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Part 4. Organizing and Managing Records

Organizing Documents that Qualify as Federal Records

General Principles

Documents that qualify as Federal records must be incorporated into a recordkeeping system. Recordkeeping systems may be either hard copy or electronic, provided that they meet the objectives as set forth in the box below. They may also be centralized or decentralized, provided that they can be accessed by all staff with a need for access.

NARA defines a recordkeeping system as:

A manual or automated system in which records are collected, organized, and categorized to facilitate their preservation, retrieval, use, and disposition." (36 CFR 1220.14)

If a program office wishes to maintain an electronic recordkeeping system, including storage of e-mail documents, the system must be capable of:

Guidance

Paper records

Documents that qualify as Federal records should be included in the appropriate file and filed according to the procedures for the recordkeeping system in place in the unit.

Documents of short-term retention should be filed separately from those that are part of the longer-term documentation of the activity.

Electronic documents

Documents that qualify as Federal records necessary for long-term documentation of the activity are to be printed out and filed as part of the paper recordkeeping system. If that is done, the electronic version can be deleted.

Alternatively, offices wishing to establish an electronic recordkeeping system and file the documents in the electronic system must work with the National Records Management Program to ensure that the electronic recordkeeping system has the capibilities listed above.

Electronic mail

A complete e-mail message consists of the message text, transmission information (identities of the sender and recipient(s) and the date of transmission), and any attachments, acknowledgments of message receipt, or other messages (e.g., an incoming e-mail request) providing context for the message.

The complete e-mail message must be filed either in paper or electronic form. If the message qualifies as a Federal record, it must be printed out and filed in the appropriate paper files. Once the message has been printed out and filed, it can be deleted from the e-mail system. If the printout does not contain the necessary transmission information, the missing information should be added by hand, together with the date and initials of the person making the annotation.

If the message is sent to a mailing list (e.g., all staff in a given unit) and the identities of those staff can be determined using other sources (e.g., a staffing roster), their names do not need to be retained in a separate electronic file.

Electronic recordkeeping systems may be used to store e-mail messages that qualify as records if the systems meet the objectives identified above. The Agency will move toward electronic maintenance of e-mail messages as technology and cost allow.

If e-mail messages are stored in an electronic recordkeeping system, that system must allow for:

For additional guidance on e-mail, see:


Retention of Federal Records

General Principles

Generally speaking, an individual document does not have a specific retention. Documents are put in files and those files have "dispositions" based on what they document and how they are used. Hence, there is no specific disposition for documentary forms (e.g., e-mail messages, minutes of meetings, drafts, correspondence, memorandums, etc.), but there are dispositions for each type of file (e.g., controlled correspondence, permits, contract management records, etc.) into which documents are placed.

NARA defines disposition as:

"...those actions taken regarding records no longer needed for the conduct of the regular current business of the agency." (36 CFR 1220.14)

The retention and disposition of each type of file is specified in the records schedules established by the Agency in conjunction with NARA. Retentions as specified in the records schedules are mandatory. Retention and disposition may vary from the extremely short (30 days or less) to extremely long (30 years and then transfer to the National Archives for permanent retention).

Program offices are required to ensure that records maintained electronically can be accessed for their entire life. This can be done in one of these ways:

Program offices are also responsible for ensuring that records determined to be of permanent value can be transferred to the National Archives in the format specified in the records schedule. The National Archives only accepts electronic records on certain specified media and in certain specified formats. Transfer specifications for electronic records are provided in 36 CFR 1228.270.

Guidance

EPA's records schedules are available on EPA's Internet and Intranet.

Always file records in recordkeeping systems. Make sure that each recordkeeping system has a valid records schedule.

The easiest way to ensure that the files are retained for the appropriate period of time is to use the Agency file codes that link files to their records schedules.

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