THE FEDERAL INFORMATION AND RECORDS MANAGERS (FIRM) COUNCIL c/o Records Manager, OPIC, 1100 New York Avenue, NW, Washington, D.C. 20527 202/336-8563, Fax 202/218-0304, e-mail: cbrock@opic.gov

June 7, 1999

Ms. Nancy Allard Policy and Communications Staff (NPOL) National Archives (NARA) at College Park 8601 Adelphi Road College Park, MD 20740-6001

Re: Response to NARAs Draft General Records Schedule (GRS) 20

Dear Ms. Allard:

This reply is a compilation of comments received from the FIRM Council members. The purpose of FIRM is to improve the efficiency and effectiveness of Information and Records Managers functions in all agencies by providing a forum for sharing knowledge, resources, and methodologies for the implementation and evaluation of systems and practices. Objectives of the FIRM Council include: A. Providing leadership to the FIRM Community as it creates partnerships with archivists, librarians, program staff, technical staff, the information industry, professional associations, and other information management professionals to: 1. manage the life cycle of federal information, and 2. protect the nation's documentary heritage.

B. Providing advice and assistance to the National Archives and Records Administration (NARA); the Office of Management and Budget; the Government Accounting Office; the Office of Personnel Management; the National Institute for Standards and Technology; the General Services Administration; and other federal entities charged with oversight of information and records management.

C. Providing a forum to advance professional knowledge and techniques through educational programs, workshops, seminars, and by sharing experiences, approaches, and information related to the records management profession.

The FIRM Council would like to make the following points in response to NARA's request for comments on the Draft GRS 20: Information Technology Operations and Management Records (version 7.2). We appreciate that the conditions for destroying these records have been simplified.

1. Item 7: IT asset and configuration management files, subitem c. What exactly is this? This item should be rewritten for clarity.

2. It appears that back-up tapes and other nonrecord items have been removed from this draft (though we were unable to find anything in writing documenting that the decision had been made to take nonrecord items out of the GRS). Back-up tapes are a big concern for all agencies. We need NARA to take a stand on this even if it is not articulated in the form of a GRS.

3. Item 9: IT operations records, subitem b. This seems like a long retention for these types of records. User complaints could have a fairly short retention based on their content and from whom they are coming. This item needs more definition.

4. Data Preparedness and Recovery Plans. Are these covered under item 6, 7c, or 14a and b? If you want us to schedule the Data Preparedness and Recovery Plans, please state this explicitly in the introduction to the schedule and make it clear which schedule item is to be used. 5. Network/Data Communication Service Records and Internet Services Records. These records were covered by the initial version of GRS 20 but did not appear in the February or April version of the proposed revisions. Does one of the proposed items cover these records (it is not apparent that one does) or have you decided that the information was nonrecord?

6. Item 14c appears to make software applications a record. This is a departure from the past. It would be helpful if you could explain the reasoning behind this.

These comments are submitted on behalf of the members of the FIRM Council, your customer base. Thank you for allowing us the opportunity to contribute to the regulatory process.

Sincerely,

Carol Brock, CRM Chair, FIRM Council

-- Anonymous, June 08, 1999