The Abbey Newsletter

Volume 16, Number 1
Feb 1992

Report to Congress on the Permanent Paper Law

A joint resolution encouraging the use of "acid free permanent papers" was signed into law by President Bush in October 1990. One of its provisions was that reports on how well the law was being implemented should be made to Congress in December 1991, 1993, and 1995. The heads of the Library of Congress, the National Archives, and the Government Printing Office were given the job of putting these reports together, and they have just turned in their first one. It is fairly long, so it will be condensed and published in two parts, beginning in this issue.

Report to Congress on the Joint Resolution to Establish a National Policy on Permanent Papers

[Introduction and Background omitted]

III. Executive Summary

As Newsweek so aptly stated in the lead to their 1989 article on the trend towards permanent papers, "It isn't often that the altruistic coincides with the economically sensible, but it does happen.''1 The economics continue to be a large factor driving the increased manufacture of alkaline papers. As the preliminary survey by the Government Printing Office demonstrates, the majority of the papers being supplied for Government printing and writing in 1991 are alkaline, even when the pH is not specified in the procurement.

While [this trend is] a convenient aid to the implementation of the permanent papers policy, all three lead agencies are in agreement that market trends are not the only answer to ensure a fulfillment of the goals of PL 101-423. A cooperative effort of the agencies along with the General Services Administration will be required to see that the proper standards, specifications, procedures and supplies are in place to serve the needs of the Federal government.

Further, all agencies agreed that a proper implementation of the law required that two other challenging issues be resolved. First of all, if all records of enduring value cannot be identified at the point of their creation, how can we implement a policy that requires only records of enduring quality to be created on permanent papers? The agencies have agreed that a policy that requires all records to be created on a more long-lasting paper is the solution. However, this brings us to the second major issue. If the implementation places any additional cost burden on Federal agencies, it will not be feasible. In 1991, paper that meets both the requirements of chemical stability and durability (truly permanent paper) is significantly more costly than non-permanent papers. Alkaline paper due to its chemical stability is more long-lasting than acidic papers and is competitively priced.

The lead agencies are therefore recommending the advancement of an alkaline paper standard for the Federal government as an economical interim step toward our ultimate goal of permanent papers. Records and publications that are clearly permanent at the time of creation should be recorded on permanent paper. All others should be recorded on alkaline papers.

Much has already been accomplished by the agencies to lay the groundwork for the implementation of PL101423 as the following pages will demonstrate. Much remains to be done in order to report an alkaline paper standard for the Federal government by our next report in 1993.

IV. Report Methodology

Public Law 101-423 has presented a unique opportunity by bringing together the three primary Government agencies involved in the production, collection, and preservation of documents and publications of enduring value. Representatives of the Public Printer, the Librarian of Congress, and the Archivist of the United States have met on four occasions in an atmosphere of collaboration to implement the urgent recommendation of Congress embodied in the public law. The meetings have proven to be educational from the standpoint of the technical aspects of paper longevity and stimulating by virtue of the unqualified cooperation that the participants have exhibited.

The first meeting of the agencies was hosted by the Government Printing Office. The agenda for this initial meeting included a review of Public Law 101-423 and a discussion of its major aspects. The group went on to discuss some of the terminology issues which are presented in Part V of this report.

The second meeting was held at the Library of Congress and included representatives from the General Services Administration's Paper Products Procurement Division in New York. The principal topics of discussion at this meeting were the need for a baseline of information as to the use of alkaline and permanent papers in the Federal Government and the necessity for a broader range of standards to be used by the procurement agencies in purchasing papers for Federal use.

The third and fourth meetings of the agencies, hosted by the National Archives and the Government Printing Office, respectively, were working sessions to divide the responsibilities for drafting this report and editing the final version.

While not named in the legislation as a participant in the interagency group, professional staff members from the Joint Committee on Printing have attended all meetings and have become an important part of the success of this effort.

The agencies also wish to thank the National Library of Medicine and the United States National Commission on Libraries and Information Science for providing appendix material for this report and thereby broadening its coverage.

V. Issues and Recommendations

As described in Part I the agencies considered both the letter and the intent of PL 101-423. In this process, various issues were identified and discussed which will affect the implementation of the law. These related to terminology, enduring value, economics, and specifications and standards. The highlights of those discussions and recommendations are outlined below.

Terminology. The terms "acid free" and "alkaline," and "permanent paper" and "archival-quality paper" were used in PL101-423, either individually or in combination with each other. The agencies determined to use the term "alkaline" rather than acid-free because it is technically more precise. The agencies also opted to use "permanent paper" rather than "archival quality paper" because it more clearly means long-lasting.

Enduring Value. Statutory authority for determining the enduring value of government records is assigned to the Archivist of the United States in Title 44, Section 2107, United States Code. The code states that "when it appears to the Archivist to be in the public interest, he may . . . accept for deposit with the National Archives of the United States the records of a Federal agency, the Congress, the Architect of the Capitol, or the Supreme Court, 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." This authority is further strengthened by Sections 3303 and 3303a, which require the head of each agency of government to submit to the Archivist for his review and approval lists of all agency records deemed to be of less than enduring value (temporary). The Archivist must approve the disposal of temporary records and authorize the agency head to actually destroy the records.

The National Archives approves schedules drawn up by each Federal agency that define the textual record groups that have enduring value. These and other records are held by the agency for thirty years, then transferred to the National Archives.

Some records can be clearly identified at the point of creation as having enduring value. International treaties, public laws, and executive orders are a few of the kinds of records that document public policy, that safeguard the rights and delineate the responsibilities of citizens, that relate to the accountability of the government to the people, or that define the nation's relationship to other countries.

Many records, however, that do not fall into any of the above categories nonetheless have continuing use for scientific, medical, legal, environmental, and historical research that is not always easily identifiable by agency personnel at the time that the records are created.

It is impossible for any agency to identify at the time they are created all records that do or will have enduring value. Selected officials in each agency are generally aware which of its record groups have enduring value, and may even have an excellent idea for certain groups which individual records do or might have enduring value. In the majority of cases this knowledge does not extend to every agency employee who might be creating records. In any case, switching back and forth between different paper grades involves considerable inconvenience to agency staff and a loss in productivity.

Ideally, agencies should use permanent paper for all publications and records of enduring value. Given the practical problems that agency personnel face both in determining enduring value and in switching between paper grades, they are faced with the real world choice of using permanent paper for either all or none of the documents they create.

While the ideal solution would be to create all Federal documents on permanent media to assure their condition when NARA receives the records for appraisal, the economics of this approach are problematic. In 1991 the cost of permanent paper is significantly higher than grades in current use and would require an alternative to the all-documents-on-permanent-paper approach.

Economics. Based on a recent procurement of permanent paper, the National Archives and Records Administration determined that paper which meets the JCP A270 standard [which is based on the ANSI standard] is approximately 30% more expensive than paper that does not meet this standard.... If no Federal records or publications were produced on permanent paper, the future preservation cost would be high. If all Federal records and publications were produced on permanent paper, the immediate direct cost would be high.

A possible solution to this economics dilemma lies with alkaline paper. It is generally true that alkaline paper of any given fiber content and performance characteristics is much more long-lasting than its acidic equivalent. Moreover, alkaline paper is now generally no more expensive than acidic paper of like grade. If the Federal government developed a policy of using alkaline paper for all recording and publishing activities, it could be assured that records and publications of enduring value would be created on a longer-lasting medium at no greater cost to taxpayers. Those offices whose records and publications include a high percentage of documents of enduring value would continue to select permanent (JCP A270).paper. Such a policy would result in no increased supply or administrative costs, and would provide savings in long-term preservation costs. The policy would require the development of additional paper specifications, but these could be developed quickly and easily.

Specifications and Standards. Agreed-upon standards and specifications for permanent papers and paper products exist, but agreement is not universal. The community of librarians, archivists, and preservation professionals has generally accepted the American national Standards Institute (ANSI) Standard Z39.48-1984 as the benchmark for the specification of permanent paper.

However, the Federal government is not allowed to use the ANSI standard in paper procurement. Under Title 44, United States Code, the Joint Committee on Printing (JCP) has the responsibility to establish quality standards for paper used in government printing and binding. The JCP standards and specifications are the only ones that the Government Printing Office and the General Services Administration ar authorized to use to procure paper. Prior to the passage of Public Law 101-423, the JCP only had one permanent paper standard, JCP A270, which was designed to meet the requirements of ANSI Z39.48-1984. In fact JCP A270 is more stringent than the ANSI standard in some of its durability requirements and is the recommended permanent paper standard for the Federal Government.

Through discussions with the agencies, the JCP was made aware of the need for more cost-competitive alkaline-based paper standards and developed two additional paper standards, JCP A560 and JCP O-560. JCP A560 is the alkaline-based version of JCP A60, an offset book paper widely used for general printing, and JCP O-560 is the first JCP standard for alkaline-based xerographic paper for use in copiers and laser printers. Given the number of record copies of Federal agency correspondence and reports being created on plain paper copiers and laser printers, this last standard is a particularly significant breakthrough for the implementation of the public law.

These additions bring to a total of five the specifications, including JCP A270, which are alkaline-based paper standards available for government use. The other two, not previously mentioned are JCP A25, a web offset book paper, and JCP A61, a high quality alkaline book stock. While five alkaline-based paper standards are an excellent start, there are still other specifications that the Joint Committee on Printing will be considering and developing for documents and publications requiring permanent retention.

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