August 27, 1998
National Archives and Records Administration Holds Final Meeting of Electronic Records Work Group
On Wednesday, August 26, 1998, an all-day meeting of the National Archives and Records Administration (NARA) Electronic Records Work Group, held at the National Archives College Park facility, produced a substantive and lively exchange of ideas on proposed recommendations for alternatives to NARA's General Records Schedule (GRS) 20 for Electronic Records. The meeting was attended by nine NARA staff members, including Lewis Bellardo, Deputy Archivist of the United States, and Michael Miller, director of Modern Records Programs, who chaired the meeting. Approximately 30 members of the public observed the meeting.
The meetingís purpose was to discuss some 45 comments in response to a Federal Register notice of the groupís tentative recommendations. A number of questions arising out of those comments formed the agenda for the meeting. Among the most important of the issues discussed were:
- Are the timeframes for agencies to submit schedules or plans for handling their e-mail and word processing documents realistic? There was a strong sense from a number of the members that the established timeframes should remain, albeit with some caveats, such as allowing agencies to ask for exceptions. The Work Group will continue to discuss this issue.
- Should NARA give priority for scheduling historically important documents? The Work Group will include suggested categories of records that agencies should consider for priority attention when developing the plans to schedule their electronic source records. Examples might include records of historical interest, unscheduled records, and mission-critical records.
- Should NARA be providing guidance for electronic record keeping? It was decided that the Final Report to the Archivist would include a recommendation that this issue be considered in the follow-on group.
- Should there be a separate glossary of terms for the report? It was decided that a glossary should be included to clarify the different terms used in the report.
Perhaps the issue that evoked the most discussion was the question of the wording of an item in Appendix D relating to the status of electronic source records after the recordkeeping copies have been produced. It was resolved that NARA members of the Work Group would capture the several different options discussed, and distribute them to the Work Group for additional comment.
The Work Group's draft report and associated draft work products were published in the Federal Register on July 21, 1998, for a 30-day comment period. Archivist John W. Carlin had encouraged interested persons and Federal agencies to submit their comments to the Work Group by the August 20 deadline announced in the Federal Register notices.
Mr. Carlin established the Electronic Records Work Group in November 1997 to review issues relating to the creation, maintenance, and disposition of certain types of electronic information, focusing on General Records Schedule 20. GRS-20 was developed to provide guidelines to Federal agencies on the disposition of electronic-mail and word-processing records once they had been copied to a paper, microfilm, or electronic recordkeeping system for management and retention. In a subsequent court opinion, a Federal district judge declared that portions of GRS-20 reached beyond the authority of the Archivist under the Federal Records Act, and declared GRS-20 "null and void." The decision is being appealed by the government on the authority issue, but Mr. Carlin determined that records disposition practices could be improved to be sure that programmatic records are protected, that schedules for the disposition of records are not medium-oriented, and that records schedules are devised so that Federal agencies can and will use them. Mr. Carlin charged the work group to do the following:
- review the current version of GRS 20;
- identify appropriate areas for revisions;
- explore other approaches for authorizing disposition of electronic records;
- identify methods and techniques that are available with current technology to manage electronic records properly and provide ready access to essential evidence; and,
- recommend practical and implementable solutions for the disposition of electronic records.
For additional PRESS information, please contact the National Archives Public Affairs staff at (301) 837-1700 or by e-mail.