The California Public Utilities Commission (CPUC) has published on its Web site (see URL and bit.ly below) several documents, at least one of which is of seminal importance in records management.
That document is titled "Records Management within the Gas Transmission Division of Pacific Gas and Electric Company prior to the Natural Gas Transmission Pipeline Rupture and Fire, San Bruno, California September 9, 2010". It is dated March 5, 2012.
Some excerpts:
This review has used the "Generally Accepted Record-keeping Principles(r)" (GARP(r)) and the Information Maturity Model defined by ARMA International as the basis of an assessment and evaluation of PG&E's records management activities. [p. 1-8]
On the basis of the GARP(r) criteria we find that records management within PG&E's Gas Transmission Division prior to the San Bruno pipeline rupture and fire were 'Sub-Standard' (Average Maturity Score = 1.2). [p. 1-8]
In lay terms, PG&E's recordkeeping was in a mess and had been for years. Gas transmission records and safety-related documents were scattered, disorganized, duplicated, and were difficult if not impossible to access in a prompt and efficient manner. The accuracy, completeness and quality of any of PG&E's digital datasets derived from its hardcopy pipeline records were at risk as PG&E did not have a complete and comprehensive master set of all job folders and files in one place that they could consult as they compiled their data. From the 1950's to date, PG&E has been aware of their legal records retention requirements. While they documented their legal requirements, their implementation of their retention standards was rather more subjective. In some instances, key record series, such as their pipeline history files were 'lost' or inadvertently destroyed. [p. 1-10]
The recordkeeping issues identified in this report could have been addressed if PG&E had put the right people, process and systems in place over time, and had provided clear records management guidance, direction with senior management support to improve the way that its different offices and teams manage their records and share information. The creation of a formal records management program with supporting records management policies, procedures, systems and training would have ensured that appropriate attention and protection was given to PG&E documents, so that the evidence and information they contain could have been retrieved more efficiently and effectively. [p. 1-10]
PG&E has requested that $222.8 million of its Pipeline Records Integration Program (PRIP) costs be funded by ratepayers from 2012 to 2014. .... As consultants, we suggest that these costs are excessive, and we cannot support PG&E's request for them regardless of their total. The scope and degree of PG&E's proposals do, however, inform the Commission of the nature of the recordkeeping transformation and improvement that PG&E must undertake. [p. 1-11]
In summary, this report, and its findings and conclusions are consistent with the findings and conclusions of the NTSB, the Blue Ribbon Panel, and PG&E itself. Each may have reached its findings and conclusions based on different considerations and perspective. But each has concluded that PG&E's recordkeeping practices have been deficient and have diminished pipeline safety. [p. 1-11]
As a result of our extensive efforts during the course of the recordkeeping investigation, we have come to believe that PG&E failed to maintain the records management practices necessary to promote the safety of its patrons, employees and the public. Examples of these failures include the lack of a company-wide strategy for record keeping; poor implementation of records management standard practices; inappropriate disposal of pipeline history files; inadequate management and control of job folders; poor metadata quality control; and the uncontrolled distribution, duplication and storage of pipeline-related job folders. [p. 6-25]
As a result of these failures: PG&E's historical pipeline records would not have been readily available, traceable, verifiable or complete; there was no single source of trusted pipeline-related documents records management was not optimized to support operations, decision making, planning or safety; and inconsistent, incomplete and out of date information would have been present in a significant number of its pipeline related job folders, as well as those systems, such as the GIS, which relied upon them. [p. 6-25]
There is no infrastructure to provide staff with education and training in records management principles and practices. No mentoring, skills transfer, or support for staff that have record-keeping responsibilities within PG&E. While compliance and ethics training has been undertaken across all of PG&E, records management and retention and disposal training has not been provided to PG&E staff. [p. 6-30]
URL: http://www.cpuc.ca.gov/PUC/events/120312_ReferenceDocumentsforCPSDReportsinRecordkeepingPenaltyConsiderationCase.htm
Bit.ly: http://1.usa.gov/xNYmdm
Looking for a records management "smoking gun"? If there is one, this is it. But let's not forget that eight lives have been lost to produce this "smoking gun".
Best regards,
Fred
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