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Appraisal at the National Archives and Records Administration

LIS 2222: Archival Appraisal

Brian Cumer

Spring 2011

Elvia Arroyo-Ramirez

Emily Davis

Emily Hikes

Rachel Millard

Eden Orelove

Amanda Scheffer

Cheyenne Stradinger

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Contents

I. Introduction and History…………….….…………………………………….………………..3

II. Summary of NARA Appraisal Policy……………………………………….……………….10

III. Evaluation of NARA’s Appraisal Policies and Practices.................................................…...16

IV. Proposals for Strengthening of Appraisal Policies…………….…………..…….………….20

V. Measuring the Success of Appraisal Policies and Practices..…….………...…….…………..24

VI. Conclusion………………………………………………………………..…………….…....29

Appendix A: Correspondence with Appraisal Archivist, Dayton Branch…………………….…30

Appendix B: Correspondence with Laura McHale, Philadelphia Branch………….………..…..32

Appendix C: Correspondence with Sean Curry, Philadelphia Branch.…..………………….…..35

Bibliography……………………………………………………………………………………..39

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I. Introduction and History

The National Archives and Records Administration is the United States’ official record keeper

and the nation’s largest government archival institution. It is responsible for the collection and

maintenance of regional archives, Federal records centers, Presidential libraries, the Federal

Register, and the National Historical and Publications Commission.1

Beginnings

The Seventy-third Congress passed the National Archives Act in 1934 during President Franklin

D. Roosevelt’s social reform and New Deal era.2 Before the establishment of the nation’s

official record keeping institution, government records were haphazardly collected at state and

local levels, and decentralized record keeping occurred at the federal level. These methods

meant records were susceptible to negligence and inadequate preservation. The impetus that

perhaps first demonstrated the need for the nation’s government to address the issue was the

1800-1801 fire that occurred at the nation’s Department of War and Department of Treasury,

seriously damaging records that were already being collected. Small initiatives were established

after this incident (i.e. a committee was established to investigate the state of the nation’s

records, which then lobbied for the construction of fireproof rooms at various federal buildings),

but “the actions taken fell far short of providing for satisfactory preservation of official records

and regularized access” to government records.3

It was not until the Civil War that the nation’s government could not turn away from addressing

the burgeoning and unsystematic collection of records. During the Civil War, the proliferation of

government records resulted in unprecedented volumes; those records that were actively kept 1 “History,” www.archives.gov, last modified October 28, 2010, http://www.archives.gov/about/history/.2 Donald McCoy, “Establishment” in The National Archives: America’s Ministry of Documents, 1934 – 1968 (Chapel Hill: North Carolina Press, 1978), 3.3 Donald McCoy, “Establishment,” 4-5.

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accumulated from 108,000 cubic feet in 1861 to 1,031,000 in 1861.4 This proliferation also first

raised questions of the retention of “useless records” by government facilities; questions of

space, value, and need for legislation to set boundaries were emerging by the 1870s5. In 1889,

the nation’s first act of appraisal and ‘deaccession’ was enacted to allow government agencies to

annually submit lists of records recommended for disposal to Congress for approval6. However,

this act had an irregular following and proved to be problematic because its enactment depended

on the discretion of each individual Federal department and their belief of what was deemed

‘useless’ or ‘valuable’.

At the turn of the century, several formative events shaped what finally drew the government to

the path of the establishment of a national archive. Events pertaining to a preliminary discussion

for this archive included a national hall of records, the purchase of a building that would have the

maximum capacity of four million cubic feet at a cost of $1.2 million in 1904, and the lobbying

efforts of the adolescent American Historical Association (AHA) which was given a voice by

one of the nation’s first professional historians, J. Franklin Jameson. On top of all of this, there

was also another fire; this time it was in the New York State House in 1911 and it destroyed

much of their archival records and artifacts. All of these events garnered enough attention from

the House of Representatives and Senate to spark their interest in making efforts in regards to

this issue.7 The AHA’s proactive involvement in lobbying for a national archive speaks to the

archival profession’s roots in the history profession. Spearheaded by Jameson, who also was in

charge of the Manuscripts Division at the Library of Congress, the AHA established the Public

Archives Commission and Conference of Archivists. These two agencies were primarily 4 Donald McCoy, “Establishment,” 5.5 Donald McCoy, “The Struggle to Establish a National Archives in the United States” in Guardian of Heritage: Essays on the History of the National Archives, ed. Timothy Walch (Washington D.C.: National Archives and Records Administration, 1985), 2.6 Ibid.7 Ibid, 5-10.

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responsible for the galvanization of Congress to pass legislation in 1926 which allowed for the

appropriation of $1,000,000 for the active construction of a national archive.8

It took five years after this legislation passed to design an adequate space for a national archive.

The secretary of the treasury was instructed to “enter into contracts for the entire estimated cost

of such building, including stacks, and site… not to exceed $6,900,000”9. And in 1933, while

the events of the Great Depression transpired, President Herbert Hoover laid the cornerstone of

the National Archives building in Washington D.C.

However, the legislative construction of the institution was not set yet. There was still a debate

about whether the National Archives should be an independent agency of the federal government

or not. It wasn’t until President Roosevelt signed the bill in 1935, that the National Archives’

birth as an independent agency finally came to pass.

The Early Years

During its first years of existence, the National Archives was to report only to the President of

the United States and it was to be headed by the Archivist of the United States. In 1934,

President Roosevelt handpicked Robert Digges Wimberly Connor, the head of the Department of

History and Government at the University of North Carolina, as the first Archivist of the United

States.10 The early drafting of the interior organization of the National Archives mirrored the

functional arrangement of the Library of Congress. Divisions such as Accessions, Cataloging,

Library, Repair and Preservation, Reference, Research, Maps and Charts, Motion Pictures and

Sound Recordings were all named as functional organs within the National Archives.11 8 Donald McCoy, “Establishment,” 6.9 Donald McCoy, “The Struggle,” 13.10 “Archival Milestones,” www.archives.gov, last modified December 7, 2010, http://www.archives.gov/about/history/milestones.html.11 Rodney A. Ross, “The Formative Years” in Guardian of Heritage: Essays on the History of the National Archives, ed. Timothy Walch (Washington D.C.: National Archives and Records Administration, 1985), 37.

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Perhaps some of the earliest active appraisal decisions the National Archives enacted upon was

their employment of deputy examiners and special examiners working in the Accessions

Division who “went out to the agencies as deputies of the Archivist of the United States to

survey, appraise, and arrange for the transfer to the National Archives of the accumulation of

pertinent federal records in the Washington area.”12 After the enactment of the National Archives

Act, the National Archives became responsible for the disposal of the records that were deemed

‘useless’ by federal agencies, and the Archivist had the power to “recommend to Congress the

disposal of government papers having no permanent value or historical interest.”13 During this

time, the National Archives developed records management-like disposition schedules,

identifying which kinds of “routine documents” were to be automatically destroyed by the

National Archives without asking for permission from Congress.

By 1937, deputy examiners had finished conducting an initial survey that identified the existence

of 3,000,000 cubic feet of records in federal agencies and recommended the transfer of 45.3

percent of it, or 1,360,000 cubic feet, to the National Archives.14 This already posed problems of

space within the National Archives building since its capacity at that time could only hold

2,033,712 cubic feet; the relocation of the 45.3 percent of the records deemed ‘valuable’ enough

to be transferred to the building would have already encompassed two-thirds of the facility.15

Furthermore, with the impending massive proliferation of records during the World War II era,

there was recognition of the need for a records management policy that would be responsible for

constructing and maintaining regular disposal schedules.

12 Ibid.13 Ibid.14 “History,” www.archives.gov, last modified October 28, 2010, http://www.archives.gov/about/history/.15 Rodney A. Ross, “The Formative Years”, 38.

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The establishment of the National Archives set the stage for the emergence of the archival

profession in the rest of the country as well. The creation of the Society of American Archivists

(SAA) in 1935 followed three years later by the publication of its quarterly journal, the American

Archivist, laid the foundation for the profession. These entities would all start a trend that

identified the need of archival education and training.

National Archives and Records Services (NARS), 1949 - 1984

In 1949, the National Archives suffered a major setback and lost its institutional independence.

It was renamed the National Archives and Records Service (NARS) and became subordinate to

the General Services Administration (GSA).16 Fortunately, the Federal Records Act of 1950

allowed NARS enough autonomy to improve procedures, methods, and standards of federal

records, retaining their responsibility to improve federal record-keeping.17 These ideals became

the main focus of the agency during the whole of the 1950s and mid-1960s, applying much more

of a records management perspective to their tasks by holding training sessions for other federal

employees on records disposition and proper records management.

It was during this time that NARS began to open offsite storage facilities for the federal agencies

that were reaching maximum capacity. NARS itself reached maximum capacity in the late

1960s, resulting in the transfer of large quantities of records to off-storage and regional

archives.18 Additionally, throughout the AOTUS administration of James B. Rhoads in the

1970s, NARS saw the establishment of more offsite storage facilities. By 1966, NARS consisted

of its central location in Washington; an annex of military records in northern Virginia; the

16 James Gregory Bradsher, “The National Archives: Serving Government, the Public, and Scholarship, 1950-1965” in Guardian of Heritage: Essays on the History of the National Archives, ed. Timothy Walch (Washington D.C.: National Archives and Records Administration, 1985), 51-52.17 Ibid.18 “About the National Archives of the United States,” www.archives.gov, last modified November 11, 2010, http://www.archives.gov/publications/general-info-leaflets/1-about-archives.html.

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Eisenhower, Hoover, Roosevelt, and Truman presidential libraries; ten regional records centers;

and a specialized personal records center in St. Louis.19 In efforts to solve space issues at the

central NARS location in Washington DC, NARS established regional centers that befitted the

retention of records to their geographical location. By 1968, NARS oversaw the opening of new

records center facilities in Chicago; Bayonne, New Jersey; San Bruno, California and Laguna

Niguel, California; and Dayton, Ohio. This period also saw the establishment of the Kennedy,

Johnson, and Ford libraries come to pass.20

However, efforts made by NARS to reduce their used up cubic feet at their central location did

not alleviate the pressure coming from the GSA. In 1978, under the GSA administration of

Admiral Roland G. Freeman, fifteen NARS records centers were forced to microfilm and dispose

of 1,000,000 cubic feet of original documents.21 The disposal of records by NARS as dictated

from above by the GSA only succeeded in creating a vitriolic relationship between the two. It

was during this time that the question of NARS regaining its independence as a separate

government entity came into popularity.

NARA Today

In 1985, the National Archives regained its independence and was officially recognized as the

National Archives and Records Administration.22 It now extends to 37 facilities in nine different

geographical regions across the United States: Pacific Alaska, Southeast, Northeast, Great Lakes,

Rocky Mountain, Southwest, Central Plains, Pacific, and Mid-Atlantic regions. In 1993, central

19 Trudy Huskamp Peterson, “The National Archives: Substance and Shadows, 1965-1980” in Guardian of Heritage: Essays on the History of the National Archives, ed. Timothy Walch (Washington D.C.: National Archives and Records Administration, 1985), 75.20 Ibid, 77.21 Ibid, 78.22“Archival Milestones,” www.archives.gov, last modified December 7, 2010, http://www.archives.gov/about/history/milestones.html.

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NARA extended to College Park, Maryland where the site can store an additional 2,000,000

cubic feet of Washington D.C. area records.

Currently, NARA and its regional centers hold 9 billion pages of textual records, 7.2 million

maps, charts, and architectural drawings, more than 20 million photographs, over 365,000 reels

of film, and 110,000 videotapes.23 Its current retention figures estimate that only 2-5% of records

generated by federal agencies are retained by NARA each year.24

There have been 10 Archivists of the United States as of 2011, with four additional Acting

Archivists. In 2009, NARA celebrated its 75th anniversary and welcomed the new Archivist of

the United States, David Ferriero.

Background on NARA Dayton

The National Archives Dayton facility is one of fourteen regional centers located throughout the

greater United States. Established in 1968, NARA Dayton is a Federal Records Center only,

housing agency-owned temporary records between the times they are no longer needed for

current business until the time they can be legally destroyed. This office serves Federal agencies

in Ohio, Indiana, and Michigan, plus the Defense Finance and Accounting Service for stations in

Europe and Asia, and three IRS Service Centers: Cincinnati, Ohio; Brookhaven,

New York; and Memphis, Tennessee.25

Background on NARA Philadelphia

23 “About the National Archives of the United States,” www.archives.gov, last modified November 11, 2010, http://www.archives.gov/publications/general-info-leaflets/1-about-archives.html.24 “About the National Archives of the United States,” www.archives.gov, last modified November 11, 2010, http://www.archives.gov/publications/general-info-leaflets/1-about-archives.html.25 Appraisal Archivist Dayton, email message to authors, April 5, 2011.

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The National Archives Philadelphia facility is one of fourteen regional centers located

throughout the greater United States. NARA Philadelphia is the lone representative of the Mid-

Atlantic Region and holds historically significant federal records from the states of Delaware,

Maryland, Pennsylvania, Virginia, and West Virginia. Its records date back to 1790 and holds

content to the present.

There are two NARA Philadelphia facilities – their archival collection is located in the Central

City of Philadelphia and their Records Center and Records Management facility is located in

Northeast Philadelphia. According to the 6th Archivist of the United States, Robert M. Warner,

the Philadelphia archives branch was originally located in the suburbs but was relocated from the

suburbs to the center of the city in 1985.26

II. Summary of NARA Appraisal Policy

The National Archives and Records Administration has a very broad and generalized appraisal

policy. This is namely because the Government is incredibly large, as described above, and must

be flexible enough to accommodate the majority of unique records the Government holds. The

NARA Appraisal Policy only covers records that are subject to the Federal Records Act (FRA).

This includes records from the executive branch and its agencies, as well as the Circuit Courts

and Legislative branch agencies. However, some agencies that are not subject to the FRA follow

these policies as well. Records created by the President and Presidential entities, the Senate, the

House of Representatives, the Architect of the Capital, and the Supreme Court are not covered

by the NARA Appraisal Policy because they are not subject to the Federal Records Act.

According to NARA, the Archivist of the United States “has the statutory responsibility to

decide how long records must be retained and which records have archival value and thus are to

26 Robert M. Warner, “The National Archives: A memoir, 1980-1985” in Guardian of Heritage: Essays on the History of the National Archives, ed. Timothy Walch (Washington D.C.: National Archives and Records Administration, 1985), 87.

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be retained permanently.”27 The Archivist of the United States also provides guidance to and

assistance to Federal Officials on the management of records; to determine the retention and

disposition of records; to store agency records in records centers from which agencies can

retrieve them; to receive, preserve, and make available permanently valuable Federal and

Presidential records; and to take NARA’s archival facilities, including Presidential libraries, for

public use donated materials that are determined by the Archivist of the United States to have

sufficient historical or other value to warrant their continued preservation by the United States

Government.28

The Archivist of the United States takes recommendations from NARA staff as well as taking

into account the opinions and views of the originating agency and the public. Strategic

Directions: Appraisal Policy states that NARA does not appraise records in isolation and works

with other parties within NARA that ensure that proper documents are managed correctly.

The NARA Directive 1441, Appraisal Policy of the National Archives and Records

Administration, provides tactical frameworks, objectives, and guidelines that NARA uses to

determine whether its records have archival value. Although this is a broad policy, it does take

into account that there are many documents in NARA and each document undergoes a specific

appraisal process that is consistent with that specific document.

In order for records to remain permanent, they must adhere to certain guidelines. They have to

provide evidence of one of three important categories. The first category is for the

documentation of the rights of American citizens. This requires that the records contain

information about the “legal status, rights and obligations of individuals, groups, organizations

and government bodies.”29 Many of these records that contain information on legal rights will

27 NARA Directive 1441.5.28 NARA, Preserving the Past, vi.29 NARA Directive 1441.7.a.

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expire. However, if the record shows evidence of endurance through the passage of time, it will

be permanently preserved. To fit into the second category, a record must document the actions of

Federal officials. This means that “NARA retains permanently those records that document the

basic organizational structure of Federal agencies and organizational changes over time, policies

and procedures that pertain to an agency’s core mission, and key agency decisions and actions.”30

The third category must document the national experience. The Government collects information

about “people, places, material objects, and scientific phenomena, as well as social conditions,

political and economic activities, and events in the United States and other countries.”31 Many of

these records contained in category three provide evidence of the documentation of national

importance and will need to be preserved. Nevertheless, not all records that possess these

characteristics will be kept. They may be destroyed if they no longer fulfill the needs of their

agency’s business. If the records fulfill these various categorizations, they meet the beginning

phase of appraisal.

The next phase of the NARA Appraisal Policy deals with appraisal objectives. With the guidance

of the three categories previously listed above, NARA will identify records that will receive

permanent retention status. NARA does this by following these guidelines:

Retain their importance for documenting legal status, rights and obligations of individuals, groups, organizations, and governmental bodies despite the passage of time;

Provide evidence of significant policy formulation and business processes of the Government;

Provide evidence of our Government’s conduct of foreign relations and national defense; Provide evidence of Federal deliberations, decisions, and actions relating to major social,

economic, and environmental issues; Provide evidence of the significant effects the Federal programs and actions on

individuals, communities, and the natural and man-made environment; Contribute substantially to knowledge and understanding of the people and communities

of our nation.32

30 NARA Directive 1441.7.b.31 NARA Directive 1441.7.c.32 NARA Directive 1441.8.

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If records make it through these guidelines for permanent retention, they may be reappraised at

some point. This may happen if earlier appraisal decisions require review, or if there is a change

in policy or a review of the policy. In addition to the points above, NARA will also ask these

questions to make easier appraisal decisions:

How significant are the records for research? How significant is the source and context of the records? Is the information unique? How usable are the records?

How does the way records were gathered, organized, presented, or used in the course of business affect their usability?

How do technical considerations affect the usability of the records? How does the physical condition of the records affect their usability?

Do these records serve as a finding aid to other permanent records? What is the timeframe covered by the information? Do the records document decisions that set precedents? Are the records related to other permanent records? Do the files contain non-archival records? What are the cost considerations for long-term maintenance of records? What is the volume of records? Is sampling an appropriate appraisal tool?33

Included in the many degrees of the appraisal process, is that of personal data. The personal data

records hold information that may be beneficial to NARA. These records contain information

that pertains to the size and nature of the United States population and the nature of information,

which includes places of residence, previously used names, and education. Occupational data

from the physical sciences are also included for selected types of records. These records include

scientific and observational data from space and Earth as well as electronic observations. The

environmental health and safety records category covers disposal of toxic waste and health

records such as vaccinations and communicable diseases. The last category of the section of

records is research and development (R&D) records. These records relate to the “planning and

33 NARA Directive 1441.12.

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execution of basic and applied research in engineering and the physical and natural sciences.

Basic research seeks to generate new knowledge, and applied research uses the results of basic

research and applies them to the design, development, and testing of new products and

processes.”34

Maybe one of the most important elements of the NARA Appraisal Policy is the intrinsic value

of records. The qualifications that a record must possess are:

Physical form that may be the subject for study if the records provide meaningful documentation or significant examples of the form.

Aesthetic or artistic quality. Unique, curious, or historical physical features or formats. Age providing a quality of uniqueness. Value for use in exhibits. Questionable authenticity, date, author, or other characteristic that is significant and

ascertainable by physical examination.35

Intrinsic value is what most people believe to be the deciding factor in what information NARA

should retain. The general public appreciates these qualities in records and so these guidelines

are generally followed when keeping records for public exhibits.

The process for the disposal of records is simple. Lists of the schedules of records need to be

filed and approved by the Appraiser. Records are also copied if they are original records. In

doing so, the head of each agency of the United States Government submits lists of records for

disposal to the Archivist of the United States:

Lists of any records in the custody of the agency that have been photographed or micro-photographed under the regulations and that, as a consequence, do not appear to have sufficient value to warrant their further preservation by the Government.

Lists of other records in the custody of the agency not needed by it in the transaction of its current business and that do not appear to have sufficient administrative, legal, research, or other value to warrant their further preservation by the Government; and

Schedules proposing the disposal after the lapse of specified periods of time of records of a specified form or character that either have accumulated in the custody of the agency or

34 NARA Directive 1441, Appendix 2.35 NARA Directive 1441, Appendix 3.

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may accumulate after the submission of the schedules and apparently will not after the lapse of the period specified have sufficient administrative, legal, research, or other value to warrant their further preservation by the Government.36

After the Archivist of the United States has approved of the disposal of the selected records, he

notifies the agency of his decision, and the agency is then allowed to dispose of the records

lawfully.

Sometimes, agencies may begin to collect records that are similar to records that have already

been approved for disposal. If this happens, the Archivist of the United States may authorize the

head of the agency to dispose of the records.

In a time of war or when hostile action by a foreign power may occur, the Archivist of the United

States or the head of the specific agency may authorize the destruction of records in his legal

custody if the records are “situated in a military or naval establishment, ship, or other depository

outside the territorial limits of the continental United States-

The retention of which would be prejudicial to the interests of the United states or Which occupy space urgently needed for military purposes and are, in his opinion,

without sufficient administrative, legal, research, or other value to warrant their continued preservation.

Within six months after their disposal, the official who directed the disposal shall submit a

written report to the Archivist in which he shall describe the character of the records and state

when and where he disposed of them.”37 However, this last rule for disposal seldom occurs.

In following the broad guidelines of the NARA Appraisal Policy, all records must be thoroughly

analyzed by the Archivist of the United States and/or the head of the government agency that is

requesting the appraisal. By following these guidelines, the United States appraises its records

and uses best practices in doing so.

36 Disposal of Records, 44 U.S.C. Chapter 33, § 3303.37 Disposal of Records, 44 U.S.C. Chapter 33, § 3311.

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III. Evaluation of Institution’s Appraisal Policies and Practices

The NARA Appraisal Policy does not fall into any of the well-defined appraisal methodologies

(i.e. macro-appraisal, documentation strategy, etc.). Instead, we interpreted the policy as being

broad in order to provide flexibility for different government departments to appraise their

records according to their needs. However, our NARA Dayton interview respondent interpreted

the policy differently: she feels that NARA’s appraisal policy is too restrictive. She wrote that

while “it is necessary to have some sort of policy in order to provide guidelines for making

appraisal decisions, the current policy’s attempt to leave no wiggle room results in a less, not

more, efficient product.”38

As is typical of other governmental archives laws, the language of the NARA appraisal policy

emphasizes the archives’ legal authority and responsibility.39 This concern over legal

responsibility is seen in the types of records NARA deems to be of archival quality. Dr. Richard

J. Cox notes that NARA’s notion of “adequacy of documentation” seems to be “a synonym for

accountability.”40 Though the appraisal policy does not state that NARA subscribes to Theodore

Schellenberg’s theoretical beliefs on appraisal, it is clear that there are some similarities in their

approaches.

Notably, NARA evaluates records for their informational and evidential values. The concept of

providing evidence is a central goal of NARA, as their mission statement proclaims, ensuring

“for the Citizen and the Public Servant, for the President and the Congress and the Courts ready

38 Appraisal Archivist Dayton, email message to authors, April 5, 2011.39 Frank Boles, Selecting & Appraising Archives & Manuscripts (Chicago: Society of American Archivists, 2005) 48.40 Richard J. Cox, Documenting Localities: A Practical Model for American Archivists and Manuscript Curators (Maryland: Society of American Archivists and Scarecrow Press, 2001): 112.

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access to essential evidence."41 The similarity between NARA’s and Schellenberg’s approaches

to appraisal is not surprising because prior to the development of a unified appraisal policy,

NARA staff relied “primarily on Schellenberg's Appraisal of Modem Public Records for

theoretical guidance, assessing the worth of records in terms of evidential and informational

values.”42

NARA’s Appraisal Policy states that the organization believes in a collaborative approach to

appraisal. Though NARA’s appraisal strategies cannot be labeled as following the

documentation strategy, their emphasis on cooperation is similar. The documentation strategy is

described as being “…carried out through the mutual efforts of many institutions and individuals

influencing the creation and management of records and the retention and archival accessioning

of some of them.”43 NARA’s Appraisal Policy does state that while the Archivist of the United

States has the legal responsibility and ultimate say as to the retention period of records and which

records have archival value, he consults with and considers the opinions of NARA staff, the

public and originating agencies before making his decision.

In addition to collaboration, NARA’s Appraisal Policy presents a “democratic dimension.”44 It

clearly “sees to it that the doings of a nation’s administrative and political machinery are fairly

well documented and made accessible to the public, be it scholars or just interested citizens...”45

This is reflected in NARA’s mission statement which is concerned with providing access to

41 NARA Appraisal Policy, under “Strategic Framework.”42 Elizabeth Lockwood, “‘Imponderable Matters:’ The Influence of New Trends in History on Appraisal at the National Archives,” American Archivist 53, no.3 (Summer 1990): 396. 43 Terry Abraham, “Collection Policy or Documentation Strategy: Theory or Practice,” American Archivist, 54 (Winter 1991): 48, https://sremote.pitt.edu/content/v2323483077xr227/,DanaInfo= www.metapress.com+fulltext.pdf.44 Ole Kosrud, “The Evolution of Basic Appraisal Principles – Some Comparative Observations,” American Archivist, 55, no.1 (Winter 1992): 37.45 Ibid, 37.

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essential evidence to people from "the Citizen and the Public Servant” to “the President and the

Congress and the Courts."46

Through our interviews, we discovered that although NARA’s Appraisal Policy is written to

encompass all branches of NARA, it may not be used in every facility. This dilemma of having

one appraisal policy for so many branches is something that most archival institutions do not

have to consider. We believe this factor contributes to the vagueness of NARA’s Appraisal

Policy. It is disconcerting that one of the appraisal archivists at the Dayton branch responded

that she had not read the NARA Appraisal Policy in its entirety. Additionally, when asked who

implemented the NARA Appraisal Policy she replied: “Theoretically, the appraisal policy is

implemented by every appraisal archivist within NARA.”47 This makes us wonder how

frequently the NARA Appraisal Policy is used, and if creating more specific versions would

make the policies more useful for individual branches.

In the 1990s, an article criticizing NARA’s lack of appraisal policy was published. It called for

NARA to become more proactive in creating a retention and collection policy that would ensure

“that tomorrow's archival collection is a well-considered and useful one.”48 While NARA’s

appraisal policy has been considerably developed in the last twenty years, there are always some

aspects that could be improved.

The last part of NARA’s Appraisal Policy focuses on reappraisal and policy review. The policy

states that “NARA will reappraise records when there is compelling evidence that earlier

appraisal decisions require review.” Furthermore, “NARA will review this policy as necessary in

consultation with Federal agencies, research communities, and other interested parties.” One

46 NARA Appraisal Policy, under “Strategic Framework.”47 Appraisal Archivist Dayton, email message to authors, April 5, 2011.48 Lockwood, “‘Imponderable Matters:’ The Influence,” 394.

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appraisal archivist stated that “we do periodically reassess holdings and deaccession records.”

Another appraisal archivist said, in response to a question about revisal and discussion of

appraisal policies that they “have a series of informal monthly meetings, where appraisal is

discussed, including best practices...there are currently teams within NARA that are reviewing

the policy.” They also said, “appraisal is revisited as realities change” and he gave an example of

a current reappraisal project that is going on. The fact that this is one of the main points of their

policy and the fact that this occurs in various facilities speaks to the strengths of the policy.49

Expectedly, NARA’s appraisal policy has significant strengths as well as weaknesses. The policy

seems to cover all of the basics of appraisal, and certainly tends to Schellenberg’s ideas. Most

significantly, the policy does not address electronic. It seems that the policy is constantly

reviewed and discussed, although it may not be read by all practioners due to its length and their

own personal mantras. Also, the length of the policy covers a breadth of material in order to

successfully allow for the appraisal of all records of the Federal Government, but the length is

also what lends to the ultimate weakness of the policy. These failings will be further discussed

and addressed in the following section.

IV. Proposals for Strengthening of Appraisal Policies

This group realizes the naiveté of thinking we could gain a substantial enough understanding of

the NARA Appraisal Policy in order to make feasible suggestions, especially given that it took

one of our interviewees several months of training and shadowing with NARA staff to gain a

comprehensive understanding of the appraisal policy.50 However, based upon our interviews

49 Sean A. Curry, email message to authors, April 14, 2011.

50 Sean A. Curry, email message to authors, April 14, 2011.

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with three NARA appraisal archivists and an analysis of the policy, there are several strengths

and weakness of the NARA Appraisal Policy highlighted here. They are followed by several

recommendations for improvements.

As previously mentioned, it is evident that many of Schellenberg’s philosophies on appraisal and

government efficiency are still reflected in the appraisal policy at NARA. For example, one of

the general guidelines for deciding whether records have archival value and are deserving of

permanent retention is to question if the records are significant enough for research.51 While

there are additional guidelines to assist in selection and the policy asserts that the appraisal

decision should not be based upon this question alone, many archivists since Schellenberg have

argued that using research interests to drive selection often results in narrow documentation that

is biased and not reflective of the true diversity present in the functions of an organization.52

The notion of appraising based upon the interests of the researchers and the potential popularity

of records was also discussed by one of the appraisal archivists interviewed for this report. She

noted that if all appraisal decisions were based on the use of records by researchers it would

“reduce appraisal to something along the order of American Idol.” 53 She further noted that such

policies consigned past U.S. Census records to be destroyed because disciplines such as Social

History had yet to be conceived. 54 Therefore, the shift away from appraising records solely on

the interests of researchers has greatly strengthened NARA’s Appraisal Policy.

While many of Schellenberg’s ideas about the informational and evidential values of records are

still relevant, numerous changes to the archival community and historiography have taken place

since his time at NARA. One of the most significant changes has been the away shift away from

51 “Strategic Directions: Appraisal Policy”, NARA, accessed March 22, 2011.52 Reto Tschan, “A Comparison of Jenkinson and Schellenberg on Appraisal,” American Archivist 65, (Fall/Winter 2002): 187.53 Appraisal Archivist Dayton, email message to authors, April 5, 2011.54 Ibid.

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content and towards context;55 a concept that is reflected in several of NARA’s appraisal

guidelines such as: How significant is the source and context of the records? And are the records

related to other permanent records? Records appraised for informational value alone are devoid

of context; therefore, the shift away from content and informational value of record has

strengthened the policy because it acknowledges that organizational structure, its functions, the

record creators, and the record creating process. Their interaction with one another provides a

vital context that better reflects the business of the government.56

NARA could further strengthen its policy along this vein by placing more emphasis on the

records within the societal context, a concept found in macro-appraisal. Macro-appraisal

“assesses the societal value of both the functional-structural context and work-place culture in

which records are created and used by their creator(s), and the interrelationship of citizens,

groups, organization – ‘the public’ – with that functional-structural context.” 57 Currently, the

NARA Appraisal Policy does not prompt archivists to place the records within the context of

society. By extending the focus of appraisal beyond the functions of government to the greater

societal context, NARA could capture the functions and activities of the government and how

they interact and influence society as a whole.58

Another weakness of the appraisal policy is how long it has been since the last major revision.

According to Laura A. McHale, an appraisal archivist at the Mid-Atlantic Regional Recorders

Center in Philadelphia, NARA’s Appraisal Policy has not undergone a major overhaul in over 10

years.59 The most recent revision to NARA’s appraisal policy found in Strategic Directions:

55 Tschan, “A Comparison,”188.56 Tschan, “A Comparison,” 184 - 188.57 Terry Cook, “Macroappraisal in Theory and Practice: Origins, Characteristics, and Implementation in Canada, 1950–2000,” Archival Science 5, 2-4 (December 2005): 101.

58 Tschan, “A Comparison,” 188-189.59 Laura A. McHale, email message to author, April 11, 2011.

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Appraisal Policy, was made in 2007. Frank Boles argues for a periodic review of the

assumptions that formulate an appraisal policy, deeming it crucial. He notes that “no model of

selection…should be considered static or unchanging”.60 Additionally, Dr. Richard J. Cox also

advocates for revisions; arguing that a continuous process of self-evaluation will help maintain a

vital records management program.61 Although it has only been four years since the last revision

to the policy at NARA, a lot has changed since then. A new administration has taken office and

with it comes new policies and federal agency appointments. Additionally, technology has

rapidly evolved alongside the modern work environment. Whereas Boles does not suggest how

often an appraisal policy should be updated, the group strongly suggests a revision at this time of

transformation. This is especially warranted due to the fact that the current version of the policy

does not mention appraisal strategies for electronic records.

A span of four years might be considered a short amount of time in between revisions,

particularly given the size and documentation scope of NARA; but it is surprising to find that the

current version of the policy hardly addresses the appraisal of electronic records. Electronic

records are not new to NARA; the first electronic records were accessioned in 1970.62 Since then,

technology has changed exponentially. The bulk of the records created by the Government are

electronic63 and the inherent nature of those records is gaining in complexity and will continue to

get more complex as the Government transitions to e-Government. The ephemeral nature and

growing complexity of electronic records combined with need to preserve the content, structure

and context of electronic records and their supporting applications emphasizes the need to

60 Frank Boles, Selecting & Appraising Archives & Manuscripts (Chicago: Society of American Archivists, 2005), 116.61 Cox, No Innocent Deposits, 112.

62 Kenneth Thibodeau, “Building the Archives of the Future: Advances in Preserving Electronic Records at the National Archives and Records Administration,” D-Lib Magazine 7, no. 2 (2001).

63 David Ferriero, preface to “Preserving the Past”, iii.

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appraise electronic records before accessioning.64 Therefore, if NARA aspires to effectively

preserve the evidence of the functions and activities of the government, appraisal strategies for

electronic records should be addressed in the appraisal policy.

The Federal Government is a large, complex entity engaged in a perplexing variety of

activities.65 NARA is responsible for preserving the records of a wide range of agencies

including the Center for Medicare and Medicaid Services (CMS), the Social Security

Administration, Department of Housing and Urban Development, and National Drug Intelligence

Center, the United States District and Circuit Courts, and Legislative branch agencies. Of the

records created by the Federal Government, only 1% to 3% of the documents it generates are of

the legal or historical importance that decides they are to be kept forever.66 This suggests that

appraisal is a vital function of NARA, and makes one question how NARA measures the success

of its policy.

V. Measuring the Success of Appraisal Policies and Practices

To determine the success of NARA’s Appraisal Policy, one must look past the immense history

of the organization and consider as objectively as possible even the most basic of the

organization’s failures. While Schellenberg’s influence has undoubtedly permeated all facets of

American archival science, within and beyond NARA, the prevalence of his ideas should not be

a substitute for a careful study of their effects. NARA is, for many, the most public face of

archives, the most apparent intersection of the public and the documentary heritage of the United

States. For these reasons, it is important that the appraisal policy of NARA undergo considerable

64 David Bearman & Margaret Hedstrom, "Reinventing Archives for Electronic Records: Alternative Service Delivery Options, "Electronic Records Management Program Strategies, ed. Margaret Hedstrom (Pittsburgh: Archives and Museum Informatics, 1993), 86.65 Thibodeau, “Building the Archives of the Future.”66 “What is the National Archives?” National Archives and Records Administation, accessed April 8, 2011, http://www.archives.gov/about/.

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scrutiny and evaluation. But, how does one evaluate such an influential appraisal policy,

especially one conducted on such an enormous scale?

An evaluation of NARA’s appraisal policy might best begin with an analysis of the overarching

strategic plan, as stated in Preserving the Past to Protect the Future: The Strategic Plan of the

National Archives and Records Administration, 2006-2016. Described in this document are the

broad goals of NARA, underlying each of which is the necessity of a successful appraisal policy.

NARA is interested most of all in a general evaluation of its policies, conducted regularly

through performance, customer satisfaction, and program evaluations.67 The three methods used

in these evaluations can also be applied more specifically to the appraisal policy. What follows

are several examples of ways to apply these evaluative mechanisms to appraisal at NARA, as

well as other suggestions for measuring the success of the program.

One of the most popular, yet also most controversial, tools for evaluating the success of appraisal

is the measurement of use. Mark Greene, a strong advocate of use as an appraisal strategy, has

argued that, “If we acknowledge that archives do not have validity aside from the value that an

institution or society places on them, then use is the only empirical measurement we have of that

value, and significantly, of the overall success of an archives’ various programs.”68 Use of

archival records will, at least to some degree, reflect the strengths and oversights of an appraisal

policy. At NARA, the use of records could be calculated three ways. Call slip analysis and

citation analysis have been useful quantitative tools in the past for other archives, in that

“without exception, these studies paint a sobering picture of how frequently and how intensively

archival collections are used.”69 Both methods reveal users’ interest in certain archival records,

thereby verifying that those materials are of continuing use to society. An absence of use, on the

67 NARA, Preserving the Past, 26-29.68 Mark Greene. “‘The Surest Proof’: A Utilitarian Approach to Appraisal,” Archivaria 45 (Spring 1998): 150.69 Greene, “‘The Surest Proof,’” 135.

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other hand, may indicate that the appraisal policy has resulted in the retention of records whose

value is suspect. User studies conducted according to the framework provided by Paul Conway

in “Facts and Frameworks: An Approach to Studying the Users of Archives” may also be

valuable indicators of use.70 Conway’s framework, with its focus on value, integrity, and quality

of materials, could easily be incorporated into reference work at NARA. Such a study would

provide a qualitative perspective on the use of records at the National Archives, potentially

indicating gaps in documentation for which appraisal may be to blame. The success of NARA’s

appraisal can thus be evaluated, at least in part, by an analysis of how the remaining records are

used.

Evaluating appraisal knowledge within the federal government may also be a worthwhile

approach. Successful appraisal depends in part upon the knowledge of the archivist responsible

for that task. As mentioned, one appraisal archivist admitted to having never read the official

appraisal policy. In regards to the appraisal policy, she also offered the following criticism of the

policy:

I can’t say as I professionally agree with everything I have read, either. I know a permanent record when I see it. While I grant that it is necessary to have some sort of policy in order to provide guidelines for making appraisal decisions, the current policy’s attempt to leave no wiggle room results in a less, not more, efficient product.71

The successful application of an appraisal policy seems to require that the appraisal archivist has

actually read the policy. Presumably the archivist in question is experienced in appraisal and is

familiar with the policy in practice if not terms of concrete knowledge. Her response is

somewhat disconcerting, nonetheless, given the role of appraisal in preserving documentary

70 Paul Conway, “Facts and Frameworks: An Approach to Studying the Users of Archives,” American Archivist 49 (Fall 1986): 393-407.71 Dayton Appraisal Archivist, email message to the authors, 5 April 2011.

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heritage. An analysis of the success of the appraisal policy might involve in-depth investigation

into how familiar NARA employees are with the most important elements of the policy.

It may also be worth investigating the appraisal knowledge of records creators in the

government, perhaps as a type of the “program evaluation” described in Preserving the Past to

Protect the Future.72 NARA has published a guide titled Documenting Your Public Service

intended to help high-level government officials make decisions about the recordkeeping

practices of their agencies. Included in this document are an explanation of the differences

between Federal records and personal records, an explanation of why officials should care about

the preservation of their records, and an explanation what responsibilities the individual has in

the retention of those materials. In this guide, NARA is very clear as to what government

workers can and cannot do with their documents, specifically stating that, “the law provides that

Federal records may only be destroyed with NARA authorization.”73 In other words, NARA

policy does not grant records creators the right to pre-appraise the Federal documents they have

created, but it does request that records creators take responsibility for their personal records.

Since NARA has taken the time to create and disseminate a guide to archives and record-keeping

for records creators, it follows that these individuals have a significant effect on the retention of

records of enduring value. It would be worthwhile to conduct a study of high-level

administrators to verify that the retention advice of NARA is being heeded in all departments.

Successful appraisal and records management policies are those which have been communicated

to all relevant employees and are understood and implemented at all stages, even by the records

creators.

72 NARA, Preserving the Past, 26-29.73 NARA, Documenting Your Public Service.

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The above approaches to measuring the success of NARA’s appraisal policy have all been based

on internal measures, which means, as Jacques Gridard has described, that “they offer the

potential to assess the ‘fit’ between roles and expectations and to determine the degree of success

or the level of excellence achieved.”74 Based on the administration’s appraisal policy and

published strategic plan, NARA is primarily interested in evaluating its successes through these

internal measures. There is, however, another approach. Grimard also describes comparative

measures by which one archives might compare its policies to another.75 A particularly valuable

method of evaluating NARA’s appraisal policy and measuring its success might be to compare

the policy to that of the National Archives of Canada. Terry Cook has argued that the appraisal

of government records should be aimed towards documenting governance, not simply preserving

records of what a government does.76 In the article “Macro-appraisal and Functional Analysis:

Documenting Governance Rather Than Government,” Cook writes that archives should be

“consciously documenting both the functionality of government and its individual programmes

that are themselves the creation of citizens in a democratic society; and, especially, by

documenting the level of interaction of citizens with the functioning of the state.”77 Leaving aside

larger debates about the value and viability of macro-appraisal, one might still ask whether or not

NARA has accomplished this in their collections. The success of the policy could be measured

by a comparison with the success of Canada’s policy. Such a comparison, combined with the

additional methods of evaluation described above, would indicate which areas of governance are

well documented, as well as areas where the appraisal policy may need to be reworked.

74 Jacques Grimard, “Program Evaluation and Archives: ‘Appraising’ Archival Work and Achievement.” Archivaria 57 (Spring 2004): 79.75 Grimard, “Program Evaluation and Archives,” 77-78.76 Cook, Terry. “Macroappraisal and Functional Analysis: Documenting Governance Rather Than Government.” Journal of the Society of Archivists 35, no. 1 (2004): 5.77 Cook, “Macroappraisal and Functional Analysis,” 8.

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VI. Conclusion

As is made evident by this report, the NARA Appraisal Policy is a significant document when

studying archival appraisal. This organization has a long history with a strong foundation in the

theories of Theodore Schellenberg. The broad policy that has developed over the decades since

his tenure covers a wide range of functions, practices, and subjects as occur within the United

States Federal Government’s offices, agencies, and affiliates. While the policy is at first glance

appears to be a thorough document and presumably effective, we found through our own

evaluations and the input of NARA archivists that the policy is not entirely ideal. Shortcomings

are inherent in the policy’s origins, in its institutional mandate, and the practices and opinions of

those employees we encountered. While we see our evaluation as being almost trivial in the face

of such a colossal entity, we do believe that NARA’s Appraisal Policy could use some thorough

review and revision. Especially in light of the recent change in leadership, NARA and Mr.

Ferriero should certainly use this opportunity to address the policy’s deficiencies and limitations;

electronic records policy, most notably. Until this occurs, let us hope that the crucial parts of the

policy are understood and practiced and that through NARA’s appraisal, the United States is left

with a fitting legacy.

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Appendix A

Emily,

My answers, attached. I doubt they will be of much value, but feel free to use them as you see

fit. Just don't attach my name to the answer that says I have not read NARA's entire appraisal

policy!

[Name of Dayton Appraisal Archivist excluded]

1.) What are the highlights of the collections at the Dayton branch?

NARA’s Dayton office has no “collection” per se. It is a Federal Records Center only, housing

agency-owned temporary records between the time they are no longer needed for current

business until the time they can be legally destroyed. This office serves Federal agencies in

Ohio, Indiana, and Michigan, plus the Defense Finance and Accounting Service for stations in

Europe and Asia, and three IRS Service Centers: Cincinnati; Brookhaven, New York; and

Memphis, Tennessee.

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2.) NARA’s appraisal policy is quite lengthy, have you read it in its entirety? How well do you

feel that you understand it? Are there specific parts that are more relevant to your regional center

than others?

I admit I have not read the appraisal policy in its entirety. I can’t say as I professionally agree

with everything I have read, either. I know a permanent record when I see it. While I grant that

it is necessary to have some sort of policy in order to provide guidelines for making appraisal

decisions, the current policy’s attempt to leave no wiggle room results in a less, not more,

efficient product.

3.) Is appraisal a daily activity at your regional center? How often does appraisal occur?

I am the appraisal archivist for two Federal agencies. Appraisal does not happen in my job on a

daily or even monthly basis. It can be feast or famine on that score.

4.) Does the appraisal process differ from each NARA regional location?

I cannot possibly imagine. I have nothing on which to base an opinion.

5.) Who is responsible for implementing the appraisal policy? Is there a group of people who

implement the policy?

Theoretically the appraisal policy is implemented by every appraisal archivist within NARA.

6.) Does NARA as a whole or does your regional center measure the success of the policy? If so,

how so?

I have no basis on which to form an opinion on this question.

7.) How often are the appraisal policies discussed and revised?

No clue.

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8.) Are there records in the collection that you think are there due to poor appraisal decisions

made in the past? Are there collections or specific records no longer in your repository that you

think were deaccessioned due to poor decisions made in the past?

The shelves of the National Archives—Washington office and Regional offices included—are

full of records the public never asks to see. This does not, however, mean that the policy has

failed. If all appraisal decisions were based solely on a records series’ popularity, that would

reduce appraisal to something along the order of American Idol. How much use is needed to

make it worthwhile to save records? One user every year? Five users per year? God would

have spared Sodom if 10 righteous men had been found in it. Should we therefore use 10 as our

minimum researcher requirement in order to be willing to save records? It’s just not possible to

justify a coherent appraisal policy on numbers.

The policy of the 19th-century Prussian archives was that anything prior to 1600 must be saved

and anything after 1600 was eligible for disposal unless other rationale for keeping it could be

argued. This same policy consigned census records to the slag heap because, of course, the study

we call “social history” had not been conceived, much less legitimized.

Still…there is no denial that NARA is bursting with records that will never be requested by a

user. Does that mean the records do not have permanent value? I’m not sure I’m willing to give

a yes/no answer to that.

9.) How could the current appraisal policy be changed or improved?

It’s not my place to say….

Appendix B

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Hi Emily,

Below are my responses, sorry they aren't more in depth.

Please let me know if you have any questions.

Good luck with your research.

Laura

1.) NARA's appraisal policy is quite lengthy, have you read it in its entirety? How well do you

feel that you understand it? Are there specific parts that are more relevant to your regional

center than others?

Yes, I have read it in its entirety. I do understand it. However,

some things such as cost/volume issues do come into play which are not

reflected in the guidance. (attached)

2.) Is appraisal a daily activity? How often does appraisal occur?

Appraisal is conducted by appraisal archivists who may be in headquarters or the field.

Generally, most sit in our headquarters office and are assigned to specific, and often multiple

agencies. The exception is when an agency is headquartered in the regions, such as the

CDC. Appraisal most often occurs when agencies send us a proposed schedule on a form called

an SF-115 (attached). This is a daily activity for most appraisal archivists.

3.) Does the appraisal process differ from each NARA regional

location?

No, the appraisal process is consistent throughout NARA.

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4.) Who is responsible for implementing the appraisal policy? What measures are taken to

implement it?

The agencies are responsible for implementing approved schedules.

5.) Does NARA as a whole or does your regional center measure the success of the policy? If

so, how so?

NARA as a whole and regional archives review gaps in holdings for

permanent records. Appraisal procedures are updated as needed. There

has not been a major revision since I've been at NARA now almost 11

years so that stays relatively static.

7.) Are there records in the collection that you think are there due to poor appraisal decisions

made in the past? Are there collections or specific records no longer in your repository that you

think were deaccessioned due to poor decisions made in the past?

We do periodically reassess holdings and deaccession records. Often, this is done through

reappraisal.

8.) How does the process of acquiring materials typically work?

Agencies sign a standard form 258 which transfers legal custody to the National Archives. This

is initiated both by the agency and by the National Archives.

9.) How could the current appraisal policy be changed or improved? If you aren’t in such a

position, who would be and what recommendations would you give them?

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I think the current policy is adequate because it is broad enough to allow for tailoring to specific

situations.

10.) Is there anything else about your job as an appraisal archivist that you would like to share?

Appraisal at NARA is different than in traditional repositories where an archivist might be

looking at records nearer to the time of transfer. There is a distinct split between records

management and archives. Appraisal is considered a records management function.

Laura A. McHale

NARA, Mid-Atlantic Region

Appendix C

Hi Emily:

Please see my responses below. Please don't hesitate to contact me with any follow-up.

Thanks!

Sean Curry

1.) NARA’s appraisal policy is quite lengthy, have you read it in its

entirety? How well do you feel that you understand it? Are there specific

parts that are more relevant to your regional center than others?

ANSWER: Yes, I have read the appraisal policy (including standard operating procedures) in its

entirety. With training, and shadowing of other NARA staff I was able to understand it within a

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few months of working on appraisals. The policy is written to be usable across all regional

centers within NARA; this ensures continuity when conducting appraisal.

2.) Is appraisal a daily activity at your regional center? How often does

appraisal occur?

ANSWER: It depends on the center and the staff member. Most regional centers have "records

management" staff, who focus on appraisal work. For example, NARA headquarter in College

Park, MD has appraisal work-groups, who focus primarily on appraisal. We in the field tend to

be split between appraisal and other functions, such as training. Speaking for myself I tend to

spend about 50% of my time on appraisal, and 50% on other duties. Appraisal Archivists are

assigned to specific Agencies. For example, I am the appraisal archivist for Centers for

Medicare and Medicaid Services (CMS), while colleagues of mine in Philadelphia are same for

the Social Security Administration, Department of Housing and Urban Development, and

National Drug Intelligence Center.

3.) Does the appraisal process differ from each NARA regional location?

ANSWER: No; see answer 1.

4.) Who is responsible for implementing the appraisal policy? Is there a

group of people who implement the policy?

ANSWER: We all fall under a unit within NARA called "National Records Management

Program" (NRMP); headquarters in College Park issues the policy, and we are all required to

follow it to ensure continuity. We have what is known as a "stake-holder review" process, which

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helps ensure checks and balances in the process, and allows other units NARA the opportunity to

comment on any given appraisal job.

5.) Does NARA as a whole or does your regional center measure the success

of the policy? If so, how so?

ANSWER: Both. We have metrics, including number of jobs assigned, and number of items (an

item on a job) signed off by the Archivist.

6.) How often are the appraisal policies discussed and revised?

ANSWER: Varies. We have a series of informal monthly meetings, where appraisal is

discussed, including best practices. There are currently teams within NARA that are reviewing

the policy.

7.) Are there records in the collection that you think are there due to

poor appraisal decisions made in the past? Are there collections or

specific records no longer in your repository that you think were

deaccessioned due to poor decisions made in the past?

ANSWER: This is somewhat subjective, but appraisal is revisited as realties change. For

example, large projects are currently occurring on reappraising court records, and case files of

the United States Attorney.

8.) How could the current appraisal policy be changed or improved?

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ANSWER: In my opinion, work is needed on the stake-holder review portion; that is, who

within NARA should be involved in the appraisal process. Luckily, this is being addressed (see

answer 6).

9.) Do you know anything about the history of the National Archives branch

at Philadelphia?

ANSWER: I have only been with NARA for about 18 months, so am still learning the history.

Currently, the region has two facilities; the Archives in down-town Philadelphia, and the Federal

Records Center (where Records Management sits) near Bensalem, in NE Philadelphia. Both

used to be joined as one facility back in the 1980s, near Wissahickon.

Sean A. Curry

National Archives and Records Administration

Mid-Atlantic Region

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