Dwight makes an excellent point here that we had to wrestle with over the
past when it came to developing retention instructions for certain types of
highly sensitive records that have a half-life (if you know what I mean and
I think you do)

The major problem came when we were discussing this with physicists,
scientists and engineers and we were explaining that because these were
Federal Records, the retention periods were set/approved by NARA, with some
guidance from the user community... but ultimately, the appraisal
archivists set the periods and the AOTUS approved the schedule.

There are a number of issues why the Federal Government in its latest phase
of operation is having problems gaining control of its records, both in
physical and electronic formats... the main reason is the guidance that
establishes the practices and requirements for management of these records
is archaic and written in records management-ese for records mangers.  As
we all know, we have our own language and we use terminology that WE all
understand but that doesn't translate well into other facets of business
management.

That's where the problem lies... the vast majority of these records are
generated in support business activities in Federal Agencies to document
decisions, transactions, activities, appointments, occurrences, research,
design, development, or some other form of "the business of the business".
  They aren't created for the sake of records management, or archives, but
to document things that have taken place and to be available for future
reference, research or validate/verify that something took place.

So, when you attempt to explain to those who created the records and/or use
them in support of mission critical efforts related to issues of National
Security, Defense, Logistics, Environmental Management, Research and
Development, and such... that the records "are to be retained locally while
in active use, then transferred to storage for the remainder of their
required retention, after which disposition decisions will be made if they
are archived or disposed of following a review by records management"
they're going to look at you as if you're crazy.

So, when Dwight stated "you need to translate those terms into language and
processes that will be understood by the staff doing the work" he was
exactly right.  And this is the problem with the language in 36CFR, and why
so many Federal Agencies have been wrestling with how to manage 'records'
in accordance with the guidance given.  The requirements as written just
plain don't make business sense... especially for electronic format records
and REALLY for email.

Over the past two decades (or longer) more of the administrative and
technical work done for Federal Agencies is being done by Contractors who
are also required to follow this guidance. The difference is, the guidance
is included in Contracts and the Contractors have the ability to "push
back"  against some of it. They MAY NOT have the ability to decline to do
what is required, but THEY DO have the ability to say "tell us WHAT we have
to accomplish, but don't tell how HOW to do it... unless you're willing to
fund us to do it that way."

Even the Federal workforce is seeing a "changing of the guard"- with the
establishment of CIOs, CTOs. and other positions that formerly existed only
in private industry, people have started questioning the published
requirements.These people and position came out of BUSINESS and the reason
you saw them moving from Agency to Agency and many going back into private
business after a couple of years is they were frustrated by all of the
regulations and practicews that hampered their ability to conduct the
business of their positions in a Federal paradigm.

The GAO and IG reports on records management and information technology of
the past 5-7 years are finding many Agencies falling far short of the marks
set for them... but it seems to have taken until the past couple of years
for them to realize almost ALL of the Agencies are getting bad marks on the
exact same things...and maybe the problem is in the ability to comply with
the regulations as written, not a lack of willingness.

The Presidential memo of late last year and the subsequent assesments by
Agencies and their responses have made it patently clear the guidance HAS
TO CHANGE to ensure it is 'implementable' and that it can be done in a
manner that the costs don't exceed the benefits of doing it and that it
makes good business sense to do it.  The first draft guidance has set goals
and target dates for achieving certain things that will NEVER BE MET.
mainly due to a lack of staffing, a lack of funds, and a failure to
comprehend the scope of the effort. Not only do Agencies have to contend
with the present volumes of information and the projections of growth going
forward, but they have a tremendous volume of legacy content that they have
to contend with.

This isn't saying it can't be done, because it MUST be done, but it has to
be done in a more logical manner. This may involve "drawing a line in the
sand" and saying "from this point forward, the following practices will be
put in place to manage newly created content in compliance with this newly
developed guidance", and then work towards developing policy and practices
for addressing legacy content in two phases. Phase One will be the content
in systems and applications which are active and still supported. Phase Two
will be assessing the volume of content in systems that are no longer
supported (true legacy systems) and determining the need to migrate that
data forward, then developing a plan to fund and begin migrating it.

Enough of this for a Friday... I should be thinking about the weekend and
the few days I'll be taking off next week instead.

Larry
[log in to unmask]

On Thu, Jul 19, 2012 at 1:54 PM, Dwight WALLIS <[log in to unmask]>wrote:

> Gordy, in my experience, who is doing the work is key. If they are high
> turnover, relatively low paid/low skilled staff,  you either have to:
> (a) have the resources or capability to continuously educate that staff on
> common records practice and terminology if you wish to utilize standardized
> terms as recommended, and that process needs to be actively supported by
> management at all levels; or
> (b) you need to translate those terms into language and processes that will
> be understood by the staff doing the work; or
> (c) you need to take responsibility for monitoring/fixing problems as they
> arise resulting from a failure to do (a) or (b).
>
> One does not have to be an auto engineer to drive a car. One should not
> have to be a records manager to perform routine records processes.
>
> Dwight Wallis, CRM
>



-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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