Chapter 2 - Vital Records Identification
This chapter provides instructions for the identification, preparation, and listing of vital records. Identification of vital records requires agreement among program staff and management and the records management program, and decisions must be made regarding the cost of protecting or reconstructing the information must be weighed against the value of the information to the Agency.
2. Definitions and Objectives.
A certain subset of the Agency's records are vital, meaning that they are absolutely essential in an emergency. In making the determination of which records are vital, the most crucial question is:
Are these records vital to continue the EPA's mission of protecting public health and the environment if normal access to EPA's records are lost for a prolonged period of time?
If the answer is yes, then the records which meet this criteria must be duplicated and stored off-site.
Records essential to continued operations during a local or national emergency comprise the vital records in EPA Offices. These records are categorized as either emergency operating records or legal and financial rights records, also known as rights and interests, records.
Emergency Operating Records. Records that are vital to the essential operating activities of EPA for the duration of an emergency if the national, regional or local area is attacked comprise the "emergency operating records." These records must be available at or in the vicinity of the relocation site and should be in a usable form that does not rely on special equipment. Emergency operating records may include classified or sensitive, unclassified information. Current copies of records identified as emergency operating records are continuously maintained at the EPA Continuity of Operations (COOP) sites.
Emergency Operating Records include records needed for:
The military effort and homeland security.
The mobilization and protection of material and personnel resources, services, and systems.
The maintenance of public health, safety and order.
The conduct of essential civil defense activities.
Records in this category consist of those operating records needed to perform or administer the following essential functions:
Oversight surveillance of the operations of licensed fuel and water facilities to ensure minimum hazard to health and safety consistent with national security needs.
Assessment of damage to life sustaining facilities essential to maintain the quality of life.
Assessment of safety criteria for monitoring the quality of the environment including air, water and land.
Assessment of threats to facility networks above and below ground level relevant to the national emergency.
Liaison with the office designated by the President to receive reports on the EPA emergency preparedness functions, for advice on the content of public instructions and information, and for recommendations concerning EPA's role in achieving national objectives.
Liaison with state agencies concerning emergency conditions and required actions related to licensed facilities and materials.
Legal and Financial Rights Records. Records that are required for the preservation of legal rights and interests of individual citizens and of the federal government comprise "legal and financial rights records," formerly known as "rights and interests records." These records require protection but need not be maintained at or in the vicinity of the COOP site, nor in paper form, because their need would not be immediate. Legal and financial rights records may include records containing proof of ownership, financial interest (payroll, leave, social security, retirement and insurance), legal proceedings decisions, contractual obligations, and similar records. These records could contain sensitive or classified information.
Copies of legal and financial rights records are safeguarded in one of the following media:
Electronic format on compact disks (CDs) at the COOP site.
Electronic format backed up at EPA's RTP facility.
Microforms located at the vital records storage site.
Paper located at the vital records site.
There are three timeframes or "tiers" of records to consider explained below.
Tier one. Also called COOP vital records because they are included in the office's COOP plan.
Tier one records are needed during the first few hours of a crisis or emergency.
Examples include: emergency preparedness plan (such as the continuity of operations plan or an occupant emergency plan), emergency telephone tree, delegations of authority, security clearance roster, office blueprints, policy for talking to the media, copy of vital records list, employee benefit information.
Tier two records are needed to respond to the emergency and to get back into the office. This assumes that no day-to-day work will be done until the building is reopened and/or there is complete access to the records.
Examples of tier two records include:
Records that may be needed to respond to the crisis such as system manuals for critical electronic databases and LANs and regulatory information such as copies of regulations or data on air quality, etc., so important environmental monitoring work can be done.
Records that may be needed to provide employee benefits such as personnel records, including medical records, and time and attendance records.
Records that may be needed to get back into the office such as combinations and/or keys to get into locked areas or equipment, and records recovery information such as phone numbers of disaster recovery companies.
Tier three records are needed to work on specific projects critical to the Agency's mission. This assumes that the records are unavailable for a prolonged period of time causing long-term displacement of personnel from the normal work site. The most critical projects would need to be continued off-site.
Tier three records would be any program-specific records on projects that are deemed to be of critical importance and cannot be interrupted. This determination must be made by each office. It is possible that an office may not have any tier three records.
There is a link between vital records and the COOP. Therefore, one of the criteria that can be used to determine an office's Tier three vital records is what the office has defined in its COOP as its "essential functions." Any records deemed necessary in supporting the office's essential functions should be a part of the office's set of vital records.
The following guidance is useful in identifying vital records.
Consider records which support essential functions identified in the office COOP.
Vital records may be in any format or medium (paper, electronic, microfilm, etc.). The vital record copy is usually just that, a copy.
The length of time the records are kept (retention) does not necessarily indicate that a record is vital, nor does the record designated as vital always remain vital. For example, Superfund remedial site files are considered vital only until cost recovery is complete.
It is helpful to ask the following questions:
What function would not be carried out if the record is destroyed and how critical would it be if it could not be done?
What would the consequences be to EPA if the records were lost?
What would the consequences be to the public or employees if the records were lost?
If the records have to be reconstructed, what would be the cost in time, money, and/or labor?
4. Vital Records Inventory.
A vital records list identifies the records which have been identified as vital as well as other information about the records, including who, what, where, when, and how. The list should be a "one-stop" place providing information on how to locate and recover vital records. The inventory provides the following information:
Who is responsible for the original records, the vital records copies, and sending the copies to storage?
What are the vital records, their format and volume, and the method used to protect them?
Where are the original records and the vital record copies maintained?
How often are the vital records replaced (known as the rotation cycle) and how are they updated?
A sample vital records inventory is shown in Appendix C.