The U.S. National Archives and Records Administration’s (NARA) recently updated guidelines for federal records management include a provision ending the use of agency-run storage facilities for analog records.
Specifically, Section 1.3 of OMB/NARA M-19-21 mandates that federal agencies must close any agency-operated Records Storage Facilities (RSF) in favor of using either NARA-approved Federal Records Centers (FRC) or NARA-approved commercial records storage facilities instead.
This requirement could have significant repercussions for many agencies, but what does it mean exactly?
First, it’s important to understand the difference between an agency operated RSF and an FRC. Both, according to NARA itself, refer to “any establishment maintained and operated by the archivist of the United States or by another federal agency primarily for the storage, servicing, and processing of records which need to be preserved for varying periods of time and need not be retained in office equipment or space.”
In other words, these are facilities store and preserve noncurrent, inactive permanent records.
The difference between them is largely procedural. NARA must approve any facility used to house government records, and it applies different approval processes for the different types of facilities. Similarly, NARA applies a specific approval process to commercial records storage facilities used by government agencies to ensure they meet the storage standards set by 36 CFR 1234.
Although questions remain, the real impact of this new requirement is likely that NARA will simply no longer approve agency-run RSFs and will decommission any such facilities currently in operation.
This should not cause panic, however. Transferring records to an approved FRC can have some significant benefits, including potentially enormous cost savings. It’s estimated that federal agencies spend around an average of $37.65 per year (adjusted for inflation) to store a single cubic foot of records in office space. By contrast, it costs only $2.67 per cubic foot in an FRC.
The new requirement does mean, however, that agencies that run their own RSF will have to undertake a project to move those records to a new facility.
David S. Ferriero the archivist of the United States, spells this out in an email to NARA staff dated June 28: “Agencies who operate their own records storage facilities [must] transfer their records to the Federal records centers program or a commercial storage facility and close their agency-owned facilities by December 31, 2022.”
However, this presents many agencies an opportunity to unify their records management – that is, handling both electronic and analog records from within the same system – or at least to bring their physical records management practices in alignment with electronic.
The result may well be a better overall records management system.
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