>
> I'm aware of the FAR requirements which are actually part of the CFR but
> that's where my dilemma is.  If you read the FAR4.7 rules the
> recordkeeping specifics are very vague and leave alot of wiggle room.  But
> if you read the CFR citations and associated text that Larry provided
> there are very specific rules especially for electronic records.  So to
> which end of the spectrum are contractors obligated to comply with or is
> there a middle ground based on sound RM principles ?


Depends on the Agency you arwe working under the direction of, and the
language in your specific contract, especially the "List of Applicable
Directives"

Most of what's in the FAR relates to financial and pay records, some of it
to contracting, procurement, etc.

As you noted, the content in 36CFR is from NARA, and applies to the
management of ALL Federal Records (as defined in the CFR) and it applies to
ALL Federal Agencies, their Contractors and their sub-contractors.  Each
Agency generally has additional guidance related to their requirements
specific to records management (DOE has Orders 200.1, 243.1, 243.2, Manual
4001-2000, etc.) and if these are in the "LoAD" in your contract, they are
also applicable to you.  As an example, if DOE Order 200.1 is in your
contract, it has in it's list of references 36CFR, Subchapter B, which makes
ALL of that document applicable to their Contractors.

Middle ground?  Well, there are cases where organizations have negotiated
with Fed Agencies to show where they have systems in place that are
"reasonably similar and accomplish the same objectives in other ways", but t
the end of the day, the Contractor is responsible to turn ALL RECORDS over
to the Agency and/or NARA and they must be maintained in a manner that
allows for transfer meeting NARA's requirements as stated in the CFR.

Very few of the records generated by a contractor are uniquely theirs, and
everything else is a Federal Record.

Larry

-- 
Larry Medina
Danville, CA
RIM Professional since 1972

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