September 21, 1998
Archivist of the U.S. Announces Actions on Electronic Records
Washington, D.C.CArchivist of the United States John W. Carlin today announced actions he will take on the basis of recommendations in the report of an Electronic Records Work Group that he created last November. Mr. Carlin’s statement is attached. The full report of the Work Group is accessible on the web site of the National Archives and Records Administration at http://www.archives.gov/records-mgmt/policy/electronic-records-work-group.html.
By John W. Carlin, Archivist of the United States
On the Report of the Electronic Records Work Group
Of the National Archives and Records Administration (NARA)
21 September 1998
Electronic records pose the biggest challenge ever to recordkeeping in the Federal Government and elsewhere. How do we identify, manage, preserve, and provide on-going access to e-mail, word-processing documents, and other kinds of electronic records that are proliferating in formats, mushrooming in quantity, and vulnerable to quick deletion, media instability, and system obsolescence? There is no option to finding answers, however, because the alternative is irretrievable information, unverifiable documentation, diminished government accountability, and lost history. Such consequences have made it imperative that we act decisively and we have. Today I am announcing a new set of steps to deal with these issues. The steps are limited, and pertain to but one part of the problem, but coupled with other initiatives I will describe, they offer real hope that we can save the records society needs in the era of electronic information.
With this statement I am releasing to the public the report I received on September 14 from the Electronic Records Work Group, which I created to advise me on how the Federal Government should deal with the disposition of types of electronic records previously covered by General Records Schedule 20. At the same time, I am announcing the actions I will take in response to the group's recommendations. And I will describe additional steps by the National Archives and Records Administration to meet the challenges posed by electronic records. It is important that everyone concerned understand that revising GRS 20 is but one project among many that must be undertaken if we are to address the government's electronic records problems successfully.
Before anything else, however, I want to thank the Work Group for the admirable job it has done. This group, composed of NARA staff members and persons with relevant expertise in other Federal agencies, and aided by special consultants from outside the Federal Government, showed what can be accomplished when experts from the public and private sectors come together to work on a problem.
I formed the Work Group to review the 1995 version of GRS 20, which a Federal court has ruled null and void, to identify appropriate areas for revision, explore other approaches for authorizing the disposition of electronic records, identify methods and techniques for using 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. We adopted an open process, in which the Work Group held a series of public meetings and also invited public comment through a web site, an e-mail address, and Federal Register notices. In consequence I think we have raised understanding, both within government agencies and within the general public, of the scope and seriousness of electronic records issues, and the absolute necessity of addressing them.
There are no easy answers, and much work remains to be done, but I am impressed with the level of the dialogue in the group's meetings, and with the responses it received to requests for comment from Federal agencies, professional organizations, and the public. I thank everyone who contributed for taking the issues seriously and looking at them thoughtfully.
Clearly Federal agencies want to manage their electronic records -- indeed, all their records -- more effectively, and NARA has pledged to help them. I acknowledge that NARA must provide better leadership in this area. NARA has known of the need since at least 1985 when a Committee on the Records of Government declared the country "in danger of losing its memory" through the transition to the use of computers in creating records. Our Strategic Plan acknowledged that the government's management of electronic records has not been as effective as it could have been. Although NARA cannot change the past, we can be aggressive now and in the future, and we must do so to ensure that essential evidence in electronic records is properly preserved.
Electronic records are here to stay; they are the present and the future. The Federal Government already is creating, keeping, and using them in large quantities. In most cases the government is not managing electronic records to the extent necessary for them to serve as the sole form of record for all aspects of its business or for the sole form of the archival record. NARA has traditionally focused on the preservation of those records that the agencies considered their "recordkeeping copies," and for documents such as memoranda and correspondence, most agencies still maintain most of their recordkeeping copies in paper. NARA would like to accession electronic mail and word processing records from electronic recordkeeping systems, but until electronic records have the integrity and reliability of records maintained in a recordkeeping system, they cannot be used as the record copies.
Currently, agencies' capabilities for managing their electronic records are limited at best. Electronic document management software is only now being developed. As is expected with all new technologies, agencies report mixed results. NARA has not developed sufficiently robust guidance to enable agencies to undertake electronic recordkeeping initiatives with confidence that their time and money will be well spent. Draft guidance NARA has provided on requirements for electronic recordkeeping systems is dated and needs a comprehensive NARA review followed by discussions with Federal agencies, software developers, and potential users. And even if a Federal agency were to decide to adopt a records management application today, actual implementation would not begin for at least two years because of time required for planning and budgeting cycles. Right now, agencies are too busy trying to solve their computer systems' Year 2000 problems, which must be fixed by a deadline that cannot be put off, to devote the necessary resources to implementing new requirements for electronic records management.
There are issues on the archival side as well. At this time, NARA has only limited ability to accept into our archives and preserve office automation records in their "native" formats. Although we are taking steps to do more, currently we can only make preservation copies of such files to avoid loss of data. We cannot archivally process, describe, and provide ready access to such records. Nor have NARA's overall records management and archival regulations been updated to address systematically the recordkeeping and archival issues raised by the transition to electronic records. And many of the guiding principles pertaining to paper records in archival and records management theory need to be rethought for the electronic age.
Most of these problems are described in our Strategic Plan, where strategies are identified to address them. In order for the government to be able to move away from its bias in favor of paper as the record of choice, NARA must do the following:
- Take initiative in resolving electronic records issues;
- Represent the government's recordkeeping needs in information policy and
- Create innovative guidance on electronic records;
- Bring together both the public and private sectors to develop workable applications and
standards for preserving and providing access to electronic records;
- Encourage agencies to implement electronic recordkeeping systems, recognizing that agencies must balance the desire of many users to have electronic access to important documents with the need agencies have to find financial resources and technical capabilities for managing and preserving records created electronically.
NARA and other Federal agencies have to develop both long-term plans for dealing with the many electronic records issues, and practical short-term solutions that can be implemented today under current limitations and in the existing environment. The challenge is to balance a solution toexisting problems with a commitment to future progress. The steps outlined below are not the ultimate solution but constitute first steps in new directions called for by NARA's Strategic Plan.
NARA will begin by adopting the four key recommendations in the Work Group's report as NARA policy. NARA's implementation of this policy will need to be consistent with our overall approach to electronic records issues and with relevant professional archival and records management principles. NARA's actions also must be responsive to the decision of the court in the GRS 20 case, address issues raised in comments on the Work Group's report, and be practical in light of agencies' technical and resource limitations. NARA will take the following actions under each of the Work Group's recommendations:
1. Agencies must schedule their program and unique administrative records in all formats. I agree. The Work Group proposed several options and models for implementing this recommendation, which it circulated for public and agency comment as part of the preliminary report in July. In response to extensive commentary, NARA is now working to revise the scheduling proposal outlined in the Work Group's report (Appendix C) with respect to the three scheduling models. The revision will be issued as a draft NARA Bulletin, which NARA will have ready for review by October 9. In light of the concerns that numerous agencies raised about the complexity, cost, and far-reaching impact of the Work GroupÆs draft recommendations, the Office of Management and Budget (OMB) has asked NARA to circulate the draft Bulletin for review prior to its final issuance. We agree with OMB on the need to ensure that the approach adopted in the final Bulletin will be feasible and will not interfere with the Federal agenciesÆ activities to address their Year 2000 problems.
Based on comments, we will revise some of the Work Group's proposals, such as the recommendation that agencies submit with each schedule a questionnaire documenting their recordkeeping practices. There are too many questions about the role of such a questionnaire in the scheduling process and the burden it could impose on agencies. I do acknowledge, however, that as part of our oversight responsibility, NARA needs to review the effectiveness of all agencies' recordkeeping programs, and we must find ways to do this more regularly than our current records management evaluation program provides.
2. NARA should modify General Records Schedules 1-16, 18, and 23 to authorize the deletion of electronic source records, including those generated with office automation systems, that correspond to administrative records covered by those GRS, after a recordkeeping copy has been produced. I agree. We will act on this recommendation, which is consistent with my belief that general records schedules are appropriate for scheduling common administrative records, and that schedules should cover all media. NARA will publish the GRS, revised as recommended, in the Federal Register by October 9, 1998, for public comment..
3. NARA should promulgate a new general records schedule for information technology records. Again, I agree. The Work Group's preliminary report in July included a proposed IT general records schedule, which received extensive comment. NARA will develop an IT schedule based on the commentary and the Work Group's recommendations, and publish it for comment through the Federal Register by March 15, 1999.
4. The Archivist should establish a follow-on group that continues to work on electronic recordkeeping guidance issues for Federal agencies. I agree because this is an integral part of our business process re-engineering of how Federal records overall are identified, appraised, scheduled, and tracked while in agency custody. The Work Group did not have time to address all guidance issues fully, but agencies need additional assistance soon. They cannot be expected to have effective recordkeeping systems until NARA provides adequate recordkeeping guidance. Therefore, working with Michael Miller, director of NARA's Modern Records Program, I will establish a follow-on group by January 1999 to develop an overall strategy for addressing electronic recordkeeping and come up with a series of tools including basic functional requirements for electronic recordkeeping systems.
With these steps, NARA and Federal agencies will begin to ensure that all electronic records are appropriately scheduled. However, I want to caution everyone that this will take time. It could take two years or more for some agencies to complete rescheduling all records previously covered by GRS 20. Even assuming that an agency submitted schedules within 180 days of issuance of a NARA Bulletin, NARA's review, including time required for public notice and comment, would take another 120 days, for a total of ten months or more. Any significant objections to or problems with proposed schedules would lengthen the process. We estimate that there may be as many as 200,000 individual dispositions that the more than 300 executive agencies and agency components will have to review in preparing the hundreds of schedules that they will submit to NARA. By comparison, NARA normally processes between 5,000 and 6,000 dispositions annually.
Following this announcement of my response to the Work Group's recommendations, the government will be updating the court with the status and the expected course of our activities, and will be addressing the impacts that agencies may be facing.
In addition to taking the steps listed above, NARA is aggressively pursuing several electronic records initiatives called for under our Strategic Plan. One of the most critical is the re-engineering I mentioned earlier of our entire process for appraising and scheduling records in all formats. The project will assess the applicability in the electronic age of fundamental records management and archival practices, and it will deal with issues raised in the Work Group report, such as appraising records that exist in multiple media or formats, the role of changing technical capabilities in the appraisal process, the appropriateness of other approaches to appraising Federal records, and how NARA can appropriately incorporate in the appraisal process concerns about electronic access to electronic records.
Meeting electronic records challenges will not be cheap. Problems created by new technologies require technological solutions that can be expensive, and we will need more trained people. Accordingly, we have sought Congressional funding for Fiscal Year 1999 to accomplish the following:
- expand NARA's staff to provide targeted assistance to agencies identified as having
particularly critical needs in managing their electronic records;
- expand NARA's capacity to preserve electronic records, both in quantity and
- increase the accessibility of electronic records to customers.
We recognize, however, that we will never have sufficient funds to deal with all electronic records issues alone. Therefore, as called for in our Strategic Plan, we are partnering with several individual Federal agencies on specific projects that we expect to meet a range of electronic records needs for government agencies in general. For example:
- We are working with the Department of Defense on three things: functional requirements
for records management application software, the testing of whether particular software products
meet those requirements, and electronic imaging standards.
- We are working with the Defense Advanced Research Projects Agency to use the power
of supercomputers to test records life-cycle management solutions for large quantities of data.
- We are working with the Patent and Trademark Office on auditing guidelines to enhance
the evidentiary value of electronic records.
- We are working with the State Department on accessioning electronic cable files.
- We are working with several agencies on electronic records declassification.
- We are working with the archives of seven other nations to begin research on how to
preserve authentic records in electronic systems.
- We are working with the Army Research Laboratory on tools available to process office
I am convinced that all these approaches, taken together, lay the foundation for meeting the government's electronic recordkeeping needs in a substantive, long-term way, while also addressing the more immediate concerns of the court in the GRS 20 case. I look forward to continuing our work with Federal agencies and the public on these critical records issues. By working together, as the Electronic Records Work Group has done through a long, hard process extending over the past eight months, we can make progress, and we absolutely must. The vulnerability of electronic records to erasure, media instability, and technological obsolescence, combined with their mushrooming quantities in multiple formats, poses an unprecedented challenge to archivists and records managers. But our democracy, in which open and accountable government depends on open and accessible records, in the electronic era as in any other, cannot afford the loss of a generation of documentation. Nor can our history. We must prevent such loss, and NARA is now working aggressively to see that we succeed in doing so.
For additional PRESS information, please contact the National Archives Public Affairs staff at (301) 837-1700 or by e-mail.