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SMITHSONIAN DIRECTIVE 600,

May 12, 2022

COLLECTIONS MANAGEMENT

1. Purpose 2

2. Background 2

3. Applicability 3

4. Authority and Responsibilities 3

5. Ethics 6

6. Financial Accounting for Collections 7

7. Acquisition and Accessioning 7

8. Deaccessioning and Disposal 10

9. Preservation 13

10. Collections Information 14

11. Inventory 16

12. Risk Management, Safety, and Security 16

13. Access 18

14. Loans 19

15. Intellectual Property Rights 21

16. Specific Legal and Ethical Issues 22

17. Smithsonian Collecting Unit Requirements 27

18. Exceptions 34

Appendix A: Smithsonian Collecting Units

Appendix B: Related Directives and References

Appendix C: Definitions
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Smithsonian Directive (SD) 600, Collections Management, is the principal policy document 

guiding Smithsonian collections management. As the Smithsonian’s collections management 

policy, SD 600 guides collections stewardship to ensure proper management, preservation, and 

use of the Institution’s collections and items in its care and custody.

This directive covers all aspects of collections management, including acquisition and 

accessioning, deaccessioning and disposal, preservation, documentation, life-cycle 

management, inventory, risk management, safety and security, access, storage, loans, and 

intellectual property management. This directive also addresses specific legal and ethical issues 

that pertain to collections, including shared stewardship and ethical returns, Native American 

and Native Hawaiian human remains and objects, cultural property, biological material, and 

objects unlawfully appropriated during the Nazi era.

SD 600 establishes and implements policies consistent with the Smithsonian Collections 

Management Guidelines approved by the Board of Regents and issued by the Secretary in 

May of 1999.

Additional policy and procedural guidance implementing the provisions of this directive is 

available on the National Collections Program SharePoint site.

The stewardship of collections is fundamental to the Smithsonian’s mission to increase and 

diffuse knowledge. Smithsonian collections are a national and global resource accessed each 

year by millions of visitors and researchers who use traditional methods and digital platforms 

to explore every subject, from aeronautics to zoology. Through its collections, the Smithsonian 

expands knowledge through high-impact research, documents our national identity, values, 

and cultural diversity, and increases public understanding of the world, its history, and our 

shared future.

Assembled throughout the Institution’s history, the national collections are fundamental to the 

Smithsonian’s mission, strategic priorities, and programmatic goals and serve as the 

intellectual base for scholarship, discovery, exhibition, and education. Smithsonian collections 

have a unique and vital role in documenting and addressing challenges facing society, such as 

the effects of climate change, structural racism, global pandemics, and the loss of biological 

and cultural diversity and its impact on global ecosystems and cultures.

Smithsonian collections represent a diverse range of materials and disciplines, including works 

of art, historical artifacts, natural and physical science specimens, living animals and plants, 

images, archives, libraries, audio and visual media, and born-digital material. Together, these 

collections preserve the past, increase our understanding of society and the natural world, and 

support the research that expands human knowledge in the arts, humanities, and sciences.

To properly manage collections, the Institution must deliberately develop, acquire, document,

1. PURPOSE

2. BACKGROUND
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steward, preserve, use, and refine its collections. The Smithsonian carries out its collections 

stewardship responsibilities through systematic collections management policies, procedures, 

and plans based on professional and discipline-specific best practices to ensure strict 

adherence to legal, ethical, and professional standards related to the Smithsonian’s diverse 

collections management activities. Smithsonian collecting units share responsibility for the 

stewardship of the national collections, with each unit maintaining collections unique to its 

purpose, character, and role in achieving the Smithsonian’s mission.

As stewards of the national collections, held in trust for the public, the Smithsonian has a 

unique responsibility to properly manage, preserve, and make accessible the collections in its 

care for current and future generations to appreciate, enjoy, and study. Through SD 600 and 

the collections management policies of individual collecting units, the Smithsonian affirms its 

commitment to communities represented in our collections and a shared future regarding 

knowledge-sharing, collaborative engagement, and ongoing stewardship.

This directive applies to all Smithsonian units authorized to acquire and manage collections 

(hereafter, “collecting units”). To formally be designated as an authorized collecting unit, the 

unit must obtain the recommendation of the National Collections Program (NCP), the Under 

Secretary for Museums and Culture, the Under Secretary for Science and Research, the 

Deputy Secretary and Chief Operating Officer, and the approval of the Secretary.

All Smithsonian collecting units must adhere to the policies set forth in this directive. Newly 

designated collecting units are subject to the SD 600 New Collecting Unit Guidance and 

the principles of this directive to guide their collections-related activities until a unit 

collections management policy is developed and approved.

The acquisition and possession of collections impose legal, ethical, and professional 

obligations to provide proper management, preservation, and use of the collections and their 

associated information. Smithsonian collections management responsibilities are delegated as 

follows.

4.1. Board of Regents

The Act of August 10, 1846, codified at 20 United States Code (U.S.C.) §§ 41, et seq., 

established the Smithsonian and vested authority for conducting the business of the Institution 

in the Smithsonian Board of Regents. The Board of Regents retains ultimate oversight 

authority and responsibility for Smithsonian collections while delegating to the Secretary 

overall collections management authority.

4.2. Secretary

The Secretary is responsible for overseeing the establishment of appropriate policies and 

programs, through which the Smithsonian ensures compliance with applicable laws,

3. APPLICABILITY

4. AUTHORITY AND RESPONSIBILITIES
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regulations, and professional standards concerning collections. The Secretary delegates to the 

Deputy Secretary and Chief Operating Officer, collecting unit directors, and other appropriate 

staff, the responsibility to implement established policies and carry out the direct, day-to-day 

management and care of Smithsonian collections.

The Secretary requires compliance with this directive by directing that development and 

implementation of collections-specific policies and plans be incorporated into the performance 

plans of the collecting unit directors, and that the Deputy Secretary and Chief Operating 

Officer and the Under Secretaries regularly review unit compliance with their policies and 

plans.

4.3. Deputy Secretary and Chief Operating Officer

The Deputy Secretary and Chief Operating Officer (hereafter, “Deputy Secretary”) supervises 

the Under Secretaries for Administration, Education, Museums and Culture, and Science and 

Research. In this capacity, the Deputy Secretary is responsible for supporting and holding 

accountable the Under Secretaries and their Smithsonian collecting units, research centers, 

and educational organizations’ implementation of their major strategic initiatives and 

programmatic goals.

4.4. Under Secretaries

The Under Secretaries for Administration, Education, Museums and Culture, and Science and 

Research share responsibility for ensuring Smithsonian collections are managed in 

compliance with this directive by providing central oversight to collecting unit directors.

While each Under Secretary is responsible for overseeing specific collecting units, the Under 

Secretary for Museums and Culture and the Under Secretary for Science and Research 

oversee the vast majority of collecting units and have the most direct responsibility for 

supervising collections management activities.

4.5. Director, National Collections Program

The NCP director provides central leadership, policy oversight, strategic planning, and support 

for Institution-wide collections initiatives.

The NCP director exercises these responsibilities by:

• serving as a principal advisor to Smithsonian senior leadership and collecting unit 

directors and staff on matters related to collections management policies, standards, 

and best practices;

• communicating, administering, and implementing this directive, and the issuance of 

additional guidance, as necessary, to implement the provisions of this directive and the 

review and revision of existing policy guidance;

• advising the Under Secretaries on the implementation of this directive, including the 

compilation of an annual report;
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• coordinating the development, review, revision, and approval and monitoring of unit 

collections management policies and collections stewardship plans to ensure that 

Smithsonian collections are maintained according to Smithsonian policy, legal 

obligations, and professional standards; and

• working with senior management and collecting unit directors to develop

long-term strategies and priorities to address Institution-wide collections needs, 

including collections care and space, and the allocation of central collections care 

resources.

4.6. Collecting Unit Directors

Each collecting unit director is responsible for:

• providing unit policy guidance, program direction and planning, and budgetary support 

to carry out the requirements established by this directive;

• establishing, approving, and implementing an up-to-date unit collections management 

policy;

• establishing, approving, and implementing an up-to-date unit collections stewardship 

plan to establish an intellectual framework and implementation strategy for collections 

development, acquisition, refinement, and resource allocation decisions;

• approving unit inventory plans and ensuring plans are appropriate to the nature, 

characteristic, and size of the unit’s collections, staff resources, and any unit-specific 

requirements, and receiving reports on the results of inventories;

• approving and implementing an up-to-date unit digitization plan in accordance with SD

610, Digitization and Digital Asset Management Policy;

• ensuring unit strategic plans include collections-specific elements;

• delegating authority and assigning collections responsibilities to appropriate unit staff;

• implementing and monitoring the unit’s collections management policy, procedures, 

goals, and reporting on collections-related information, such as the Collections and 

Digitization Reporting System (CDRS) and the Collections Space System (CSS);

• allocating resources for and aligning training of unit collections staff with the 

requirements of unit strategic plans, professional standards, job descriptions, delegated 

authority, and assigned responsibilities; and

• ensuring unit compliance with this directive and unit collections management policy, 

including the submission of an annual report.

4.7 Collecting Unit Advisory Boards or Commissions

A collecting unit may have an advisory board or commission, created by the Board of 

Regents, pursuant to federal law, or by agreement, to provide advice and assistance to 

the Board of Regents, the Secretary, and collecting unit directors.
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The role of advisory boards or commissions with respect to collections shall be specified in 

bylaws approved by the Board of Regents or the applicable approval authority.

By statute or legal agreement, the boards of the Archives of American Art, the Hirshhorn 

Museum and Sculpture Garden, the National Museum of the American Indian, and the 

National Museum of African American History and Culture have authority for specified 

collections management decisions. This authority shall be carried out in accordance with the 

general policies of the Board of Regents and applicable directives established by the 

Secretary, including this directive.

4.8 Collecting Unit Staff

Collecting unit staff are responsible for carrying out assigned collections management 

responsibilities to ensure:

• implementation of this directive and unit collections management policies, procedures, 

and plans;

• adherence to applicable laws and professional ethics and practices;

• proper acquisition, management, preservation, and responsible use of collections 

throughout their life cycle; and

• the integrity of collections information.

4.9 Smithsonian Collections Advisory Committee

The Smithsonian Collections Advisory Committee (SCAC), chaired by the NCP director and 

composed of representatives from across the Institution, assists the NCP, senior leadership, 

and collecting unit directors in implementing this directive by advising on policies, priorities, 

initiatives, and funding strategies for collections management.

4.10 Other Central Offices and Directives

Other central offices providing collections management functions include the OGC the Office 

of Finance and Accounting (OF&A) Risk Management Branch, the Office of the Chief 

Information Officer (OCIO) and the Digitization Program Office (DPO), the Office of 

Contracting and Personal Property Management (OCon&PPM), the Office of Protection 

Services (OPS), Smithsonian Facilities (SF), the Office of Safety, Health, and Environmental 

Management (OSHEM), and the Office of Emergency Management (OEM).

Additional program-level guidance may be provided by other Smithsonian directives on 

matters related to collections management and the specific function and purpose of the other 

directive (see Appendix B: Related Directives and References).

The Smithsonian recognizes and accepts its responsibility to provide proper management, 

resources, preservation, access, and use of the collections and associated information it holds 

for the benefit of the public.

5. ETHICS
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Smithsonian staff have legal, ethical, and professional obligations to discharge their official 

duties with honesty, integrity, and loyalty to the Institution, as set forth in the Smithsonian

Institution Statement of Values and Ethics and SD 103, Standards of Conduct. Smithsonian 

staff are expected to be aware of the standards of conduct issued by professional associations 

relevant to their disciplines and general responsibilities.

Smithsonian collections are held for public exhibition, education, and research in furtherance 

of public service rather than financial gain. Collections are protected, kept unencumbered, 

cared for, and preserved, and they are subject to the requirement that proceeds from sales of 

collections are to be used for the acquisition of additional collection items or the direct care of 

existing collections. Accordingly, the Smithsonian does not treat its collections as assets for 

purposes of reporting in its financial statements. The Smithsonian adheres to the applicable 

financial reporting standards governing collections held in public trust.

The NCP is responsible for submitting to the OF&A the information required for disclosure on 

the Smithsonian’s financial statement.

Acquisition is the act of gaining legal title to a collection item or group of items.

Accessioning is the formal process used to legally acquire and record a collection item or 

group of items into a collection.

The acquisition of collections is fundamental to ensuring the continual development and 

refinement of collections in support of the mission and programmatic goals of the Smithsonian. 

The acquisition of collections imposes legal and ethical obligations on the Smithsonian and its 

collecting units to provide proper planning, management, documentation, preservation, 

storage, and use of collections and their associated information. The Smithsonian observes 

the highest legal, ethical, and professional standards in the acquisition and care of collections. 

Acquisition and accessioning procedures are designed to ensure thoughtful, well-documented 

consideration of such decisions based on responsible stewardship planning and the long-term 

interests of the Smithsonian, the public, and the collection item.

Accessioned collections are subject to a high standard of care and comprise items the 

Smithsonian intends to keep, preserve, protect, steward, and document for an indefinite period 

for public exhibition, education, research, and/or other mission-enabling activities. Some 

collection items may be acquired and designated for non-accessioned status for exhibit, 

education, research, or consumptive use.

Non-accessioned collections still require the same acquisition documentation as accessioned 

collections for accountability and use.

6. FINANCIAL ACCOUNTING FOR COLLECTIONS

7. ACQUISITION AND ACCESSIONING
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7.1. Policy

The Smithsonian adheres to the following policies regarding the acquisition and accessioning 

of collections:

1) The Smithsonian may only acquire collections in accordance with established 

authority and only when consistent with established acquisition criteria, applicable 

law, and professional and Institutional ethics. All applicable federal, state, local, and 

international laws, treaties, regulations, and conventions will be observed and 

compliance documented.

2) The Smithsonian observes the highest legal, ethical, and professional standards in 

the acquisition and care of collections. The Smithsonian shall exercise due diligence 

in the acquisition and care of collections, including making reasonable inquiries into 

provenance to determine that the Smithsonian can acquire a valid title to the item(s) 

and that the acquisition will conform to all legal and ethical standards, including the 

Smithsonian Institution Policy on the Acquisition of Art, Antiquities, Archaeological

and Ethnographic Material, and Historic Objects.

3) The Smithsonian must gain legal title, or its equivalent, to all items acquired and 

recorded as accessioned or non-accessioned collections. The only exceptions to this 

policy are for (i) certain transfers of federal scientific collections, formally titled in the 

United States, for which the Smithsonian retains permanent custodial responsibility, 

and (ii) certain transfers of biological material from foreign countries, formally titled in 

the foreign country, for which the Smithsonian retains permanent custodial 

responsibility.

4) As a general rule, collections are acquired and accessioned only when there is a 

good-faith intention to retain them for an indefinite period of time. Certain types of 

collections, such as those acquired for consumptive use, fall outside of this rule.

5) If collections are acquired with a specific intent at the time of acquisition not to add 

them to the collections but rather to sell, exchange, or use them for financial gain, the 

NCP and OGC must be notified in advance.

6) As a general rule, the Smithsonian only acquires unrestricted collections. Common 

restrictions, such as retention by the donor of intellectual property rights, may be 

accepted following appropriate review and approval. Restrictions that would 

substantially limit the Smithsonian’s ability to use or dispose of an acquisition may be 

accepted only after consultation with the NCP and OGC. Under no circumstances, 

however, may the Smithsonian agree to conditions requiring the retention or display 

of a collection item in perpetuity.

7) The Smithsonian may acquire collection items by a variety of methods, including gifts, 

bequests, purchases, exchanges, transfers, field collecting, and, in certain instances, 

through propagation or birth.
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8) The Smithsonian provides responsible collections management through disciplined 

acquisition and accessioning procedures consistent with established Institutional 

standards of long-term stewardship, preservation, care, and use.

9) Potential acquisitions must undergo a rigorous evaluation process based on the 

following criteria:

• consistency with the mission, strategic plan, and programmatic goals of the 

Smithsonian;

• quality, physical condition, intellectual value, and significance;

• documentation of legal title, provenance, and any restrictions on use;

• size, volume, or quantity;

• ability and resources to provide appropriate management, care, and 

accessibility, including documentation, conservation, long-term preservation, 

digitization, and storage; and

• potential for exhibition, education, and research use.

10) Deeds of gift, gift agreements, bequest documents, and other documents evidencing 

a gift to the Smithsonian should be signed by the donor or, in the case of a bequest, 

their executor or personal representative, and by the appropriate collecting unit 

director or the director’s designee, or another authorized Smithsonian official. The 

OGC must review and approve all standard deeds of gift or gift agreements and any 

substantial alterations to these standard forms. Collecting units must also obtain the 

review and approval of the OGC for any bequest documents requiring signatures.

11) When acquiring collections by gift, the Smithsonian shall provide written 

acknowledgment of the gift with a letter to the donor within 30 days following the 

completion of the gift. The letter must acknowledge receipt of the donation, state 

whether or not any goods or services were provided to the donor in return for the gift, 

and include appropriate tax disclosures. The OGC has established standardized 

acknowledgments and may be consulted regarding tax requirements.

12) The Smithsonian may only acquire collections after considering the obligations of 

long-term stewardship to determine that it can reasonably anticipate the ability to 

meet such responsibilities with existing and projected resources over the life cycle of 

the collection. The appropriate Under Secretary or Under Secretaries, following 

consultation with the NCP, must approve the acquisition of any collection item that 

would require substantial resources beyond a collecting unit’s allocated budget or 

substantial resources of other Smithsonian units for the management or preservation 

of the collection.

13) When determining whether to acquire collections, the Smithsonian will consider 

sharing existing, renovated, or new collections storage spaces based on space, type, 

and environmental needs.
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14) While overlap in collecting among Smithsonian collecting units is inevitable, 

competition for a particular acquisition is inappropriate. When more than one 

collecting unit seeks to acquire the same collection item, the respective unit directors 

must agree on which unit will acquire the collection item or consider pursuing a joint 

acquisition/ownership agreement. In those rare cases when the placement of a 

collection item cannot be resolved by the directors, the Deputy Secretary will decide 

after consultation with the NCP and the appropriate Under Secretary or Under 

Secretaries.

15) On occasion, collecting units may jointly acquire collections with other museums, 

educational organizations, or other Smithsonian collecting units with which they agree 

to share ownership and management. In such circumstances, a written agreement 

that stipulates the terms and conditions of the joint acquisition/ownership

arrangement and the responsibilities of each party must be formalized and approved 

before final acceptance. The NCP and OGC must be consulted in advance of such 

cases, and in certain circumstances the collecting unit(s) must obtain approval from 

the appropriate Under Secretary or Under Secretaries, who may consult with the 

Deputy Secretary as appropriate.

16) The Smithsonian will avoid competitive bidding with federal organizations for 

collection items of common interest and will seek mutually acceptable agreements 

whenever the potential for competitive bidding with such organizations becomes 

apparent.

Deaccessioning is the process used to formally approve and record the removal of a 

collection item or group of items from an accessioned collection.

Disposal is the act of physically removing a collection item or group of items from a collection.

Deaccessioning and disposal are legitimate components of responsible collections 

management. The periodic review, evaluation, deaccessioning, and disposal of existing 

collections is intended to refine and improve the quality and relevance of collections with 

respect to the Smithsonian mission. The Smithsonian acquires collections only when there is a 

good-faith intention to retain them for an indefinite period of time. Collections are retained as 

long as they can be properly maintained and used and align with the collections stewardship 

objectives of the Institution.

The acquisition and possession of collections impose legal and ethical obligations founded on 

public trust. For this reason, decisions concerning the deaccessioning and disposal of 

collections require careful planning and analysis, an appropriate justification, and due 

diligence. Deaccessioning and disposal procedures are designed to ensure thoughtful, welldocumented consideration of such decisions in the context of the long-term interest of the 

Smithsonian, the public, and the collection item.

8. DEACCESSIONING AND DISPOSAL
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8.1. Policy

The Smithsonian adheres to the following policies regarding deaccessioning and disposal of 

collections:

1) The Smithsonian may deaccession and dispose of collections only when consistent 

with deaccessioning and disposal criteria and approvals, applicable law and 

professional and Institutional ethics, and any other applicable restrictions. All 

applicable federal, state, local, and international laws, treaties, regulations, and 

conventions will be observed and compliance documented.

2) Deaccessioning and disposal may occur for a variety of reasons, including:

• Lack of capacity to provide proper stewardship;

• Deterioration of collection items beyond repair or usefulness;

• Duplication or redundancy of collection material;

• Insufficient relationship between an item(s) and the mission, programmatic 

goals, or collections stewardship plan of the collecting unit, such that the item 

would be better placed elsewhere;

• Ethical returns;

• Repatriation;

• Collection items containing hazardous materials which present threats to other 

items or create significant health and safety risks to staff or the public;

• Selection for educational or consumptive use; and

• Reconciliation of collections accessioned in error.

3) The Smithsonian may dispose of collections by a variety of methods, including 

donation, transfer, exchange, sale, repatriation, return, educational or consumptive 

use, destruction, destructive analysis, and, in certain instances, disposal by 

euthanasia or death.

4) Disposals resulting in a transfer of ownership to a third party must be documented in 

a written agreement approved by the OGC.

5) Disposals of deaccessioned collection items to foreign entities must comply with SD

611, Export Compliance and Trade Sanctions Related to Research, Export and

Museum Activities.

6) If the estimated value of a single collection item or a group of collection items 

considered for disposal is:

• More than $10,000 — requires a written, independent appraisal or informed 

estimate of fair market value.
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• More than $100,000 — requires two written, independent appraisals or 

informed estimates of fair market value and approvals from the NCP, OGC, the 

appropriate Under Secretary, and the Secretary.

• More than $500,000 — requires two written, independent appraisals or 

informed estimates of fair market value and approvals from the NCP, OGC, the 

appropriate Under Secretary, the Secretary, and the Board of Regents.

7) Documentation of proposed deaccessions may refer to any of the following valuation 

sources: written, independent appraisals; sales histories of the collection items or 

comparable items; or other standard valuation sources, including informed estimates 

by staff.

8) The deaccession and disposal of collection items that, notwithstanding their monetary 

value, have significant research or historical value, or when the deaccession might 

create significant public interest, must be approved by the NCP, OGC, and the 

appropriate Under Secretary, who may consult with the Deputy Secretary and seek 

higher levels of authorization as appropriate.

9) The disposal of non-accessioned collections does not require the same appraisal and 

approval processes as deaccessioning accessioned collections. Nevertheless, the 

disposal of non-accessioned collections should be conducted thoughtfully and 

consistent with the nature and importance of the items. The disposal of certain

non-accessioned collections may warrant the same appraisal and approval 

procedures as accessioned collections. Collecting units shall consult with the NCP 

and OGC when considering the disposal of significant non-accessioned collections.

10) Significant collection items manufactured by or for government entities, having no 

commercial or secondary markets, do not require appraisals of fair market value for 

deaccessioning and disposal. Deaccessioning and disposal of such collection items 

are subject to the following procedures:

• Transfer of a duplicate collection item to a U.S. Government agency requires 

consultation with the NCP and OGC.

• Transfer of a collection item to a Government agency or non-profit organization 

in the United States requires approvals from the NCP, OGC, and the 

appropriate Under Secretary, who may consult with the Deputy Secretary as 

appropriate.

• Transfer of a collection item to a Government agency or non-profit organization 

outside the United States requires approvals from the NCP, OGC, the 

appropriate Under Secretary, and the Deputy Secretary.

11) Smithsonian collecting units shall have a right of first refusal for collection items 

proposed for disposal, except as otherwise stipulated by authorizing legislation or 

other restrictions, or in the case of hazardous materials that present a health or safety 

risk. Such transfers are made without financial compensation, except when a 

collecting unit disposes of a collection item acquired through purchase. If required,
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compensation shall be based on the fair market value of the collection item at the 

time of disposal or the value negotiated by the involved collecting units.

12) Under no circumstances may the ownership of any collection item that has been 

removed from a collecting unit be transferred, either directly or indirectly, to any 

employee, volunteer, officer, trustee, or affiliated person of the collecting unit or of the 

Smithsonian Institution.

13) Any proceeds realized from the sale of collection items may be designated only for 

collections acquisitions or the direct care of existing collections. Direct care may 

include:

• Collections assessments and preservation surveys;

• The purchase of collections storage equipment, housing materials, and 

supplies;

• Conservation treatment and stabilization, and preservation of collections; or

• Collections reformatting, re-housing, processing, documentation, inventory, 

cataloguing, and digitization.

14) Proceeds realized from the sale of deaccessioned collection items may not be used 

for operating expenses. Collecting units should consult with the NCP and OGC 

regarding the appropriate use of proceeds for direct care.

15) Collecting units that are members of the Association of Art Museum Directors (AAMD) 

may limit the use of sale proceeds for the acquisition of collections only as stipulated 

by the AAMD’s policies on deaccessioning.

Preservation is the protection and stabilization of collections and their associated information 

through a coordinated set of activities aimed at minimizing chemical, physical, and biological 

deterioration and damage and preventing loss of intellectual, aesthetic, cultural significance, 

and monetary value.

Preservation, preventive care, and remedial conservation are integral components of 

collections management, ensuring collections are available for use. The ability of the 

Smithsonian to carry out its mission directly relates to its ability to preserve and safeguard 

collections, collections records, and other documentary materials for public benefit. Given the 

diverse nature and educational significance of Smithsonian collections, it is imperative to 

balance use and access with preservation needs.

9.1. Policy

The Smithsonian adheres to the following policies regarding the preservation of collections:

9. PRESERVATION
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1) The Smithsonian shall provide the appropriate preservation, care, protection, and 

security for all collections and their associated information acquired, borrowed, or in 

the custody of the Institution.

2) The Smithsonian will balance current exhibition, educational, and research, use with 

the preservation requirements of collection items to ensure collections are properly 

maintained and rightfully serve their intended purpose.

3) Preservation policies, plans, and standards shall be developed in accordance with the 

intended purpose and use of collections and based on the principles of preventive 

conservation to ensure protection from the agents of deterioration. The Smithsonian 

should consider the American Institute for Conservation (AIC) Code of Ethics and

Guidelines for Practice when developing preservation policies, standards, and 

procedures.

4) The Smithsonian is responsible for developing and implementing preservation 

strategies, policies, procedures, and plans for collections and collections information 

which respect the diverse nature and purpose of collections, including providing 

access.

5) The Smithsonian is committed to sustainability in the preservation and management 

of its collections, including the design, management, and maintenance of collections 

space and preservation environments in accordance with SD 422, Sustainable

Design of Smithsonian Facilities.

6) The Smithsonian aims to provide and actively manage optimized preservation 

environments based on a balance of scientific research, engineering capability, 

collections management protocols, and environmental impact. Collecting units, 

Smithsonian Facilities (SF), and the NCP shall support collaborative, evidence-based, 

decision making processes among the professional disciplines and stakeholders who 

share responsibility for establishing and implementing sustainable collections 

environments, as outlined in the Smithsonian Institution Declaration on the

Collections Preservation Environment.

7) Any conservation intervention, restoration, destructive sampling, or consumptive use 

of collection items must be authorized, documented, and justified for the purpose of 

preservation or professional scholarship.

Collections information is the incremental, cumulative documentation of the intellectual 

significance, physical characteristics, legal status, use, provenance, and history of collection 

items, and the collections management processes and transactions they undergo. Collections 

information can be in analog or digital form and include text and images.

The Smithsonian relies on the well-documented results of scientific, historical, and aesthetic 

research to fulfill its mission. The Smithsonian acquires, develops, and maintains collections

10. COLLECTIONS INFORMATION
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information systems that enhance access to and accountability for its collections and research 

findings to ensure the long-term preservation of the resulting information in analog and digital 

formats. The value of collections information rests in its quality, integrity, availability, and 

potential for use and public access.

10.1. Policy

The Smithsonian adheres to the following policies regarding collections information:

1) Collections information systems must support the mission and public access goals of 

the Smithsonian.

2) The systems of record for Smithsonian collections data include unit collections 

information systems (CIS) for information, the Smithsonian’s enterprise-wide Digital 

Asset Management System (DAMS) for digital media assets, and the Smithsonian’s 

enterprise-wide 3D repository for 3D data.

3) The Smithsonian is committed to placing collections information in publicly accessible 

digital platforms, implementing professional documentation practices and standards, 

and sharing collections information through collaborations among collecting units, 

other educational and research institutions, and the public. The Smithsonian 

maintains its digital assets to advance the Smithsonian’s mission, support its strategic 

and programmatic goals, and facilitate access.

4) The Smithsonian seeks to provide the widest dissemination of its digital assets 

consistent with the stewardship, management, and preservation responsibilities for its 

collections. Following SD 609, Digital Asset Access and Use, these obligations take 

into consideration a wide range of legal, ethical, and practical factors, and reflect the 

staff and financial resources to generate, maintain, and render digital assets publicly 

accessible.

5) In its commitment to increasing access to collections as broadly as possible, the 

Smithsonian launched the Open Access Initiative, dedicating eligible digital assets 

into the public domain with a Creative Commons Zero (CC0) license. Certain digital 

assets are not part of the Smithsonian’s Open Access Initiative because their use is 

restricted, and they carry a Usage Conditions Apply designation. Use of digital assets 

can be restricted for various reasons specified in SD 609. These reasons include, but 

are not limited to, copyright restrictions, restrictions imposed by donors, restrictions 

imposed by contracts, and restrictions due to the cultural sensitivity of the collection 

item.

6) The Smithsonian may restrict access to sensitive information involving privacy, 

collecting localities, security, storage location, value, intellectual property restrictions, 

and culturally sensitive content.

7) Business or financial records (e.g., vendor enrollment forms) containing personally 

identifiable information (PII) or sensitive PII (sPII) about individuals associated with a
SD 600 — 5/12/22

16

collection item (i.e., artists, donors, collectors, or researchers) are subject to SD 118,

Privacy Policy.

8) Collections information, including all records of collections-related decisions and 

activities, must comply with established Smithsonian and collecting unit standards 

and be maintained according to accepted professional practices.

9) The Smithsonian is responsible for the development, maintenance, preservation, and 

retention of collections information. All media containing collections information are 

maintained for long-term use and must be preserved according to current 

professional standards.

Inventory is an itemized listing of collection items, groups, or lots that identifies the current 

physical location of each item, group, or lot; the process of physically locating all or a selection 

of items for which the collecting unit is responsible; and appropriate information to facilitate 

research, collections management, security, and access.

Effective collections management requires an inventory system to support decisions regarding 

the management, use, growth, storage, intellectual control, value, condition, physical 

information, and security of collection items. Inventory records serve as a tool for 

accountability and are useful in supporting other Smithsonian programs when augmented with 

additional documented information.

11.1. Policy

The Smithsonian adheres to the following policies regarding the inventory of collections:

1) Inventories of collections are conducted in accordance with established authority, 

inventory processes, and a written inventory plan appropriate to the purpose, 

character, and size of the collections in the collecting unit’s care and staff resources.

2) Inventories of collections shall be conducted according to a predetermined schedule. 

Inventories may include a complete inventory, a specific percentage or sampling of 

the collection, or project-oriented inventories conducted during collections moves, rehousing, or digitization, using predetermined, statistically sound inventory methods.

3) Inventory control requires creating and maintaining reliable information about the 

identification, location, and presence of collection items. Inventory is a critical 

component of ongoing collections documentation.

Risk Management is the process of identifying and evaluating risk to prevent or minimize 

exposure to factors which may cause loss or damage to collections or injury or illness to staff 

and the public.

11. INVENTORY

12. RISK MANAGEMENT, SAFETY, AND SECURITY
SD 600 — 5/12/22

17

Safety encompasses occupational health and safety, industrial hygiene, and environmental 

management.

Security encompasses an entire range of activities concerned with the protection of life, 

facilities, and property, including collections, from direct or perceived threats.

The programmatic activities of the Smithsonian naturally expose collections to certain levels of 

risk of damage or loss during exhibition, loan, transit, storage, research, treatment, or handling. 

Collection items may also contain a wide range of chemical, biological, and physical hazards, 

whether inherent in the nature, composition, or construction of the item itself or as a result of 

preparation, treatment, alteration, or degradation.

Certain collections-related activities may expose staff and affiliated persons to residual 

hazardous materials associated with a collection item, storage equipment, or exhibit case 

materials. The Smithsonian has adopted an integrated risk management assessment program 

to mitigate exposure to a variety of risks by requiring the thoughtful review of potential 

hazards, including natural and human-made emergencies; climate change; vandalism and 

theft; disease; space and environmental deficiencies; human error; mechanical or operational 

system failures; deterioration; and collections-based hazards.

12.1. Policy

The Smithsonian adheres to the following policies regarding the risk management, safety, and 

security of collections:

1) The Smithsonian shall minimize and control the level of risk of damage or loss to 

collections and injury and illness to staff, affiliated persons, and visitors through 

established risk management practices.

2) The Smithsonian will provide hazard awareness and establish safe work practice 

information in accordance with SD 419, Smithsonian Institution Safety, Health, and

Environmental Program. OSHEM is responsible for the direction, planning, and 

technical supervision of occupational safety, health, and environmental protection at 

the Smithsonian.

3) All Smithsonian staff have an obligation to be aware of the Institution’s risk 

management, safety, and security directives.

4) Except in extraordinary circumstances, the Smithsonian has chosen not to insure its 

own collections while in Smithsonian-owned facilities, either in storage or on display, 

and in the care and possession of the Institution. However, during transit between 

Smithsonian units and facilities, insurance can be placed on collection items.

5) Collections on loan to the Smithsonian and Smithsonian collections on loan to or in 

the custody of others will be insured as stipulated by an authorized loan agreement or 

negotiated contract. The OF&A Risk Management Branch coordinates Smithsonian 

risk management and insurance in accordance with SD 108, Insurance and Risk

Management.
SD 600 — 5/12/22

18

6) Insurance proceeds from the settlement of claims for damage to Smithsonian 

collection items may be used only for the conservation and restoration of the affected 

collection item. Insurance proceeds received due to a total loss of a collection item or 

in excess of the cost of conservation and restoration of a damaged collection item 

shall be designated only for collections acquisition or the direct care of existing 

collections.

7) In accordance with SD 420, Security Operations and Policies and Collections Space

Security Standards, collecting unit directors, in collaboration with OPS, shall define 

the protection policy and goals for collections and ensure that such policies are 

implemented. Policies are based on risk assessments and consultations with unit staff 

and central offices such as the NCP and SF. The OPS is responsible for providing 

physical security and protection of personnel, visitors, collections, facilities, and 

property of the Smithsonian.

8) All Smithsonian facilities, owned or leased, must have a written, comprehensive 

emergency plan and procedures as required by SD 109, Smithsonian Emergency

Management Program. The OEM is responsible for the management and oversight of 

the Smithsonian Emergency Management Program.

9) The Preparedness and Response in Collections Emergencies (PRICE) team is 

responsible for providing Institution-wide training, policy, procedural, and logistical 

support in collections emergency preparedness, response, and recovery, promoting 

improved communication and collaboration across Smithsonian units.

Access is the opportunity for the public, scholars, and staff to explore and use the diverse 

collections and associated information resources of the Smithsonian.

The Smithsonian promotes access to its collections and associated information through 

research opportunities, traditional and digital exhibitions, educational programs and 

publications, reference systems, loans and exchanges of collections, and digital platforms.

13.1. Policy

The Smithsonian adheres to the following policies regarding access to collections:

1) The Smithsonian will provide access to its collections and associated information in a 

manner consistent with its stewardship, management, and preservation 

responsibilities. Physical and intellectual access to the collections must be balanced 

with preservation concerns.

2) The Smithsonian will control, monitor, and document physical access to and use of its 

collections.

3) The Smithsonian may be required to restrict access for various reasons, including 

resource limitations, security and safety, preservation constraints, object availability,

13. ACCESS
SD 600 — 5/12/22

19

concerns related to cultural sensitivity and privacy, and legal restrictions (such as 

copyright and restrictions imposed by contract). Collecting units should consult with 

the OGC regarding access requests involving restrictions such as privacy and 

intellectual property rights.

4) The Smithsonian generally provides access to Smithsonian information under SD

807, Requests for Smithsonian Institution Information, through the OGC. SD 807

applies to transactional documents related to collections, such as gift and purchase 

agreements, but it does not apply to requests for other kinds of collections 

information. For requests for collections information other than transactional 

documents, the collecting unit responsible for the maintenance of the requested 

information handles the request in accordance with the unit's collections management 

policy and in consultation with the OGC, as necessary.

5) Requests for information citing SD 807 or the Freedom of Information Act (FOIA) 

must be referred to the OGC.

6) The Smithsonian may charge fees to provide digital assets in response to access or 

use requests in accordance with SD 609.

A loan is the temporary transfer of possession of collection items for an agreed-upon purpose 

and on the condition that the collection items are returned at a specified time. Loans are not 

generated with the intent to result in a change of ownership.

Fundamental to the Smithsonian’s strategic plan and programmatic goals, the lending and 

borrowing of collection items between Smithsonian units and other cultural, educational, and 

scientific organizations for public exhibition, research, and education is an integral part of the 

Institution’s mission.

14.1. Policy

The Smithsonian adheres to the following policies regarding loans of collections:

1) All loans to or from the Smithsonian must adhere to applicable federal, state, local, 

and international laws, treaties, regulations, and conventions, including the 

Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and 

Ethnographic Material, and Historic Objects.

2) Smithsonian collection items may be lent or borrowed only in accordance with a 

written, authorized loan agreement and established authority, and only when 

consistent with applicable law and professional and Institutional ethics.

3) As a general rule, Smithsonian collections will only be lent for public exhibition, 

research, and other educational, scientific, or preservation purposes. Smithsonian 

collections may not be loaned for commercial purposes or private pecuniary gain.

14. LOANS
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20

4) The Smithsonian adheres to individual collecting unit guidelines for developing 

exhibitions and procedures for planning public programs, in accordance with

SD 603, Exhibition, Program Planning, Research, and Educational Content, and with 

the Guidelines for Exhibiting Borrowed Objects issued by the American Alliance of 

Museums (AAM).

5) All loans are for a specified period of time and may contain an option for renewal, if 

appropriate. The Smithsonian does not permit indefinite or permanent loans, whether 

as a lender or borrower.

6) Collections on loan to the Smithsonian and Smithsonian collections on loan to, or in 

the custody of others, will be insured as stipulated by an authorized loan agreement.

7) Requests from lenders for absolute liability — terms and conditions requiring the 

Smithsonian to agree to accept liability for damage or loss potentially in excess of 

insurance coverage — are subject to the following procedures:

• Requests concerning a loaned collection item(s) with an insurance value of

$10 million or less require approval from the appropriate Under Secretary and 

the Under Secretary for Administration, in consultation with the OGC and the 

OF&A Risk Management Branch.

• Requests concerning a loaned collection item(s) with an insurance value of 

more than $10 million require approval from the Deputy Secretary, who may 

consult with the Secretary as necessary.

8) In addition to actual expenses, the Smithsonian may charge loan fees to borrowing 

organizations in accordance with approved collecting unit policies.

9) The Smithsonian may lend collection items for display in the offices of high-ranking

U.S. Government officials, in accordance with the Loans to High-Ranking 

Government Officials Guidance.

10) The Smithsonian may lend collection items to for-profit entities in accordance with the

Loans to For-Profit Entities Guidance.

11) The applicable provisions of the Board of Regents Ethics Guidelines govern loans to 

the Smithsonian from members of the Board of Regents.

12) The applicable provisions of the Smithsonian Advisory Board Ethics Statement

govern loans to the Smithsonian from members of Smithsonian advisory boards.

13) Loans to foreign entities must comply with SD 611, Export Compliance and Trade

Sanctions Related to Research, Export and Museum Activities.

14) Regardless of the length or type of outgoing loans, the Smithsonian retains ownership 

and stewardship responsibility of its collections.

15) Smithsonian collecting units may accept items for temporary custody in accordance 

with unit collections management policies and under a temporary custody agreement.
SD 600 — 5/12/22

21

16) The internal lending of collections for exhibition and public display among collecting 

units is fundamental to cross-unit collaboration and increasing public access to 

Smithsonian collections. Collecting units will, to the extent possible, facilitate and 

subsequently expedite exhibition and public display loans to other Smithsonian units, 

including newly designated collecting units, in accordance with the Smithsonian Unitto-Unit Object Loan Guidelines.

Intellectual property rights are protections based on federal or state statutes or common law 

such as patent, trademark, copyright, privacy, and publicity.

Distinct from the right to possess a collection item, intellectual property rights arise from the 

content of a collection item. The Smithsonian’s ability to use and provide access to collections 

and their associated intellectual property may be subject to copyright, privacy, and publicity 

rights held by others, which may restrict access to or use of the material.

As both a holder and a user of intellectual property, the Smithsonian seeks to protect the 

intellectual integrity of collections and the rights of creators and owners of intellectual property, 

including the Institution itself as a rights holder, to promote the broadest possible access to 

collections for research and educational purposes.

15.1. Policy

The Smithsonian adheres to the following policies regarding intellectual property rights and 

collections:

1) Smithsonian collections may be subject to intellectual property rights that may be 

owned by the Smithsonian or others. The Smithsonian shall manage its collections 

and collections in its custody in a manner that avoids any infringement of intellectual 

property rights. The Smithsonian will protect the intellectual property rights of creators 

and intellectual property owners, including the Institution itself as a rights holder.

2) The Smithsonian may charge fees to outside organizations and individuals to use and 

reproduce images of collection items, in accordance with SD 609.

3) The Smithsonian may rely on the doctrine of fair use in making reproductions of 

collections for standard museum purposes, such as for archival, research, 

educational, exhibition, and other similar uses. Fair use assertions must be made on 

a case-by-case basis, taking into consideration the legal parameters of the fair use 

doctrine, and the OGC should be consulted as necessary concerning fair use 

determinations.

4) Smithsonian collections may be used consistent with the current Smithsonian Terms

of Use.

15. INTELLECTUAL PROPERTY RIGHTS
SD 600 — 5/12/22

22

Certain collections present specific issues because of applicable legal and ethical standards. 

Smithsonian collecting units that acquire, hold, or manage collections must take these legal 

and ethical issues into account, including incorporating appropriate standards into unit 

collections management policies. The following sections address six specific legal and ethical 

issues raised by Smithsonian collections that fall within the scope of the following.

Section 16.1 addresses shared stewardship and ethical returns of tangible and intangible 

cultural heritage collections; Section 16.2 addresses repatriation and other issues related to 

Native American and Native Hawaiian human remains and objects covered by the National 

Museum of the American Indian Act; Section 16.3 addresses provenance requirements for 

acquiring art, antiquities, archaeological and ethnographic material, and historic objects; 

Section 16.4 addresses requirements for borrowing, collecting, and managing biological 

material; and Section 16.5 addresses issues related to objects that have been or may have 

been unlawfully appropriated during the Nazi era.

16.1. Shared Stewardship and Ethical Returns

Over the course of its long history, the Smithsonian has acquired collections originating from 

national and international sources, from individuals, communities, and indigenous peoples, 

from non-profit, for-profit, and governmental entities, and through a variety of methods and 

circumstances. During this time, ethical norms and professional best practices related to 

collecting have changed, particularly with respect to collecting cultural heritage (tangible and 

intangible) from individuals and communities. As a result, the Smithsonian has collections that 

it would not have acquired under present-day ethical and professional standards.

Although the Smithsonian has legal title or custody of collections it holds in trust for the benefit 

of the public, continued retention or sole stewardship of such collections may cause harm to 

communities and be fundamentally inconsistent with the Smithsonian’s ethical standards and 

Institutional values. In these unique circumstances, shared stewardship or ethical return may 

be necessary to fulfill the Smithsonian’s custodial obligations.

The Smithsonian recognizes the value of community representation in Smithsonian 

collections, the benefit of preserving and making available to the public, with honor and 

respect, a diverse range of collections, stories, and histories, and the role of museums as 

collaborative custodians of cultural and historical legacies. The Smithsonian is committed to 

working transparently and in consultation with descendants, communities, and relevant 

governmental and regional stakeholders to consider matters of shared stewardship and the 

potential return of collections, based on ethical considerations. These circumstances, which 

may vary depending on the nature and scope of a unit’s collections, may include but are not 

limited to the manner in which a collection was originally acquired and the context of its 

acquisition. A review of the circumstances may demonstrate unethical acquisition through 

means such as coercion, duress, assertion of power, or forcible taking.

The Smithsonian adheres to the following policies regarding shared stewardship and ethical 

return of objects in its collections.

16. SPECIFIC LEGAL AND ETHICAL ISSUES
SD 600 — 5/12/22

23

1) Collecting units may enter into shared stewardship arrangements with communities 

represented in the unit’s collections in appropriate circumstances, based on ethical 

considerations. Collecting units must establish authority and evaluation criteria and 

assign responsibility to approve, document, and implement such arrangements within 

the unit’s collections management policy. Shared stewardship arrangements may 

include, but are not limited to, collaborative consultations for the respectful attribution, 

documentation, interpretation, display, care, storage, access, use, or disposition of 

collections. Shared stewardship arrangements must be documented in a written 

agreement approved by the appropriate Under Secretary in consultation with the 

OGC and NCP.

2) Collecting units may deaccession and return collections in appropriate circumstances, 

based on ethical considerations. Collecting units must establish authority and 

evaluation criteria and assign responsibility to approve, document, and process such 

deaccessions and returns, including transfer of associated collections information, 

within the unit’s collections management policy. Before collections may be 

deaccessioned and returned for ethical reasons, collecting units must consult with the 

appropriate Under Secretary, the NCP, and the OGC and must obtain all approvals 

for deaccessioning and returns required under Section 8 of this directive. Before a 

collecting unit can deny a claimant’s request for return of a collection for ethical 

reasons, the collecting unit must consult with the appropriate Under Secretary.

3) Collecting units must establish and implement readily accessible processes for 

descendants, communities, and other parties with claims to request shared 

stewardship or return of collections based on ethical considerations. These processes 

shall prioritize transparency, respectful engagement, meaningful consultation, and 

prompt responses to requests.

16.2. Native American and Native Hawaiian Human Remains and Objects

The 1989 National Museum of the American Indian (NMAI) Act, 20 U.S.C. §80q et seq., as 

amended in 1996, requires the Smithsonian to return culturally affiliated human remains, 

funerary objects, sacred objects, and objects of cultural patrimony to Indian tribes and Native 

Hawaiian organizations. Under the NMAI Act, the Smithsonian is required to prepare 

inventories and summaries about such objects, and to disseminate the information to and 

consult with Indian tribes and Native Hawaiian organizations about human remains and other 

cultural objects that may be eligible for repatriation under the NMAI Act.

The NMAI Act established the Smithsonian Institution Repatriation Review Committee, which 

serves as an advisory body to the Secretary or the Secretary’s designee on the application of 

the NMAI Act with respect to the collections of the National Museum of Natural History.

Additionally, the NMAI Act also established the NMAI Board of Trustees, which, subject to the 

general policies of the Board of Regents, has sole authority over certain collections decisions, 

including final resolution of repatriation claims submitted to the NMAI.

In addition to the applicable requirements of the NMAI Act, Smithsonian collecting units with 

Native American and Native Hawaiian collections should be aware of and sensitive to other
SD 600 — 5/12/22

24

issues that arise out of cultural concerns of Native American Tribes, Native Hawaiian 

organizations named in the NMAI Act, and other Native American and Native Hawaiian 

groups. Such concerns may relate to appropriate standards for the use, management, and 

care of culturally affiliated human remains and cultural objects and protections for interests in 

the intellectual content associated with these objects. Collecting units are encouraged to 

consult with Native American Tribes, Native Hawaiian organizations named in the NMAI Act 

and other Native American and Native Hawaiian groups associated with the human remains 

and objects in their collections, and to take their interests into account in establishing policies 

for the use, management, and care of these collections, provided that such policies are 

consistent with applicable law and the Smithsonian’s responsibilities for the care and 

management of its collections.

The Smithsonian adheres to the following policies regarding Native American and Native 

Hawaiian human remains and objects:

1) Smithsonian repatriation of Native American and Native Hawaiian human remains 

and objects is governed by the requirements set forth in the NMAI Act, 20 U.S.C. § 

80q, as amended.

2) Final repatriation decisions are made by the Secretary or the Secretary’s designee, 

except for the collections of the National Museum of the American Indian. In 

accordance with the NMAI Act, the NMAI Board of Trustees has sole authority to 

dispose of any part of NMAI collections, which includes repatriation. All NMAI 

repatriation decisions are subject to the general policies of the Board of Regents.

3) Any Native American or Native Hawaiian collections whose return or repatriation is 

not required by the NMAI Act shall be managed in accordance with this directive. 

Decisions to return collection objects outside the scope of the NMAI Act (e.g., to 

indigenous people in other countries) will be managed in accordance with this 

directive and unit collections management policies.

16.3. Cultural Property

The Smithsonian Board of Regents first adopted a policy on the acquisition of art, antiquities, 

and other specimens in 1973. Updated and revised by the Board of Regents on April 13, 2015, 

the Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and 

Ethnographic Material, and Historic Objects reaffirms the Smithsonian’s support for efforts of 

local, state, national, and international authorities to protect art, antiquities, national treasures, 

and ethnographic material from destructive exploitation. The policy establishes rules for the 

acquisition and borrowing of art, antiquities, archaeological and ethnographic material, and 

historic objects.

The Smithsonian repudiates the illicit traffic in art and cultural objects that contributes to the 

despoliation of museums and monuments and the irreparable loss to science and humanity of 

archeological remains. Objects and specimens which have been stolen, unscientifically 

gathered or excavated, unethically acquired, or unlawfully exported from their country of origin 

should not be made part of Smithsonian collections.
SD 600 — 5/12/22

25

The Smithsonian adheres to the following policies regarding cultural property:

1) All Smithsonian collections management policies and activities will comply with the 

Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and

Ethnographic Material, and Historic Objects.

2) Before acquiring or borrowing a collection item, the Smithsonian must conduct due 

diligence sufficient to ascertain, from the circumstances surrounding the transaction 

or knowledge of the item’s provenance, that the collection item was not stolen or 

wrongfully converted and is not illegally present in the United States.

3) Before acquiring or borrowing a collection item, the Smithsonian must ascertain 

through provenance research that the collection item was not unethically acquired 

from its source or unscientifically excavated.

4) Before acquiring or borrowing a collection item, the Smithsonian must ascertain 

through provenance research that the collection item was outside its country of 

probable modern discovery before November 17, 1970, or was legally exported from 

its country of modern discovery and lawfully imported into the United States after 

November 17, 1970. For collection items lacking a complete documented provenance 

history, the Smithsonian Institution Policy on Acquisition of Art, Antiquities,

Archaeological and Ethnographic Material, and Historic Objects provides guidelines, 

based on professional museum standards, for collecting unit directors to make an 

informed decision as to whether the collection item can be acquired or borrowed.

5) The provenance of collection items shall be a matter of public record.

16.4. Biological Material

The Smithsonian has long been a leader in the effort to halt the continuing degradation of the 

world’s natural history and environmental resources. Smithsonian research and collecting 

activities must be undertaken with sensitivity to the continued protection of biological diversity 

and in compliance with applicable federal, state, local, tribal, and international laws, treaties, 

regulations, and conventions protecting animal and plant species, especially those that are 

threatened or endangered.

Field studies and collecting of biological material should be preceded by disclosure and 

consultation with the proper authorities and interested scientific institutions in the location of 

the fieldwork. Field activities must be conducted lawfully, support educational and scientific 

purposes, and not cause undue detriment to the biodiversity and ecological conditions in the 

location or region of the activity.

Biological material (e.g., ivory, feathers, blood, and bone) embodied in art or other objects or 

acquisitions must comply with all applicable laws relating to import, export, and possession of 

the embedded biological material.

The Smithsonian adheres to the following policies regarding biological material:

1) Biological material may be acquired by or on behalf of the Smithsonian through field 

collecting only when such collecting is legally authorized in advance; the biological
SD 600 — 5/12/22

26

material is obtained solely for the purposes of scientific research or conservation, to 

add to the Smithsonian collections, or for other educational purposes; and the 

Smithsonian’s collecting activities will not cause undue detriment to the biodiversity 

and ecological conditions in the area of the activity.

2) Nothing in this directive shall prevent collecting units, when acquiring international 

biological material, from also considering international conventions governing the 

transfer of biological materials even if such conventions are not legally applicable to 

the Smithsonian.

3) The Smithsonian name may not be used to justify or support permit applications for 

activities that have not been authorized by or on behalf of the Smithsonian in 

accordance with this directive and unit collections management policies.

4) The Smithsonian may acquire or borrow biological material collected or obtained by 

others, including when embodied in art and other objects, only when consistent with 

established collecting unit criteria for the transaction and applicable international, 

national, state, local, and tribal laws.

5) Biological material in Smithsonian collections or in its custody will be managed in 

accordance with all applicable legal requirements.

16.5. Unlawful Appropriation of Objects During the Nazi Era

Between 1933 and 1945, the Nazi regime and its collaborators orchestrated a system of 

confiscation, coercive transfer, looting, and destruction of cultural property and artwork 

throughout Europe on an unprecedented scale. Millions of objects were unlawfully 

appropriated from their rightful owners, including private citizens, victims of the Holocaust, 

public and private museums and galleries, and religious, educational, and other institutions. 

Some of these objects were ultimately transferred, in good faith and without knowledge of their 

prior unlawful appropriation, through the legitimate market and may have been acquired by 

museums. Postwar restitution efforts to return unlawfully seized objects to their rightful owners 

did not lead to complete and comprehensive restoration.

Guidance issued by the AAM and the AAMD concerning objects that may have been 

unlawfully appropriated during the Nazi era recommends museums identify objects in their 

collections that were created before 1946, acquired by the museum after 1932, underwent 

changes in ownership during the Nazi era, and were or may reasonably be thought to have 

been in continental Europe between 1933 and 1945. The Smithsonian is committed to 

implementing the AAM and AAMD guidelines by researching, identifying, and making public 

any objects that fall within their scope.

The Smithsonian adheres to the following policies regarding unlawful appropriation of objects 

during the Nazi era:

1) The Smithsonian shall not knowingly acquire collection items unlawfully appropriated 

during the Nazi era without subsequent restitution.
SD 600 — 5/12/22

27

2) If the Smithsonian has in good faith acquired a collection item subsequently 

determined to have been unlawfully appropriated during the Nazi era without 

restitution, the Smithsonian will take prudent and necessary steps to resolve the 

status of the collection item.

3) The Smithsonian shall apply the applicable provisions of the AAM Guidelines 

Concerning the Unlawful Appropriation of Objects During the Nazi Era and the AAMD 

Report on the Task Force on the Spoliation of Art during the Nazi/World War II Era 

(1933–1945) to its collection management activities.

Smithsonian collecting units must adhere to the policies of this directive, including the following 

policies regarding unit collections management.

A well-managed collection is governed by specific documents that guide collections-related 

decisions based on strategic planning goals and priorities. In accordance with this directive, 

each Smithsonian collecting unit must develop, implement, and maintain the following.

17.1 Collections Stewardship Plans

A collections stewardship plan provides an intellectual framework for collections that 

establishes well-defined goals and priorities to guide collections-related decisions regarding 

acquisition, deaccessioning, resource allocation, institutional and community partnerships, and 

other activities related to the growth and refinement of collections.

Each collecting unit must develop, implement, and adhere to an authorized, up-to-date 

collections stewardship plan to guide collections-related activities that are consistent with 

strategic planning objectives.

Collections stewardship plans should be reviewed and updated every five years to align with 

unit strategic planning and require written approval from the collecting unit director and review 

by the NCP and the appropriate Under Secretary.

17.2 Unit Digitization Plans

Unit digitization plans support the Smithsonian’s commitment to promote access to collections 

and collections information in databases and online platforms to maximize the application of 

networked technologies, implement professional documentation standards, and share 

collections information through collaborations among collecting units and with other cultural, 

educational, and research institutions.

In accordance with this directive and SD 610, Digitization and Digital Asset Management

Policy, each collecting unit must develop, implement, and maintain an authorized, up-to-date 

unit digitization plan that establishes unit-specific goals, priorities, and standards for the 

digitization of its collections. Unit digitization plans should be reviewed and updated every 

three years.

17. SMITHSONIAN COLLECTING UNIT REQUIREMENTS
SD 600 — 5/12/22

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17.3 Unit Collections Management Policies

Collections management policies establish general principles and standards to govern the 

collections-related activities and operations of a collecting unit to achieve its mission, 

programmatic goals and objectives, and responsibilities regarding collections. Unit collections 

management policies define areas of authority and responsibility for collections, establish 

decision-making criteria, and provide guidance on collections management activities that carry 

out the unit’s legal, ethical, and professional obligations for collections in its care.

Each collecting unit designs policies specifically tailored to the nature, scope, character, and 

intended purpose of its collections. Collections are defined by each collecting unit within their 

collections management policy.

In accordance with this directive, each Smithsonian collecting unit must develop, implement, 

and adhere to an authorized, up-to-date collections management policy consistent with the 

policies established by this directive.

The Smithsonian is increasingly acquiring diverse types of collections, collected for vastly 

different purposes and uses, and composed of various kinds of materials, which are most 

appropriately stewarded in accordance with discipline-specific standards of management and 

care. These discipline-specific standards may in some cases deviate from the standards 

outlined in this directive. Therefore, the NCP may approve, in consultation with the collecting 

unit director and the appropriate Under Secretary, to exempt specific types of collections from 

specific provisions of SD 600. Such exemptions must be specified in the collecting unit’s 

collections management policy, and the unit’s policy must specify the national or international 

discipline-specific standards which will instead apply to the type of collection granted the 

exemption.

Unit collections management policies must be reviewed every five years and, if necessary, 

revised and reauthorized as appropriate. Revised collections management policies must be 

approved by the collecting unit director, the NCP, the OGC, the appropriate Under Secretary, 

and the Secretary. If a collecting unit reviews its collections management policy and chooses 

not to revise its policy, the unit director must notify the NCP and appropriate Under Secretary.

In certain circumstances, collecting units may make minor amendments to their existing 

collections management policy in advance of a full review and revision. Written approval is 

required from the collecting unit director, the NCP, the OGC, and the appropriate Under 

Secretary. Any approved amendments are addressed through the formal review and approval 

process during the unit’s next periodic review and revision of its collections management 

policy.

Certain collecting units may have varying levels of authority that limit the unit from adhering to 

certain policy requirements. Collecting units that do not have delegated authority to conduct 

specific transactional activities must clearly articulate such restrictions in the unit’s policy.

Each unit collections management policy must include the following components:
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1) Introductory Statements. Each collecting unit must clearly articulate the mission, 

strategic priorities, programmatic goals, and role of the collecting unit within the larger 

Smithsonian community in the following introductory statements:

• Statement of purpose;

• Statement of authority;

• Definition of collections;

• Collections scope; and

• Description of applicable collections management activities.

2) Acquisition and Accessioning. Collecting units must include the following policy 

components regarding the acquisition and accession of collections. Each unit must:

• establish authority and assign responsibility to approve, document, and 

process acquisitions and accessions;

• develop and implement formalized evaluation criteria for potential 

acquisitions;

• establish appropriate methods of acquisition;

• ensure the documentation of legal title and provenance for all collection items 

acquired; and

• ensure the creation and maintenance of permanent records for acquisitions 

and accessioning.

3) Deaccessioning and Disposal. Collecting units must include the following policy 

components regarding deaccession and disposal of collections. Each unit must:

• establish authority and assign responsibility to approve, document, and 

process deaccessions and disposals;

• develop and implement formalized evaluation criteria for deaccessioning and 

disposal decisions;

• establish appropriate methods of disposal;

• develop and implement disposal plans at the time of deaccession;

• develop policies and procedures, in accordance with their professional 

membership, for the appropriate use of proceeds realized from the disposal 

of deaccessioned items — the acquisition of additional collection items or the 

direct care of existing collections; and

• stipulate authority and approval for the disposal of non-accessioned 

collections.

4) Preservation. Collecting units must include the following policy components 

regarding the preservation and care of collections. Each unit must:
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• establish authority and assign responsibility for the physical care, storage, 

handling, preventive conservation, conservation treatment, restoration, pest 

management, preservation environment, sustainability, and maintenance of 

collections;

• develop, implement, and adhere to established preservation policies, 

standards, and procedures consistent with the mission of the unit and the 

nature, purpose, and intended use of its collections;

• ensure collections and their associated information are cared for and 

maintained in conditions that preserve and extend their physical and 

intellectual integrity for use in exhibitions, research, and education; and

• ensure that all collections acquired, borrowed, and in the collecting unit’s 

custody receive the appropriate level of care.

5) Collections Information. Collecting units must include the following policy 

components regarding collections information. Each unit must:

• establish authority and assign responsibility for the development, 

management, preservation, and maintenance of collections information;

• establish authority and assign responsibility for the implementation and 

management of collections information systems;

• establish authority and assign responsibility for the development and 

implementation of a unit digitization plan that defines the unit’s digitization 

program and its objectives and priorities for collections digitization;

• establish documentation standards to ensure the quality, integrity, and proper 

maintenance, management, and dissemination of collections information;

• ensure the maintenance of collections information on the cultural, historical, 

scientific, or aesthetic significance, legal status, provenance, and the use and 

management of its collections and collections in the unit’s custody; and

• promote the widest dissemination of collections information consistent with unit 

stewardship responsibilities.

6) Inventory. Collecting units must include the following policy components regarding 

the inventory of collections. Each unit must:

• establish and assign responsibility for developing and implementing inventory 

processes and standards, and a written inventory plan appropriate to the 

purpose, character, and size of the collections in its care and staff resources;

• establish authority and assign responsibility for conducting, supervising, 

approving, and reporting on inventories and reconciliation of collection records; 

and
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• ensure adequate separation of duties and other internal controls to minimize 

the possible unauthorized removal of collection items and corresponding 

records.

7) Risk Management, Safety, and Security. Collecting units must include the following 

policy components regarding risk management, safety, and security of collections. 

Each unit must:

• establish authority and assign responsibility for unit risk management, safety, 

and security activities to identify, eliminate, or mitigate conditions which may 

create the potential for damage or loss to collections, risks of personal injury, 

or legal, reputational, or financial liability;

• establish authority and assign responsibility for the development, 

implementation, and coordination of the unit’s emergency management plan 

and program for its facilities housing collections;

• develop policies and procedures for reporting and documenting damage, loss, 

or possible theft of collections in its custody and on loan;

• make reasonable efforts to identify, document, and promote the appropriate 

communication of potential collections-based hazards in accordance with this 

directive, SD 419, and applicable chapters of the Smithsonian Institution Safety

Manual; and

• ensure collections are maintained in controlled areas which are adequately 

protected to reduce exposure to risks such as fire, theft, vandalism, and natural 

disasters.

8) Access. Collecting units must include the following policy components regarding 

access to collections. Each unit must:

• establish authority and assign responsibility to control, monitor, approve, 

document, and provide access to physical collections, digital collections, and 

collections information consistent with the specific type and purpose of the 

unit’s collections and applicable access restrictions;

• establish policies, criteria, and procedures for permitting responsible access to 

collections, collections storage, and collections information consistent with the 

unit’s mission and the purpose and intended use of the collections; and

• make access policy statements available to the public.

9) Loans. Collecting units must include the following policy components regarding 

lending and borrowing collections. Each unit must:

• establish authority and assign responsibility to approve, process, document, 

and monitor loans, including, where appropriate, temporary custody;
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• establish policies, criteria, and procedures for lending and borrowing 

collections; and

• apply the provisions of SD 603, the Smithsonian Unit-to-Unit Object Loan 

Guidelines, and the AAM Guidelines for Exhibiting Borrowed Objects in unit 

borrowing activities.

10) Intellectual Property Rights. Collecting units must adhere to the following policy 

requirements regarding intellectual property rights. Each unit must:

• establish authorities to approve permissible use of collections information and 

images, and assign responsibility for rights management;

• establish policies and procedures to ascertain whether collection items or 

proposed acquisitions are encumbered by intellectual property rights or other 

restrictions, and document any SD 609 restrictions for collection items in 

collection records to determine, if possible, what steps are required to obtain 

any rights necessary for the intended use of the item;

• establish policies and procedures for handling and documenting outside 

requests and permissions to publish or reproduce collections information and 

images in accordance with SD 609;

• determine permissible uses of collections information, metadata, and images to 

ensure consistency with the mission of the Smithsonian and the collecting unit; 

and

• ensure that collection records are consulted for possible restrictions or 

prohibitions to determine permissible image use and reproduction by the 

Smithsonian and others in all media formats, such as print, digital, audio, 

video, and the Internet.

11) Specific Legal and Ethical Issues. Each collecting unit must determine if it acquires, 

holds, or manages any collections that fall within the scope of the following and 

incorporate the appropriate legal and ethical standards in its collections management 

policy:

Shared Stewardship and Ethical Returns

Each collecting unit must establish authority and evaluation criteria and assign 

responsibility to approve, document, and implement shared stewardship 

arrangements and ethical returns in appropriate circumstances, based on ethical 

considerations. Each collecting unit must further establish readily accessible, 

transparent, and consultative processes for descendants, communities, and other 

parties with claims to request shared stewardship or return of collections based on 

ethical considerations.
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Native American and Native Hawaiian Human Remains and Objects

Each collecting unit must determine if its collections include Native American or 

Native Hawaiian materials to which the requirements of the National Museum of the 

American Indian Act (NMAI Act), as amended, may be applicable. Any collecting unit 

with Native American or Native Hawaiian collections must:

• develop written policies and procedures consistent with the legal requirements 

of the NMAI Act;

• assign responsibility to complete inventories and summaries, and assess the 

cultural affiliation of the collections in accordance with the provisions of the 

NMAI Act;

• establish authority and assign responsibility to review, evaluate, document, 

and process repatriation requests and returns; and

• establish authority and assign responsibility to review proposed acquisitions to 

determine the applicability of the NMAI Act.

Cultural Property

Each collecting unit must establish authority and assign responsibility for 

implementing and ensuring compliance with the Smithsonian Institution Policy on

Acquisition of Art, Antiquities, Archaeological and Ethnographic Material, and Historic

Objects, and other applicable laws and professional standards regarding the 

acquisition, borrowing, and management of cultural property.

Biological Material

Each collecting unit with responsibility for biological material must establish authority 

and assign responsibility to approve, document, and ensure compliance with legal 

requirements for collections transactions involving biological material.

Unlawful Appropriation of Objects During the Nazi Era

Each collecting unit must establish authority and assign responsibility for 

implementing and ensuring compliance with the Smithsonian policy on

Nazi-appropriated objects and the applicable professional guidelines issued by AAM 

and AAMD.

12) Ethics. Each collecting unit must establish policies and procedures for implementing 

the collections-specific requirements of SD 103 and other standards of professional 

conduct, including personal collecting, appraisals, and authentication.

13) Financial Accounting for Collections. Each collecting unit must include a statement 

on financial accounting for collections in compliance with the Smithsonian’s policy 

regarding the non-capitalization of collections.

14) Monitoring and Revision of Unit Collections Management Policies. Each 

collecting unit must establish authority and assign responsibility for monitoring and
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reporting on the implementation of SD 600 and the unit collections management 

policy. Each collecting unit must establish authority and assign responsibility for the 

development, revision, and implementation of the unit’s collections management 

policy and establish procedures for the periodic review, and, if necessary, revise and 

obtain reauthorization of the unit’s policy. Unit collections management policies must 

be reviewed every five years to ensure the policy is up to date.

A collecting unit may seek an exception to the policies set forth in this directive or its 

collections management policy if the application of such a policy directly hinders the unit’s 

ability to achieve the mission objectives or programmatic goals of the Smithsonian. Requests 

for any such exception must be submitted in writing by the collecting unit director for approval 

by the NCP, the OGC, and the appropriate Under Secretary.

SUPERSEDES: SD 600, issued on October 26, 2001.

INQUIRIES: National Collections Program (NCP).

RETENTION: Indefinite. Subject to review for currency 36 months from date of issue.

18. EXCEPTIONS