National Archives and Records Administration: Actions Needed to Ensure Facilities That Store Federal Records Meet Standards
Highlights
What GAO Found
Agencies are to store federal records in three types of facilities:
- Federal records centers: The National Archives and Records Administration (NARA) operates 18 federal records centers that are comprised of 24 facilities (buildings) located across the United States. Each facility includes storage areas, referred to as bays.
- Agency records centers: Agencies also establish and operate records centers for storing their own records. As of May 2013, NARA had identified 18 agency records centers that were operated by 6 agencies or offices.
- Commercial records storage facilities: Agencies also use private sector commercial facilities. As of May 2013, agencies reported that 12 vendors provided 22 facilities, which were used by 11 agencies.
These facilities notwithstanding, NARA does not know where all agencies are storing records. NARA has solicited data from agencies about their use of agency records centers and commercial records storage facilities, but not all agencies have submitted data. Further, the data agencies submitted--mostly from 2008 and 2009--are now outdated. As a result, NARA cannot be assured that all agencies are using one of the three types of authorized facilities.
NARA determined that 20 of its 24 federal records center facilities were fully compliant with 36 C.F.R. Part 1234 because all of their bays satisfied the regulation; of the remaining 4, 2 facilities with inadequate shelving were partially compliant, 1 facility with insufficient protections against pipe leaks was not compliant, and the remaining facility was to be replaced. As of July 2013, NARA had plans to bring these 4 facilities into full compliance, but did not have a schedule for completing the plans at 2 of the facilities. As a result, NARA does not have a basis for determining progress toward correcting deficiencies in those facilities that do not yet fully meet the standards. Also, while NARA had approved 10 agency records centers and 22 commercial records storage facilities, it has inspected 1 of 18 agency records centers and 13 commercial records storage facilities. Until NARA completes planned inspections of all remaining facilities, it cannot be reasonably assured that agencies are storing records in facilities that meet standards.
To facilitate the protection of federal records from permanent damage, NARA had generally taken steps consistent with a checklist it requires federal records centers to follow when incidents (e.g., roof or sprinkler leaks) occur. However, it did not always document the results of its efforts to minimize damage because the checklist does not include a step for doing so. Specifically, of the 55 incidents that occurred from January 2009 through March 2013, NARA provided documentation about the final outcome for 46 incidents. For the remaining 9 incidents, it could not provide documentation that included the final results of its efforts. Without a process that includes documenting the results of its efforts, NARA is not positioned to fully report on the effectiveness of its actions to minimize damage to federal records and to provide a third party with information to validate the results of its efforts.
Storage fees are determined by NARA's Federal Records Centers Program and the Office of the Chief Financial Officer using the existing fee schedule, expense projections, and workload projections. The storage fees charged by NARA in fiscal year 2013 were comparable to fees charged by commercial vendors in that same time frame. For example, NARA's fee of $0.23 per cubic foot was higher than fees charged by two vendors and lower than fees charged by two other vendors.
Why GAO Did This Study
NARA manages the Federal Records Centers Program, which is to ensure the storage and preservation of federal records, including paper, photographic, audio, video, and film. Records storage facilities are required to meet certain minimum structural, environmental, property, and life safety standards set forth in federal regulations.
GAO was requested to conduct a study of key aspects of the program. GAO's objectives were to (1) determine the types of facilities agencies use to store federal records and the extent to which NARA's data on agencies' use of storage facilities are complete, (2) evaluate the extent to which NARA has determined these facilities to be compliant with standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has taken to minimize damage to records in federal records centers and the extent to which it documents such efforts, and (4) determine how NARA determines storage fees and whether fees differ among facilities. To do so, GAO obtained, analyzed, and corroborated documentation on records storage facilities, identified and compared records storage fees, and interviewed NARA officials.
Recommendations
GAO recommends that NARA (1) obtain complete data on where agencies are storing records, (2) develop a schedule to bring noncompliant storage areas into compliance with 36 C.F.R. Part 1234, and (3) establish a requirement to document the results of efforts to minimize damage to federal records. NARA concurred with the recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| National Archives and Records Administration | To assist NARA in its responsibility to ensure that federal records are stored in compliant facilities, the Archivist of the United States should direct the Chief Operating Officer to place increased priority on the collection of complete, current, and valid information from agencies about their use of agency and commercial records storage facilities. |
In response to our recommendation, we verified in September 2017 that the National Archives and Record Administration (NARA) increased its efforts to communicate records storage facilities requirements to agencies. Specifically, NARA provided agencies with compliance requirements for records storage facilities, collected and compiled information on agencies use of storage facilities using a survey, and created an action plan to manage and track records management self-assessment survey responses. For unclear responses, NARA sent emails, priority one letters requiring a response within 30 days, and conducted follow-up telephone calls. Additionally, a Federal Records Storage Facility Standards Toolkit was created for online support to agency records managers, and NARA staff attended and participated in bi-monthly discussion groups and conferences. As a result of these actions, NARA will reduce the likelihood of inaccuracies reported by agencies and will have greater assurance that all agencies are using authorized facilities.
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| National Archives and Records Administration | To assist NARA in its responsibility to ensure that federal records are stored in compliant facilities, the Archivist of the United States should direct the Chief Operating Officer to develop a schedule for executing plans to resolve issues at each of the federal records centers that is not fully compliant with 36 C.F.R Part 1234. |
In response to this recommendation, NARA provided documents that disclosed plans and actions taken or scheduled to resolve issues at federal records centers that were not fully compliant with 36 C.F.R Part 1234. Actions taken included: (1) closure of a records storage facility and relocating its records to a CFR 36 Section 1234 certified facility; (2) engaging a contractor with specified timeframes for completion of tasks; and providing funding for a pipe protection and leak detection system at a records storage center; and (3) establishing timeframes and initiating efforts to repair structural and shelving issues at two records storage centers. These actions represent NARA efforts to execute plans and bring federal records centers into full compliance with 36 C.F.R. Section 1234 requirements and help ensure that federal records are stored in compliant facilities.
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| National Archives and Records Administration | To assist NARA in its responsibility to ensure that federal records are stored in compliant facilities, the Archivist of the United States should direct the Chief Operating Officer to clarify NARA's checklist for handling incidents that may involve permanent damage to records by including a requirement to document the results of the steps taken to minimize permanent damage to records |
In response to this recommendation, in August 2015, NARA issued a policy memo, FRCP 15-045, pertaining to the tracking and management of records emergency events. The memo specifically directs federal records centers to complete a checklist called the Records Emergency After-Actions Report that was designed for documenting incidents that may involve permanent damage to records. The memo states that records centers must report all records emergencies, regardless of the size or impact of the damage to records; requires documentation of and reporting of the results of steps taken to minimize permanent damage to records; and requires that the report be used to determine if long-term actions are required to ensure that no permanent damage to records occurs after a records emergency This action modified, clarified, and described usage and application of the NARA checklist used to manage and mitigate incidents with potential damage to federal records and will help minimize the risk of permanent damage to records and non-compliant records centers.
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