Records management responsibilities for EPA contractors are defined in Agency policy and guidance and federal regulations:
All EPA employees are responsible for creating and managing the records necessary to document the Agency's official activities and actions, including those records generated by EPA contractors and grantees, in accordance with EPA recordkeeping requirements. - EPA Records Management Policy
Records Custodian: Any Agency employee or contractor with responsibilities over a particular set of records is a records custodian. A records custodian must keep the RLO and the records contact informed of any issues regarding the records in their custody. - EPA Records Management Manual
All government employees and contractors are required by the FRA [Federal Records Act] to make and preserve records which document the organization, functions, policies, decisions, procedures, and essential transactions of the Agency. In addition, Federal regulations provide that these records must be properly stored and preserved, available for retrieval, and subject to appropriate approved disposition schedules. - E-Mail Legal Requirements (EPA General Counsel Memo)
Contractors performing Congressionally-mandated program functions are likely to create or receive data necessary to provide adequate and proper documentation of these programs and to manage them effectively. - Creation and Maintenance of Federal Records (36 CFR 1222)
EPA contractors create and receive federal records, which must be managed according to the mandatory instructions in Agency records schedules. This is not restricted to the contractors who maintain large volume of records in EPA records centers; other contractors are affected as well.
Agency records maintained by contractors are also subject to the Freedom of Information Act (FOIA). – OPEN Government Act 2007, Section 9. For more information, see the U.S. Department of Justice's FOIA Post: Treatment of Agency Records Maintained For an Agency By a Government Contractor for Purposes of Records Management.
Examples of records created, received and maintained by contractors include, but are not limited to:
Information Requests and Acknowledgment Files (309)
This includes records of requests for information and replies (e.g., public access questions).
Visitor Control Files (1008)
This includes records of sign-in logs (e.g., Superfund Records Center).
Web Sites (0095)
This includes records of Web site management and operations.
EPA Library Program Files (1022)
This includes records of library reports, statistics, holdings, and services.
Records Disposition Files (307)
This includes records of retiring records to, and retrieving records from, federal records centers (FRCs). (In some programs, this is done through e-mail directly from the contractor to the FRC.)
Examples of records created by contractors, but received and maintained by federal employees include, but are not limited to: