Report on the NARA ERWG open meeting

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I attended the NARA ERWG open meeting held yesterday at Archives II. Of the 30 or more observers who were there, I was the only one I know of who was from DoD. The meeting was the last open session the working group will hold before the fianl draft of the GRS-20 report is presented to John Carlin on September 30 and published in the Federal Register. Its purpose was to discuss prospective changes to the draft report in response to agency and public comment received since it appeared in the Register on July 21. Some of the agency and public comment and ERWG's response may be of value to us as we start work on a revision of the conbined SSIC/SECNAV. Among the most useful comments:

Most readers found the NARA draft hard to comprehend. GSA suggested that it be rendered in plain English without the usual jargon. NARA's reponse to that was to consider appending a glossary of records mangement and IT terms that appear in the report.

ARMA International suggested that general concepts or requirements be accompanied by specific examples for illustration.

SAA (the Society of American Archivists) noted that all agencies have hybrid records holdings -- a mix of paper, elctronic, micrographic, and so on, and that retention requirements should reflect that fact.

Finally, many suggestions were received to the effect that ERWG should continue to meet and it should solicit more input from IT specialists. NARA has already decided to sponsor an "ERWG II" to continue working at least through the end of FY 99. The work group next considered changes to each of the three appendices to the report, beginning with Appendix E, the draft retention schedule for IT system records. Those who commented on it said that in general, they understood it, but complained that it was too complex. Specifically, they called for

-- fewer records series, fewer disposition requirements, and an emphasis on standardized and more precisely defined retention terminology, and

-- more time-driven as opposed to event-driven dispositions whenever possible. Though these comments were directed towards IT system records, they are practical enough to be worthy of our consideration when we start thinking about how to revise the SECNAV.

Appendix D deals with specific modifications to GRS 20. There were so many comments and so much discussion about language and semantics that it was eventually decided to substantially rewrite the whole appendix.

Appendix C is the proposal to develop schedules for office automation records. It is here that ERWG proposed that agencies revise their schedules to include the disposition of source records after record copies have been captured to recordkeeping systems within 180 days, to begin some time after September 30; or failing that, to submit a "planning package" with milestones within 120 days. Agencies' response to this was along the lines of "what, are you crazy?" and "when after September 30 is this work supposed to start?"

The ERWG decided after lengthy dicussion to beep the time periods as they are, but to grant extensions to large agencies like DoD, if requested. In the final report it agreed to specify on what date after September 30 the work should commence.

This should be of interest to us because when we begin revising the SSIC/SECNAV we'll need support from NARA. We will probably want to use the time period they specify as a frame of reference at least.

There were some other comments I thought were worthy of note. Lewis Bellardo, the Associate Archivist of the US, stated that the Federal Records Act gives agencies the authority to determine when records become non-records and to base the determination on business practices. He said that with regard to what becomes of electronic source records after they are captured to a recordkeeping sytem. Since they support business activities, there are business and legal reasons for promptly disposing of them. To me, his comments implied the necessity for identifying electronic information, whether it be e-mail messages, or other data created or received via iffice applications, as records if they support business activities, and to schedule and dispose of them. This seems to be at variance with the contention that technology now allows us to "keep everything", and consider its retention or disposition only as a sort of afterthought.

There was slso talk of revising the Federal Records Act to bring it up to date with current technology issues. There were questions raised about how long to retain records in machine readable formats, and about whether "mandatory" retention requirements should always apply or be considered with regard to electronic records.

To sum up, I think ERWG will be working on issues that will be of interest to us. We all should at least keep an eye on its web page. I notice that there is now a link to it from this site.

Dean



-- Anonymous, October 01, 1998


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