System-building blueprint evokes mixed feelings

The National Archives and Records Administration is preparing to issue guidelines for agencies to follow when building systems for managing electronic records.

James Hastings director of NARA's Records Appraisal and Disposition Division said the final blueprint expected to be completed this fall will not require agencies to have such systems but it will outline the components such systems should have if agencies decide to purchase them.

"What we're saying is Agencies that decide for their own business purposes to manage records electronically need to have the following standards built in " Hastings said.

A draft of the guidelines issued earlier this year noted that "few if any" commercial software packages support all the functions NARA has proposed.

According to the draft guidelines electronic record-keeping systems should have three main functions:* Allow users to designate whether a document is a record and to track identifying information. * Maintain and preserve records so that they can be easily retrieved by authorized users in agencies or the public.* Enable agencies to dispose of records according to federal regulations either by deleting them or by transferring them to NARA.

The draft would also require agencies to maintain system documentation and to plan for migrating records to new formats or ensure other ways electronic documents can still be retrieved as technology changes.Agencies that reviewed the draft requirements earlier this year gave them mixed reviews. Some said the standards were on the right track while others complained they would be too hard to meet given available technology and budget resources.

"The procedures and policies set forth in the publication far exceed this department's resources in the near term " said Kenneth Schmalzbach assistant general counsel with the Treasury Department. He worried that NARA's prescriptions would be interpreted by the public as mandates and that agencies would be sued if they had not met them.

William Henry director of records services with the South Carolina Department of Archives and History said he is looking to NARA to provide models for how to manage records electronically and asked the agency to include sample systems in its guidelines.

Hastings said "there really isn't a model yet" but that NARA would probably refer agencies to the Defense Department which is setting up a test facility at Fort Huachuca Ariz. to evaluate commercial software for records management applications. "We can't endorse any specific ones " he added.

Commenters also reopened an ongoing debate between NARA and agencies over obligations of federal government employees to decide whether documents they create are records because the proposed guidelines would require record-keeping systems to allow end users to specify whether certain files must be preserved.

Agencies have argued that this is too much of a burden for employees. But Hastings countered that unless users make such decisions NARA would be overwhelmed with thousands of electronic documents that might not be necessary to preserve.

Many commenters also said the guidelines were confusing a problem Hastings said would be remedied by reducing the overlap between the electronic recordkeeping requirements and other NARA guidance such as how to identify electronic records that should be preserved.