January 3, 2007 Colleagues- Probably many of you are working within your
agencies (using the term loosely) to determine whether "flexible" and or
"big-bucket" records schedules are appropriate for your organization. 
If they are, I suspect that many of you are trying to design and
implement these types of records schedules. At the US National Archives
and Records Administration (NARA) we have been reviewing, and approving
functional/big-bucket schedules for approximately 3-4 years.  NARA
guidance for big bucket scheduling is found at:
http://www.archives.gov/records-mgmt/bulletins/2005/2005-05.html I
commend this guidance for your review. Lately, we have been receiving
"big bucket" schedules from various agencies that are arranged not by
"function," or "line of business," but by "retention driven buckets."
That is the schedules are arranged by retention period, by say,
retention periods of 1 year, 3 years, 5 years, 20 years, and then
thereunder by the records created.  The schedules are not arranged by
business operations (policy, fiscal, administrative, etc.)- but by
retention periods. NARA is not amused by retention based arrangement. 
NARA Bulletin 2005-05 states specifically that a big bucket schedule is
an application of disposition instructions against a body of records
grouped at a level of aggregation greater than the traditional file
series or electronic system that can be along a specific program area,
functional line, or business process (Paragraph 5).  These function- or
business process-based schedules reflect the way work is actually
accomplished in each office or program area, and the records created
during these activities arise from the same context and are subject to
the same legal and regulatory obligations. Function-based schedules thus
preserve the context and therefore the meaning of records, as well as
reflecting the business process. In our opinion, retention based
schedules will not maintain the context and meaning of the records.  If
the context and meaning of these records is not ensured, then we cannot
endorse the concept that the agency is maintaining adequate and proper
documentation. I should emphasize at this point that this is my own
interpretation of NARA policy. All of that being said, and not wishing
to argue the point, how do others of you all feel? Are there any who
have implemented a successful functional/big-bucket schedules arranged
by retention periods? Any bad experiences? Is there anything in the
records management/archival literature supporting a pro-retention
arrangement view point? (I have not had time to check out the
literature.) Are there many who see the virtues of such a schedule
arrangement? Is there agreement with NARA that only functionally
arranged big bucket schedules are appropriate? Is there anything in the
records management/archival literature supporting the idea that only
functional based arrangements will work? (I have not had time to check
out the literature.) I'm more interested in general thoughts.  I'd be
happy to provide any clarification or clear up any confusion I may have
created. Happy New Year! Jim Cassedy  (This interpretation of NARA
policy has not been approved by higher authority, and should in no way
be interpreted as NARA policy (for the present purpose).  Any
inaccuracy/vagueness/stupidity reflected in this query is completely my
own. 

 
 
James Cassedy
Archivist, Work Group 4 Leader
LifeCycle Management Division (NWML)
National Archives and Records Administration
8601 Adelphi Road
College Park, MD  20740
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(301)-837-1584
301-837-3697 (fax)

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