39202 Federal Register / Vol. 63, No. 139 /Tuesday, July 21, 1998 / Notices

5Programming changes can appear to work initially, but prove to have problems over a longer period of time. The Work Group specifically invites comments on whether 3 system cycles is sufficient for all administrative systems. Retention of basic programming information can be crucial with problems like the Year 2000 conversions. In contrast to item 3e which contains ‘‘copies of master files or databases, application software, logs, directories, and other records needed to restore a system in case of a disaster or inadvertent destruction,’’ 2d deals with the very

basic operating system program. (2d is the frame and foundation of the house; 3e is the brick, aluminum siding, and drywall.) 6This is not the official contract file maintained by the agency procurement office and covered by GRS 3, item 3. Documentation pertaining to

system requirements in the RFP, the language used by the vendor in proposals and quotes, and the benchmark/acceptance testing information

can substantially impact assessment of vendor performance. Further, this can impact the specifications of future IT acquisitions. 7 ISSUE: Should this item be deleted because GRS 3, Item 3, already covers all? Another alternative that has been proposed is to leave the

description here, but provide a cross reference to GRS 3, Item 3c. 8Please see Schedule 18, Item 27.

9 Items 3 f, g, and h could be collapsed into one item. Comments on the advisability of doing so are invited. For this draft, item 3f is separate

because it focuses upon an individual user (for example, a procurement officer leaves the organization). Item 3g is a general log used to spot

substantial differences in volume of traffic. Use of item 3g may trigger an audit of item 3f records (for example, a 40% increase in one unit’s use

may raise questions about why the increase; next step, a look at item 3f). Item 3h is a summary report, used for billing purposes. 10 ISSUE: Can this retention period be easily applied? Is it appropriate for all administrative systems, including security-classified ones? 11Validity checks are routines in a data entry program that test the input for correct and reasonable conditions, such as numbers falling within

a range and correct spelling, if possible. Valid transaction files are the reports of those validity checks. 12 ISSUE: Disposition of item 4d is impossible to implement in the case of print files that are automatically generated and deleted by applications software. This may be a policy issue as to whether those files should be automatically deleted by the applications software. 13The disposition for Item 5a is for the operating system records; Item 2c covers the records for planning the system. 14 In contrast to Item 2, which deals with systems application and development, Item 6 addresses end user support records. 15These logs can be invaluable in resolving customer complaints, providing appropriate follow-up service, and spotting problem trends in systems and networks. 16GRS 12, Communications Records, is under review and will have to be modified at a later date to address redundancies. 17 Network installation records are included because the history of wiring in buildings, locations of switches, etc., has been a problem. Recent

building renovations have revealed that agencies have unused phone lines, which are still live and costing money. Employees had moved to new

offices, received new phone numbers, and never had the old phone lines disconnected.

[FR Doc. 98–19468 Filed 7–20–98; 8:45 am]

BILLING CODE 7515–01–P

NATIONAL ARCHIVES AND RECORDS

ADMINISTRATION

Electronic Records Work Group Draft

Report; Comments Requested

AGENCY: National Archives and Records

Administration (NARA).

ACTION: Request for comment.

SUMMARY: This notice contains a

working draft of the Electronic Records

Work Group’s proposed report to the

Archivist outlining the Work Group’s

recommendations and the effort that

went into developing the

recommendations and implementation

strategy. This draft has been modified

slightly from the June draft that was

posted on the Web and sent to agencies

for review. This draft reflects the Work

Group’s decisions to use the term

‘‘electronic source record’’ to describe

the records created using office

automation applications and to place

the discussion of program and

administrative records, formerly in draft

Appendix B, in the introductions to

draft Appendixes C and D where they

are most pertinent. For purposes of this

review, we have not changed the

Appendix designations that were used

in the June draft and have, therefore,

reserved Appendix B for a discussion in

the final report of the public and

Federal comments received on the draft

products.

DATES: Comments must be received on

or before August 20, 1998.

ADDRESSES: Comments may be sent

electronically to the e-mail address

<grs20@arch2.nara.gov>. We ask that

lengthy attachments be sent in ASCII,

WordPerfect 5.1/5.2, or MS Word 6.0

format. If you do not have access to email, comments may be mailed to

Electronic Records Work Group (NPOL),

Room 4100, 8601 Adelphi Rd., College

Park, MD 20740–6001, or faxed to 301–

713–7270.

FOR FURTHER INFORMATION CONTACT:

Michael Miller at 301–713–7110, ext.

229.

SUPPLEMENTARY INFORMATION: The draft

report appears at the end of this notice.

Dated: July 16, 1998.

Lewis J. Bellardo,

Deputy Archivist of the United States.

Draft Electronic Records Work Group

Report to the Archivist of the United

States

Table of Contents

Executive Summary

Introduction

Work Group Approach

Recommendations of the Electronic Records

Work Group

Rejected Options

Future Steps

Appendix A—Electronic Records Work

Group membership

Appendix B—[Reserved]

Appendix C—Proposal for developing agency

records schedules that include office

automation records

Appendix D—Proposal to revise the entire

GRS to cover all formats of the

administrative records included therein

Appendix E—Proposed General Records

Schedule, Information Technology

Records

Executive Summary

The Electronic Records Work Group

(Work Group) is an interagency group

formed by the Archivist of the United

States on November 21, 1997, to review

the 1995 version of General Records

Schedule (GRS) 20, which was declared

null and void by the U.S. District Court

for the District of Columbia. (That ruling

is on appeal.) Specifically, the Work

Group was asked to identify appropriate

areas for revision, explore alternatives

for authorizing disposition of electronic

records, identify methods and

techniques that are available with

current technology to manage and

provide access to electronic records, and

recommend practical solutions for the

scheduling and disposition of electronic

records. The Archivist also gave the

Work Group several guiding principles

and policies, including: program records

should not be scheduled in the GRS,

electronic records should be scheduled

as series, and solutions must be

workable.

The Work Group membership was

drawn from staff of the National

Archives and Records Administration

(NARA) and other Federal agencies with

records management and/or electronic

records expertise under the oversight of

Deputy Archivist Lewis Bellardo.

Michael Miller, the Director of NARA’s

Modern Records Programs, serves as the

group leader. In addition, electronic

records management experts from state

archives and records programs, the

National Archives of Canada, academia,

and records management consulting

firms serve as consultants to the Work

Group on a pro bono basis.

In conducting its review and

developing the recommendations

contained in this report, the Work

Group aggressively sought input from

Federal agencies, other interested
Federal Register / Vol. 63, No. 139 /Tuesday, July 21, 1998 / Notices 39203

individuals and groups, and the general

public. In addition to the public

meetings held on December 19, 1997,

and January 29, April 7, and May 18,

1998, NARA maintained a web page

devoted to the work of the Electronic

Records Work Group (http://

www.nara.gov/records/grs20/);

published public notices in the Federal

Register; sent memos to Federal agency

records officers asking for their

comments at various points in the

process; solicited comments from

subscribers to the Archives Listserv and

Records Management Listserv; and

invited comments from professional

organizations, such as the American

Historical Association (AHA),

Organization of American Historians

(OAH), Society of American Archivists

(SAA), National Association of

Government Archives and Records

Administrators (NAGARA), Association

of Records Managers and

Administrators International (ARMA),

and the National Coordinating

Committee for the Promotion of History,

and from other individuals with an

interest or expertise in electronic

records.

By March 1998 the group had drafted

a number of options to be explored to

replace GRS 20 disposition authorities,

including authorities for the deletion of

program and administrative electronic

mail and word processing records, and

for system maintenance and operations

records. The group also explored

options for electronic maintenance of

electronic source records (records that

remain in word processing and

electronic mail and other office

automation systems after a record has

been produced for incorporation into an

agency recordkeeping system) on an

interim basis prior to the installation of

proper electronic recordkeeping

capability. After carefully considering

the public and consultant comments on

the preliminary options, the Work

Group determined that there was only

one feasible alternative approach to GRS

20, and that was to schedule the records

at the series level.

The two other options initially

proposed as possible approaches for

managing electronic source records

generated with electronic mail and word

processing software were found to have

significant flaws. Both options (to

establish a uniform minimum retention

period or to develop retention standards

based on an individual’s position in the

agency’s hierarchy) failed to meet

requirements for the proper

maintenance of records. Neither

provided for proper organization or

categorization of records to facilitate

access. In both cases, disposition

appeared to be based on factors other

than business needs. The group could

not identify supplemental measures that

could be taken in conjunction with

either of these options to make them

useful.

The Work Group, therefore,

recommends to the Archivist of the

United States a three-part approach for

scheduling the electronic source records

that previously were authorized for

disposal under GRS 20, items 13, 14,

and 15. The Work Group’s

recommendations also address other

concerns with the 1995 edition of GRS

20, i.e., authorization for the disposition

of electronic source records produced

with other office automation systems

such as presentation software and

electronic calendaring software, and

authorization for the disposal of

electronic records that correspond to the

records covered in GRS 1–16, 18 and 23.

fl First, agencies must schedule their

program and unique administrative

records in all formats. As part of its

report, the Work Group proposes an

implementation strategy to assist

Federal agencies and NARA in

accomplishing this task.

fl Second, the Work Group

recommends that NARA modify General

Records Schedules (GRS) 1–16, 18, and

23 to authorize the deletion of electronic

source records, including those

generated with office automation

systems, that correspond to

administrative records covered by those

GRS, after a recordkeeping copy has

been produced.

fl Third, the Work Group

recommends that NARA develop a new

General Records Schedule that covers

only systems administration (or systems

management) and operations records,

such as files related to system use and

maintenance, backup tapes, and other

records (e.g., system user access records)

used in managing information systems

throughout their life cycle. This new

GRS would cover records in all media.

The Work Group originally conducted a

preliminary review of issues facing

agencies that want to move toward

electronic recordkeeping, but

determined that working

simultaneously on the scheduling

approach and the electronic

recordkeeping approach was not

feasible given the deadlines and the

complexity of electronic recordkeeping

issues that need to be studied. The Work

Group recommends that the Archivist

establish a follow-on group that

continues to work on electronic

recordkeeping. This follow-on group

should recommend guidance on

electronic recordkeeping for Federal

agencies.

Introduction

The Archivist of the United States

established an interagency Electronic

Records Work Group on November 21,

1997. In his charge to the Work Group,

the Archivist asked the group to:

fl Review the current version of

General Records Schedule (GRS) 20;

fl Identify appropriate areas for

revision;

fl Explore alternatives for

authorizing disposition of electronic

records;

fl Identify methods and techniques

that are available with current

technology to manage and provide

access to electronic records; and

fl Recommend practical solutions

for the scheduling and disposition of

electronic records.

The Work Group was asked to

develop and weigh advantages of

various options and assess the

practicality and feasibility of each in

light of the availability of electronic

records management tools and other

resources. The Archivist asked the Work

Group to keep in mind the following

working assumptions in performing its

work:

fl General records schedules should

focus on administrative ‘‘housekeeping’’

records, not program records, and there

should be guidance in place to

distinguish between them.

fl Records may be transferred from

one medium to another; however, key

information about those records must be

preserved as part of the transfer process.

fl Electronic records should be

scheduled as series, not classes of

media.

fl Solutions to electronic records

challenges must be workable and be

something agencies can and will use.

The Work Group membership was

drawn from NARA staff and

representatives of other Federal agencies

with records management and/or

electronic records expertise under the

oversight of Deputy Archivist Lewis

Bellardo. Michael Miller, the Director of

NARA’s Modern Records Programs,

serves as the group leader. In addition,

electronic records management experts

from state archives and records

programs, the National Archives of

Canada, academia, and records

management consulting firms serve as

consultants to the Work Group on a pro

bono basis. A list of the Work Group

members and consultants is provided in

Appendix A to this report.

Throughout this report, the term

‘‘electronic source record’’ has been

used to describe the electronic record

that resides on an agency’s electronic

mail, word processing, or other office
39204 Federal Register / Vol. 63, No. 139 /Tuesday, July 21, 1998 / Notices

automation systems, i.e., the ‘‘copy’’

that formerly was authorized for

disposal by GRS 20 after a

recordkeeping copy was produced. This

report addresses the disposition of the

electronic records which are the sources

of the records filed in the agency’s

recordkeeping system. Therefore these

records are designated as ‘‘electronic

source records.’’ Agencies need to

recognize that records created using

word processing, e-mail and other

software on office automation systems

must be scheduled according to the

same requirements which apply to all

records. NARA will authorize the

disposal of electronic source records in

office automation systems only when

copies of these records have been

captured in a recordkeeping system.

A main thrust of this report is to

provide guidance and techniques to

agencies for scheduling electronic

source records that are created using

word processing, electronic mail, and

other end-user software. These records

typically are stored in desktop and

laptop computer systems and in

networked servers. In the modern

Federal office environment, most staff

members are provided with generic

software tools, such as word processing

and e-mail, which they use to generate

electronic records related to their work,

regardless of the nature of the work.

These records need to be filed in a

recordkeeping system so that they will

be retrievable with other related records

such as attachments, the corresponding

incoming or outgoing record, and, if part

of a case file, the forms and other

records that comprise that file. The

complete files, and individual records

within them, need to be accessible to

other staff members who need them in

the course of their work and in response

to inquiries from the public. Failure to

place electronic records generated as

electronic mail messages, word

processing files, and other office

automation products in a recordkeeping

system will result in files which are

incomplete or unreliable. Consequently,

these electronic source records must be

copied to a recordkeeping system

established by the agency for

maintenance, use, and disposition.

However, even after these records are

placed in a recordkeeping system, a

record remains on the originating

system. These electronic source records,

like other Federal records, can be

destroyed (deleted from the office

automation system) only with NARA’s

authorization. The Work Group

proposes that NARA revise the GRS to

provide governmentwide authorization

for the disposition of electronic source

records used to create the types of

records covered by GRS 1-16, 18, and

23. Agencies must obtain authorization

for disposition of all other electronic

source records by submitting a schedule

(Standard Form 115) to NARA.

The Work Group considered using

terms other than ‘‘electronic source

record’’ but found them problematical.

Some readers saw ‘‘electronic copy’’ as

implying nonrecord status. The term

‘‘version’’ is often used to distinguish

between a paper record and the same

record in electronic form. However,

‘‘version’’ is frequently used to describe

a record that is an iteration of an earlier

or later record. Hence, ‘‘version control’’

may be a feature of a document

management or electronic

recordkeeping system, to distinguish

between the first record produced and

later variants of the same record.

Conversely, the Work Group chose

not to use the term ‘‘duplicate’’ because

that term implies an exact match which

may not exist. The electronic source

record that resides in an individual’s

word processing directory or electronic

mail box would be a duplicate of the

record in the recordkeeping system only

if the recordkeeping system were

electronic and if all of the metadata

produced by the word processing or

electronic mail utility were transferred

to the recordkeeping system. Because so

many agencies are still maintaining

paper files as their recordkeeping

systems, use of the term ‘‘duplicate’’

would be inappropriate.

Work Group Approach

In conducting its review and

developing the recommendation and

products contained in this report, the

Work Group made special efforts to

engage the Federal community and the

public in discussion of possible

alternatives to the 1995 General Records

Schedule 20, and to keep them informed

of the Work Group’s activities. A GRS

20 web page on NARA’s Internet web

site at <http://www.nara.gov/records/

grs20/>, and a special e-mail address

(grs20@arch2.nara.gov) was established.

Posted on that web page were

documents for public comment, meeting

notices and agendas, summaries of

public meetings, and other background

materials relating to the Work Group

and the Public Citizen v. Carlin

litigation. Notices of public meetings

and information about documents for

public comment were published in the

Federal Register. Information and

requests for comment also were

provided to Federal agency records

officers through NARA memos and to

subscribers of the Archives Listserv and

Records Management Listserv through

electronic messages.

The Work Group’s first public

meeting was held on December 19,

1997, at NARA’s Archives II facility in

College Park, MD, with one member and

several consultants participating by

teleconference. The purpose of the

meeting was to bring the members of the

Electronic Records Work Group and

consultants together to outline the tasks

and to answer questions concerning the

logistics of the Work Group. The Work

Group and consultants received a set of

detailed preliminary issues proposed for

discussion and other background

materials. The list of preliminary issues

was posted on the GRS 20 Page and also

published for public comment in the

Federal Register on December 24.

Comments were received from Work

Group members and consultants and a

Federal agency contractor by the

January 9, 1998, deadline. In an effort to

obtain wider input on the list of issues

and options the Work Group should

consider, a second public meeting was

held on January 29, 1998, at the

National Archives Building in

Washington, DC. More than 70 Federal

agency staff and interested members of

the public attended. Two Federal

employees provided formal remarks,

and a number of individuals, most from

Federal agencies, made comments from

the audience.

Immediately following the public

meeting on January 29 and continuing

on February 9, 1998, the NARA

members and Federal members of the

Electronic Records Work Group held

working sessions at the National

Archives Building in Washington, DC,

to discuss alternatives for GRS 20. The

members discussed the framework in

which they were working, ranging from

the goals of the group to the current

status of electronic records management

in the Federal government. The

members also discussed the comments

submitted by members of the public and

brainstormed on possible alternatives to

GRS 20. From these comments and

ideas, the Work Group developed three

possible short-term approaches for

scheduling electronic records for further

analysis and review. These were

described in the March 12, 1998, paper

‘‘Preliminary Options for Replacing GRS

20.’’ The Work Group’s consultants,

who had reviewed a draft of the paper,

were asked to provide their views on

enabling requirements and related

issues for specific options, and to

comment on any other aspect of the

paper. Work Group members also

developed comments on specific

options.

The Preliminary Options paper laid

out three options. The first option,

based on a traditional approach to
Federal Register / Vol. 63, No. 139 /Tuesday, July 21, 1998 / Notices 39205

scheduling records by series, had three

complementary sections for scheduling

program and administrative records,

revising GRS 20 to cover only systems

records, and revising the remaining GRS

to provide disposal authority for source

records not needed for recordkeeping.

The second and third options offered

alternative interim approaches for

handling the disposition of electronic

source records that remain on electronic

mail and word processing systems.

Option 2 involved saving electronic

source records for a specific minimum

period of time and option 3 proposed

saving the electronic source records

created or received by individuals

holding specific positions within an

organization.

Public input on the options paper and

suggestions for additional approaches

were sought in a variety of ways. The

paper was posted on the GRS 20 Page

as <http://www.nara.gov/records/grs20/

opt312.html> on March 14, and a notice

announcing the availability of the paper

and requesting comments was

published in the Federal Register on

March 19, 1998. NARA sent a memo to

Federal agency records officers and

information management officials on

March 13 (NWM 06–98) inviting

comments on the paper.

Announcements were sent to the

Archives Listserv and Records

Management Listserv, and messages

were sent by e-mail or fax to individuals

interested in electronic records issues

and to professional organizations,

including the American Historical

Association (AHA), Organization of

American Historians (OAH), Society of

American Archivists (SAA), National

Association of Government Archivists

and Records Administrators (NAGARA),

Association of Records Managers and

Administrators International (ARMA),

and the National Coordinating

Committee for the Promotion of History.

Comments were requested by March 31.

Public comments were received from

eight individuals and the Small Agency

Council Records Officers Committee.

None suggested additional approaches

although several commented on aspects

of the entire GRS and on GRS 20

coverage. Option 1 was generally

preferred.

Most of the Work Group’s consultants

submitted comments on all of the

options and issues. No other short term

options were identified. Several

comments offered other approaches to

appraising records (a systems or macro

approach, the Canadian model, the

Pittsburgh Project ‘‘warrant’’ concept).

Given the time frame that the Work

Group had to develop its

recommendations, these approaches

were not pursued; however, they

deserve further review later. The

consultants found options 2 and 3

problematic.

Copies of all of the comments

received were circulated to the Federal

members of the Work Group and to the

consultants prior to an all-day public

meeting on April 7 at the Office of Thrift

Supervision Amphitheater in

Washington, DC. All but two Work

Group members attended the meeting,

as did five of the 8 consultants. The

meeting was called specifically to

receive comments from the ERWG’s

consultants on the March 12, 1998,

Options Paper, but the meeting was

opened to the public and approximately

ten persons observed all or part of the

meeting. Most of the consultant

comments and discussion focused on

Option 1, and they agreed that options

2 and 3 lacked merit. No additional

options were identified.

The Work Group met in a working

session on April 17 to evaluate further

the written comments and discussions

at the April 7 meeting and to make

assignments for developing products to

implement Option 1. Several

consultants were asked to contribute to

those products and other consultant and

agency/public comments were

incorporated in the approaches where

feasible. A fourth public meeting was

held on May 18, 1998, at the National

Archives Building in Washington, DC,

to brief Federal agencies and the public

on Work Group’s progress and to obtain

public comments and questions. In

addition to the Federal Register notice

and memo to records officers and IRM

officials announcing the meeting,

invitations were sent to the Chief

Information Officers (CIO) Council,

plaintiffs in the Public Citizen versus

Carlin litigation, and other organizations

and individuals. More than 200 people

attended the meeting and provided a

number of comments and questions.

As the Work Group discussed in the

May 18 public meeting, the report and

its appendixes were sent to Federal

agencies for comment in June and a

copy of the report, without the

appendixes, was posted on the GRS 20

Page at that time. The Federal members

of the Work Group met on July 13 to

discuss changes and clarifications

needed in the report and appendixes

that would be published in the Federal

Register for public and formal Federal

agency comment the week of July 20.

The Work Group and its consultants

will review the comments received and

prepare a final report and

implementation plan to the Archivist of

the United States in time for his review

and approval before September 30,

1998.

Recommendations of the Electronic

Records Work Group

The Electronic Records Work Group

recommends to the Archivist of the

United States that NARA take the

following actions to replace the 1995

General Records Schedule 20:

1. NARA should instruct agencies to

schedule their program and unique

administrative records in all formats.

On March 10, 1998, NARA issued

such instructions in NARA Bulletin 98–

02, Disposition of Electronic Records,

for new and revised series that are

submitted to NARA for approval. NARA

should issue instructions for scheduling

the electronic source records generated

with office automation systems that

were authorized for disposal under the

1995 GRS 20.

If the scheduling process to replace

the disposition authority formerly

provided by GRS 20 is to move ahead

expeditiously, it is essential that the

process must both minimize the burden

on Federal agencies as much as possible

and continue to provide the public an

opportunity to comment on the

proposed schedules through the usual

Federal Register process. In carrying out

the proposed scheduling process,

agencies must perform a series-based

review of their schedules, NARA must

appraise proposed dispositions on a

series basis, and the public must have

the opportunity to comment on

proposed dispositions on a series basis.

However, the Work Group does not

believe that it is necessary, at this time,

for agencies to submit individual

schedule items for these electronic

source records series by series. As

agency records schedules are revised or

amended, the disposition authorities for

these electronic source records will be

integrated into the agency disposition

manual at the series level.

The Work Group has developed

Appendix C to facilitate implementation

of this recommendation. Appendix C

proposes guidance to agencies on how

to develop records disposition

schedules to replace the dispositions

formerly provided by GRS 20 and

outlines in a general manner how those

proposed schedules will be processed

by NARA.

2. NARA should modify General

Records Schedules (GRS) 1–16, 18, and

23 to authorize the deletion of source

records corresponding to the

administrative records covered by those

GRS that are not needed for

recordkeeping purposes, after a

recordkeeping copy has been produced.
39206 Federal Register / Vol. 63, No. 139 /Tuesday, July 21, 1998 / Notices

Proposed language and a discussion

of the recommendation is provided in

Appendix D, along with definitions of

‘‘program records’’ and ‘‘administrative

records.’’ The definitions should be

added to the general records

management definitions in NARA

regulations at 36 CFR 1220.14, and

where appropriate in other NARA

records management guidance.

3. NARA should revise GRS 20

disposition authorities to cover only

systems administration (or systems

management) and operations records,

such as files related to system use and

maintenance; backup tapes; and other

records (e.g., system user access

records) used in managing information

systems throughout their life cycle. The

new schedule should cover only

administrative records, but should

cover them in all media.

A proposed draft general records

schedule is provided in Appendix E.

This draft has been modeled after the

New York State Archives and Records

Administration (SARA) General

Administrative Schedule’s section on

Electronic Data Processing, but adapted

to reflect the mandatory nature of the

General Records Schedules. (The New

York General Administrative Schedule

is advisory and provides minimum

retention periods.) The New York SARA

approach was developed with the

assistance of the State government data

processing community. The Work

Group emphasizes that this draft revised

general records schedule will need to be

reviewed carefully by Federal agency

CIO’s and their information technology

(IT) organizations to ensure that it

accurately describes Federal IT records

and includes only temporary

administrative records that can be

scheduled by a common disposition

authority in a GRS.

Rejected Options

In early deliberations, the Electronic

Records Work Group considered two

other options for maintaining electronic

source records used to generate some or

all program records.

Those options, numbers 2 and 3 in the

Preliminary Options Paper dated March

12, 1998, were:

• Establish a uniform minimum

retention period for electronic records

currently covered by GRS 20, items 13

and 14

• Develop retention standards for

electronic records currently covered by

GRS 20, items 13 and 14, based on an

individual’s position in agency

hierarchy

These options were proposed as

possible approaches for maintaining

electronic source records of all or some

of the most important agency program

records created or maintained on e-mail

and word processing systems. In

discussing these two options, Work

Group members came to the conclusion

that they were significantly flawed. Both

options failed to meet requirements for

the proper maintenance of records.

Neither provided for proper

organization or categorization of records

to facilitate access. In both cases,

disposition appeared to be based on

factors other than business needs.

(Business needs refers to an agency’s

need to conduct its business, maintain

a record of its essential activities and

decisions for its own use, support

oversight and audit of those activities,

and permit appropriate public access.)

The Work Group could not identify

supplemental measures that could be

taken in conjunction with either of these

options to make them useful.

A significant concern with both

approaches was that they might be

viewed by agencies and the public as a

satisfactory interim way to manage

records electronically until the agencies

have fully functioning electronic

recordkeeping systems. Such electronic

collections of mail and word processing

records are incomplete, without proper

recordkeeping organization, and

unindexed. Moreover, they lack the

context of the related documentation

filed in the recordkeeping system.

Access to such collections is limited to

full text search, which has the dual

drawbacks of finding many irrelevant

documents and missing key documents

that may not contain the word(s) used

in the query.

An additional concern with option 2

was that some agencies may believe that

this option could be implemented by

retaining backup tapes for a minimum

period of time. As stated in NARA

regulations (36 CFR 1234.24(c)) and

guidance (the 1995 Agency

Recordkeeping Requirements: A

Management Guide), backup tapes

should not be used for recordkeeping

purposes for a variety of reasons. One

compelling reason is that records on

backup tapes are not readily accessible

to agency staff members. While

necessary for disaster recovery, backup

tapes are not useful for day-to-day

agency operations.

The proposed option 3, to retain

electronic source records generated with

mail and word processing systems based

on organizational position, was a

variation of rejected option 2 and

seemed to be based on archaic archival

and records management theory. Work

Group members and other NARA staff

believe that setting retention periods

based on hierarchical placement would

not produce useful results. At one time,

appraisal theory assumed that records of

high level officials were generally more

valuable than records in lower level

offices, as significant program decisions

are reached at the higher levels. Over

many years, NARA has found that in

many agencies much of the

documentation of policy development

and justification is maintained at lowerlevel program offices of an agency.

Currently, appraisal of Federal records

is conducted by assessing the

documentation patterns in agencies and

identifying the most valuable records

based on function and recordkeeping

practices, as well as content.

Finally, Work Group members

recommended against these options

because implementation of either would

drain records and information

management resources from more

productive efforts to control agency

records properly, including long-term

plans to move toward electronic

recordkeeping.

In conclusion, the Electronic Records

Work Group, after careful deliberation,

rejected options 2 and 3 in the

Preliminary Options Paper dated March

12, 1998, as unworthy to be included in

the recommendations to the Archivist.

Future Steps

This report of the Electronic Records

Work Group addresses the

recordkeeping practices of most

agencies, which are still primarily

paper-based. However, business needs

and technology advances will lead

agencies to electronic recordkeeping

over time. The many Federal initiatives

for electronic commerce and the

reliance on computer technology to

create the records that document

government business are examples of

the forces moving most agencies in this

direction. NARA must provide guidance

to agencies on sound policies and

techniques for managing electronic

records and for implementing electronic

recordkeeping systems.

The Work Group recommends that the

Archivist establish a follow-on group to

look at the electronic recordkeeping

issue and to make recommendations in

that area. The follow-on group should

begin as soon as possible and build on

the work done by this Work Group. The

Work Group suggests that the Archivist

should set a relatively short time frame

for submitting these electronic

recordkeeping recommendations.
Federal Register / Vol. 63, No. 139 /Tuesday, July 21, 1998 / Notices 39207

Appendix A: Electronic Records Work

Group Membership

Members—National Archives And Records

Administration

Lewis J. Bellardo, Deputy Archivist of the

United States

Michael L. Miller, Director, Modern Records

Programs

Nancy Allard, Policy and Communications

Staff

Mark Giguere, Modern Records Programs

Jean Keeting, Modern Records Programs

Miriam Nisbet, Special Counsel for

Information Policy

Susan Sallaway, Information Resources

Policy and Projects Division

Kenneth Thibodeau, Director, Electronic

Records Programs

Members—Other Federal Agencies

Edward Barrese, Records Officer, Federal

Deposit Insurance Corporation

Maya Bernstein, Office of Information and

Regulatory Affairs, Office of Management

and Budget

Elizabeth Behal, Departmental Records

Officer, U. S. Department of Agriculture

Christopher L. Olsen, Chief, Records

Classification and Management, Records

Classification and Management Group,

Office of Information Management, Central

Intelligence Agency

Dan Hocking, Computer Scientist, Army

Research Laboratory

Eleanor Melamed, Department of Energy

Alan Proctor, CIO Council Liaison,

Department of the Treasury

Catherine Teti, Director for Records

Management and Information Policy,

Office of Thrift Supervision

Non-Federal Expert Consultants

Rick Barry, Barry Associates

Luciana Duranti, University of British

Columbia

Bruce Evans, Nuclear Information and

Records Management Association (NIRMA)

Margaret L. Hedstrom, University of

Michigan

James Henderson, State Archivist, Maine

Alan Kowlowitz, New York State Archives

and Records Administration

John McDonald, National Archives of Canada

Charles Robb, Kentucky Department for

Library and Archives

Robert Williams, Cohasset Associates

Appendix B [Reserved]

Appendix C—Proposal for Developing

Agency Records Schedules That

Include Office Automation Records

Note: See the second document published

in this Part V of the Federal Register.

Appendix D—Proposal To Revise the

Entire GRS TO Cover All Formats of the

Administrative Records Included

Therein

Note: See the third document published in

this Part V of the Federal Register.

Appendix E—Proposed General

Records Sechedule, Information

Technology Records

Note: See the fourth document published

in this Part V of the Federal Register.

[FR Doc. 98–19469 Filed 7–20–98; 8:45 am]

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