Having subject-matter experts decide and declare what messages rise to the
level of federal records and which do not is not a "legal loophole". It's
pretty much how a records management program works. It's not surprising
that a huge majority of text messages are transitory (requiring only
180-day retention). Texts tend to serve the same purpose as notes jotted on
post-it notes or marginalia; there's no need to retain them if the decision
and information imparted is captured in a more formal memo or report.

It's interesting how many people outside of the RM world (especially those
comment on government operations) assume that every digital bit and byte is
automagically stored as a record. RM staff have always depended on
subject-matter experts to make the first cut of the wheat from the chaff.
Allowing agency staff to decide which texts are records and which are not
is a policy that applies to all agency information, whether email, text,
handwritten notes, reports, memos, or what have-you.

I'm not saying EPA has their policies down pat. The suggestions from the IG
for better awareness of Congressional inquiry and FOIA searches is
definitely needed. The same goes for getting IT folks to talk about records
when they replace or upgrade mobile devices. But it really looked like
Daily Caller and the IG report are just talking past each other in what
they assumed should be happening.

Christopher Ferry, CRM
Boston, MA

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