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Chapter 3. Active Records

records lifecycle

Active records are those used to conduct current Agency business, and that are generally maintained in office space and equipment. Events in this phase of the lifecycle include creating or receiving records and capturing them in a recordkeeping system.

Creating and Receiving Records

Federal agencies are required to create and receive records that document:

EPA offices must determine what records they need to create or receive to meet these requirements. Records contacts and Agency staff should work together to ensure that complete and accurate records are created. Offices should develop guidelines and procedures to incorporate the records creation and receipt process into business functions.

Capturing Records

After creating or receiving a record, EPA staff must capture it by filing, storing, or otherwise systematically maintaining it in a recordkeeping system. Capturing records ensures that the information is accessible to all authorized staff. It also assists offices in dispositioning records in accordance with the applicable records schedules.

An office's records program must capture records to:

Staff should ensure that they capture metadata along with related records, including:

Recordkeeping Systems

EPA offices must capture records in a recordkeeping system that facilitates maintenance and use of the records in an efficient and cost-effective manner. A recordkeeping system has several components:

A recordkeeping system must allow records to be:

Once records are organized within a recordkeeping system, the office must regularly review the system to determine when records are ready to be closed, retired, and destroyed or transferred.

Special Considerations in Capturing Records

EPA staff must preserve records created with software applications in a recordkeeping system for the length of time designated in the approved records schedule for the functions they support. For example, if a letter is produced using Microsoft Word to respond to a controlled correspondence, retention is governed by the records schedule for controlled correspondence.

E-mail records with an approved retention of six months or less may be retained in the e-mail system, and do not have to be captured in a recordkeeping system.

Any verbal communication in which an Agency decision or commitment is made, and that is not otherwise documented, needs to be captured and placed in a recordkeeping system. Voicemail systems are not recordkeeping systems. These systems delete messages automatically after a set number of days.

Centralized vs. Decentralized

EPA uses a combination of centralized and decentralized recordkeeping systems.

A centralized recordkeeping system:

A decentralized recordkeeping system:

An office may choose to maintain specific types of records in a central location, while maintaining other types of records at individual work stations. Records maintained at individual work stations should be identified in the recordkeeping system, so that everyone in the office can locate the records.

See Centralized vs. Decentralized Filing for more information.

Electronic Recordkeeping Systems

Electronic records must be maintained in an electronic recordkeeping system, such as EPA's enterprise content management system (ECMS). The Agency's requirements for electronic recordkeeping systems are listed in Basic Requirements of an Electronic Recordkeeping System at EPA.

If an office does not have an electronic recordkeeping system that meets these requirements, it must print records and capture them in a paper recordkeeping system. In some cases, printing may cause loss of context (e.g., databases, complicated spreadsheets or geospatial data). In those cases, the records may be maintained electronically, but must be readable, accessible and usable for the entire life of the records, and dispositioned according to the applicable records schedule.

Computer drives, backup tapes, and software applications such as Lotus Notes are not recordkeeping systems. However, in the absence of an electronic recordkeeping system, offices may establish network directories using the Agency-wide file structure to facilitate access and retrieval of the electronic copy, while maintaining the record copy in a paper recordkeeping system.

EPA must maintain adequate and up-to-date technical documentation for each electronic recordkeeping system. The documentation must include narrative description of the system, and the physical and technical characteristics of the records, including a description of the data format, a record layout describing each field, and any other technical information needed to read or process the records.

If electronic records are produced in response to litigation or audits, offices must demonstrate consistent usage of the electronic recordkeeping system in accordance with federal and EPA requirements.

File Plans

A file plan lists the records in an office, and describes how they are organized and maintained. It should include identifying information about the records, such as the:

EPA policy requires offices to organize records according to the Agency-wide file structure. If an office maintains electronic copies of records (e.g., on a share drive), it should organize the directories in the same way to facilitate retrieval.

See the File Plan Guide for more information.


Offices can choose to store their active records on-site, or, with permission, in an off-site storage facility. All on-site records centers and off-site storage facilities the Agency uses must protect federal records from threats such as fire, pests, theft, natural disasters and water damage.

Permanent records must be stored on archival-quality media and in containers and facilities appropriate to long-term preservation. Offices should arrange records in storage media with like schedules and disposition dates.


Filing equipment and supplies should be the most economical possible to meet recordkeeping requirements. In selecting equipment, offices must consider:

Offices should use equipment that accommodates letter-sized records unless there is a requirement for other sizes. Offices should also consider purchasing used or reconditioned equipment when available.

Electronic Records

Electronic records are usually stored on magnetic media (e.g., tapes, magnetic cartridges) or optical media (e.g., CD-ROMs, flash drives). Offices must monitor electronic records to ensure that the records are accessible and readable until final disposition. Offices may need to reformat or migrate the records.

Electronic records require special care, including:

System backups used to restore computer system operations are not adequate for storage of electronic records. Offices must destroy system backup tapes or media according to established rotation schedules and applicable records schedules.

Offices must meet NARA regulations (36 CFR 1234) when selecting electronic records storage media.

Special Media Records

Special media records such as film, video recording and microform have unique storage requirements. Storage of the records must meet the requirements in NARA regulations (36 CFR 1237 and 36 CFR 1238).


Imaging is a process by which a paper document is converted from a human-readable format to microform or a computer-readable digital image file. Imaged pictures of documents can be stored on a variety of media.

See Frequently Asked Questions About Imaged Records for more information.

Tracking Systems

Offices should implement a tracking system for retrieving and checking out records from its recordkeeping system. The system should include, at a minimum, chargeout cards that are placed in the record's location in the filing cabinet or shelf to indicate:

When returning the record, office staff should:

Offices may implement electronic tracking systems (e.g., barcodes) to track records at the document, folder or box level. These systems should track the same type of information described above.


Each office must maintain its records securely, protecting the integrity and confidentiality of the records as appropriate. The criteria for determining the level of security control should include the sensitivity, value and replaceability of the information.

Offices should secure records by:


Agency staff using records at alternate work sites must follow the security requirements in EPA's Flexiplace Policy (PDF) (27 pp, 92K) 3180, Section V.G. Records Management. Specific requirements mandate that:

Employee Separation

RLOs or records contacts must work with the departing employee to ensure that the following activities are complete:

Departing employees must obtain permission from their supervisors to remove extra copies of any documentary materials, which may still be subject to FOIA or discovery actions.

Vital Records

Each office must implement a plan that identifies and protects its vital records in accordance with EPA's Records Management Policy (PDF) (9 pp, 109K). Each office within EPA is required to establish and maintain a records management program which includes a plan to protect vital records and assess damage to and the recovery of any records affected by an emergency or disaster.

See the following for more information:

Introduction | Chapter 1 | Chapter 2 | Chapter 3 | Chapter 4

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