June 19, 2008
MEMORANDUM TO FEDERAL AGENCY CONTACTS: Federal agencies' responsibilities regarding facility standards for storing Federal records.
We would like to reiterate Federal agencies' responsibilities regarding facility standards for storing Federal records and explain actions the National Archives and Records Administration (NARA) is taking to more clearly present those responsibilities.
The head of each Federal agency is responsible for ensuring that his or her agency has a records management program compliant with 44 U.S.C. Chapter 31. Part of each agency's responsibility in establishing a records management program is ensuring Federal records - including data created or received and maintained for the Government by contractors - are maintained and stored according to NARA standards. Included in these requirements are standards for the facilities where a Federal agency may transfer records for storage and the physical and environmental standards under which the Federal records must be stored.
Agencies' responsibilities for establishing and managing their records management programs are outlined in 36 CFR 1222 - Creation and Maintenance of Federal Records. In 36 CFR 1228 - Disposition of Federal Records - NARA provides regulations for disposition programs.
Specific to the subject of this memo, 36 CFR 1228, Subpart I (Transfer of Records to Records Storage Facilities) provides regulations on where a Federal agency may transfer records for storage. 36 CFR 1228, Subpart K (Facility Standards for Records Storage Facilities) provides the standards for records storage facilities storing Federal records.
Because of recent inquiries from agencies, we need to reiterate three major points from these regulations:
- Federal agencies - through their designated records officers - are responsible for ensuring that Federal records are stored in compliance with the regulations.
- Under authority in 44 U.S.C. Chapter 29, NARA promulgates facility standard regulations that all agencies must comply with when storing their records. NARA ensures compliance of its own facilities with these standards. When an agency uses an agency-operated or commercial records storage facility, the agency records officer must verify and submit documentation to NARA that the facility meets NARA standards. While it approves agencies' use of non-NARA facilities to store Federal records, NARA does not "certify" facilities.
- NARA must approve Federal agency-operated records centers prior to transfer of agency records for storage. Prior written approval must be obtained by each agency that uses the facility.
To make Federal agencies' responsibilities clearer regarding these issues, NARA is developing a "Records Storage Facility Standards Toolkit" which will be available online and as an actual toolkit package. The toolkit will be completed during the 4th quarter, FY 2008. The toolkit is designed to provide the information needed by records officers to verify a facility meets the required storage standards. Information about the Records Storage Standards Toolkit is located at: http://www.archives.gov/records-mgmt/storage-standards-toolkit/. This is also where the online version of the toolkit will located when completed.
To reduce confusion, we have removed from the NARA website the Central Registry of Approved Facilities for the Storage. We took this action because the Central Registry left the misimpression that non-NARA facilities on the registry are automatically "approved" for use by other Federal agencies when in fact each agency must individually self-certify and report compliance to NARA on an agency-by-agency basis.
If you have any questions about your agency's general responsibilities, please contact your agency's NARA appraiser. A list of the appraisal and scheduling work groups is posted on the NARA web site at http://www.archives.gov/records-mgmt/appraisal/. The Records Management staff in NARA's regional offices provides assistance to records officers across the country. A complete list of NARA regional facilities may be found at http://www.archives.gov/locations/.
If you have any questions about the facility standards specifically, please contact Rick Blondo at firstname.lastname@example.org or on 301-837-1844.
PAUL M. WESTER, JR.
Modern Records Programs