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

December 31, 1993

Letter of Transmittal

To the Clerk of the United States House of Representative and the Secretary of the United States Senate:

Pursuant to the provisiion of Public Law 101-423, the Librarian of Congress, the Archivist of the United States, and the Public Printer herewith submit the second report in accordance with section 3 of the Joint Resolution to Establish a National Policy on Permanent Papers.


James H. Billington
The Librarian of Congress

Trudy Huskamp Peterson
Acting Archivist of the United States

Michael F. DiMario
Public Printer

I. Introduction

Public Law 101-423 (Permanent Paper) was passed by Congress and signed by the President in October 1990. The law states in Section 1 that "It is the policy of the United States that Federal records, books, and publications of enduring value be produced on acid free permanent papers." In Section 3, the law further specifies that the Librarian of Congress, the Archivist of the United States, and the Public Printer shall jointly monitor the Federal Government's progress in implementing the national policy declared in Section 1 regarding acid free permanent papers, and shall report to the Congress regarding such progress on December 31, 1991, December 31, 1993, and December 31, 1995. This is the second of the three required reports. It summarizes actions and events during 1992 and 1993 that have supported and assisted implementation of the law, and also discusses actions and events that have the potential for hampering the rate at which implementation moves forward.

As stated in the 1991 report, statutory authority for determining which publications and records have enduring value is assigned to the Archivist of the United States. The National Archives and Records Administration (NARA) approves schedules drawn up by each Federal agency that define the agency's records that have enduring value. Although some records can be clearly identified at the point of creation as having enduring value, no agency can identify at the time of creation all records that do, or will, have enduring value.

The ideal solution, therefore, would be to create all Federal documents on permanent paper. However, since the cost of procuring permanent paper (paper that meets the standards of JCP A270) for all documents would make across-the-board purchase of permanent paper unfeasible, the 1991 report recommended an interim step. It suggested that all publications and records that are clearly permanent at the time of creation should be produced on permanent paper and all others should be produced on alkaline paper.

II. Summary

Several steps were taken in 1992 and 1993 toward establishing a government-wide alkaline paper standard:

Issues for future consideration were identified:

III. Implementation of PL 101-423

Dissemination of information. Working toward the goal of establishing a governmentwide alkaline paper standard, NARA developed during 1993 a bulletin (in the final stages of release) to the heads of Federal agencies. The bulletin will advise agency heads of the permanent paper policy established by Public Law 101-423, will suggest initial steps agencies should take to implement that policy, and will advise agencies to use alkaline paper for all Federal records.

Early in 1994, NARA plans to hold a roundtable meeting for records management officials from representative Federal agencies for the purpose of discussing the draft bulletin. The questions, suggestions, and concerns advanced by participants will be used to refine the bulletin. The completed bulletin is scheduled for dissemination to agency heads in mid-1994 and is to be accompanied by guidance for procuring alkaline papers for Federal records.

Paper standards and specifications. The 1991 report to Congress noted that the Joint Committee on Printing's Advisory Council on Paper Specifications had issued two additional cost-competitive alkaline-based paper specifications. These were for a general printing paper and a paper suitable for xerographic and laser printing. During 1992 and 1993 the Advisory Council added these lower-cost alkaline paper options to many more grades of papers, including cover paper. It also provided that coated papers can be specified to have an alkaline coating and base sheet.

In 1991 only one permanent paper specification (JCP A270) was available for Government publications and printing that required a paper stock having maximum longevity potential and durability. Two new permanent paper specifications are now available. They are JCP G-40 (Option A), a 25% Bond paper suitable for letterheads; and JCP O-60 (Option A) a plain copier, xerographic paper suitable for photocopiers and laser printers. All three papers are typically much more expensive than the simple alkaline sheet.

Monitoring GPO publications. In recent years the demand by Government publishers and librarians for more "permanent" paper has increased. Since contemporary permanent papers are alkaline, it is fortunate that, primarily for economic reasons, the paper industry is gradually switching from the production of acidic paper to the production of alkaline paper. As a result, some Government publications and documents have been produced on alkaline paper (with no increase in paper cost) when alkalinity was not specified.

To monitor the Government's progress in implementing the national policy for acid free permanent papers, the GPO's paper testing laboratory has been routinely measuring the acid content of paper used in jobs procured through the GPO printing procurement offices. In FY93 tests were conducted on paper procured for 2,055 (out of 254,214) federal agency jobs. The sampling plan included a 100% selection of printing jobs procured at quality levels 1 and 2 (of five levels with level 1 being the highest), and approximately 10% of printing jobs procured at levels 3 and 4. Samples for the latter tests were selected randomly. Results are shown in Table 1. Table 2 shows the breakdown of the major grades of papers included in the GPO survey by alkalinity, and by its distribution among the total jobs examined.

Table 1. Results of acid/alkaline tests on randomly selected procured printing samples (the coating on coated papers is typically alkaline).

Paper Type

Percent of Samples

Uncoated, alkaline sheet


Uncoated, acidic sheet


Coated, alkaline base sheet


Coated, acidic base sheet




Table 2. Results of acid/alkaline tests, by paper type.

Type of Paper

% Alkaline

No. of samples




A180 (coated)









A170 (coated)






A240, A260, L10 (coated)



Other (coated, uncoated)




Almost half of the publications monitored were printed on coated paper because all level 1 and 2 jobs, which are typically produced on coated papers, were part of the sample. Thirty-five percent of all monitored coated paper is represented by the following grades of paper.

A170 (publication-grade, gloss coated text paper)
A180 (gloss coated text paper)
A240 (matte-finish, coated text paper)
A260 (dull-finish, coated text paper)
L10 (gloss-finish, cover paper)

Of the uncoated papers, 40% were printed on the following four grades of paper.

A60 (offset book paper)
A80 (opacified offset book)
D10 (writing paper)
L20 (vellum-finish cover paper)

Bulk purchases. For the GPO's FY93 quarterly term (requirements) contracts for bulk paper purchases, 83% of the paper supplied was alkaline (compared to 81% in FY92). These figures show that GPO receives a high percentage of alkaline paper when alkaline paper was not specifically required.

In GPO's bulk purchases, the amount of alkaline paper received was unaffected by the requirement that recycled fibers be included in the paper's composition.

Typically, for those procurements that require a high percentage of postconsumer (PC) recovered fiber content (10%, 15%, 20%, or higher) the specification requirement for pH was revised upward to a minimum of pH 6.5. The pH value was intentionally raised to counteract possible adverse effects of undesirable or unsuitable fibers (e.g., trace groundwood or lignin-containing fiber) that may have entered a paper mill's wastepaper source as a contaminant when it is purchasing postconsumer recovered material to meet the Government's PC requirement. The change in the minimum pH value to 6.5 from 4.5 on these highly recycled grades has been a problem for only one Government paper supplier thus far.

The GPO also buys a few grades of paper that require a minimum pH 7.0 value. On these grades, the quality of competition (e.g., number of bidders) has not declined. These papers have also been available with a highly sorted recycled fiber content (50% waste paper, as defined under EPA's Guideline for Federal Procurement of Paper and Paper Products Containing Recovered Materials). Thus far, GPO has not attempted to purchase these papers with a postconsumer recovered material content.

IV. Education and Training

The GPO has demonstrated that alkaline paper costs should be no more than acidic paper of the same grade. It has also shown that alkaline papers are routinely furnished on Federal contract without being specified. Such activity indicates that availability and the level of competition for alkaline paper is substantial. GPO has, in at least one instance, specified an alkaline paper, and discovered upon testing it, that an acidic paper was furnished. If this experience repeats itself, it may portend a pattern of "hit and miss" in contractual requirements and deliveries that can only be overcome through the development of an education and training program for both vendors and Federal procurement officers.

The lead agencies plan to develop a short lecture/seminar format as the ideal vehicle to relay to Federal users the issues surrounding permanent records. Pertinent extracts of the lecture/seminar, in an easily distributable form, will be made available to industry suppliers. The objective of the education program through this format is to present guidelines on a variety of subjects, such as how to identify records of enduring value, how to select paper specification standards, and what manner of documentation should be required of suppliers to assure that the paper ordered is that which was specified. To preclude costly administrative remedies in rectifying selection and acquisition mistakes, it is imperative that mistakes be diminished or, preferably, eliminated. This objective can only be accomplished through education and effective monitoring.

V. Concerns

Impact of Executive Order 12873 of October 20, 1993: Federal Acquisition, Recycling and Waste Prevention. In its individual update in Part V of the first report to Congress, the Government Printing Office stated:

. . . the presorting of postconsumer waste would have to be performed at a high degree of competence to exclude paper and paper products that contain groundwood fibers. The introduction of groundwood fiber into the source material would be detrimental to the enduring qualities of the paper and defeat the purpose for which it was manufactured.

Although it might appear from Section 505 (Revision of Brightness Specifications and Standards) of the executive order that the concern expressed for years is in danger of becoming reality, this is not the case. The inclusion in standards or specifications of unbleached fiber, other lignin-containing fibers, or groundwood, would be evaluated, revised, or eliminated in circumstances related to performance. The lead agencies interpret Section 505 of the executive order to state that permanence is without a doubt a factor of performance and that the Section will therefore have little or no effect on the acquisition of permanent papers. The rationale behind this conclusion is embodied in Federal Acquisition regulations and case law where:

Agencies shall prepare specifications and purchase descriptions which reflect the MINIMUM NEEDS of the agency and the market available to satisfy such needs. Specifications and purchase descriptions may be stated in terms of . . . performance, including specifications of the range of acceptable characteristics or of the minimum acceptable standards. (FAR 10.002) (Editor's note: emphasis added.)

The lead agencies agree that both permanence and the inclusion of a recovered materials content can be achieved. There are, however, two caveats. First, Federal agencies must be vigilant and rigorous in determining and specifying their minimum needs for acid free paper. Second, as the amount of postconsumer materials increases so must the volume and degree of presorting for a suitable source material (e.g., compatible to permanence) increase. Increased presorting will result in higher cost. In an effort to contain cost, the time will eventually come when the Government will have to balance the costs associated with requiring presorted recovered source material, suitable for use in permanent paper without further processing, against those associated with accepting unsuitable source material (groundwood) that requires further processing.

SMALL-QUANTITY PAPER PURCHASES. While bulk or large-lot purchases of permanent or alkaline paper containing postconsumer recovered materials are not anticipated to be affected by the new executive order, the acquisition of small quantities that contain higher levels of postconsumer recovered materials will be difficult for the Government and small commercial printers. Small quantities, defined as "off-the-shelf," approximate 200,000 tons (42%) of the Government's paper use per year. Off-the-shelf quantities are used for printed materials produced by agency printing plants or through commercial printing contracts.

Since the implementation of the Environmental Protection Agency's Guideline for Federal Procurement of Paper and Paper Products Containing Recovered Materials, GPO has been monitoring the paper usage in commercial printing contracts. The data indicate that the EPA Guidelines which define recycled fibers as waste paper have not affected the quality or availability of the most common off-the-shelf paper grades (for example, offset book paper). Manufacturers typically produce over 75% of these common printing papers with an alkaline chemistry.

However, the new executive order encourages paper mills to produce paper that contains higher percentages of postconsumer waste. The Government may have difficulty purchasing paper that meets the new postconsumer recovered materials content requirements. The two primary reasons for this potential problem are: the Government's share of the market is small; and few paper supply companies have the capacity to store small quantities of the myriad brands and grades of paper that the Government purchases.

DEFINITION OF PERMANENCE. Both the ANSI standard Z39.48-1984 (permanent paper) and the recently adopted International Standards Organization (ISO) standard on permanent paper (ISO DIS 9706 - Information and Documentation - Paper for Documents - Requirements for Permanence) are in accord in defining a permanent paper as having several properties.

These include an alkaline pH (pH 7.5-10), an alkaline reserve of at least 2%, minimum tear resistance requirements that are similar, and a paper stock that is essentially fully bleached, which means that only a very low level of lignin (the component of wood pulp that is removed by bleaching) is acceptable in permanent papers. A standard guide drafted by the American Society for Testing Materials (ASTM), Standard Guide for the Selection of Permanent and Durable Offset and Book Papers also permits a low percentage of lignin in permanent papers.

The low lignin requirement has generated opposition from the papermaking industry, particularly those producers who use bleached chemi-thermo-mechanical pulps (BCTMP, CTMP) or who are not bleaching their pulps thoroughly. Papers currently produced by these manufacturing processes contain a level of lignin high enough to cause the paper to discolor significantly with exposure to light. The papermakers using these processes argue that the properties essential for permanence are not compromised by the presence of lignin. Neither the archival and library communities nor the manufacturers producing paper that meets the ANSI Z39.48-1984 and ASTM standards concur with this view.

The ANSI committee that revised the Z39.48-1984 standard has recommended that a research program on the effects of lignin on paper properties be undertaken prior to or in conjunction with the next revision of this standard. ASTM has scheduled a seminar on the influence of fiber composition on printing and writing paper permanence that will address essentially the same questions as the proposed ANSI research program. The lead agencies are watching these developments closely.

Currently, the methods of producing very low lignin paper or bleached "free sheet" (groundwood-free) that minimize the production of dioxins are to bleach without chlorine-containing compounds. Although paper mills are experimenting with alternative bleaching methods, the needed quantity of free sheet bleached without chlorine-containing compounds is not available in the United States. At the present time, the inclusion in specifications of increasing amounts of postconsumer waste and of non-traditional methods of removing lignin will probably result in higher cost for papers that must also have the strength and chemical properties necessary to assure longevity.

DECENTRALIZED PRINTING. Changes in publishing technology and dispersal of the printing functions in the Government may reduce ability to monitor effectively the implementation of Public Law 101-423. In publishing, for example, the use of desktop publishing software—an increasingly popular method of producing documents—allows the individual creating the document to select the paper on which the document will be printed. The paper selected may or may not be the permanent bond paper that meets or exceeds the requirements of JCP A270.

Similarly, if the Administration's proposed legislation is adopted that the number of formal Government publications through GPO be reduced, the selection of paper will be made by the procurement operation of the publishing agency. Routine testing through the GPO has allowed the lead agencies to monitor the use of alkaline and permanent paper, and some effective, coordinated, and systematic method of monitoring the quality of paper used in Government publishing must continue. Otherwise, control over paper quality is likely to be left to the discretion of individual printing officers and procurement officials without the aid of archives and library preservation professionals whose special expertise must be brought to bear on this critical issue.

Appendix A

104 Stat. 912, Public Law 101-423—Oct. 12, 1990, Public Law 101-423, 101st Congress

Joint Resolution to Establish a National Policy on Permanent Paper

Whereas it is now widely recognized and scientifically demonstrated that the acidic papers commonly used for more than a century in documents, books, and other publications are self-destructing and will continue to self destruct;

Whereas Americans are facing the prospect of continuing to lose national, historical, scientific, and scholarly records, including government records, faster than salvage efforts can be mounted despite the dedicated efforts of many libraries, archives, and agencies, such as the Library of Congress and the National Archives and Records Administration;

Whereas nationwide hundreds of millions of dollars will have to be spent by the Federal, State, and local governments and private institutions to salvage the most essential books and other materials in the libraries and archives of government, academic, and private institutions;

Whereas paper manufacturers can produce a sufficient supply of acid free permanent papers with a life of several hundred years, at prices competitive with acid papers, if publishers would specify the use of such papers, and some publishers and many university presses are already publishing on acid free permanent papers;

Whereas most Government agencies do not require the use of acid free permanent papers for appropriate Federal records and publications;

Whereas librarians, publishers, and other professional groups have urged the use of acid free permanent papers;

Whereas even when books are printed on acid free permanent paper this fact is often not made known to libraries by notations in the book or by notations in standard bibliographic listings; and

Whereas there is an urgent need to prevent the continuance of the acid paper problem in the future: Now, therefore, be it


SECTION 1. It is the policy of the United States that Federal records, books, and publications of enduring value be produced on acid free permanent papers.

SEC. 2. The Congress of the United States urgently recommends that—

  1. Federal agencies require the use of permanent papers for publications of enduring value produced by the Government Printing Office or produced by Federal grant or contract, using the specifications for such paper established by the Joint Committee on Printing;
  2. Federal agencies require the use of archival quality acid free papers for permanently valuable Federal records and confer with the National Archives and Records Administration on the requirements for paper quality;
  3. American publishers and State and local government use acid free permanent papers for publications of enduring value, in voluntary compliance with the American National Standard;
  4. all publishers, private and governmental, prominently note the use of acid free permanent paper in books, advertisements, catalogs, and standard bibliographic listings; and
  5. the Secretary of State, Librarian of Congress, Archivist of the United States, and other Federal officials make known the national policy regarding acid free permanent papers to foreign governments and appropriate international agencies since the acid paper problem is worldwide and essential foreign materials being imported by our libraries are printed on acid papers.

SEC. 3. The Librarian of Congress, Archivist of the United States, and the Public Printer shall jointly monitor the Federal Government's progress in implementing the national policy declared in section 1 regarding acid free permanent papers and shall report to the Congress regarding such progress on December 31, 1991, December 31, 1993, and December 31, 1995. In carrying out the monitoring and reporting functions under this section, the Librarian of Congress, the Archivist of the United States, and the Public Printer may consult with the National Endowment for the Humanities, National Agricultural Library, National Library of Medicine, other Federal and State agencies, international organizations, private publishers, paper manufacturers, and other organizations with an interest in preservation of books and historical papers.

Approved October 12, 1990.

Appendix B

State and Local Action on Acid Free Paper

Most action by state governments began in 1990 immediately following passage of Public Law 101-423. The Federal policy focused attention on and helped articulate the importance and benefits of using permanent paper for public records. From 1990 to the present, the law has provided an impetus and foundation for state governments and their constituencies to define policies of their own. This trend can be seen in published articles and conference sessions sponsored by such organizations as the National Association of Government Archives and Records Administrators (NAGARA).

To date, many states have followed the government's lead in establishing policy for the use of permanent papers. For example, the state governments of Arizona, Colorado, Connecticut, Indiana, Montana, Massachusetts, Nebraska, New York, North Carolina, Rhode Island, South Dakota, Vermont, and Virginia have established legislative mandates for the use of alkaline and permanent papers for public records. The Vermont initiative, Bill 446, is particularly noteworthy because it has successfully combined goals for enduring paper for public records and environmental recycling. Several state governments have also pursued administrative provisions to promote the use of alkaline papers. The state of Florida, for example, has established alkaline paper specifications and quality assurance testing that is applied by Florida's General Services Department to state purchasing contracts.