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In the Loop - July 2010

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

Tip of the Month: Interim Strategies for Maintaining Electronic Records (14-JUL-2010)

EPA's official policy on maintaining electronic records is that they be maintained in the records repository of the content management system, when available. If the content management system is not available, the records must be printed and filed in a paper recordkeeping system. There are two exceptions.

1. If permanent records are maintained in an electronic information system that has its own approved records schedule and are transferred to the National Archives according to the schedule instructions, they may be maintained in the electronic system and do not also need to be filed in the content management system or printed, unless they are needed for another reason (e.g., FOIA response). For example, the record copy of the National Biennial Hazardous Waste Report in RCRAInfo, covered by records schedule 257, is maintained in the RCRAInfo electronic system.

2. There may be situations where EPA staff create or receive records that cannot be printed. For example:

  • The data or document is very large and not cost effective to print (e.g., analytical data packages); or,
  • The content, structure or context of the information is lost or compromised if it is printed (e.g., geospatial data, complicated spreadsheets).

Here are some interim steps you can take to preserve records electronically until they can be saved in the content management system.

  • Set up a file plan on a shared network drive, using the Agency-wide file structure and file the documents in the appropriate file category. One advantage to this approach is that the network is automatically backed up on a regular basis. Access restrictions can also be set for confidential material.
  • Save the records on CDs and set up an onsite repository to maintain them. Be sure the CDs are labeled with content, file plan information and other important metadata that will make access, retrieval, and disposition possible.

Any system you establish needs to be monitored on a regular basis to ensure that the records can be accessed, retrieved, and read for the entire length of their approved retention, as authorized by EPA's records schedules. This also means that the information may need to be migrated to future versions of hardware and software.

Disposition for electronic records maintained in this fashion will need to be done manually, according to the records schedule instructions. For disposable records, see EPA's Procedures for Disk Sanitization. For permanent records that will be transferred to the National Archives, see NARA's regulations and additional guidance on the transfer of electronic records.

For more information about electronic recordkeeping systems, see:

ALERT: GAO Testimony on Information Management, The Challenges of Managing Electronic Records (08-JUL-2010)

The GAO has released a report on testimony before the Subcommittee on Information Policy, Census and National Archives, Committee on Oversight and Government Reform, House of Representatives by Valerie C. Melvin, Director, Information Management and Human Capital Issues.

From the report: "Federal agencies are increasingly using electronic means to create, exchange, and store information, and in doing so, they frequently create federal records: that is, information, in whatever form, that documents government functions, activities, decisions, and other important transactions. As the volume of electronic information grows, so does the challenge of managing electronic records. Both federal agency heads and the National Archives and Records Administration (NARA) have responsibilities for managing federal records. This testimony describes the challenges of electronic records management and potential means of addressing these challenges".

Tip of the Month: Destruction of paper records after imaging (02-JUL-2010)

Currently EPA has many scanning initiatives to capture paper records and associated metadata. In most cases, after scanning, the paper is retained onsite or retired to the Federal Records Centers (FRCs). To reduce the number of boxes retired to the FRCs and the associated costs, follow these guidelines.

  • Scanning hardware and software must comply with NARA standards.
  • Scanning procedures must include finding aids and metadata, in order to be able to locate images in the future.
  • The scanned images must be retained in an official recordkeeping system, such as EPA's Enterprise Content Management System (ECMS) or a system which is DOD 5015.2 compliant.
  • Strict quality assurance must be performed for all scanning. Quality assurance must be performed on 100% of all images for all permanent records.
  • Before destruction, each scanned collection must be certified by upper management as being complete and findable, and the scanned image certified to be the official record copy.

For more information about imaged records, see:

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