NARA OKs DOD records plan

The National Archives and Records Administration last week endorsed a Defense Department standard for electronic recordkeeping systems for use governmentwide, giving civilian agencies for the first time an officially sanctioned framework to build digital records management applications.

In a Nov. 19 memo to agency records officers and information resource managers, Michael Miller, director of NARA Modern Records Programs, said DOD Standard 5015.2 is "one possible approach to managing electronic records" but is, nonetheless, "an appropriate starting point" for agencies that want to develop systems for maintaining digital files.

The announcement provides reassurance for agencies that have been using the DOD standard as the basis for their own recordkeeping systems requirements. "It lays to rest the chance that they might switch [policies] midstream," said Tim Wheeles, director of the National Institutes of Health's Division of Management Support.

Agencies have been clamoring for official guidance on building electronic records management systems ever since a federal judge ruled last year that agencies must maintain electronic documents in digital form instead of printing them out. Although the government is appealing that decision, in the case Public Citizen v. Carlin, many agencies are exploring ways to comply with the mandate.

Michael Tankersley, senior staff attorney with Public Citizen, which represents the plaintiffs in the case, called the NARA announcement "a halting, half-step forward'' because NARA still has not told agencies how to decide which electronic records they need to keep. Endorsement of the DOD standard does, however, "confirm that technology is not the obstacle to preserving and managing agencies' electronic records," he said.

NARA did not endorse any of the eight software products that DOD has certified as compliant with its standard. Deputy Archivist Lewis Bellardo said NARA and DOD are jointly reviewing the testing process used by the Joint Interoperability Test Command, Fort Huachuca, Ariz., to evaluate electronic records management applications.

He said the review may be completed by spring. Meanwhile, he said, if agencies want to buy DOD-certified products, "I think they have to make decisions on the basis of their own business needs and how urgent it is to go forward."

Although optional for civilian agencies, the standard remains mandatory for DOD. The NARA endorsement "really has no effect on our policy," said Burt Newlin, a computer specialist with the Defense Information Integration and Interoperability Directorate, which manages the standard.

Bellardo said agencies should be aware that if they adopt the DOD standard for their systems, "it's all or nothing." The numerous functional requirements for recordkeeping systems described by the DOD standard conform with federal records laws and policies only when adopted all together.

He added that if agencies do not have policies in place for cataloging their electronic documents and ensuring they are preserved or deleted according to those policies, any systems they build will not work.

NARA did find the DOD standard lacking in some areas, which, the memo notes, would be addressed in future versions of the policy, or agencies could address the gaps on their own. For example, NARA wants recordkeeping systems to track e-mail by an "intelligent representation of the e-mail account name," such as the real names of message authors rather than their e-mail addresses. Software that meets DOD specifications does not do this automatically unless that feature is available within the agency's e-mail package.

Newlin said the Office of Management and Budget may consider making the DOD standard a governmentwide mandate. OMB officials could not be reached for comment.