SLA Urges Improvements to Records Digitization Proposal

Inadequate oversight, lack of sufficient resources are chief concerns

McLean, Virginia, U.S.A., 15 February 2021—The Special Libraries Association has joined with several other interested organizations and individuals in submitting comments to the U.S. National Archives and Records Administration (NARA) in response to proposed regulations that would (1) establish a specific schedule for government agencies to review their existing records and (2) establish standards for digitizing permanent paper and photographic records.

Under current regulations, U.S. Government agencies are required to review their existing records schedules “regularly.” The NARA proposal clarifies the word “regularly” by establishing five years as the time frame in which agencies must review records schedules that are 10 years or older.

The proposed regulations, issued on 1 December 2020, also build on 2019 changes to the Federal Records Act that added standards for digitizing temporary records, which constitute the majority of Federal records. The proposed regulations establish standards for digitizing permanent paper and photographic records. Permanent records are those considered to have sufficient historical or other value that warrants continuing to preserve them beyond the time agencies need the records for administrative, legal, or fiscal purposes.

The comments on the proposal, submitted by SLA and other organizations and individuals that use federal records in their work, laud the NARA proposal as “a huge leap in the right direction” but express concerns about “several practical gaps.” Chief among these gaps are inadequate oversight of agencies’ digitization plans and their implementation and a lack of sufficient resources to support agencies’ digitization efforts.

“In the past two years alone, a Federal Housing Finance Agency records audit to check its compliance with NARA requirements was unable to readily and reliably locate permanent records, finding many of them misplaced,” the comments state. “Separately, an Office of Inspector General’s audit of the Department of Labor found that the Department lacked procedures for effectively managing its electronic messages as federal records. Indeed, the Office of Attorney General has already warned that NARA must be more active in oversight and enforcement to fulfill its statutory role as records manager for the Federal Government. If NARA does not start effectively exercising its oversight authority, including providing and codifying specific best practices, permanent records will likely be lost and destroyed.”

The comments also note that federal agencies typically lack archiving expertise. “NARA must ensure that agencies consult with archiving and topical experts as they draft and implement their project management and quality management plans,” the comments state.

Joining SLA in submitting the comments were groups such as In the Public Interest and the PEGI Project (Preservation of Electronic Government Information Project) as well as individuals from the Concerned Archivists Alliance, Sage Information Services, and Free Government Information.

About SLA
The Special Libraries Association (SLA) is a nonprofit international organization for innovative information professionals and their strategic partners. SLA serves information professionals in more than 50 countries and in a range of working environments, including business, academia, and government agencies. SLA promotes and strengthens its members through learning, advocacy, and networking initiatives. For more information, visit sla.org.

Contact
Kathy Bradley
kbradley@sla.org
+1.703.647.4900

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