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Comments by the Society of American Archivists on NARA's "Proposal
for a Redesign of Federal Records Management"
Prepared for SAA by its Electronic Records Section, and
endorsed by its Government Records Section and SAA Council
11 September 2002
Executive Summary
SAA would like to commend NARA for the considerable research and analysis
represented in this document. Realistic recordkeeping strategies require
an understanding of the current practices and constraints faced by government
agencies. NARA openly recognizes that many aspects of the current recordkeeping
regime are not working as intended. In order to improve this situation,
NARA must present procedures, services, tools and facilities to agencies
that are perceived as adding value, rather than simply imposing additional
administrative burdens.
Given NARA's limited resources and the vast number and heterogeneity
of recordkeeping systems in the federal government, we agree that it is
essential to "empower agencies to determine for themselves how
best to manage their records," but we would also like to emphasize
the importance of the qualifier that NARA includes with this statement:
"within general parameters provided by NARA." While NARA cannot
take part directly in the design, procurement and implementation of every
new electronic information system in the federal government, it can develop,
disseminate, maintain, and actively promote detailed guidance on how best
to build recordkeeping requirements into new systems. Consistent with
NARA's proposal to move away from a narrow focus on the distinction between
records and nonrecords, such guidance could adopt language that is more
inclusive of the considerations involved in developing and maintaining
trustworthy information systems. In addition to some degree of direct
involvement by NARA staff, this may be an area in which NARA could apply
its "training, certification, and monitoring program for contractor
staff who offer technical assistance."
We would warn NARA against the concept of "pre-accessioning"
electronic records in the federal records center (FRC), and instead treat
the FRC service more like full-fledged accessioning. Apart from the important
stipulation of leaving the reference load and Freedom of Information Act
(FOIA) fulfillment responsibilities with the creating agencies, it is
not clear what it would mean for NARA to offer an electronic records FRC
as a means to "take on the preservation responsibilities for the
agencies prior to legal accessioning." Rather than seeing ingest
into the Electronic Records Archive (ERA) as a separate and distinct process,
NARA should address the ERA's requirements with any transfer of electronic
records to NARA, even if those records are not considered permanent.
We would recommend that NARA further clarify several issues. First,
it is not clear what sort of retention period might qualify records as
candidates for transfer to the FRC. We specifically recommend that NARA
consider and explicitly decide whether or not the FRC will provide preservation
services for records with temporary but not permanent value. Second, we
raise some questions related to the details of FRC transfer procedures.
Third, we would find it helpful for NARA to further elaborate on how agency
and NARA responsibilities for FRC services would be identified and assigned.
Fourth, and perhaps most importantly, we raise some cautionary notes about
the large financial and technical implications of offering a free FRC
for electronic records. Finally, we suggest a reconsideration or refinement
of the term "continuing value (CV) records."
Most of all, we applaud NARA for looking with fresh eyes at the issues
associated with modern records management. We hope that this redesign
of records management can serve as guidance not only for NARA and federal
agencies but also to many others struggling with an increasingly complex
records universe with very limited resources. Many of the ideas expressed
in the paper need to be tested to see if they can actually improve the
records management process, and we hope that NARA will continue to actively
test and refine its thinking on these important issues.
1. Introduction
In response to the request for comments on the National Archives and
Records Administration's "Proposal for A Redesign of Federal Records
Management" available at <http://www.archives.gov/records_management/initiatives/rm_redesign_project.html>,
the Society of American Archivists (SAA) submits the following document
[1]. SAA is the oldest and largest association
of professional archivists in North America. Representing more than 3,000
individuals and 400 institutions, the SAA is the authoritative voice in
the United States on issues that affect the identification, preservation,
and use of historical records.
The SAA commends NARA on its recent and continuing efforts to face the
daunting challenge of managing and preserving the records of the federal
government. NARA's call for comments on the "Proposal for A Redesign
of Federal Records Management" represents not only a bold move in
taking leadership on these issues but also a willingness to engage with
the larger archival community in their discussions. We appreciate the
opportunity to comment on such a groundbreaking effort.
2. Comments on the Records Management Background and Challenge
SAA would like to commend NARA for the considerable research and analysis
represented in this document. Realistic recordkeeping strategies require
an understanding of the current practices and constraints faced by government
agencies. NARA openly recognizes that many aspects of the current recordkeeping
regime are not working as intended. According to the "Proposal for
a Redesign," "a vast majority of retention schedules are out
of date, inaccurate, or nonexistent. A large majority of electronic records
series of continuing value are not coming into archival custody."
In order to improve this situation, NARA must present procedures, services,
tools and facilities to agencies that are perceived as adding value, rather
than simply imposing additional administrative burdens.
3. Comments on Breaking Down the Barriers
Given NARA's limited resources and the vast number and heterogeneity
of recordkeeping systems in the federal government, we agree that it is
essential to "empower agencies to determine for themselves how
best to manage their records," but we would also like to emphasize
the importance of the qualifier that NARA includes with this statement:
"within general parameters provided by NARA."
3.1 Addressing Recordkeeping Systems, Not Just Records
One proposed change that the SAA can heartily endorse is the decision
to move away from distinctions between "record" and "nonrecord"
in records management systems. In archival theory, the definition of what
is a record is of great importance, as Mark Greene has recently argued
in his article "The Power of Meaning: The Archival Mission in the
Postmodern Age."[2] From a practical records management perspective,
however, the distinction between records and nonrecords is often more
confusing than it is enlightening. NARA proposes quite properly to change
its focus to record keeping systems, rather than individual records.
Consistent with NARA's proposal to move away from a narrow focus on the
distinction between records and nonrecords, such guidance could adopt
language that is more inclusive of the considerations involved in developing
and maintaining trustworthy information systems. A long-standing maxim
of electronic records work is that archivists and records managers must
get involved as early in the record life cycle (or continuum) as possible.
Ideally, this should involve active guidance on the design of systems
before any records have even been created. While NARA cannot take part
directly in the design, procurement and implementation of every new
electronic information system in the federal government, it can develop,
disseminate, maintain, and actively promote detailed guidance on how
best to build recordkeeping requirements into new systems [3].
We believe that it is important to distinguish between two areas of
consideration:
- NARA's priorities for focusing its own resources.
- The content of services, assistance, policies, guidance and tools
that NARA offers to agencies.
For the first, we agree with NARA's suggestion in the document that
it should focus more precisely on areas of high accountability, rights,
risk, and preservation value. This should ideally be based on what NARA
knows or can discover about the operations, business and functions of
the agencies and the federal government more generally. How such an approach
would work in practice is one of the great unanswered questions, and we
therefore support NARA's efforts to investigate further, ideally through
pilot projects, how exactly a more high-level functional approach to records
management would work.
As regards the services, assistance, policies, and guidance that NARA
can offer to agencies, we would contend that much of the focus should
be on systems. Agencies tend to plan, design, manage and migrate data
at the system level. As NARA points out this document, agencies are often
either unable or unwilling to prioritize their own efforts in terms of
a strict definition of the word "records." From the perspective
of agencies, the implementation of recordkeeping requirements makes the
most sense if it can be framed in terms of designing, developing, managing
and using the agencies systems. While the ultimate goals of NARA are to
ensure the capture, management, preservation and access to the essential
evidence that the systems contain, these larger goals can best be achieved
through language and methods that address the specific system characteristics
that agencies confront on a daily basis.
In order for such guidance to serve its intended purpose, it should be
advocated and supported by individuals with sufficient expertise in
both records management and the design and implementation of information
technology. Since such human resources are limited, involvement in system
design and management could conform to the same prioritization and graduated
approach that NARA is proposing more broadly in this document. The most
attention could be paid to government functions and systems that involve
the most rights and accountability, continuing value and risk. It is
important, however, not to frame these priorities primarily in terms
of the records that meet these criteria. In order for NARA's
strategy to be scalable, it should attempt to address the most important
recordkeeping systems before the records themselves have been created.
Contributions could include, among others:
- model language for requests for proposals (RFPs),
- suggestions for the purchasing and bidding process,
- tools for introducing recordkeeping into an agency's system development
life cycle,
- guidance and training on addressing recordkeeping in standard project
management methodologies.
In addition to some degree of direct involvement by NARA staff, this
may be an area in which NARA could apply its "training, certification,
and monitoring program for contractor staff who offer technical assistance."
These concerns are particularly important if NARA is to take the more
active role in the custody of electronic records that it proposes. According
to the "Reference Model for an Open Archival Information System (OAIS)," [4]
the "ingest" of digital objects into an archival repository
requires that the digital objects follow certain submission information
package (SIP) conventions. An OAIS ingest scenario is much more feasible
if NARA has provided agencies with specific guidance on the forms and
formats of digital objects.
3.2 Rethinking the Concept of a Federal Records Center for Electronic
Records
NARA should establish clear conventions for the submission of digital
objects, not only to the Archives for long-term preservation, but also
to its proposed electronic federal records centers (FRC). In an environment
of paper records, the FRC plays a dual role: (1) providing agencies with
intellectual and physical control of their semi-active records, and (2)
serving as a point of transition from agency custody to NARA custody of
records. For electronic records, both of these roles require that records
conform to certain format, encoding and metadata requirements before they
are transferred to the FRC.
It is for this reason that we would warn NARA against the concept of
"pre-accessioning" electronic records in the FRC, and instead
treat the FRC service more like full-fledged accessioning. Apart from
the important stipulation of leaving the reference load and Freedom of
Information Act (FOIA) fulfillment responsibilities with the creating
agencies, it is not clear what it would mean for NARA to offer an electronic
records FRC as a means to "take on the preservation responsibilities
for the agencies prior to legal accessioning." When NARA accepts
paper records into the FRC, it takes certain measures and issues certain
guarantees about the physical protection that those records will receive.
When accepting electronic records into the FRC, these measures and guarantees
become much more involved and resource-intensive (persistent naming, media
refreshment, periodic data transformations, etc.), in order to ensure
the accessibility and understandability of those records. Once such measures
and guarantees are made, it would seem that the records have then been
ingested by NARA into its Open Archival Information System (OAIS) [5]. Thus,
rather than seeing ingest into the Electronic Records Archive (ERA) as
a separate and distinct process, NARA should address the ERA's requirements
with any transfer of electronic records to NARA, even if those records
are not considered permanent.
With paper records, transfer from agency to FRC to Archives involves
the movement of one physical object. In a digital environment, one can
store any number of copies of the same object in multiple locations at
very little cost. Disposition of records can, therefore, be treated quite
differently. It is not necessary to wait until the end of a retention
period for a disposition act of "transfer to Archives" to be
triggered. If the long-term preservation value of given records is already
known, copies of those records can be transferred to the Archives any
time after they have been created. During their period of active use within
the agency, it is quite likely that the agency would continue to rely
on its own internal copies of records that reside in its active systems,
rather than relying on the copies [6] that are being maintained within the
FRC. The difference between the copies in the agency and the copies in
the FRC would be that the former are being managed in a way that optimizes
their short-term use, while the latter are being managed in a way that
ensures their ongoing reliability, authenticity, integrity and usability
to future users both within and outside of the creating agency.
While we agree with NARA that the descriptive metadata created for long-term
records should be more detailed than that for short-term records, there
are many recordkeeping, administrative and preservation metadata elements
that should be created or captured for all records within the FRC. Earlier
in the document, NARA states that "many electronic records are being
kept as backup tapes in tape libraries until systems are replaced or shut
down. At that point, if not sooner, records of continuing value are likely
to be lost." It is important that NARA's FRC for electronic records
not simply replicate such libraries of backup tapes. In order for the
FRC to serve what NARA states as its goal of "preservation work,"
it must make a significant commitment of resources to the proper ingest,
management and dissemination of digital objects. Otherwise, the FRC will
simply serve as a "bit repository" with no guarantee of appropriate
management, preservation or access. It is possible that NARA could decide
to offer only bit-level preservation services itself, while partnering
with third parties to provide the other components of the repository.
Such an arrangement, however, would take a great deal of explicit planning
and agreement. It would also be important for NARA to identify and manage
the risks associated with such a dependence on third parties.
3.3 Further Elaboration of FRC Functions, Responsibilities and Costs
We would recommend that NARA further clarify several issues related
to the electronic records FRC. First, it is not clear what sort of retention
period might qualify records as candidates for transfer to the FRC. Most
of the electronic records that are at risk in government are those with
a moderate-term retention (more than a year but less than permanent).
If it were to live up to the standard definition of records center, then
those moderate-term records should be transferred to the FRC in order
to save them from loss within the agency. If agency systems are updated
every 3-5 years, the records within them can be at risk. Apart from obsolescence,
deletion and migration issues, mismanagement within the agency is also
likely to become an issue once records have existed for some time within
the agency. Permanent records are obviously very important, but they also
represent only a tiny portion of the records universe. In order to add
value to agencies in the sort of "virtuous circles" that the
document describes, we recommend that NARA consider and explicitly decide
whether or not the FRC will provide preservation services for records
with temporary but not permanent value.
Another issue related to the FRC is that of transfer procedures. How
soon after creation should records be transferred to the records center?
2 seconds? 6 months? In batches?
Just-in-time? Since there can be any number of copies of the same records,
transfer could be implemented in many different ways. The transfer process
should also include provisions for avoiding widespread duplication. If
NARA were to ingest copies of records from active agency systems, future
ingests from those same systems could result in a great deal of redundancy.
This would seem to lend additional support to the argument that NARA should,
to the extent possible, assist agencies in ensuring that their internal
recordkeeping systems are appropriately designed, implemented, managed
and maintained. In order to address some of these issues, perhaps NARA
could identify several different transfer scenarios, depending on the
needs of the agency and the recordkeeping context.
We would also find it helpful for NARA to further elaborate on how agency
and NARA responsibilities for FRC services would be identified and assigned.
Provisions should include not only technical submission agreements [7] but
also legal issues such as who would be responsible for satisfying legal
discovery motions and, as mentioned previously, how responsibility for
reference and Freedom of Information Act (FOIA) duties would be fulfill
and possibly transferred over time. This may be an area in which the traditional
conception of "official records" needs further refinement. Since
exact copies of electronic records are both feasible and likely, it could
be case that the agency copy will be considered the official records for
purposes of FOIA but that the NARA copy is considered the archival copy,
i.e. the master from which preservation efforts and long-term access will
derive.
The final area, and perhaps the most important, is cost. Throughout
this document, NARA is careful to emphasize that its resources are quite
limited. We would caution NARA about the large financial and technical
implications of offering a free FRC for electronic records. If a free
records center for paper records is no longer a sustainable proposition
for NARA in the current political context, then it would seem that the
same would be true for electronic records. Perhaps NARA should consider
making either some or all of its electronic FRC services fee-based or
tied to some sort of in-kind contribution from agencies. Ultimately, we
feel the federal government should be providing NARA with considerably
more funding to fulfill these essential government services, and we see
future advocacy of this position as vital to NARA's mission. Even if more
funding is allocated to NARA in the future, however, there will always
be limits to its resources, and we recommend careful consideration of
the sustainability of any services that might be offered in this area.
3.4 Clarification of Continuing Value
If NARA is going to offer FRC services for electronic records, we would
also suggest a reconsideration or refinement of the term "continuing
value (CV) records." Strictly speaking, any records that are still
being purposely (as opposed to accidentally) retained—either for
a limited period as per a retention schedule or for an indefinite time
in the Archives—have been deemed to have continuing value. As NARA
is using the term in its discussion of resource allocation strategies
and agency profiles (e.g. Figure 6), it would seem that it is roughly
synonymous with "records with long-term retention value."
This seems to contradict NARA's claim elsewhere that "the term
'records of continuing value' is used interchangeably with 'records
documenting the national experience' and 'archival records.'"
In other parts of the document, the "national experience"
is listed as a consideration separate from business needs, rights and
accountability. Does this mean that CV is assessed on the basis of considerations
apart from business needs, rights and accountability?
Should one assume that all the records that NARA designates to be CV
are to be retained indefinitely, or are there CV records that have limited
retention periods? Is there a general range of retention periods that
would qualify as CV, e.g. more than 25 years? If identifying records as
CV is about more than simply their period of retention, what other factors
would be considered?
4. Comments on New Approaches to Scheduling and Appraising Records
As stated above, we laud NARA for its efforts in this area and its informed
recognition that "the current approach is not working." We agree
that a higher-level and more functional approach to the appraisal and
scheduling of federal records may make more effective use of NARA's limited
resources, and is certainly worth exploring further. We would suggest
that this Appendix might be enhanced by providing some examples, particularly
those that illustrate how the proposed retention standards would differ
from existing general retention schedule (GRS) or agency retention schedule
entries. It is also not clear what meaning and rationale are behind the
following statement: "Keep GRS 20 items 13 and 14 but continue to
add these items in at a high level to agency specific schedules."
Perhaps NARA could elaborate further on this point.
5. Conclusion
SAA lauds NARA's continuing efforts in redefining its approach to federal
recordkeeping. Historically, many other archival institutions have looked
to NARA as the model for how to approach records management and preservation.
"Proposal for a Redesign of Federal Records Management" represents
a bold new step in this long tradition. In addition to NARA's vital work
in contributing to the development of standards, policy, and legislation
to bolster the greater archival mission, we hope that this redesign of
records management can serve as guidance not only for NARA and federal
agencies but also to many others struggling with an increasingly complex
records universe with very limited resources. While we encourage and hope
for further clarification on several issues raised in NARA's document,
we see it as a promising step in the right direction, and eagerly await
the results of NARA's future investigations on the topic.
End Notes:
[1] The Electronic Records Section, a constituent unit of the SAA, is responsible
for most of the comments included here. The following individuals contributed
texts and comments during the process of drafting this document: Charles
Arp, Ohio Historical Society; Rosemary Pleva Flynn, University of North
Dakota; Robert Horton, Minnesota Historical Society; Geof Huth, New York
State Archives; Cal Lee, University of Michigan. The Electronic Records
Section includes members who are employees of the National Archives and
Records Administration. Those members have abstained from the formal process
of endorsing this document.
[2] Mark A. Greene, "The
Power of Meaning: The Archival Mission in the Postmodern Age," American
Archivist 65:1 (Spring/Summer 2002)
[3] For one excellent example
of such guidance, see Shawn P. Rounds and Mary P. Klauda, "Trustworthy
Information Systems Handbook," Saint Paul, Minnesota: State Archives
Department, Minnesota Historical Society, Version 4, July 2002, http://www.mnhs.org/preserve/records/tis/tis.html.
[4] "Reference Model for
an Open Archival Information System (OAIS)," Washington, DC: Consultative
Committee for Space Data Systems, 2002, http://www.ccsds.org/documents/pdf/CCSDS-650.0-B-1.pdf.
[5] According to the "Reference Model for an Open Archival Information
System," an OAIS is "An archive, consisting of an organization
of people and systems, that has accepted the responsibility to preserve
information and make it available for a Designated Community" (p.
1-11).
[6] It is our assumption that the FRC would rely on redundant storage.
[7] According to the "Reference Model for an Open Archival Information
System," a submission agreement is the "agreement reached between
an OAIS and the Producer that specifies a data model for the Data Submission
Session. This data model identifies format/contents and the logical constructs
used by the Producer and how they are represented on each media delivery
or in a telecommunication session" (p.22).
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