Chapter 2. Scheduling Records
General Records Schedules (GRS) are issued by the Archivist of the United States to provide disposition authorization for records common to several or all agencies of the federal government.
Standard Form 115 (SF 115), Request for Records Disposition Authority, is used by Federal agencies to obtain disposition authority from NARA. It is generally used for unscheduled records.
A records schedule describes EPA records, identifies the records as either temporary or permanent, and provides specific, mandatory instructions for the disposition of the records when they are no longer needed for current Agency business.
NARA regulations (36 CFR 1227.12) require EPA to apply the GRS to eligible records and to submit an SF 115 for all remaining records.
Matching Records to Schedules
Staff must match records in their office with records schedules to determine whether the records are temporary or permanent and how long the records must be retained before destruction or transfer.
If the records match a schedule, the office must apply the mandatory disposition instructions.
If the records match a schedule, but the retention period does not fulfill the office's business needs, the RLO must work with the ARO to revise the schedule.
If the records do not match a schedule, the records may be unscheduled. Contact the Records Help Desk for confirmation. If the records are truly unscheduled, the RLO must work with the ARO to develop a new schedule.
See the following for more information:
Reviewing, Revising and Developing Schedules
The ARO must review Agency records schedules annually and update them as necessary. RLOs also must annually review schedules that specifically apply to their program office, region or laboratory, and notify the ARO if the schedules need to be revised.
An office may need to revise a schedule if:
The records are not adequately described, because the business process or the statutory or regulatory requirements have changed.
The authorized retention period no longer meets the Agency's business needs.
An electronic information system is being discontinued or incorporated into new systems, or a new system is being implemented.
The function has moved to a different office or agency.
The office is implementing an imaging system, and plans to destroy paper records after they are converted to microform or electronic images.
The office is implementing electronic reporting and electronic signatures.
Schedules undergo an approval process with records stakeholders to ensure they meet administrative, legal, and audit requirements. Stakeholders include Agency offices, NARA, and the Government Accountability Office (GAO).
NRMP posts changes made during this process to the EPA Records intranet monthly.
Internal Approval Process for All-Programs Schedules
When the ARO, in collaboration with Agency staff, develops a schedule that applies to all programs, he or she posts it to the EPA Records intranet, and sends an e-mail notification to the Records Network, informing them that the schedule is ready for review.
The Records Network has a 30-day comment period to review the schedule to ensure that it adequately describes the records to which it pertains, and confirm that the schedule's retention and disposition meet the Agency's business needs. After the 30-day period, the ARO consolidates the comments, and revises the schedule as needed.
Next, the ARO submits the schedule to the Office of Inspector General (OIG), who ensures that the schedule's retention and disposition meet the Agency's auditing requirements. If OIG does not concur, the ARO revises the schedule as needed, and then resubmits it to OIG.
When OIG approves the schedule, the ARO submits it to OGC, who ensures that the schedule's retention and disposition meet the Agency's legal requirements. If OGC does not concur, the ARO revises the schedule as needed, and then resubmits it to OGC.
When OGC approves the schedule, the ARO submits it to NARA.
Internal Approval Process for Program-Specific Schedules
When the ARO, in collaboration with program staff, develops a schedule that applies to a specific program, he or she submits it to the program's RLO and IMO for approval.
The RLO and IMO review the schedule to ensure that it adequately describes the records to which it pertains, and confirm that the schedule's retention and disposition meet the program's business needs. If the RLO and IMO do not concur, the ARO revises the schedule as needed, then resubmits it to them.
When the RLO and IMO approve the schedule, the ARO submits it to OIG, who ensures that the schedule's retention and disposition meet the Agency's auditing requirements. If OIG does not concur, the ARO revises the schedule as needed, and then resubmits it to OIG.
When OIG approves the schedule, the ARO submits it to OGC, who ensures that the schedule's retention and disposition meet the Agency's legal requirements. If OGC does not concur, the ARO revises the schedule as needed and resubmits it to OGC.
When OGC approves the schedule, the ARO submits it to NARA.
When EPA completes the internal approval process, the ARO submits an SF 115 to NARA. The SF 115 may cover:
- all records not scheduled by the GRS,
- records scheduled by the GRS for which EPA needs a different retention period,
- automated systems, or
- permanent or unscheduled records, if the records already exist in paper and are being converted to electronic or microform image and the paper destroyed. (No SF 115 is required if the records are temporary.)
When NARA receives an SF 115, it takes the following steps:
Reviews the SF 115 for completeness. NARA appraisers may consult with Agency officials and examine the records.
Determines whether the SF 115 should be revised, approved, withdrawn or rejected.
NARA may revise the SF 115 for clarity and accuracy. Minor changes require only the Agency's oral approval, while major changes require the Agency's written approval.
If NARA approves the request, it sends the Agency a copy of the approved SF 115.
If both the Agency and NARA agree to withdraw an entire SF 115 or individual items, NARA will mark the job or the items "withdrawn" and request a new SF 115.
If NARA rejects an SF 115, the Agency must revise and submit a new one to NARA.
Publishes in the Federal Register a notice of Agency requests for the disposition of records. If NARA has previously approved disposition of the records covered in an Agency request, it only publishes a notice if the proposed retention period is shorter.
NARA requires GAO's written approval when the Agency proposes retention periods for administrative records that are shorter than those prescribed by GRS 2 through 10.
All programmatic records having a proposed retention period of less than three years require justification with GAO. GAO neither approves nor disapproves proposed retention periods for programmatic records held three years or longer, although it recommends that their retention periods be as short as possible.
GAO approval of the retention period is also required for records relating to claims or demands by or against the government. Excluded from this category are any such records covered by the GRS, provided that the proposed retention period is not shorter than that prescribed by the GRS.
While GAO's approval is pending, NARA will process the SF 115 but not approve it until GAO submits a written concurrence.