Preparing Electronic Records for Transfer to the National Archives

Introduction

Many of EPA's records have been determined to be "permanent" records. This means that the EPA and the National Archives and Records Administration (NARA) have decided that the records are sufficiently valuable for historical or other purposes to warrant continued preservation by the Federal government beyond EPA's business needs.

Permanent records may be electronic in format; that is, they are stored in a form that only a computer can process. Permanent electronic records require special care and storage, including:

Keeping them at the appropriate temperature and humidity,
Recopying the information to new media periodically or migrating to new technology, and
Testing the readability of an annual sample.

Another special requirement for permanent electronic records is their transfer to NARA's Electronic and Special Media Records Services Division in accordance with instructions in EPA's records schedules. NARA has special format requirements as stated in 36 CFR § 1228.270. In addition to the formats specified in the Code of Federal Regulations (CFR), NARA is now accepting other formats, such as Portable Document Format (PDF) files, scanned images, digital photographs, and Web content.

Note that the formats required for transfer to NARA may be different than the formats currently used (e.g., NARA's PDF requirements are different than EPA's standard) and provisions must be made for eventual transfer of permanent electronic records to NARA in their accepted format.

Responsibilities

A successful transfer of permanent electronic records to NARA requires coordination by the records sponsor or custodian (the person who is responsible for maintaining the records) with the assistance of:

Your office Records Liaison Officer (RLO),
Your information technology (IT) support staff,
The National Records Management Program (NRMP), and
NARA.

Before You Begin

There are several pieces of information you, as the records custodian, need to have prior to beginning the transfer process:

First, review the records schedule which provides information on what is to be transferred and when.
Second, review NARA's requirements for electronic records management at 36 CFR Part 1234.
Third, determine if there are any special restrictions on the information; for example, confidential business information (CBI), or information subject to the Privacy Act.
Fourth, identify your organization's technical support person to assist with the transfer.

Step 1

Collect the documentation you need to prepare:

Obtain copies of the Standard Form 258 (SF 258), Agreement to Transfer Electronic Records to the National Archives of the United States, and NA Form 14097, Technical Description for Transfer of Electronic Records to the National Archives. (Your office RLO can help you with this.)
Contact the Records Help Desk if you have additional questions.

Step 2

Call EPA's electronic records representative at NARA, Paula Larich (Paula.Larich@nara.gov), 301-837-3062 or Ted Hull (Theodore.Hull@nara.gov), 301-837-1824) to:

Establish a contact,
Describe the records to be transferred, and
Set a date for a meeting to include EPA program and technical staff and a representative from NARA to discuss the process.

Step 3

Prepare records for transfer. Each transfer must include the following:

Electronic records in the format specified by NARA.
See 36 CFR § 1228.270 and NARA's guidance on other formats (e.g., PDF, scanned images, digital photographs, and Web content). The specific format is determined when you meet with representatives from NARA (Step 2). NARA may also request you complete a form certifying the format meets their transfer requirements.

NARA has also notified agencies that they may transfer permanent electronic records via two additional methods, File Transfer Protocol (FTP) and Digital Linear Tape (DLT) Type IV (NARA Bulletin 2002-02).

System documentation that provides information on how the system captures, manipulates, and outputs data.
Electronic is the preferred format for the documentation. If the system documentation is on the EPA Internet, indicate which pages to download. If the system documentation is available only in paper, make a complete copy and send to NARA with the electronic data.

A list of files corresponding with what is contained on the electronic media (e.g., tapes, disks).
Completed forms, SF 258 and NA 14097.
The SF 258 must be signed by the EPA Records Officer.

Note: When the work is done by the National Computer Center (NCC) they may charge your working capital fund to perform the work.

Step 4

Send completed paperwork as follows:

Original and one copy of SF 258 with accompanying list of files to NRMP. NRMP will send the original to NARA and keep one copy.
If arrangements have been made for a NARA representative to pick up the records from the program office, note that fact on the SF 258 sent to NRMP.

One copy of the SF 258 and accompanying list of files to your program office RLO or records contact.

Keep the complete package including the electronic media and documentation until NARA has approved the transfer. The media may be maintained offsite at the NCC for safe preservation until the actual transfer.

Step 5

The last step... Once NARA has notified NRMP that the transfer has been approved, NRMP notifies the records sponsor and the program or regional office RLO.

When the records are physically transferred, NARA takes legal custody of the records by signing the SF 258 and returning a copy to NRMP. A copy of the signed SF 258 is sent to the submitting program or regional office RLO.

Congratulations! You have successfully transferred permanent records to the National Archives.