>If NARA isn't enforcing, I'm sure it's not because they are "lax," but
>rather they lack the staff to do enforcement, as well as backing from
>"higher." 

So what Gary seems to be saying here is they aren't "lax", but instead are
"lacks" =)

Here's the rub for me- NARA goes through the efforts to promulgate a
multitude of regulations requiring certain steps be taken by Federal
Agencies (and their Contractors) to adequately document the business of the
Agency as Federal Records to assist in documenting the work done on behalf
of us as citizens of the US... Right??

THEN... they fail to comprehend that to ensure this takes place, they need
to provide training, then audit for compliance, and enforce the regulations?
 And to recognize that it takes staff and funding to do that??

This reminds me of a phrase a good friend of mine uses regularly when he
hears about a problem someone creates for themselves that they are unable to
deal with...

"Can God create a rock that's so large and heavy that even He can't lift it?"

If NARA were to spend as much time evaluating things like the 2008 CREW
report http://bit.ly/4j24uR  on the status of e-recordkeeping in the Govt,
or past IG Reports on findings in Agency records systems of an inability to
manage to the requirements, maybe they'd get a better handle on what needs
to be done.  

A perfect example would be to look at what happened with the FBI Vrtual Case
File (VCF) system, http://bit.ly/15KRWv money down the rabbit hole thrice
($170MM once,  then $2MM to prove it wasn't working, then $17MM to decide
what to do)  and now the estimate is $425MM to build a system that weill do
what they need to do.

And yep, this DOES fall under the purview of NARA, because those records
from this system that meet the definition of a Federal Record (all of them)
and are a Permanent retention (some of them) will eventually need to be
transferred to NARA.

As for the "new regulations" http://bit.ly/VXA5M they really aren't all new,
NARA simply reorganized ALL of the content of 36CFR Subchapter B, Records
Management to supposedly make it easier to use.  There is a cross reference
table to what was where and how to find it now provided, and that list any
'major changes' and if you review it, there aren't many... and for those of
us who refer to these regulations frequently, believe me, this IS NOT EASIER
to use and I've already found **3** critical Standards references that did
not survive the rewrite from one version to the next.

Larry
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