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Subject:
From:
"Michael, Lee" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 9 Dec 2005 11:18:25 -0700
Content-Type:
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I have to agree with Bill R. on his reply.  36 CFR 1222.42 (part of the
regulations issued by NARA that are applicable to US federal agencies)
discusses the removal of nonrecord materials.  Even copies of federal
records are not to be removed from agency custody without the "approval
of the head of the agency or the individual authorized to act for the
agency on matters pertaining to agency records."  Although this
regulation probably didn't exist in 1975, it seems pretty clear today.

As for "real world" scenarios...  I have a discussion with each
departing staff member about records, copies, and nonrecord material.
If they identify their desire to take anything with them, they compile a
list.  The list is reviewed and approved my senior management, the legal
office, and me.  Without the approval, the items stay behind.  I've had
differences of opinion with legal counsel on these issues, but they have
always been resolved appropriately and the departing staff member does
not always get their way.  In addition, the departing staff member signs
a form acknowledging that they are not removing records, or copies upon
their departure.  I've only had one person refuse to sign this form, and
this was a situation involving an involuntary separation.


Lee Michael, CRM
Records Program Manager
National Renewable Energy Laboratory
Golden, CO

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