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File Work Ahead Frequent Questions about Working Files

What are working files?

The National Archives and Records Administration (NARA) defines working files as: "rough notes, calculations, or drafts assembled or created and used to prepare or analyze other documents. Also called working papers."

Everyone creates working files, and they are very often a mixture of record and nonrecord materials. How to manage them is the question. If working files are poorly organized and inscrutable to anyone but the creator, identifying record material to document program activity is difficult. If records and nonrecords are mixed in one voluminous working file, the Agency is forced to manage an even larger volume of material than is necessary.

Basically, you need to make sure that records needed to document Agency activity are filed in official files and working files are maintained separately and kept to a minimum.

Are working files records?

NARA's regulations (36. CFR 1222.34(c)) say that working files are records if:

  1. They were circulated or made available to employees, other than the creator, for official purposes such as approval, comment, action, recommendation, follow-up, or to communicate with agency staff about agency business; and

  2. They contain unique information, such as substantive annotations or comments included therein, that adds to a proper understanding of the agency's formulation and execution of basic policies, decisions, actions, or responsibilities.

Each EPA office is responsible for establishing procedures that identify which documents are part of the official files, who is responsible for maintaining them, and when they are placed in the recordkeeping system. Staff can then determine which documents in their possession need to be filed and retained as records, and which documents can be safely recycled or destroyed.

Are supporting materials the same as working files?

No, true supporting materials are documents that are necessary to substantiate the final document or decision trail. Supporting materials are part of the official record, although they may be filed separately if volume warrants.

What types of documents are found in working files?

Unfortunately, many people keep a substantial amount of their project documentation in working files. Here is a list of the types of documents that may be found and what should be done with them.

Are working files the same as personal papers?

No, personal papers are nonofficial, or private, papers relating solely to an individual's own affairs. Working files, by definition, relate to Agency business and are not personal papers.

What is the best way to manage working files?

There are two common approaches to manage working files:

  1. Create an official file when an action is initiated and file the official records, and only the official records, in it. This works especially well for repetitive actions where approvals are required, such as the issuing of permits, travel vouchers, purchase requests, or the approval of directives.

  2. Retain most or all of the papers until a specified milestone is reached or the activity or task is completed. At that time, compile an official file. This works well when several individuals are contributing to one product or result, or when projects are unique. Some programs also use this approach in compiling administrative records.

Are working files subject to the Freedom of Information Act (FOIA)?

The FOIA does not exclude working files. If there are documents in the files that are exempt from the FOIA under one of its exclusions, those documents are withheld from disclosure. However, the fact that they are working files does not, in itself, exempt them from disclosure. See the FOIA web site for more details.

How can I get additional guidance?

If you have policy questions about your working files, you should contact the Records Help Desk. You can find additional guidance in the following publications:

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