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In the Loop - June 2007

Some In The Loop articles and links are pertinent to EPA staff and are available to EPA Intranet users only.

Tip of the Week: Legally acceptable records management programs (19-JUN-2007)

The opening session of this year's Managing Electronic Records (MER) conference, sponsored by Cohasset Associates, Inc., focused on recent revisions to the Federal Rules of Civil Procedure (FRPC) and how organizations can demonstrate a "good faith" records management program that is acceptable to regulators, judges and juries.

The session speakers, adapting the Federal Sentencing Guidelines promulgated by the United States Sentencing Commission, proposed seven elements that must exist for a records management program to meet a legally acceptable standard of performance:

  • Good policies and procedures
  • Executive-level program responsibility
  • Proper delegation of program roles and responsibilities
  • Program communication and training
  • Auditing and monitoring to measure program compliance
  • Effective and consistent program enforcement
  • Continuous program improvement

Tip of the Week: Training Records (12-JUN-2007)

Training materials created for EPA and non-EPA employees are federal records. This includes training material for sessions conducted or attended within or outside the Agency. Examples include:

  • training on EPA's regulations for state and local agencies,
  • training for contracting officers' representatives, and
  • training on information security for all employees.

There are several records schedules for training materials; choosing the correct one depends on the type of training and/or who maintains the record copy.

Type Custodian Schedule
EPA-sponsored training about the Agency's activities, functions, or specialized program areas Training sponsor 200 - Training Material
Personnel training developed for EPA employees by the personnel office Personnel office 571 - Personnel Training Records
Training documents maintained in the official personnel folder Personnel office 553 - Official Personnel Folders (OPF) - Civilian for civilian employees
554 - Agency Personnel Folders - Public Health Service Corps Commissioned Personnel for PHSC employees
Supervisors' copies of training documents Supervisor 122 - Supervisors' Personnel Files and Duplicate OPF Documentation
Employees' copies of personal training materials Any employee N/A - these are personal papers

Tip of the Week: Records Lifecycle (07-JUN-2007)

Most records have two lifecycle phases: active and inactive. Each phase ends according to a retention policy "trigger," which is documented in the applicable records schedule.

There are three basic triggers:

  • Calendar (e.g., end of fiscal year)
  • Time-Length (e.g., 5 years)
  • Event (e.g., permit issued)

The Enterprise Content Management System (ECMS) automates much of the records lifecycle. When you save a record in ECMS, the system automatically:

  • applies a retention policy.
  • assigns calendar triggers, if applicable.
  • calculates time-length triggers, if applicable.
  • asks you if an event trigger has occurred, if applicable.
  • notifies you when a lifecycle phase is ending.

Records Liaison Officers (RLOs) and designate records contacts play a key role in the records lifecycle. Only they have the authority in ECMS to:

  • apply an event trigger to a record or group of records once it has occurred.
  • extend the lifecycle phase of a record, if needed. (You must provide a valid reason; e.g., litigation hold, FOIA response, audit.)

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