• During another roof leak at the center in May 2011, a large number of 

boxes of records became wet. NARA staff noted the locations of the 

leaks, notified management, and took steps to address the incident. 

The staff initiated triage efforts to relocate the records to another area 

to determine how the incident had affected the records. While some 

records were air dried, those that were substantially wet were placed 

in a freezer truck. After the records were held in the freezer truck for 

several days, NARA reassessed them, and removed and reboxed 

records that had dried. The remaining 252 cubic feet of wet records 

were freeze dried at an offsite facility. NARA documented the actions 

it took to address the wet records and the center director notified the 

affected agencies.

• A roof leak that occurred at the center in June 2011 affected 7 cubic 

feet of records. NARA documented the actions it took, noting that 5 

cubic feet of records were reboxed, and the remaining records were 

air dried.

 

13We assessed incidents of potential records damage that occurred at federal records 

centers from January 2009 through March 2013. The incidents that occurred during this 

time frame were specific instances involving water, in which federal records could have 

been permanently damaged or destroyed. 
 

Page 18 GAO-13-668 Federal Records Centers Program

• Another roof leak later that month resulted in a large number of boxes 

of records becoming wet. NARA staff noted the locations in which the 

leaks occurred, notified management, and took actions to address the 

records involved in the incident. The staff initiated triage efforts to 

relocate the records to another area and determine the level of 

severity for the affected records. Records that could be dried with 

minimal effort were removed from boxes and placed on pallets to 

begin the air-drying process onsite. Records that were found to be 

substantially wet were placed in a freezer truck. After the records 

were held in the freezer truck for several days, NARA reassessed 

them and determined that some of the records had dried. While the 

dry records were removed from the freezer truck and reboxed, 414 

cubic feet of records were freeze dried at an offsite facility. NARA 

documented the actions it took to address the wet records and the 

center director notified the affected agencies.

In addition, at the National Personnel Records Center (Valmeyer):

• A sprinkler leak in August 2012 affected 27 cubic feet of records. Five 

of the 27 cubic feet of records were determined to not be wet and 18 

cubic feet of records were removed from the location and dried. The 

remaining 4 cubic feet of records were reboxed.

While NARA has taken steps to minimize damage to records, the agency 

has not tracked the results of its efforts in all cases. For example, of the 

55 incidents, NARA provided documentation that verified that the actions 

it took in responding to 46 incidents resulted in no permanent damage to 

records. For the remaining 9 incidents, officials stated that NARA’s 

actions prevented permanent damage to records; however, the agency 

could not provide documentation that would allow us to verify this 

assertion. For example, NARA could not provide documentation that 

described the results of its efforts to prevent permanent damage to 6 

cubic feet of records that became wet due to faulty floor and roof drains at 

the Chicago Federal Records Center in June 2011. A contributing factor 

is that while the NARA 1561 checklist provides generally defined 

requirements for final reporting, it does not require the federal records 

centers to document the results of the actions they have taken to prevent 

permanent damage to records that were at risk. As a result, NARA is not 

positioned to fully report on the effectiveness and outcome of its actions 

to minimize damage to records and does not have an institutional record 

that a third party can use to validate the results of its efforts.
 

Page 19 GAO-13-668 Federal Records Centers Program

The Treasury and General Government Appropriations Act, 2000, 

established a Records Centers Revolving Fund to pay for expenses and 

equipment necessary to provide storage and related services for federal 

records.14 Accordingly, the Federal Records Centers Program and 

NARA’s Office of the Chief Financial Officer are responsible for annually 

developing the fees charged to agencies for records storage and related 

services. These fees are to be developed for the upcoming fiscal year 

using the current fiscal year fee schedule, expense projections, and 

workload projections for NARA’s records centers. In determining the fees, 

it is to consider costs associated with full operation of the records storage 

facilities, taking into consideration expenses, such as reserves for 

accrued annual leave, worker’s compensation, depreciation of capitalized 

equipment and shelving, and amortization of IT software and systems. 

Annually, all federal records centers are required to submit expense15 and 

workload16

The fees developed for the upcoming fiscal year are approved by the 

Director of the Federal Records Centers Program, Executive for Agency 

Services, Chief Financial Officer, and Chief Operating Officer before 

receiving final approval from the Archivist. According to NARA officials 

responsible for managing the Federal Records Centers Program, the 

newly developed fees are then used at all federal records centers for the 

upcoming fiscal year.

projections to the Federal Records Centers Program 

headquarters operation. The expense and workload projections are used 

to develop budget and revenue projections, which are then used as the 

basis to develop rates for the upcoming fiscal year. Factors such as 

inflation, customer impact, the frequency of rate change, and 

competitiveness with the private sector are then considered when 

developing new rates.

 

14Pub. L. No. 106-58, title IV, 113 Stat. 460-461 (1999), as amended by Pub. L. No. 108-

383, § 3, 118 Stat. 2218 (2004).

15The expense projections provide data on the existing annual expense budget, current 

year-to-date spending levels, and projections for revenues and costs of items, including 

personnel costs and benefits, rent, communications and utilities, supplies and materials, 

transportation, equipment, and contractual services.

16The workload projections provide data for 3 prior years of workload data, midyear data 

for the current fiscal year, and projections for the amount of work required for storage and 

services, such as storage and disposition, at federal record centers.

Federal Record 

Centers Storage Fees 

Are Developed 

Annually and Are 

Comparable to 

Commercial Vendors’ 

Fees 
 

Page 20 GAO-13-668 Federal Records Centers Program

Storage fees charged by NARA in fiscal year 2013 were comparable to 

fees charged by commercial vendors on the GSA schedule in that same 

time frame. Specifically, of the 12 commercial vendors that provided 

storage services for 11 federal agencies, 5 had price lists that were 

posted on GSA’s Federal Acquisition Service webpage. Table 6 provides 

a comparison of storage fees for NARA and these 5 commercial vendors 

for fiscal year 2013.

Table 6: Comparison of Federal Records Centers and Commercial Vendors’ Storage Fees from the GSA Schedule

Vendor 1 Vendor 2 NARA Vendor 3 Vendor 4 Vendor 5

3,600 cubic feet or less $0.145 $0.16 $0.23 $0.25 $0.27 $ 1.25 

Between 3,600 and 48,000 cubic feet $0.145 $0.16 $0.23 $0.25 $0.27 $ 0.50 

Between 48,000 and 50,000 cubic feet $0.145 $0.16 $0.23 $0.25 $0.27 $ 0.38 

50,000 cubic feet, up to 99,999 cubic feet $0.135 $0.16 $0.23 $0.25 $0.27 $ 0.38 

100,000 cubic feet up to 499,999 cubic feet $0.135 $0.16 $0.23 $0.25 $0.18 $ 0.38 

500,000 cubic feet or more $0.135 $0.15 $0.23 $0.25 $0.18 $ 0.38 

Minimum not met $65 n/a n/a $25 $100 n/a 

Source: GAO analysis of agency and GSA schedule data.

Note: Each of the commercial vendors has at least one facility that is compliant with 36 C.F.R. Part 

1234.

As shown in the table, NARA’s fee of $0.23 per cubic foot was consistent 

regardless of the storage quantity. Specifically, NARA’s fee was higher 

than fees charged by vendors 1 and 2, although its fees were lower than 

those of vendors 3 and 5. In addition, NARA’s fees were lower than those 

of vendor 4 if storing less than 100,000 cubic feet and higher if storing 

100,000 or more cubic feet. NARA also did not charge additional fees that 

certain vendors charged. Specifically, vendors 1, 3, and 4 applied a $65, 

$25, and $100 fee, respectively, to a customer’s account when the 

storage charges did not meet the customer’s contractual minimum 

storage requirement. In addition, vendor 4 charged an administration fee 

of $25.12 or $62.80 per account, respectively, for summary or detailed 

billing.

Although federal regulations call for records to be stored in one of three 

types of facilities—NARA-operated federal records centers, agency 

records centers, or commercial records storage facilities—the extent to 

which agency and commercial facilities are used to store records is 

uncertain because NARA does not know where all agencies store their 

records. NARA’s efforts to collect data from agencies about the facilities 

Conclusions 
 

Page 21 GAO-13-668 Federal Records Centers Program

they use to store records have yielded data that are incomplete, outdated, 

and of questionable validity.

NARA has determined that most of its federal records center facilities are 

fully compliant with the standards established in regulations, but that four 

facilities are partially or entirely noncompliant—a situation that increases 

the risk of damage to the records stored in the facilities. Although it has 

plans for bringing these four facilities into full compliance with the 

regulations, NARA has not established dates for completing its plans at 

two of the facilities. As a result, NARA does not have a basis for 

determining progress toward correcting deficiencies in those facilities that 

do not fully meet the standards

Additionally, although NARA has taken steps to prevent permanent 

damage to records in their facilities on a total of 55 occasions over a 

recent 4-year time period, the federal records centers did not always keep 

track of the results of their efforts and were unable to provide 

documentation confirming they were successful in 9 cases. Therefore, 

NARA is not positioned to fully report on the effectiveness of its actions to 

minimize permanent damage to federal records.

To assist NARA in its responsibility to ensure that federal records are 

stored in compliant facilities, we recommend that the Archivist of the 

United States direct the Chief Operating Officer to take the following three 

actions:

• Place increased priority on the collection of complete, current, and 

valid information from agencies about their use of agency and 

commercial records storage facilities.

• Develop a schedule for executing plans to resolve issues at each of 

the federal records centers that is not fully compliant with 36 C.F.R 

Part 1234.

• Clarify NARA’s checklist for handling incidents that may involve 

permanent damage to records by including a requirement to 

document the results of the steps taken to minimize permanent 

damage to records.

Recommendations for 

Executive Action
 

Page 22 GAO-13-668 Federal Records Centers Program

NARA provided written comments on a draft of this report, which are 

reprinted in app. II. In its comments, the agency concurred with all three 

of our recommendations for executive action regarding facility inspections 

and other areas related to safe storage of federal records. In addition, we 

received technical comments via email from NARA, which we have 

incorporated as appropriate.

We are sending copies of this report to the appropriate congressional 

committees; the Archivist of the United States; and other interested 

parties. This report also is available at no charge on the GAO website at 

http://www.gao.gov.

Should you or your staffs have any questions on information discussed in 

this report, please contact me at (202) 512-6304 or melvinv@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. GAO staff who made 

major contributions to this report are listed in appendix III.

Valerie C. Melvin

Director

Information Management 

 and Technology Resources Issues

Agency Comments

and Our Evaluation
Appendix I: Objectives, Scope, and 

Methodology

Page 23 GAO-13-668 Federal Records Centers Program

Our objectives were to (1) determine the types of facilities agencies use 

to store federal records and the extent to which NARA’s data on 

agencies’ use of storage facilities are complete, (2) evaluate the extent to 

which NARA has determined these facilities to be compliant with 

standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has 

taken to minimize damage to records in federal records centers and the 

extent to which it documents such efforts, and (4) determine how NARA 

determines storage fees and whether fees differ among facilities.

To accomplish the first objective, we reviewed 36 C.F.R. Part 1234 and 

developed a thorough understanding of the regulation through 

discussions with NARA officials who are responsible for administering it. 

We then obtained lists of NARA, agency, and commercial records storage 

facilities from NARA. These lists included NARA’s central registry of 

approved facilities. We corroborated the lists by comparing them with 

other documentation such as facility approval memoranda and inspection 

schedules, as well as through interviews with agency officials. 

Additionally, we obtained NARA’s database of agencies’ records storage 

facilities and discussed NARA’s methods for populating the database with 

responsible NARA officials. We determined the database to be unreliable 

because it was incomplete, outdated, and largely reliant on self-reported 

data from agencies.

For the second objective, we obtained and reviewed memoranda from 

NARA that indicated approval of NARA, agency, and commercial records 

storage facilities and the facilities’ compliance with 36 C.F.R. Part 1234. 

We then used additional documentation, including detailed facility 

inspection checklists, fire inspection reports, and structural engineering 

reports to determine the existence of support for NARA’s approval 

determinations. We also discussed NARA’s method for approving and 

inspecting facilities, in addition to plans for conducting future facility 

inspections with the officials who are responsible for performing the 

inspections.

To accomplish the third objective, we reviewed NARA policies and 

procedures for the storage and management of federal records and 

compared them with applicable internal control standards. We also 

reviewed procedures for handling records damage in NARA records 

centers and documentation relative to records emergency planning and 

training. We collected and analyzed documentation on 55 incidents that 

occurred at NARA records centers from January 2009 through March 

2013, including reports that described NARA’s actions to mitigate or 

reduce records damage. We also compared requirements in NARA’s 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 24 GAO-13-668 Federal Records Centers Program

1561 checklist to the documentation described above. Further, we 

interviewed NARA officials to determine the actions taken to minimize 

records damage in federal records centers and corroborated the officials’ 

statements with aforementioned documentation.

To accomplish the fourth objective, we obtained and analyzed 

documentation from the NARA Federal Records Centers Program and 

General Services Administration (GSA) schedules that identified and 

discussed records storage fees and then compared fees among records 

storage facilities. To determine the reliability of the data provided from 

NARA, we performed basic steps to ensure the data provided were valid, 

and reviewed relevant information describing the data. We reviewed 

documentation related to the data sources, including NARA’s fiscal year 

2013 fee schedule, fee determination process description documents, 

and workload and expense projections. Although we could not 

independently verify the reliability of all this information, we compared the 

data with other available supporting documents to determine data 

consistency and reasonableness. We also obtained price lists from GSA’s 

website for commercial vendors that listed facilities that are compliant 

with 36 C.F.R. Part 1234. We did not determine whether individual 

agencies had negotiated lower prices than those listed in the price lists. 

We compared storage fees for NARA and commercial vendors by 

extracting fee data from NARA’s fee schedule and commercial vendor 

price lists. For our comparison, we reviewed the publicly available price 

lists for five commercial vendors (referred to as vendors 1-5 in our 

analysis). Four of the five vendors’ price lists charged storage fees based 

on cubic feet of storage per month and the fifth vendor charged based on 

the number of boxes stored.1

We supplemented our analyses with interviews of NARA officials who are 

knowledgeable about the Federal Records Centers Program, including 

NARA’s Chief Operating Officer, the program director, and assistant 

director. We also interviewed representatives of private sector record 

storage companies that were relevant to our study.

In order to directly compare fees 

established by NARA and the five vendors, we converted boxes to cubic 

feet for vendor 5. Storage fees were then arranged in order from lowest to 

highest.

 

1

The size of one box is approximately 1.2 cubic feet. In order to directly compare fees 

established by NARA and the five vendors, we have converted boxes to cubic feet for 

vendor 5. 
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-13-668 Federal Records Centers Program

We conducted this performance audit from November 2012 to September

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Comments from NARA

Page 26 GAO-13-668 Federal Records Centers Program

Appendix II: Comments from NARA
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 27 GAO-13-668 Federal Records Centers Program

Valerie C. Melvin at (202) 512-6304 or melvinv@gao.gov

In addition to the contact name above, the following staff also made key 

contributions to this report: Mark Bird, Assistant Director; Sharhonda 

Deloach; Elena Epps; Rebecca Eyler; Jacqueline Mai; and Constantine 

Papanastasiou.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(310997)
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