Well, I'm glad to see some discussion beginning on these new proposed
Standards, but I think I need to clear up a few things that seem to be
misunderstood about my comments related to them.

#1  I NEVER suggested these were replacing 15489.

My comments with respect to 15489 and the relationship between the two were
more directed at the decision by ISO to "shelve" 15489 and rather than
revising the Standard related to practice issues that was available to
Practitioners that was, and is, in need of revision (it was published in
2001) they instead were pressing the need for a "Management Standard" for
Records.

#2 There is no value in, or that the proposed Standards should be dismissed.

My concern was with the content and how it's presented, and the confusion in
the terms/definitions and arrangement of information presented.  I can see
where at some point there could potentially be value in having a "Management
Standard" for a practice such as Records Management, but the area that needs
the most work are the PRACTICAL Standards directly related to the practices. 

Unfortunately, it seems the ultimate goal of this seems to be the issuance
of other companion pieces that allow certification and compliance... but
what value will any of that be to organizations if the core documents
(15489, 23081, whatever else) are lacking in content and no longer relevant?
  That they can certify their programs are compliant with a Standard that
should have been revised 5 or more years ago?

This comment was clearly made to ISO (through NISO) by the ARMA SDC in 2006
and again in 2007 when work on 15489 was set aside by ISO in favor of
developing the concept of "Families of Standards", which seemed much more
focused on marketing than what the core purpose of TC46/SC11 has been.

#3 The language in the proposed Standards is a problem.

I don't have a problem with the decision to write these consistent with
other ISO "Management Standards", obviously they need to be arranged and
organized in the same manner so they look and feel the same.  

But these are related to a practice, not a product.  The same might be able
to be said about "Quality", but ISO 9001 and 14001 aren't about explaining
to management the need to implement quality practices, they're about
managing the systems put in place to ensure quality is ingrained in an
organizations processes. 

Removing my Professional and Practitioner hat and reading these drafts from
a management point of view, I don't get any understanding of the value of
implementing sound RM Practices and why it should be incumbent upon
organizations to be certified as compliant with them. What they look to
comply with are the  Laws, Regulations, Statutes and Industry Requirements
for the industry segment they work in.

From the ISO Web site, "Management Standards, Understand the Basics":
Generic means that the same standard can be applied to any organization,
large or small, whatever its product or service, in any sector of activity,
and whether it is a business enterprise, a public administration, or a
government department.

The same standards for performance and compliance don't apply to all
industry segments, public and private, when it comes to RM, at least in the
US.  Finance, Healthcare, Education, Transportation, Utilities, Legal all
have different requirements and are regulated by different entities.  How
does the "generic" model for management of RM across all organizations fit?
 Aside from giving some lofty general requirements like "do good stuff for
the right reasons and follow all the laws and regulations that apply to you"
I don't see it.

Many organizations are getting a better understanding of the value of a
sound RM Program but many of those that are look to technology to assist in
achieving compliance with

#4 Terms and definitions don't comply with other ISO Standards.

Let me say first that I know Dr. Xiaomi An and have a substantial respect
for her and her work.  Terms/Definitions in our practice field are tough,
people can spend hours arguing what a "record" is (depending on your
industry and business model) and the differences between a "document and a
record"... and that's when they do business in the same Country, maybe even
across the street from each other... so I appreciate the effort required to
make these consistent for international use.

My criticisms were twofold: 

- the manner in which the definitions were segregated into three categories
rather than appearing in a single list, with annotations describing which
aspects of the Standard they apply to.  To divide them into "records",
"management" and "records management" makes absolutely no sense. The
document isn't divided this way, why do this with the definitions? 

- the need to repeatedly state the definitions were 'adapted from' ISO 15489
clearly indicates the definitions in ISO 15489 need to be rewritten... just
like the rest of the Standard, which was my original point.

Again, I'll point to the definitions for "conversion" and "migration" and
the fact the examples are incorrect.  And still, what's worse (for me) is
the need to create Annex A to give multiple graphical representations
explaining how the definitions and terms relate to each other, whether they
are used in records, management or records management! 

#5 Not enough has been done to get the word out about these until now.

I understand from comments provided that multiple countries have worked on
these and that a lot of effort has gone into attempting to make people aware
of them through various methods.  I think the silence on this list of nearly
2200 RIM Professionals and Practitioners should tell you that essentially NO
ONE IN THE US RM community had any idea that these were in development or
draft form, much less ready for public review.  Had it not been for the
notice on the UK RM List (and Peter posting that here), that would STILL be
the case.

Believe me, I do not turn a deaf ear to Standards potentially impacting the
RM industry... my history with the involvement in Standards Development is
known by many here. The last thing I heard about this effort was when ARMA's
past (2007) Director of Professional Resources told me ISO was CONSIDERING
developing a set of overarching Standards for Information Management and
that ISO 15489 was not being revised until a decision had been made on this.  

Not nit-picking the comments from others in support of this effort, I just
think there is a LONG WAY TO GO before we're ready for this and I'm unsure
where the concept that there was a need came from.  Generally, it's
professionals working within the industry that express a potential need for
a guideline, technical report or standard to be developed.  I haven't hear
this battle cry raised in a concerted voice.

I can tell you that if I were to present these drafts to anyone in "top
management" where I am now, they'd be more confused after looking at them
than they were before. If I said "we need to comply with these" and they
pointed to ISO 15489 as to how we should achieve this, I couldn't explain
how that Standard in it current state adequately frames how RM needs to
function.

However this is read, it is not intended as biased mud-slinging designed to
derail the efforts of the ISO/NISO to move forward with the development of
Standards intended to support Records Management, and naturally, I can't
speak for other RMs here, but I think this is a clear case of "cart before
the horse" thinking.

Anyone else read them and care to weigh in?  

Respectfully

Larry Medina
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