National Archives: The Challenge of Electronic Records Management
(Testimony, 10/20/1999, GAO/T-GGD-00-24).

Records generated electronically--such as E-mail messages, word
processing documents, CD ROMS, and web site pages--present special
archival challenges for the National Archives and Records Administration
(NARA) and federal agencies. NARA has tried to address agencies'
immediate needs for guidance and direction on electronic records
management by revising its bulleting and other guidance as well as
forming a new group to help answer agencies' questions. Some of NARA's
actions have come about because of a court decision, which held that
NARA's guidance for the deletion of electronic records exceeded
statutory authority. The Archivist appealed the decision, and an appeals
court reversed the decision. The Archivist said, however, that NARA
would continue to work toward ensuring preservation and ready access to
electronic records.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-GGD-00-24
     TITLE:  National Archives: The Challenge of Electronic Records
	     Management
      DATE:  10/20/1999
   SUBJECT:  Archives
	     Federal records management
	     Electronic publications
	     Reengineering (management)
	     Foreign governments
	     State governments
	     Surveys
IDENTIFIER:  NARA Fast Track Guidance Development Project
	     Florida
	     Oklahoma
	     Oregon
	     Texas
	     Australia
	     Canada
	     United Kingdom

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GAO/T-GGD-00-24

NATIONAL ARCHIVES: The Challenge of Electronic Records Management (GAO/T-GGD-00-24)
NATIONAL ARCHIVES The Challenge of Electronic Records Management
Statement of L. Nye Stevens Director, Federal Management and Workforce Issues General Government Division
United States General Accounting Office
GAO Testimony Before the Subcommittee on Government Management,
Information, and Technology Committee on Government Reform House of Representatives
For Release on Delivery 10: 00 a. m. EDT on Wednesday October 20, 1999

GAO/T-GGD-00-24

Statement National Archives: The Challenge of Electronic Records Management
Page 1 GAO/ T- GGD- 00- 24
Mr. Chairman and Members of the Subcommittee: I am pleased to be here today to discuss the challenges that face the National Archives and Records Administration (NARA) and federal agencies in their efforts to manage the rapidly increasing volume of electronic records. Records generated electronically, such as electronic mail (E- mail) messages, word processing documents, CD ROMs, and World Wide Web site pages, present special archival challenges for NARA and the agencies because these technologies are new and constantly changing. Consistent, sustained oversight from Congress  through avenues such as today's hearing -- is needed to ensure that records management policies and practices keep pace with today's environment.
My testimony today centers on our report to the Senate Governmental Affairs Committee in July 1999. 1 In that report, we noted that NARA and the agencies must address several hardware and software issues to ensure that electronic records are properly created, permanently maintained, secured, and retrievable in the future. Also, because of the wide variance in electronic records management (ERM) policies and practices at four agencies we visited, we recommended that NARA conduct a baseline survey of all agencies as a part of its planned business process reengineering (BPR) effort. NARA had earlier planned to do such a survey but has decided to postpone it because the Archivist gave higher priority to such activities as BPR. Instead, NARA plans to collect information from a small, judgmentally selected sample of agencies. We continue to believe NARA's BPR effort would benefit from a complete baseline assessment survey of all agencies' records management capabilities.
NARA has taken actions to address the agencies' immediate needs for ERM guidance and direction -- revising its bulletins and other guidance as well as forming a new group to help answer agencies' questions on ERM issues. Some of NARA's actions have been taken as a result of a court decision, 2 which held that NARA's guidance for the deletion of electronic records exceeded statutory authority. The Archivist appealed and on August 6, 1999 the U. S. Court of Appeals reversed the lower court's decision. 3 The Archivist said, however, that NARA would continue to work toward ensuring preservation and ready access to electronic records.
1 National Archives: Preserving Electronic Records in an Era of Rapidly Changing Technology (GAOGGD- 99- 94, July 19, 1999). 2 Public Citizen v. Carlin, 2 F. Supp. 2d 1 (D. D. C. 1997).
3 Public Citizen v. Carlin, 184 F. 3d 900 (D. C. Cir. 1999).
Statement National Archives: The Challenge of Electronic Records Management
Page 2 GAO/ T- GGD- 00- 24
NARA is the successor agency to the National Archives Establishment, which was created in 1934, then incorporated into the General Services Administration in 1949 and renamed the National Archives and Records Service. NARA became an independent executive branch agency in 1985 in a move designed to give the Archivist greater autonomy to focus resources on the primary mission of preserving the country's documentary heritage.
NARA's mission is to make the permanently valuable records of the government  in all media  available to the public, the President, Congress, and the courts for reference and research. The Federal Records Act defines a record as all books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form, made or received by an agency in connection with the transaction of public business as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the government. 4 As a result, NARA preserves billions of pages of textual documents and numerous maps, photographs, videos, and computer records.
Under the Federal Records Act, both NARA and federal agencies have responsibilities for records management. NARA must provide guidance and assistance to federal agencies on the creation, maintenance, use, and disposition of government records. 5 Federal agencies are then responsible for ensuring that their records are created and preserved in accordance with the act. NARA and agency staff work together to identify and inventory an agency's records to appraise the value of the records and determine how long they should be kept and under what conditions.
We found that NARA and federal agencies are confronted with many ERM challenges, particularly technological issues. NARA must be able to receive electronic records from agencies, store them, and retrieve them when needed. Agencies must be able to create electronic records, store them, properly dispose of them when appropriate, and send valuable electronic records to NARA for archival storage. All of this must be done in the context of the rapidly changing technological environment.
NARA officials told us that NARA needs to expand its capacity to accept the increasing volume of electronic records from agencies. Over the past quarter century, NARA received approximately 90,000 agency electronic
4 44 U. S. C. 3301. 5 44 U. S. C. 2904 Background
NARA and Federal Agencies Face ERM Challenges
Statement National Archives: The Challenge of Electronic Records Management
Page 3 GAO/ T- GGD- 00- 24
data files. However, now NARA estimates that some federal agencies, such as the Department of State and Department of the Treasury, are individually generating 10 times that many electronic records annually just in E- mail  and many of those records may need to be preserved by NARA.
In addition to increasing volume, NARA must address some definitional problems, such as what constitutes an electronic record. In addition, because agencies follow no uniform hardware or software standards, NARA must be capable of accepting various formats from agencies and maintaining a continued capability of reading those records. The longterm preservation and retention of those electronic records is a challenge because of the difficulty in providing continued access to archived records over many generations of systems, because the average life of a typical software product is 2 to 5 years. NARA is also concerned about the authenticity and reliability of records transferred to NARA.
NARA is not alone in facing ERM challenges, the agencies also must meet Federal Records Act responsibilities. Records management is the initial responsibility of the staff member who creates the record, whether the record is paper or electronic. Preservation of and access to that record then also becomes the responsibility of agency managers and agency records officers.
Agencies must incorporate NARA's guidance into their own recordkeeping systems. Agencies' responsibilities are complicated by the decentralized nature of electronic records creation and control. For example, agencies' employees send huge volumes of E- mail, and any of those messages deemed to be an official record must be preserved. Agencies must assign records management responsibilities, control multiple versions, and archive the messages.
Agencies' reactions to the challenges I just mentioned are varied. On the basis of our discussions with NARA and some agency officials, we learned that some agencies are waiting for more specific guidance from NARA while others are moving forward by looking for ways to better manage their electronic records. However, there has been no recent governmentwide survey to determine the extent of agencies' ERM programs and capabilities or their compliance with the Federal Records Act.
NARA officials consider the Department of Defense (DOD) as one of the agencies most advanced in its ERM efforts. NARA has worked with DOD Agencies Vary in Their
Implementation of ERM
Statement National Archives: The Challenge of Electronic Records Management
Page 4 GAO/ T- GGD- 00- 24
for several years to develop DOD's ERM software standard, 6 which is intended to help DOD employees determine what are records and how to properly preserve them. NARA endorsed the DOD standard in November 1998 as a tool that other agencies could use as a model until a final policy is issued by NARA. NARA, however, did not mandate that agencies use the DOD standard.
The DOD standard (1) sets forth baseline functional requirements for records management application software; (2) defines required system interfaces and search criteria; and (3) describes the minimum records management requirements that must be met, according to current NARA regulations. A number of companies have records management application products that have been certified by DOD for meeting this standard.
Other agencies have also been testing ERM software applications for their electronic records. For example, the National Aeronautics and Space Administration (NASA) and the Department of the Treasury's Office of Thrift Supervision (OTS) have both tested ERM software with mixed results.
Even though NARA is aware of what some agencies are doing  such as DOD, NASA, OTS, and some others -- it does not have governmentwide data on the records management capabilities and programs of federal agencies. NARA had planned to do a baseline assessment survey to collect such data on all agencies by the end of fiscal year 2000. The survey would have identified best practices at agencies and collected data on (1) program management and records management infrastructure, (2) guidance and training, (3) scheduling and implementation, and (4) electronic recordkeeping. NARA had planned to determine how well agencies were complying with requirements for retention, maintenance, disposal, retrieval/ accessibility, and inventorying of electronic records. The Archivist decided, however, to temporarily postpone doing this baseline survey because he accorded higher priority to such activities as reengineering NARA's business processes. NARA's BPR will address its internal processes as well as guidance and interactions with agencies.
In our July 1999 report, we recommended that NARA do the baseline survey now, as part of its BPR, instead of waiting until BPR  which is
6 The DOD standard, Design Criteria Standard for Electronic Records Management Software Applications, November 1997, was issued under the authority of DOD Directive 5015. 2, Department of Defense Records Management Program, April 11, 1997. NARA Does Not Have
Governmentwide Data on Agencies' ERM Efforts
Statement National Archives: The Challenge of Electronic Records Management
Page 5 GAO/ T- GGD- 00- 24
scheduled to take 18 to 24 months -- is completed. Conducting the baseline survey now could provide valuable information for the BPR effort while also accomplishing the survey's intended purpose of providing baseline data on where agencies are with regards to records management programs. NARA would also be in a better position in later years to assess the impacts of its BPR effort.
In response to our draft report and in a September 17, 1999, letter to the Comptroller General, the Archivist said that much of this baseline data would not be relevant to BPR and therefore NARA would not collect it at this time. However, NARA does have plans to collect limited information from a sample of agencies after starting BPR. We continue to believe that the baseline data is necessary to give NARA the proper starting point for proceeding with its BPR. Because agencies vary in their implementation of ERM programs, the baseline survey would provide much richer data than the limited information collection effort now planned by NARA.
Even though NARA lacks governmentwide data on how agencies are implementing ERM, NARA has already begun revising its guidance to agencies. Historically, NARA's ERM guidance has been geared toward mainframes and databases, not personal computers. NARA's electronic records guidance to agencies, which establishes the basic requirements for creation, maintenance, use, and disposition of electronic records, is found in the Code of Federal Regulations. 7
In 1972, before the widespread use of personal computers in the government workplace, NARA issued guidance  General Records Schedule (GRS) 20  on the preservation of electronic records. Several revisions occurred prior to a 1995 version which provided that after electronic records were placed in any recordkeeping system, the records could be deleted. In December 1996, a public interest group filed a complaint in federal district court challenging the 1995 guidance.
In an October 1997 decision, the court found that the Archivist had exceeded the scope of his statutory authority in promulgating GRS 20. The court said that GRS 20 did not differentiate between program records and administrative housekeeping records, and electronic records are distinct from printed versions of the same record. The court also said that the Archivist failed to carry out his statutory duty to evaluate the value of records for disposal, and GRS 20 violated the Records Disposal Act because it failed to specify a period of time for retention of records to be
7 36 C. F. R. Part 1234. NARA Is Revising Its
ERM Guidance
Statement National Archives: The Challenge of Electronic Records Management
Page 6 GAO/ T- GGD- 00- 24
disposed of under a general schedule. Thus, the court ruled GRS 20 null and void.
Following the court's ruling, NARA established an Electronic Records Working Group in March 1998 with a specific time frame to propose alternatives to GRS 20. In a subsequent ruling, the court ordered the NARA working group to have an implementation plan to the Archivist by September 30, 1998. In response to the working group's recommendations, NARA agreed in September 1998 to take several actions:
 It issued a revision in the general records schedules on December 21, 1998, to authorize agencies' disposal of certain administrative records (such as personnel, travel, and procurement) regardless of physical format, after creation of an official recordkeeping copy.
 It initiated a follow- on study group (made up of NARA staff, agency officials, and consultants) in January 1999  Fast Track Development Project  intended to answer the immediate questions of agencies about ERM that can be solved relatively quickly.
 It issued NARA Bulletin 99- 04 on March 25, 1999, to guide agencies on scheduling how long to keep electronic records of their program activities and certain administrative functions formerly covered under GRS 20.
 It drafted a new general records schedule for certain administrative records to document the management of information technology. NARA has received comments from agencies on the draft, and the draft is still under review by NARA and the Office of Management and Budget. NARA hopes to have this guidance issued by the end of 1999.
On August 6, 1999, the U. S. Court of Appeals reversed the lower court's decision and held that GRS 20 is valid. That reversal was not appealed by the public interest group. In response to the court of appeals decision, the Archivist said that NARA would continue in an orderly way to develop practical, workable strategies and methods for managing and preserving records in the electronic age and ensuring access to them. He said that NARA remains committed to working aggressively toward that goal.
Our review of the ERM activities in four states and three foreign governments showed that approaches to ERM differ. These entities often did things differently from each other and/ or NARA.
In general, the four state archiving agencies (Florida, Oklahoma, Oregon, and Texas) provide centralized policies and procedures that are described in either state law or administrative rules. State archiving agencies that take physical custody of the actual records do so when the records are no ERM Activities in
Some States and Foreign Countries Differ from Those of the Federal Government
Statement National Archives: The Challenge of Electronic Records Management
Page 7 GAO/ T- GGD- 00- 24
longer needed by the individual agencies but are of archival value. Two of the states also emphasized the use of the Internet as a mechanism that allows both the archivist and the general public to determine where records may be found. State officials indicated that state law and administrative rules that they issue guide their records management requirements, but they also interact with NARA and other states to assist in determining their states' policies.
Our review of public documents from three foreign governments (Australia, Canada, and the United Kingdom) showed that although these countries share common challenges, they each have taken somewhat different approaches to ERM decisions. For example, Australia has strong central authority and decentralized custody of records, and it maintains a governmentwide locator system. Canada issues vision statements rather than specific policies, and individual agencies maintain their own electronic records until they have no more operational need for them. The United Kingdom established broad guidelines, which are put into practice by its individual agencies in partnership arrangement with its national archives. Realizing the common problems faced by all countries, NARA is part of international initiatives that are to study and make recommendations regarding ERM.
In conclusion, it is obvious that NARA and federal agencies are being challenged to effectively and efficiently manage electronic records in an environment of rapidly changing technology and increasing volume of electronic records. It is certainly not an easy task. Much remains for NARA and the agencies to do as they tackle the issues I have discussed.
We believe that NARA is moving in the right direction. However, because of the variance of ERM programs and activities across the government, we continue to believe that the Archivist should conduct the baseline assessment survey as we recommended in our July 1999 report. This survey would produce valuable information for NARA's use during its critical BPR effort. A well- planned and successful BPR should be a stepping- stone for NARA as it moves into the next phase of its management of all records, particularly electronic.
As you know, Mr. Chairman, NARA has not had concerted congressional oversight as an independent agency. Such oversight is essential to help NARA ensure that the official records of our country are properly maintained and preserved. I commend the efforts of this Subcommittee for holding this hearing and bringing the issues surrounding government records into the spotlight. I look forward to future hearings in this area. Concluding
Observations
Statement National Archives: The Challenge of Electronic Records Management
Page 8 GAO/ T- GGD- 00- 24
Mr. Chairman, this concludes my prepared statement. I would be pleased to respond to any questions you or other Members of the Subcommittee may have.
Contacts and Acknowledgement
For further information regarding this testimony, please contact L. Nye Stevens or Michael Jarvis at (202) 512- 8676. Alan Stapleton, Warren Smith, and James Rebbe also made key contributions to this testimony.
Page 9 GAO/ T- GGD- 00- 24
Page 10 GAO/ T- GGD- 00- 24
Page 11 GAO/ T- GGD- 00- 24
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NATIONAL ARCHIVES: The Challenge of Electronic Records Management
(GAO/T-GGD-00-24) NATIONAL ARCHIVES The Challenge of Electronic
Records Management Statement of L. Nye Stevens Director, Federal
Management and Workforce Issues General Government Division United
States General Accounting Office GAO Testimony Before the
Subcommittee on Government Management, Information, and Technology
Committee on Government Reform House of Representatives For
Release on Delivery 10: 00 a. m. EDT on Wednesday October 20, 1999
GAO/T-GGD-00-24  Statement National Archives: The Challenge of
Electronic Records Management Page 1 GAO/T-GGD-00-24 Mr. Chairman
and Members of the Subcommittee: I am pleased to be here today to
discuss the challenges that face the National Archives and Records
Administration (NARA) and federal agencies in their efforts to
manage the rapidly increasing volume of electronic records.
Records generated electronically, such as electronic mail (E-
mail) messages, word processing documents, CD ROMs, and World Wide
Web site pages, present special archival challenges for NARA and
the agencies because these technologies are new and constantly
changing. Consistent, sustained oversight from Congress  through
avenues such as today's hearing -- is needed to ensure that
records management policies and practices keep pace with today's
environment. My testimony today centers on our report to the
Senate Governmental Affairs Committee in July 1999. 1 In that
report, we noted that NARA and the agencies must address several
hardware and software issues to ensure that electronic records are
properly created, permanently maintained, secured, and retrievable
in the future. Also, because of the wide variance in electronic
records management (ERM) policies and practices at four agencies
we visited, we recommended that NARA conduct a baseline survey of
all agencies as a part of its planned business process
reengineering (BPR) effort. NARA had earlier planned to do such a
survey but has decided to postpone it because the Archivist gave
higher priority to such activities as BPR. Instead, NARA plans to
collect information from a small, judgmentally selected sample of
agencies. We continue to believe NARA's BPR effort would benefit
from a complete baseline assessment survey of all agencies'
records management capabilities. NARA has taken actions to address
the agencies' immediate needs for ERM guidance and direction --
revising its bulletins and other guidance as well as forming a new
group to help answer agencies' questions on ERM issues. Some of
NARA's actions have been taken as a result of a court decision, 2
which held that NARA's guidance for the deletion of electronic
records exceeded statutory authority. The Archivist appealed and
on August 6, 1999 the U. S. Court of Appeals reversed the lower
court's decision. 3 The Archivist said, however, that NARA would
continue to work toward ensuring preservation and ready access to
electronic records. 1 National Archives: Preserving Electronic
Records in an Era of Rapidly Changing Technology (GAOGGD- 99- 94,
July 19, 1999). 2 Public Citizen v. Carlin, 2 F. Supp. 2d 1 (D. D.
C. 1997). 3 Public Citizen v. Carlin, 184 F. 3d 900 (D. C. Cir.
1999). Statement National Archives: The Challenge of Electronic
Records Management Page 2 GAO/T-GGD-00-24 NARA is the successor
agency to the National Archives Establishment, which was created
in 1934, then incorporated into the General Services
Administration in 1949 and renamed the National Archives and
Records Service. NARA became an independent executive branch
agency in 1985 in a move designed to give the Archivist greater
autonomy to focus resources on the primary mission of preserving
the country's documentary heritage. NARA's mission is to make the
permanently valuable records of the government  in all media
available to the public, the President, Congress, and the courts
for reference and research. The Federal Records Act defines a
record as all books, papers, maps, photographs, machine readable
materials, or other documentary materials, regardless of physical
form, made or received by an agency in connection with the
transaction of public business as evidence of the organization,
functions, policies, decisions, procedures, operations, or other
activities of the government. 4 As a result, NARA preserves
billions of pages of textual documents and numerous maps,
photographs, videos, and computer records. Under the Federal
Records Act, both NARA and federal agencies have responsibilities
for records management. NARA must provide guidance and assistance
to federal agencies on the creation, maintenance, use, and
disposition of government records. 5 Federal agencies are then
responsible for ensuring that their records are created and
preserved in accordance with the act. NARA and agency staff work
together to identify and inventory an agency's records to appraise
the value of the records and determine how long they should be
kept and under what conditions. We found that NARA and federal
agencies are confronted with many ERM challenges, particularly
technological issues. NARA must be able to receive electronic
records from agencies, store them, and retrieve them when needed.
Agencies must be able to create electronic records, store them,
properly dispose of them when appropriate, and send valuable
electronic records to NARA for archival storage. All of this must
be done in the context of the rapidly changing technological
environment. NARA officials told us that NARA needs to expand its
capacity to accept the increasing volume of electronic records
from agencies. Over the past quarter century, NARA received
approximately 90,000 agency electronic 4 44 U. S. C. 3301. 5 44 U.
S. C. 2904 Background NARA and Federal Agencies Face ERM
Challenges Statement National Archives: The Challenge of
Electronic Records Management Page 3 GAO/T-GGD-00-24 data files.
However, now NARA estimates that some federal agencies, such as
the Department of State and Department of the Treasury, are
individually generating 10 times that many electronic records
annually just in E- mail  and many of those records may need to be
preserved by NARA. In addition to increasing volume, NARA must
address some definitional problems, such as what constitutes an
electronic record. In addition, because agencies follow no uniform
hardware or software standards, NARA must be capable of accepting
various formats from agencies and maintaining a continued
capability of reading those records. The longterm preservation and
retention of those electronic records is a challenge because of
the difficulty in providing continued access to archived records
over many generations of systems, because the average life of a
typical software product is 2 to 5 years. NARA is also concerned
about the authenticity and reliability of records transferred to
NARA. NARA is not alone in facing ERM challenges, the agencies
also must meet Federal Records Act responsibilities. Records
management is the initial responsibility of the staff member who
creates the record, whether the record is paper or electronic.
Preservation of and access to that record then also becomes the
responsibility of agency managers and agency records officers.
Agencies must incorporate NARA's guidance into their own
recordkeeping systems. Agencies' responsibilities are complicated
by the decentralized nature of electronic records creation and
control. For example, agencies' employees send huge volumes of E-
mail, and any of those messages deemed to be an official record
must be preserved. Agencies must assign records management
responsibilities, control multiple versions, and archive the
messages. Agencies' reactions to the challenges I just mentioned
are varied. On the basis of our discussions with NARA and some
agency officials, we learned that some agencies are waiting for
more specific guidance from NARA while others are moving forward
by looking for ways to better manage their electronic records.
However, there has been no recent governmentwide survey to
determine the extent of agencies' ERM programs and capabilities or
their compliance with the Federal Records Act. NARA officials
consider the Department of Defense (DOD) as one of the agencies
most advanced in its ERM efforts. NARA has worked with DOD
Agencies Vary in Their Implementation of ERM Statement National
Archives: The Challenge of Electronic Records Management Page 4
GAO/T-GGD-00-24 for several years to develop DOD's ERM software
standard, 6 which is intended to help DOD employees determine what
are records and how to properly preserve them. NARA endorsed the
DOD standard in November 1998 as a tool that other agencies could
use as a model until a final policy is issued by NARA. NARA,
however, did not mandate that agencies use the DOD standard. The
DOD standard (1) sets forth baseline functional requirements for
records management application software; (2) defines required
system interfaces and search criteria; and (3) describes the
minimum records management requirements that must be met,
according to current NARA regulations. A number of companies have
records management application products that have been certified
by DOD for meeting this standard. Other agencies have also been
testing ERM software applications for their electronic records.
For example, the National Aeronautics and Space Administration
(NASA) and the Department of the Treasury's Office of Thrift
Supervision (OTS) have both tested ERM software with mixed
results. Even though NARA is aware of what some agencies are doing
such as DOD, NASA, OTS, and some others -- it does not have
governmentwide data on the records management capabilities and
programs of federal agencies. NARA had planned to do a baseline
assessment survey to collect such data on all agencies by the end
of fiscal year 2000. The survey would have identified best
practices at agencies and collected data on (1) program management
and records management infrastructure, (2) guidance and training,
(3) scheduling and implementation, and (4) electronic
recordkeeping. NARA had planned to determine how well agencies
were complying with requirements for retention, maintenance,
disposal, retrieval/ accessibility, and inventorying of electronic
records. The Archivist decided, however, to temporarily postpone
doing this baseline survey because he accorded higher priority to
such activities as reengineering NARA's business processes. NARA's
BPR will address its internal processes as well as guidance and
interactions with agencies. In our July 1999 report, we
recommended that NARA do the baseline survey now, as part of its
BPR, instead of waiting until BPR  which is 6 The DOD standard,
Design Criteria Standard for Electronic Records Management
Software Applications, November 1997, was issued under the
authority of DOD Directive 5015. 2, Department of Defense Records
Management Program, April 11, 1997. NARA Does Not Have
Governmentwide Data on Agencies' ERM Efforts Statement National
Archives: The Challenge of Electronic Records Management Page 5
GAO/T-GGD-00-24 scheduled to take 18 to 24 months -- is completed.
Conducting the baseline survey now could provide valuable
information for the BPR effort while also accomplishing the
survey's intended purpose of providing baseline data on where
agencies are with regards to records management programs. NARA
would also be in a better position in later years to assess the
impacts of its BPR effort. In response to our draft report and in
a September 17, 1999, letter to the Comptroller General, the
Archivist said that much of this baseline data would not be
relevant to BPR and therefore NARA would not collect it at this
time. However, NARA does have plans to collect limited information
from a sample of agencies after starting BPR. We continue to
believe that the baseline data is necessary to give NARA the
proper starting point for proceeding with its BPR. Because
agencies vary in their implementation of ERM programs, the
baseline survey would provide much richer data than the limited
information collection effort now planned by NARA. Even though
NARA lacks governmentwide data on how agencies are implementing
ERM, NARA has already begun revising its guidance to agencies.
Historically, NARA's ERM guidance has been geared toward
mainframes and databases, not personal computers. NARA's
electronic records guidance to agencies, which establishes the
basic requirements for creation, maintenance, use, and disposition
of electronic records, is found in the Code of Federal
Regulations. 7 In 1972, before the widespread use of personal
computers in the government workplace, NARA issued guidance
General Records Schedule (GRS) 20  on the preservation of
electronic records. Several revisions occurred prior to a 1995
version which provided that after electronic records were placed
in any recordkeeping system, the records could be deleted. In
December 1996, a public interest group filed a complaint in
federal district court challenging the 1995 guidance. In an
October 1997 decision, the court found that the Archivist had
exceeded the scope of his statutory authority in promulgating GRS
20. The court said that GRS 20 did not differentiate between
program records and administrative housekeeping records, and
electronic records are distinct from printed versions of the same
record. The court also said that the Archivist failed to carry out
his statutory duty to evaluate the value of records for disposal,
and GRS 20 violated the Records Disposal Act because it failed to
specify a period of time for retention of records to be 7 36 C. F.
R. Part 1234. NARA Is Revising Its ERM Guidance Statement National
Archives: The Challenge of Electronic Records Management Page 6
GAO/T-GGD-00-24 disposed of under a general schedule. Thus, the
court ruled GRS 20 null and void. Following the court's ruling,
NARA established an Electronic Records Working Group in March 1998
with a specific time frame to propose alternatives to GRS 20. In a
subsequent ruling, the court ordered the NARA working group to
have an implementation plan to the Archivist by September 30,
1998. In response to the working group's recommendations, NARA
agreed in September 1998 to take several actions:  It issued a
revision in the general records schedules on December 21, 1998, to
authorize agencies' disposal of certain administrative records
(such as personnel, travel, and procurement) regardless of
physical format, after creation of an official recordkeeping copy.
It initiated a follow- on study group (made up of NARA staff,
agency officials, and consultants) in January 1999  Fast Track
Development Project  intended to answer the immediate questions of
agencies about ERM that can be solved relatively quickly.  It
issued NARA Bulletin 99- 04 on March 25, 1999, to guide agencies
on scheduling how long to keep electronic records of their program
activities and certain administrative functions formerly covered
under GRS 20.  It drafted a new general records schedule for
certain administrative records to document the management of
information technology. NARA has received comments from agencies
on the draft, and the draft is still under review by NARA and the
Office of Management and Budget. NARA hopes to have this guidance
issued by the end of 1999. On August 6, 1999, the U. S. Court of
Appeals reversed the lower court's decision and held that GRS 20
is valid. That reversal was not appealed by the public interest
group. In response to the court of appeals decision, the Archivist
said that NARA would continue in an orderly way to develop
practical, workable strategies and methods for managing and
preserving records in the electronic age and ensuring access to
them. He said that NARA remains committed to working aggressively
toward that goal. Our review of the ERM activities in four states
and three foreign governments showed that approaches to ERM
differ. These entities often did things differently from each
other and/ or NARA. In general, the four state archiving agencies
(Florida, Oklahoma, Oregon, and Texas) provide centralized
policies and procedures that are described in either state law or
administrative rules. State archiving agencies that take physical
custody of the actual records do so when the records are no ERM
Activities in Some States and Foreign Countries Differ from Those
of the Federal Government Statement National Archives: The
Challenge of Electronic Records Management Page 7 GAO/T-GGD-00-24
longer needed by the individual agencies but are of archival
value. Two of the states also emphasized the use of the Internet
as a mechanism that allows both the archivist and the general
public to determine where records may be found. State officials
indicated that state law and administrative rules that they issue
guide their records management requirements, but they also
interact with NARA and other states to assist in determining their
states' policies. Our review of public documents from three
foreign governments (Australia, Canada, and the United Kingdom)
showed that although these countries share common challenges, they
each have taken somewhat different approaches to ERM decisions.
For example, Australia has strong central authority and
decentralized custody of records, and it maintains a
governmentwide locator system. Canada issues vision statements
rather than specific policies, and individual agencies maintain
their own electronic records until they have no more operational
need for them. The United Kingdom established broad guidelines,
which are put into practice by its individual agencies in
partnership arrangement with its national archives. Realizing the
common problems faced by all countries, NARA is part of
international initiatives that are to study and make
recommendations regarding ERM. In conclusion, it is obvious that
NARA and federal agencies are being challenged to effectively and
efficiently manage electronic records in an environment of rapidly
changing technology and increasing volume of electronic records.
It is certainly not an easy task. Much remains for NARA and the
agencies to do as they tackle the issues I have discussed. We
believe that NARA is moving in the right direction. However,
because of the variance of ERM programs and activities across the
government, we continue to believe that the Archivist should
conduct the baseline assessment survey as we recommended in our
July 1999 report. This survey would produce valuable information
for NARA's use during its critical BPR effort. A well- planned and
successful BPR should be a stepping- stone for NARA as it moves
into the next phase of its management of all records, particularly
electronic. As you know, Mr. Chairman, NARA has not had concerted
congressional oversight as an independent agency. Such oversight
is essential to help NARA ensure that the official records of our
country are properly maintained and preserved. I commend the
efforts of this Subcommittee for holding this hearing and bringing
the issues surrounding government records into the spotlight. I
look forward to future hearings in this area. Concluding
Observations Statement National Archives: The Challenge of
Electronic Records Management Page 8 GAO/T-GGD-00-24 Mr. Chairman,
this concludes my prepared statement. I would be pleased to
respond to any questions you or other Members of the Subcommittee
may have. Contacts and Acknowledgement For further information
regarding this testimony, please contact L. Nye Stevens or Michael
Jarvis at (202) 512- 8676. Alan Stapleton, Warren Smith, and James
Rebbe also made key contributions to this testimony. Page 9 GAO/T-
GGD-00-24 Page 10 GAO/T-GGD-00-24 Page 11 GAO/T-GGD-00-24 Ordering
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