Volume 4, Number 1
Feb 1991

The National Archives and the Permanent Paper Law

Copyright 1991. Reprinted with permission of the Society of American Archivists from the January 1991 SAA Newsletter, where it appeared under the title "From the Archivist of The United States."

On October 12, 1990, President Bush signed a Congressional Joint Resolution on permanent papers. This resolution, which the National Archives vigorously supported, makes it national policy to use acid-free permanent paper for federal records, books, and other publications having enduring value. The measure also recommends that American Publishers and state and local governments Voluntarily use acid-free permanent paper.

Testifying on behalf of the resolution last February, I pointed out some of the truly daunting preservation problems that NARA faces and identified some issues that must be resolved before we can move to full use of acid-free, permanent paper. NARA safeguards approximately 3 1/4 billion documents, some of which are on impermanent (usually acidic) paper and so subject to deterioration. This deterioration threatens to erode our national memory, depriving ourselves and those who follow us of vitally important information and insights.

A particularly poignant example are many of the records of World War II. Even as we launch the 50th anniversary remembrance of that great conflict, we face the consequences of the wartime recommendation of the Bureau of the Budget that Federal agencies use inexpensive paper as an economy measure. Many of the records of World War II are on paper that is today fragile and difficult to use, and NARA faces the monumental task of transferring these deteriorating records to a more stable medium. We estimate the costs of this process to be more than $71 million.

If records begin stable, naturally the risk of losing this information, as well as the cost of conserving and transferring it, is much reduced. In order to achieve the goal of paper that is both acid-free and permanent, however, we must resolve two major issues.

First, we must develop applicable standards for such paper that will meet the preservation qualities demanded by archival repositories. What is "acid-free" paper is quite straightforward: it is paper with a neutral or alkaline pH. What is "permanent" though, is more difficult to determine. Paper may last, but how durable is it in repeated use? Will it tear or break? Durability is thus a key virtue in any so-called "permanent" paper, at least from an archival point of view.

A recent regulation issued by the Environmental Protection Agency complicates the picture. This regulation requires the federal government to purchase paper for writing and publication that contains at least 50%. recycled stock. The concern of the National Archives is that such paper 'might not have the physical characteristics needed for permanence; that is, modifications taking place during the recycling process may produce chemical and physical changes that will affect the long-term durability of the resulting paper. Recycling is a worthy goal, but archivists must ensure that we do not repeat the mistake made during World War II: adopting a paper for reasons, however admirable, that unwittingly undermine our ability to ensure that the information recorded on this paper will remain indefinitely.

One solution, proposed by the paper industry, is thickening recycled paper in order to offset any loss in durability. Unfortunately, most archivists, librarians, and others would find additional thickness in documents and publications a problems because of the additional storage costs that they would incur.

The EPA regulations do enable a federal agency to exclude recycled papers if they do not meet reasonable performance standards. Few agencies, though, have the incentive or the expertise to develop such standards on their own. Fortunately, there has been considerable work on guidelines and standards for permanent papers in printed materials, and work continues on standards for permanent papers in other applications. But we need to develop more specific standards and specifications before we can actually implement the Permanent Papers Resolution.

The National Archives intends to work with interested parties-the Library of Congress, standards organizations, the Government Printing Office, the paper industry itself, other users, the General Services Administration, and members of the archival profession as a whole-to develop comprehensive standards for acid-free, permanent papers for many uses: bone, ledger, and manifold papers; carbon-copy and carbonless papers; index card stock; computer paper; and xerographic copier paper. Once these standards are prepared, and then adopted by the Joint Committee on Printing, the General Services Administration's Federal Supply Service can apply appropriate specifications for the procurement Of truly permanent papers, as required by federal agencies.

The Joint Resolution requires the Archivist of the United States, together with the Librarian of Congress and the Public Printer, to "monitor the federal government's progress in implementing the national policy" on permanent paper, and to report to Congress at the end of 1991, 1993, and 1995. NARA thus will have a continuing involvement in the campaign for the use of permanent paper.

Another issue, however, is determining which documents unit be created on acid-free permanent paper. Some of these applications are clear (e.g., documents that establish an agency's policies). Other documents, not thought of as permanently valuable at first, later are found to contain important--and permanently valuable--information. It may make sense, then, to require acid-free permanent paper for all federal records (excepting, perhaps, the many bulky Housekeeping records like travel forms and routine personnel actions that are clearly destined for disposal). Calculating the cost/benefit ratio between what it will cost to preserve truly permanent records and what it would cost to mandate the use of acid-free paper for all records will be an interesting proposition, I think--particularly as the paper industry itself adjusts to the new demand for acid-free paper.

Changes within the paper industry make it economically feasible now to require such paper for at least correspondence and publications, and perhaps even for other categories of documents. Measured against what it costs to conserve, treat, and duplicate impermanent papers, changing entirely to acid-free permanent papers of a durable nature might already be cost-effective. The principle we have learned in health care functions here as well: it is less costly to prevent dm to treat. All archivists need to redouble their efforts to care for deteriorating documents, but it is a smart investment to prevent future deterioration.

NARA will clearly play a leading role as these two issues unfold. Since what happens at the federal level often affects developments elsewhere in the United States, we will share our experience, research, and recommendations within the broader archival community, as well as within the federal government. Staff involved in NARA's preservation efforts are active participants in national and international efforts to achieve the goals we have set, and they will be happy to share their knowledge and experience with the entire archival profession.

In addition, we welcome information about parallel efforts within the states or the private sector. We can work together to persuade or governments, our colleges and universities, our corporations, and our "parent" institutions-those who buy paper, in other words-to purchase and use the kind of paper that will truly meet the test of time.