Chapter 1 - Vital Records Program Administration
This vital records tool kit was developed to serve as part of the Continuity of Operations (COOP) Plan as required by the Federal Emergency Management Agency (FEMA) to ensure that Agency records are protected and efficiently recovered or salvaged using cost effective methods necessary to resume Agency operations during and after a disaster. The tool kit was originally prepared by a work group of the Regional Records Officers. It has been revised to serve as an Agency-wide tool kit for use by headquarters, regional, laboratory and field office records officers who serve as Vital Records Officers.
An effective vital records program is essential to successful records management, is an integral part of the Agency's information resources management program, and is one of the emergency preparedness responsibilities of every federal agency.
Identifying and protecting vital records will save valuable time and resources after an emergency and will allow recovery personnel to concentrate on restoring operations rather than finding the information or spending money and time on restoring unnecessary information.
The objectives of the vital records program in EPA offices are to:
Identify records containing information that programs need to conduct business under emergency operating conditions.
Identify those records that support and are needed for the performance of the Agency's most critical functions.
Protect the legal and financial rights of the EPA, its employees, and the people it serves.
Develop policies, procedures, and a plan of action that will allow for the assessment of damage to and the recovery of any records that may be affected by an emergency or disaster, regardless of the medium of the records.
Develop and implement cost effective methods, including off-site storage and the application of technology, to protect and safeguard those records identified as vital from loss, misuse, and unauthorized information access or modification.
3. Authorities and References.
The primary authority establishing the vital records program within the federal government is 36 CFR 1236, Management of Vital Records. A detailed listing of all authorities and references for the Agency's vital records program can be found in Appendix A.
4. Background and Definitions.
Background. Every federal agency is required by statute to establish and maintain a vital records protection program. Every Agency employee has responsibilities for records management which are defined by statute, regulation, and Agency policy. The vital records program is one element of the Agency's overall emergency management and disaster preparedness and records management functions. It is developed to identify and protect those records that specify how EPA offices will operate in case of emergency or disaster and those records vital to the continued operations of the Agency during and after an emergency or disaster.
Definitions. Definitions of terms used in this manual can be found in Appendix B - Glossary of Terms.
EPA Order 2160.1 - Vital Records establishes EPA's policy for identifying and protecting records and information necessary for EPA to continue its key functions and activities in the event of an emergency or disaster.
Each EPA office is responsible for reviewing their records to determine which, if any, meet the criteria for vital records. The provisions of this tool kit are applicable to all EPA and associate personnel assigned to and/or working in support of EPA headquarters, regional, and field offices. It is applicable to man-made, natural, technological and national security emergencies.
Roles and responsibilities for all EPA personnel are included in EPA Order 2160.1 - Vital Records. Headquarters, regional, laboratory, and field office records liaison officers (RLOs) serve as vital records officers and their responsibilities are as follows:
Ensuring vital records are identified and maintained in accordance with established requirements.
Working with program staff and EPA's Emergency Coordinators to assess possible threats and risks to determine the level of protection or response that may be required.
Working with program staff and EPA's Emergency Coordinators to develop an action plan for protection of vital records and systematically reviewing and testing the plan at least annually.
Preparing and updating the list of vital records and how they are protected.
Submitting the list through senior management (e.g., Assistant Administrator (AA), Regional Administrator (RA)) to the Director, Office of Information Collection (OIC), Office of Environmental Information (OEI), on October 1st of each year, certifying that the list has been reviewed and updated.
Transferring and replacing copies of vital records as documented in the vital records inventory.
Conducting vital records briefings, training sessions, and validation tests.
The steps required for establishing and maintaining a vital records management program are as follows:
Identify records that might be considered vital. The Vital Records Officer, with the assistance of appropriate office staff, develops a list of the records supporting essential program functions, as well as other records that might constitute vital records.
Assess the threats. The Vital Records Officer works with the EPA Emergency Coordinator to assess threats of loss, as determined by the Agency's emergency preparedness function on a location-by-location basis. The range of possible threats of loss include fire, flood, tornado, hurricane, earthquake, sabotage, terrorism, and infestation by vermin or rodents.
Assess the risks. The Vital Records Officer assesses the level and scope of each type of potential risk to determine the level of protection or response that may be required.
Develop an action plan. The Vital Records Officer develops a plan for protecting those records deemed to be vital. The plan addresses protection methods, specific measures for storing, accessing and periodically cycling (updating) the records, loss, prevention and reduction techniques, and procedures for the resumption of business. The plan includes an implementation and monitoring plan, as well as a disaster recovery plan.
Prepare a list of vital records and how they are protected. The Vital Records Officer prepares a list of records that are vital to each office's functional operations. Planning includes considering ways to avoid, where possible, the occurrence of emergency situations, however, not all situations may be foreseen.
Update the list. The Vital Records Officer updates the list at least annually to document current information regarding records cycling and storage. Include a certification that the vital records list is reviewed and updated annually.
Certify the list. Records Officers submit their certification that their vital records list has been updated to the Director of the OIC/OEI, through senior management (e.g., AA, RA), on October 1st of each year to document the status of the office's vital records protection effort for auditing purposes.
Transfer records. The Vital Records Officer transfers copies of vital records in accordance with the instructions as documented in the vital records list.
The frequency with which they are transferred depends upon their cycling or rotation schedule. Some records may require cycling on a daily or weekly basis, while others may only need to be updated monthly.
It is important that vital record copies are kept for only the specified period of time and discarded when the rotation schedule indicates. As records are cycled, the previous copy of the record must be discarded. Following correct procedures here is critical to the success of the vital records program; if multiple copies of the same vital records exist, some of which are outdated, it will be very difficult to determine the appropriate copy for use in an emergency.
Transfers are done electronically whenever possible.
Offices may need to engage the services of a contractor to act as a courier between the office and the off-site location.
Documentation of transfers are maintained in a log noting the dates of transfer.
Conduct a test. A test should be conducted every six months to evaluate the condition and readiness of the process. Report test results to management within 30 days after the test, along with recommendations for resolving any deficiencies found during the test.
Conduct annual audits of the program. The responsibility for conducting an audit of the vital records program lies with the Agency's Vital Records Officer. When offices submit their annual certification to OEI, they include the statement that such plans are current, and that they will cooperate with any potential audits that may occur. This may include checking the inventory of vital records at the off-site storage location, as well as the procedures for cycling vital records.