National Archives and Records Administration: Actions Needed to Ensure Facilities That Store Federal Records Meet Standards
Released: 2013-09-10T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: NARA manages the Federal Records Centers Program, which is to ensure the storage and preservation of federal records, including paper, photographic, audio, video, and film. Records storage facilities are required to meet certain minimum structural, environmental, property, and life safety standards set forth in federal regulations.

GAO was requested to conduct a study of key aspects of the program. GAO's objectives were to (1) determine the types of facilities agencies use to store federal records and the extent to which NARA's data on agencies' use of storage facilities are complete, (2) evaluate the extent to which NARA has determined these facilities to be compliant with standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has taken to minimize damage to records in federal records centers and the extent to which it documents such efforts, and (4) determine how NARA determines storage fees and whether fees differ among facilities. To do so, GAO obtained, analyzed, and corroborated documentation on records storage facilities, identified and compared records storage fees, and interviewed NARA officials.

section_title: What GAO Found
paragraphs: Agencies are to store federal records in three types of facilities:

Federal records centers : The National Archives and Records Administration (NARA) operates 18 federal records centers that are comprised of 24 facilities (buildings) located across the United States. Each facility includes storage areas, referred to as bays.

Agency records centers : Agencies also establish and operate records centers for storing their own records. As of May 2013, NARA had identified 18 agency records centers that were operated by 6 agencies or offices.

Commercial records storage facilities : Agencies also use private sector commercial facilities. As of May 2013, agencies reported that 12 vendors provided 22 facilities, which were used by 11 agencies.

These facilities notwithstanding, NARA does not know where all agencies are storing records. NARA has solicited data from agencies about their use of agency records centers and commercial records storage facilities, but not all agencies have submitted data. Further, the data agencies submitted--mostly from 2008 and 2009--are now outdated. As a result, NARA cannot be assured that all agencies are using one of the three types of authorized facilities.

NARA determined that 20 of its 24 federal records center facilities were fully compliant with 36 C.F.R. Part 1234 because all of their bays satisfied the regulation; of the remaining 4, 2 facilities with inadequate shelving were partially compliant, 1 facility with insufficient protections against pipe leaks was not compliant, and the remaining facility was to be replaced. As of July 2013, NARA had plans to bring these 4 facilities into full compliance, but did not have a schedule for completing the plans at 2 of the facilities. As a result, NARA does not have a basis for determining progress toward correcting deficiencies in those facilities that do not yet fully meet the standards. Also, while NARA had approved 10 agency records centers and 22 commercial records storage facilities, it has inspected 1 of 18 agency records centers and 13 commercial records storage facilities. Until NARA completes planned inspections of all remaining facilities, it cannot be reasonably assured that agencies are storing records in facilities that meet standards.

To facilitate the protection of federal records from permanent damage, NARA had generally taken steps consistent with a checklist it requires federal records centers to follow when incidents (e.g., roof or sprinkler leaks) occur. However, it did not always document the results of its efforts to minimize damage because the checklist does not include a step for doing so. Specifically, of the 55 incidents that occurred from January 2009 through March 2013, NARA provided documentation about the final outcome for 46 incidents. For the remaining 9 incidents, it could not provide documentation that included the final results of its efforts. Without a process that includes documenting the results of its efforts, NARA is not positioned to fully report on the effectiveness of its actions to minimize damage to federal records and to provide a third party with information to validate the results of its efforts.

Storage fees are determined by NARA's Federal Records Centers Program and the Office of the Chief Financial Officer using the existing fee schedule, expense projections, and workload projections. The storage fees charged by NARA in fiscal year 2013 were comparable to fees charged by commercial vendors in that same time frame. For example, NARA's fee of $0.23 per cubic foot was higher than fees charged by two vendors and lower than fees charged by two other vendors.

section_title: What GAO Recommends
paragraphs: GAO recommends that NARA (1) obtain complete data on where agencies are storing records, (2) develop a schedule to bring noncompliant storage areas into compliance with 36 C.F.R. Part 1234, and (3) establish a requirement to document the results of efforts to minimize damage to federal records. NARA concurred with the recommendations.

section_title: Letter
paragraphs: The National Archives and Records Administration (NARA) manages the  Federal Records Centers Program, which is to ensure the storage and  preservation of federal records, including paper, electronic, photographic,  audio, video, and film. Records storage facilities are required to comply  with regulations (i.e., 36 C.F.R. Part 1234) that specify certain minimum  structural, environmental, property, and life safety standards that facilities  must meet in order to minimize damage to the records. NARA operates  records storage facilities on a reimbursable fee-for-service basis by  charging fees to federal agencies for storing records in the facilities.

At your request, we conducted a study of key aspects of the Federal  Records Centers Program. Our specific objectives were to (1) determine  the types of facilities agencies use to store federal records and the extent  to which NARA’s data on agencies’ use of storage facilities are complete,  (2) evaluate the extent to which NARA has determined these facilities to  be compliant with standards in 36 C.F.R. Part 1234, (3) determine what  actions NARA has taken to minimize damage to records in federal  records centers and the extent to which it documents such efforts, and (4)  determine how NARA determines storage fees and whether fees differ  among facilities.

To accomplish the objectives, we obtained and reviewed documentation  identifying facilities that federal agencies use to store records. We then  corroborated the lists of facilities through analysis of other documentation,  such as compliance memoranda and inspection schedules, and through  interviews with NARA officials. In addition, we obtained and reviewed  documentation, such as NARA’s central registry of approved facilities that  discussed the characteristics of each identified records storage facility.  We analyzed information describing NARA’s assessment of each facility  in comparison to applicable standards in 36 C.F.R. Part 1234. These  information sources included compliance checklist documentation and  official NARA documentation supporting approval of the facility. We also  interviewed NARA officials regarding certification documentation. Further,  we interviewed NARA officials to identify what actions NARA has taken to  minimize damage to records in federal records centers and corroborated  the officials’ statements with available documentation pertaining to  records storage and management. We also interviewed officials from  companies that operate commercial records storage facilities that NARA  has approved for use by federal agencies to gain their perspectives on  storing records for federal agencies. Finally, we obtained and analyzed  documentation from the NARA Federal Records Centers Program and  General Services Administration (GSA) schedules that identified and  discussed records storage fees. We then compared fees among the  records storage facilities.

We conducted this performance audit from November 2012 to September  2013 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives. Appendix I provides  further details on our objectives, scope, and methodology.
subsections: section_title: Background
paragraphs: NARA’s mission is to safeguard and preserve the records of the U.S.  government, ensuring that the people can discover, use, and learn from  this documentary heritage. In this way, NARA is to ensure continuing  access to the essential documentation of the rights of American citizens  and the actions of their government.

In carrying out this mission, NARA (among other things) is to provide  guidance and assistance to federal officials on the management of  records; determine the retention and disposition of records; store agency  records in federal records centers from which agencies can retrieve them;  receive, preserve, and make available permanently valuable federal and  presidential records in archives; and centrally file and publish federal laws  and administrative regulations, the President’s official orders, and the  structure, functions, and activities of federal agencies through the daily  Federal Register. Table 1 summarizes NARA’s organizations, their  missions, and the levels of staff in each (expressed as full-time  equivalent—FTE).

NARA’s Agency Services group includes the Federal Records Centers  Program, with approximately 1,100 FTE. The placement of this program  within the larger NARA organization is depicted in figure 1.

In carrying out its responsibilities to store and archive federal records  under the Federal Records Act and its implementing regulations, the  Federal Records Centers Program provides storage facilities for federal  agencies. Specifically, chapters 21, 29, and 31 of title 44 of the United  States Code, and Parts 1232 and 1234 of title 36 of the Code of Federal  Regulations authorize NARA to establish, maintain, and operate records  centers for federal agencies. Further, 36 C.F.R. Part 1234 Subparts B, C,  and D describe facility standards related to quality, effectiveness,  durability, and safety; the handling of deviations from NARA’s facility  standards; and facility approval and inspection requirements. These  standards are applicable to all records storage facilities that federal  agencies use to store, service, and dispose of records. To carry out these  responsibilities, NARA developed an internal policy directive that outlines  the procedures its officials should use to ensure the compliance of  records storage facilities.  36 C.F.R. Part 1234 also includes provisions allowing NARA to grant  waivers from meeting the standards set forth in the regulations for records  storage facilities. In these instances, waivers are allowed when the  storage systems, methods, or devices are demonstrated to have facility  standards that are equivalent or superior to 36 C.F.R. Part 1234  standards for quality, strength, fire resistance, effectiveness, durability,  and safety, among other things. Underground facilities may obtain  waivers from regulatory requirements that pertain to the roofs of  aboveground facilities. Agencies can request a waiver by providing: a statement identifying the 36 C.F.R. Part 1234 provision for which the  waiver is requested, in addition to a description of the proposed  alternative, and an explanation of how it is equivalent or superior to  the NARA requirement; and supporting documentation demonstrating that the alternative does not  provide less protection for federal records than what is required by the  36 C.F.R. Part 1234 standard, which may include certifications from a  licensed fire protection engineer or a structural or civil engineer, as  appropriate; reports of independent testing; reports of computer  modeling; and/or other relevant information.

According to 36 C.F.R. Part 1234, NARA is to review the waiver request  and supporting documentation, and in some circumstances, consult with  the appropriate industry body or qualified experts, such as a fire- suppression specialist, before making a determination. If NARA is in  agreement with the proposed waiver and the supporting documentation, it  is to grant the waiver and notify the requesting agency. However, if NARA  evaluates the waiver request and the supporting documentation  unfavorably, it is not to approve the waiver.

The Federal Records Centers Program is financed through a revolving  fund, which in fiscal year 2012 earned revenue totaling approximately  $185 million. Revenues for the fund are generated from the fees that  NARA charges federal agencies for storing, servicing, and ultimately  disposing of temporary federal records on their behalf, based on a  standard fee schedule. NARA develops the fees annually for the  upcoming fiscal year.

In November 2011, a presidential memorandum on managing  government records was issued to the heads of executive departments  and agencies. The purpose of the memorandum was to begin an  executive branch-wide effort to reform records management policies and  practices and to develop a 21st-century framework for the management  of government records. Specifically, the memorandum stated, among  other things, that all agencies were required to designate a Senior  Agency Official to oversee a review of their records management  program. The Senior Agency Official would be responsible for  coordinating with the Agency Records Officer and appropriate agency  officials to ensure the agency’s compliance with records management  statues and regulations.
subsections: section_title: NARA’s Inspector General Previously Reported on Federal Records Centers Challenges
paragraphs: In January 2012 and March 2012, NARA’s Inspector General reported on  one of NARA’s federal records centers, the Washington National Records   For example, the  Center, and found that it had numerous weaknesses.Inspector General reported that formalized procedures were not in place  to properly track and resolve problems with records received, stored, or  removed from the center; documented procedures did not exist for many  of the center’s operations; and periodic inventories of the records held at  the center were not conducted. In order to address the weaknesses cited  above, the Inspector General made recommendations, which included  developing a problem resolution process and mechanism for tracking all  problems at the center until they are resolved, ensuring a formal tracking  mechanism is implemented for new records received, and ensuring a  systematic and repeatable process is in place to perform periodic  inventories of the records held at the Washington National Records  Center.

NARA concurred with these recommendations and began taking actions  to address them. Specifically, the Archivist ordered all federal records  centers operated by NARA to assess their operations during a 1-day  stand down. In addition, NARA officials stated that they established a  Washington National Records Center oversight group to ensure that the  center leadership participated in plans, actions, and results related to  resolving record storage issues. However, as of May 2013, NARA was in  the process of addressing the recommendations.

section_title: Federal Records Are to Be Stored in Three Types of Facilities; NARA Does Not Have Reliable Data about All Agencies’ Use of Records Storage Facilities
paragraphs: Federal agencies are to store records in three types of facilities: federal  records centers that are managed by NARA, agency records centers, and  commercial records storage facilities. Each of these types of facilities is  authorized by 36 C.F.R. Part 1234, which also requires agencies to notify  NARA when they use agency records centers or commercial facilities to  store federal records. While NARA is aware of the extent to which  agencies use the federal records centers that it manages, its awareness  of the extent to which agencies’ use their own and commercial records  storage facilities is incomplete.
subsections: section_title: NARA Federal Records Centers
paragraphs: As of May 2013, NARA manages 18 federal records centers located  across the United States. These centers consist of a total of 24 facilities  where records are actually stored. Each facility includes storage areas,  which NARA refers to as bays. (According to NARA, the typical bay is  approximately the size of a football field.) Collectively, the facilities  provide a total of 162 bays that are used by approximately 200 entities.  Table 2 provides a listing of NARA’s federal records centers and their  related facilities, and the number of bays at each facility.

In addition to the federal records centers that NARA operates, agencies  also are authorized to establish and operate their own centers for storing  records. As of May 2013, NARA had identified 18 records centers that  were being operated by six federal agencies or offices: the Department of  Energy, the Department of Veterans Affairs, the Federal Bureau of  Investigation, the National Geospatial-Intelligence Agency, the National  Reconnaissance Office, and the Transportation Security Administration’s  Office of Law Enforcement – Federal Marshal Records Center. These  agencies varied in the number of storage facilities that they operated— ranging from 7 at the Federal Bureau of Investigation to 1 facility at each  of three other agencies (the Department of Veterans Affairs, the National  Reconnaissance Office, and the Transportation Security Administration’s  Office of Law Enforcement). Table 3 identifies the number of records  storage facilities operated by each of the agencies.

Federal agencies are also authorized to use private sector commercial  facilities for records storage, retrieval, and disposition. As of May 2013,  agencies reported to NARA that 22 such facilities, operated by 12  vendors, are under contract with and provide storage services for 11  federal agencies or entities. These federal agencies or offices are the  Bureau of Public Debt, Centers for Medicare and Medicaid Services,  Commodities Futures Trading Commission, Department of Veterans  Affairs, Environmental Protection Agency, Federal Aviation  Administration, Federal Energy Regulatory Commission, Federal Public  Defender, Naval Sea Systems Command, United States Customs and  Border Protection, and the United States International Trade Commission.  Table 4 identifies each vendor and their facilities that provide records  storage services to federal agencies.

To determine whether all agencies were storing their records in one of the  three types of allowable facilities, NARA collected data and compiled a  database of agencies and the records storage facilities that they use.  Specifically, in 2008, NARA officials sent letters to agencies’ records  managers that asked them to provide a list of all records storage facilities  used. Subsequently, NARA sought to obtain information about where  agencies were storing their records by sending follow-up letters and by  including a question regarding the storage of federal records in a  voluntary annual survey of agencies’ records management practices.  However, the database was unreliable because it did not include  complete, current, and valid data. Specifically, NARA’s database of  agencies’ records storage facilities included a reporting status for about  260 agencies, but did not have a date associated for when 47 of these  agencies reported. Additionally, the data were derived primarily from  information agencies submitted to NARA in 2008 and 2009, thereby  rendering it outdated. Also, the self-reported nature of agencies’ data  raised questions about the validity of the data they provided.

NARA officials responsible for determining where agencies store records  acknowledged that the data about agencies’ and the records storage  facilities they use are incomplete, outdated, and of questionable validity.  The officials attributed this situation to agencies’ not reporting data to  NARA because they were unfamiliar with the 36 C.F.R. Part 1234  requirement to notify NARA when they use agency records centers or  commercial facilities to store federal records, as well as NARA having  insufficient staff to ensure that all agencies report the required data, keep  the data current, and verify the data agencies provide.

NARA officials responsible for communicating records storage  requirements to agencies stated that the Senior Agency Officials for  records could provide NARA with points of contact that can help identify  all the facilities where agencies store their records. Nevertheless, until  NARA ensures that it has complete, current, and valid data on agencies’  records storage facilities, it cannot be certain that agencies are using one  of the three types of authorized facilities.

section_title: NARA Has Approved Almost All of Its Federal Records Centers as Compliant with Applicable Standards, but It Has Not Inspected and Validated the Majority of Agency and Commercial Records Facilities
paragraphs: In carrying out its responsibilities to store and archive federal records,  Title 44 of the United States Code authorizes NARA to establish,  maintain, and operate records centers for federal agencies; approve  agency records centers; and promulgate standards, procedures, and  guidelines to federal agencies with respect to the storage of their records  in commercial records storage facilities. Regulations implementing the  statute, at 36 C.F.R. Part 1234, specify the minimum structural,  environmental, property, and life-safety standards that a records storage  facility must meet when the facility is used for the storage of federal  records. For example, facilities must be designed in accordance with the  applicable national, regional, state, or local building codes to provide  protection from building collapse or failure of essential equipment.  Further, a floor load limit must be established for the records storage area  by a licensed structural engineer, and the facility must be 5 feet above  and 100 feet from any 100-year flood plain areas, or be protected by an  appropriate flood wall that conforms to local or regional building codes. In  addition, NARA’s Review of Records Storage Facilities policy directive  outlines the procedures for NARA to ensure records centers comply with  36 C.F.R. Part 1234 specifications. Specifically, the directive requires  NARA to conduct inspections of its federal records centers and agencies’  records centers to validate those facilities as compliant. In addition, 36  C.F.R. Part 1234 requires that agencies ensure that their own or NARA  officials have the right to inspect commercial records storage facilities for  compliance with the facility requirements. If a commercial facility fails an  inspection, federal agencies that store records at the facility are required  to bring the facility into compliance with the standards within 6 months or  to transfer their documents to a compliant facility within 18 months.  Standard practices in program management call for documenting the  scope of a project as well as milestones and time frames for timely  completion and implementation of repairs or transfers to ensure results  are achieved.

NARA conducted inspections of 23 of its 24 federal records center  facilities from February 2005 through January 2013 and determined that  20 of the facilities were compliant with 36 C.F.R. Part 1234. It also  determined that 2 facilities were partially compliant because they included  at least 1 storage bay that did not satisfy the regulation. Specifically,  NARA found that 2 of the 16 bays at the Lenexa, Kansas facility and 6 of  the 17 bays at the Lee’s Summit, Missouri facility were noncompliant  because they included shelves that were determined to be too weak to  meet the load requirements for records storage shelving and racking  systems. Further, it found that all 7 bays at the San Francisco, California  records center were noncompliant because, contrary to the regulation,  there were pipes (other than sprinkler pipes) that ran through the records  storage areas which lacked supplemental protective measures such as   The remaining facility consisting of 1 bay at the Anchorage,  drip pans.Alaska center was not inspected; however, NARA had considered the  facility to be noncompliant and had planned to relocate the records being  stored there. Table 5 summarizes the compliance status of each federal  records center facility.

As of July 2013, NARA indicated that it had plans to address the  deficiencies at the noncompliant federal records centers, although it had  not established schedules for doing so at the San Francisco and  Anchorage facilities. For example, to correct the shelving at the Lenexa  and Lee’s Summit facilities, NARA had plans to contract for a detailed  inspection of the existing shelving, prepare a report identifying necessary  repairs, and then conduct the repairs and/or replacement of the  noncompliant shelves. It expected to award a contract for this work in  August 2013 and to complete the work within the following 6 months. In  addition, NARA officials responsible for facility compliance had developed  a plan for corrective actions at the San Francisco facility. This plan calls  for the installation of water sensing cables and protective drip pans and  guttering to provide supplemental protection of pipes that run through  records storage areas. However, the plan does not include a schedule for  completing these tasks consistent with standard practices for program  management. NARA officials responsible for facility compliance attributed  the lack of a schedule to uncertainty about the availability of funding and  personnel resources to execute the plan. Further, NARA facility managers  developed plans to replace the existing Anchorage, Alaska facility with a  newly constructed facility. However, NARA did not have a schedule for  completing the construction because it had not secured funding to  construct the new facility.

While NARA has stated that it plans to bring all of its federal records  center facilities into compliance with applicable regulations, the agency  has not established a schedule for doing so at all facilities. Thus, although  NARA has determined that the vast majority of the space (i.e., bays) in  which its facilities store records is fully compliant with applicable  standards, NARA has not established a basis for tracking and reporting  progress toward resolving deficiencies at all of its facilities that do not yet  fully meet the standards.
subsections: section_title: NARA Has Not Inspected and Validated Compliance for the Majority of Agency and Commercial Records Storage Facilities
paragraphs: Agencies must obtain approval from NARA to store federal records at  their own or a commercial records storage facility and, to do so, must  provide documentation to show that the facility satisfies the requirements   After a facility is approved, agencies are able to  of 36 C.F.R. Part 1234.store federal records at the facility and an inspection may be conducted to  ensure that the facility meets the requirements of the standard. According  to NARA officials responsible for determining facility compliance,  inspections have been an important means of determining whether  facilities are in fact compliant with the requirements.

NARA has approved 10 of the 18 agency facilities that agencies have  reported using. According to NARA officials, the remaining 8 centers were  not approved because the agencies that operate them did not provide  NARA with sufficient documentation to support approval. NARA has  approved all 22 identified commercial facilities.

However, of the 10 approved agency records centers, 1 had been  inspected; and of the 22 approved commercial facilities, 13 had been  inspected (1 inspection was deemed unfavorable and the facility was  removed from the approved list). For the 9 agency records centers and 10  commercial facilities that had not been inspected, NARA provided a  schedule for doing so. According to this schedule, NARA plans to inspect  4 facilities per fiscal year from fiscal years 2014 through 2017, with the  remaining 3 facilities scheduled for inspection in fiscal year 2018. For the  commercial facilities, NARA had scheduled all 10 of the remaining  facilities, with the last of these inspections planned in fiscal year 2017.

Until all facilities are inspected, NARA cannot be reasonably assured that  agencies are storing federal records in facilities that comply with  standards, thus increasing the risk that these records will be damaged.

section_title: NARA Has Taken Steps to Minimize Permanent Damage to Records in Federal Records Centers, but Does Not Always Track the Results of Its Efforts
paragraphs: In keeping with NARA’s mission to safeguard and preserve the records of  the U.S. government, the agency has a process in place to handle  incidents in which records could potentially become damaged at its  federal records centers. In particular, NARA requires its federal records  centers to follow the Emergency First Response for NARA Records  checklist to facilitate the protection of federal records from further impact  and/or permanent damage when an incident occurs. As part of the  agency’s 1561 directive, the checklist requires (1) notification and  immediate actions, such as notifying management; (2) an initial response,  including steps to take if water damage occurs; and (3) damaged records  response operations, including the requirement to document NARA’s  immediate response to incidents in an after-action report and a general  requirement to provide a report after completing follow-up activities.  Additionally, internal control standards specify, among other things, the  need for significant events to be clearly documented.

In addition to the checklist requirements, NARA’s Chief Operating Officer  told us about specific steps NARA is to take when boxes of records get  wet. For example, based on the volume of records that are involved and  available resources, boxes are to be air dried and stored in an onsite  freezer or in freezer trucks to minimize the growth of mold and prevent or  reduce potential damage to records. Boxes of records are then to be  individually removed, treated, and dried, or sent to a contractor that can  freeze dry various types of records. NARA is also to use in-house  restoration services, such as industrial fans, for incidents that are  considered minor. For major incidents (where affected records are not  expected to be available to the agency that owns them for more than 48  hours), NARA’s process indicates that it will work with a contractor for  drying services.

NARA generally followed its process to prevent damage to records when  incidents occurred. Documentation that we reviewed for 55 incidents that  NARA reported as occurring from January 2009 through March 2013  indicated that the agency had taken steps consistent with its Emergency  First Response for NARA Records checklist. For example, NARA  provided documentation of steps taken to handle incidents at the  Washington National Records Center and at the National Personnel  Records Center in Valmeyer, Illinois from March 2011 through August  2012.

Specifically, at the Washington National Records Center:

A roof leak incident in March 2011 impacted 47 cubic feet of records  stored at the center. According to NARA’s documentation, 2 cubic feet  of records were placed on drying racks and dried, 3 cubic feet of  records were reboxed, and the remaining records were air dried in  their original boxes.

During another roof leak at the center in May 2011, a large number of  boxes of records became wet. NARA staff noted the locations of the  leaks, notified management, and took steps to address the incident.  The staff initiated triage efforts to relocate the records to another area  to determine how the incident had affected the records. While some  records were air dried, those that were substantially wet were placed  in a freezer truck. After the records were held in the freezer truck for  several days, NARA reassessed them, and removed and reboxed  records that had dried. The remaining 252 cubic feet of wet records  were freeze dried at an offsite facility. NARA documented the actions  it took to address the wet records and the center director notified the  affected agencies.

A roof leak that occurred at the center in June 2011 affected 7 cubic  feet of records. NARA documented the actions it took, noting that 5  cubic feet of records were reboxed, and the remaining records were  air dried.

Another roof leak later that month resulted in a large number of boxes  of records becoming wet. NARA staff noted the locations in which the  leaks occurred, notified management, and took actions to address the  records involved in the incident. The staff initiated triage efforts to  relocate the records to another area and determine the level of  severity for the affected records. Records that could be dried with  minimal effort were removed from boxes and placed on pallets to  begin the air-drying process onsite. Records that were found to be  substantially wet were placed in a freezer truck. After the records  were held in the freezer truck for several days, NARA reassessed  them and determined that some of the records had dried. While the  dry records were removed from the freezer truck and reboxed, 414  cubic feet of records were freeze dried at an offsite facility. NARA  documented the actions it took to address the wet records and the  center director notified the affected agencies.

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

A sprinkler leak in August 2012 affected 27 cubic feet of records. Five  of the 27 cubic feet of records were determined to not be wet and 18  cubic feet of records were removed from the location and dried. The  remaining 4 cubic feet of records were reboxed.

While NARA has taken steps to minimize damage to records, the agency  has not tracked the results of its efforts in all cases. For example, of the  55 incidents, NARA provided documentation that verified that the actions  it took in responding to 46 incidents resulted in no permanent damage to  records. For the remaining 9 incidents, officials stated that NARA’s  actions prevented permanent damage to records; however, the agency  could not provide documentation that would allow us to verify this  assertion. For example, NARA could not provide documentation that  described the results of its efforts to prevent permanent damage to 6  cubic feet of records that became wet due to faulty floor and roof drains at  the Chicago Federal Records Center in June 2011. A contributing factor  is that while the NARA 1561 checklist provides generally defined  requirements for final reporting, it does not require the federal records  centers to document the results of the actions they have taken to prevent  permanent damage to records that were at risk. As a result, NARA is not  positioned to fully report on the effectiveness and outcome of its actions  to minimize damage to records and does not have an institutional record  that a third party can use to validate the results of its efforts.

section_title: Federal Record Centers Storage Fees Are Developed Annually and Are Comparable to Commercial Vendors’ Fees
paragraphs: The Treasury and General Government Appropriations Act, 2000,  established a Records Centers Revolving Fund to pay for expenses and  equipment necessary to provide storage and related services for federal  records. Accordingly, the Federal Records Centers Program and  NARA’s Office of the Chief Financial Officer are responsible for annually  developing the fees charged to agencies for records storage and related  services. These fees are to be developed for the upcoming fiscal year  using the current fiscal year fee schedule, expense projections, and  workload projections for NARA’s records centers. In determining the fees,  it is to consider costs associated with full operation of the records storage  facilities, taking into consideration expenses, such as reserves for  accrued annual leave, worker’s compensation, depreciation of capitalized  equipment and shelving, and amortization of IT software and systems.  Annually, all federal records centers are required to submit expense and  workload projections to the Federal Records Centers Program  headquarters operation. The expense and workload projections are used  to develop budget and revenue projections, which are then used as the  basis to develop rates for the upcoming fiscal year. Factors such as  inflation, customer impact, the frequency of rate change, and  competitiveness with the private sector are then considered when  developing new rates.

The fees developed for the upcoming fiscal year are approved by the  Director of the Federal Records Centers Program, Executive for Agency  Services, Chief Financial Officer, and Chief Operating Officer before  receiving final approval from the Archivist. According to NARA officials  responsible for managing the Federal Records Centers Program, the  newly developed fees are then used at all federal records centers for the  upcoming fiscal year.

Storage fees charged by NARA in fiscal year 2013 were comparable to  fees charged by commercial vendors on the GSA schedule in that same  time frame. Specifically, of the 12 commercial vendors that provided  storage services for 11 federal agencies, 5 had price lists that were  posted on GSA’s Federal Acquisition Service webpage. Table 6 provides  a comparison of storage fees for NARA and these 5 commercial vendors  for fiscal year 2013.

As shown in the table, NARA’s fee of $0.23 per cubic foot was consistent  regardless of the storage quantity. Specifically, NARA’s fee was higher  than fees charged by vendors 1 and 2, although its fees were lower than  those of vendors 3 and 5. In addition, NARA’s fees were lower than those  of vendor 4 if storing less than 100,000 cubic feet and higher if storing  100,000 or more cubic feet. NARA also did not charge additional fees that  certain vendors charged. Specifically, vendors 1, 3, and 4 applied a $65,  $25, and $100 fee, respectively, to a customer’s account when the  storage charges did not meet the customer’s contractual minimum  storage requirement. In addition, vendor 4 charged an administration fee  of $25.12 or $62.80 per account, respectively, for summary or detailed  billing.

section_title: Conclusions
paragraphs: Although federal regulations call for records to be stored in one of three  types of facilities—NARA-operated federal records centers, agency  records centers, or commercial records storage facilities—the extent to  which agency and commercial facilities are used to store records is  uncertain because NARA does not know where all agencies store their  records. NARA’s efforts to collect data from agencies about the facilities  they use to store records have yielded data that are incomplete, outdated,  and of questionable validity.

NARA has determined that most of its federal records center facilities are  fully compliant with the standards established in regulations, but that four  facilities are partially or entirely noncompliant—a situation that increases  the risk of damage to the records stored in the facilities. Although it has  plans for bringing these four facilities into full compliance with the  regulations, NARA has not established dates for completing its plans at  two of the facilities. As a result, NARA does not have a basis for  determining progress toward correcting deficiencies in those facilities that  do not fully meet the standards  Additionally, although NARA has taken steps to prevent permanent  damage to records in their facilities on a total of 55 occasions over a  recent 4-year time period, the federal records centers did not always keep  track of the results of their efforts and were unable to provide  documentation confirming they were successful in 9 cases. Therefore,  NARA is not positioned to fully report on the effectiveness of its actions to  minimize permanent damage to federal records.

section_title: Recommendations for Executive Action
paragraphs: To assist NARA in its responsibility to ensure that federal records are  stored in compliant facilities, we recommend that the Archivist of the  United States direct the Chief Operating Officer to take the following three  actions:

Place increased priority on the collection of complete, current, and  valid information from agencies about their use of agency and  commercial records storage facilities.

Develop a schedule for executing plans to resolve issues at each of  the federal records centers that is not fully compliant with 36 C.F.R  Part 1234.

Clarify NARA’s checklist for handling incidents that may involve  permanent damage to records by including a requirement to  document the results of the steps taken to minimize permanent  damage to records.

section_title: Agency Comments and Our Evaluation
paragraphs: NARA provided written comments on a draft of this report, which are  reprinted in app. II. In its comments, the agency concurred with all three  of our recommendations for executive action regarding facility inspections  and other areas related to safe storage of federal records. In addition, we  received technical comments via email from NARA, which we have  incorporated as appropriate.

We are sending copies of this report to the appropriate congressional  committees; the Archivist of the United States; and other interested  parties. This report also is available at no charge on the GAO website at  http://www.gao.gov.

Should you or your staffs have any questions on information discussed in  this report, please contact me at (202) 512-6304 or melvinv@gao.gov.  Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this report. GAO staff who made  major contributions to this report are listed in appendix III.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to (1) determine the types of facilities agencies use  to store federal records and the extent to which NARA’s data on  agencies’ use of storage facilities are complete, (2) evaluate the extent to  which NARA has determined these facilities to be compliant with  standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has  taken to minimize damage to records in federal records centers and the  extent to which it documents such efforts, and (4) determine how NARA  determines storage fees and whether fees differ among facilities.

To accomplish the first objective, we reviewed 36 C.F.R. Part 1234 and  developed a thorough understanding of the regulation through  discussions with NARA officials who are responsible for administering it.  We then obtained lists of NARA, agency, and commercial records storage  facilities from NARA. These lists included NARA’s central registry of  approved facilities. We corroborated the lists by comparing them with  other documentation such as facility approval memoranda and inspection  schedules, as well as through interviews with agency officials.  Additionally, we obtained NARA’s database of agencies’ records storage  facilities and discussed NARA’s methods for populating the database with  responsible NARA officials. We determined the database to be unreliable  because it was incomplete, outdated, and largely reliant on self-reported  data from agencies.

For the second objective, we obtained and reviewed memoranda from  NARA that indicated approval of NARA, agency, and commercial records  storage facilities and the facilities’ compliance with 36 C.F.R. Part 1234.  We then used additional documentation, including detailed facility  inspection checklists, fire inspection reports, and structural engineering  reports to determine the existence of support for NARA’s approval  determinations. We also discussed NARA’s method for approving and  inspecting facilities, in addition to plans for conducting future facility  inspections with the officials who are responsible for performing the  inspections.

To accomplish the third objective, we reviewed NARA policies and  procedures for the storage and management of federal records and  compared them with applicable internal control standards. We also  reviewed procedures for handling records damage in NARA records  centers and documentation relative to records emergency planning and  training. We collected and analyzed documentation on 55 incidents that  occurred at NARA records centers from January 2009 through March  2013, including reports that described NARA’s actions to mitigate or  reduce records damage. We also compared requirements in NARA’s  1561 checklist to the documentation described above. Further, we  interviewed NARA officials to determine the actions taken to minimize  records damage in federal records centers and corroborated the officials’  statements with aforementioned documentation.

To accomplish the fourth objective, we obtained and analyzed  documentation from the NARA Federal Records Centers Program and  General Services Administration (GSA) schedules that identified and  discussed records storage fees and then compared fees among records  storage facilities. To determine the reliability of the data provided from  NARA, we performed basic steps to ensure the data provided were valid,  and reviewed relevant information describing the data. We reviewed  documentation related to the data sources, including NARA’s fiscal year  2013 fee schedule, fee determination process description documents,  and workload and expense projections. Although we could not  independently verify the reliability of all this information, we compared the  data with other available supporting documents to determine data  consistency and reasonableness. We also obtained price lists from GSA’s  website for commercial vendors that listed facilities that are compliant  with 36 C.F.R. Part 1234. We did not determine whether individual  agencies had negotiated lower prices than those listed in the price lists.  We compared storage fees for NARA and commercial vendors by  extracting fee data from NARA’s fee schedule and commercial vendor  price lists. For our comparison, we reviewed the publicly available price  lists for five commercial vendors (referred to as vendors 1-5 in our  analysis). Four of the five vendors’ price lists charged storage fees based  on cubic feet of storage per month and the fifth vendor charged based on  the number of boxes stored. In order to directly compare fees  established by NARA and the five vendors, we converted boxes to cubic  feet for vendor 5. Storage fees were then arranged in order from lowest to  highest.

We supplemented our analyses with interviews of NARA officials who are  knowledgeable about the Federal Records Centers Program, including  NARA’s Chief Operating Officer, the program director, and assistant  director. We also interviewed representatives of private sector record  storage companies that were relevant to our study.

We conducted this performance audit from November 2012 to September  2013 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

section_title: Appendix II: Comments from NARA

section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact name above, the following staff also made key  contributions to this report: Mark Bird, Assistant Director; Sharhonda  Deloach; Elena Epps; Rebecca Eyler; Jacqueline Mai; and Constantine  Papanastasiou.


Question-summary annotations: questions: question: What does NARA know about the agencies use of records storage facilities?
answer: These facilities notwithstanding, NARA does not know where all agencies are storing records.
child_questions: question: Why does NARA not know where all agencies are storing records?
answer: NARA has solicited data from agencies about their use of agency records centers and commercial records storage facilities, but not all agencies have submitted data. Further, the data agencies submitted--mostly from 2008 and 2009--are now outdated.
child_questions: question: What are the results of missing and outdated data?
answer: As a result, NARA cannot be assured that all agencies are using one of the three types of authorized facilities.

question: What data has NARA solicited from agencies?
answer: NARA has solicited data from agencies about their use of agency records centers and commercial records storage facilities, but not all agencies have submitted data.

questions: question: Why were some of the federal records center facilities not fully compliant with 36 C.F.R. Part 1234?
answer: NARA determined that 20 of its 24 federal records center facilities were fully compliant with 36 C.F.R. Part 1234 because all of their bays satisfied the regulation; of the remaining 4, 2 facilities with inadequate shelving were partially compliant, 1 facility with insufficient protections against pipe leaks was not compliant, and the remaining facility was to be replaced.
child_questions: question: How did NARA deal with the 4 facilities' lack of full compliance as of July 2013?
answer: As of July 2013, NARA had plans to bring these 4 facilities into full compliance, but did not have a schedule for completing the plans at 2 of the facilities.
child_questions: question: What is the result of a lack of schedule for completing the plans?
answer: As a result, NARA does not have a basis for determining progress toward correcting deficiencies in those facilities that do not yet fully meet the standards.

question: What is NARA's progress on the inspections of all facilities?
answer: Also, while NARA had approved 10 agency records centers and 22 commercial records storage facilities, it has inspected 1 of 18 agency records centers and 13 commercial records storage facilities.
child_questions: question: What is the result of incomplete planned inspections of all remaining facilities?
answer: Until NARA completes planned inspections of all remaining facilities, it cannot be reasonably assured that agencies are storing records in facilities that meet standards.

questions: question: How are storage fees determined?
answer: Storage fees are determined by NARA's Federal Records Centers Program and the Office of the Chief Financial Officer using the existing fee schedule, expense projections, and workload projections.

question: How did the storage fees charged by NARA compare to those charged by commercial vendors in fiscal year 2013?
answer: The storage fees charged by NARA in fiscal year 2013 were comparable to fees charged by commercial vendors in that same time frame.
child_questions: question: In what ways were the storage fees charged by NARA comparable to fees charged by commercial vendors?
answer: For example, NARA's fee of $0.23 per cubic foot was higher than fees charged by two vendors and lower than fees charged by two other vendors.

questions: question: What was GAO requested to do with the program?
answer: GAO was requested to conduct a study of key aspects of the program.
child_questions: question: What are the GAO's objectives?
answer: GAO's objectives were to (1) determine the types of facilities agencies use to store federal records and the extent to which NARA's data on agencies' use of storage facilities are complete, (2) evaluate the extent to which NARA has determined these facilities to be compliant with standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has taken to minimize damage to records in federal records centers and the extent to which it documents such efforts, and (4) determine how NARA determines storage fees and whether fees differ among facilities.
child_questions: question: How did GAO achieve its objectives?
answer: To do so, GAO obtained, analyzed, and corroborated documentation on records storage facilities, identified and compared records storage fees, and interviewed NARA officials.