On Fri, Mar 13, 2015 at 12:26 PM, Peter Kurilecz <[log in to unmask]>
wrote:

> which particular parts of 36 CFR are relevant?
>
> Larry Medina <[log in to unmask]>
> wrote:
>
> > Capstone is an "approach" 36CFR is the regulation.
>

it starts with 36CFR, Chapter XII, Subchapter B, Part 1220

Defining Records, Creating and Maintaining, Scheduling, Dispositioning,
Unlawful or Accidental Removal/Defacing/Alteration/Destruction, Transfer of
Custody, Standards for Storage, Managing in Electronic Form...

it's ALL relevant, if you are working for an Agency or a Contractor to an
Agency.

The CFR sets the rules for Agencies (1220.10), the Agencies issue Orders,
Guidance, Manuals interpreting how to apply the requirements (1222.24),
they also issue guidance for Contractors telling them WHAT they have to do
(1222.32), and then they write policies and procedures as to HOW they will
comply.

It's a direct flow down, and for Contractors, the requirements are embedded
in Contracts through the FAR (Federal Acquisition Regulations).

But what makes it 'work' is NARA performing inspections and enforcing the
guidance... and that's the weak link.  Writing things like CAPSTONE, or
even ghost writing things like the Presidential Directives with unrealistic
schedules and no funding to accompany the new requirements, DOES NOTHING
except frustrate everyone.

And so nothing happens, more reports get written, people continue to shout
at the rain and we continue to stand still.


-- 
Larry
[log in to unmask]



*----Lawrence J. MedinaDanville, CARIM Professional since 1972*

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