An Instructional GuideNational Archives and Records Administration
NOTE: This publication is being prepared for printing. The printed edition will include illustrations and other enhancements, which when possible, will be available electronically also. NARA anticipates availability of the printed copies in the spring of 1996. Distribution of NARA records management publications is handled by the Publications Distribution Staff, NECD, Room G-9, 7th & Pennsylvania Ave., NW, Washington, DC 20408 (1- 800-234-8861, FAX 202-501-7170).
Introduction Background Contingency Planning and Risk Assessment Levels of Risk Vital Records Program Program Objectives Responsibilities Vital Records Plan Training Review and Testing Records Disaster Mitigation and Recovery Program Program Objectives Levels of Risk Responsibilities Records Recovery Plan Training Review and Testing Appendix A. Further Guidance and Assistance Appendix B. Regulations - 36 CFR 1236 Appendix C. Sample Vital Records Directives Appendix D. Sample Records Recovery Plan Appendix E.Vital Records/Records Disaster Mitigation and Recovery Self-Evaluation Guide Appendix F. Glossary
The management of vital records is part of a Federal agency's emergency preparedness responsibility. This instructional guide addresses the identification and protection of records containing information that Federal agencies may need to conduct business under emergency operating conditions or to protect the legal and financial rights of the Federal government and the people it serves. This guide also recommends policies and procedures that will allow agencies to assess the damage to and implement the recovery of any of their records that may be affected by an emergency or disaster. An emergency means a situation or an occurrence of a serious nature, developing suddenly and unexpectedly, and demanding immediate action. This is generally of short duration, for example, an interruption of normal agency operations for a week or less. It may involve electrical failure or minor flooding caused by broken pipes. A disaster, on the other hand, means an unexpected occurrence inflicting widespread destruction and distress and having long-term adverse effects on agency operations. Each agency defines what a long-term adverse effect is in relation to its most critical program activities. Much of the information in this instructional guide is advisory in nature, rather than regulatory. It is left to the discretion and judgment of Federal agency officials how best to implement the practices and procedures described herein, particularly given the human, financial and information resources available for implementing them.
The identification and protection of copies of records containing vital information and the implementation of records disaster mitigation and recovery programs constitute an insurance policy against the disruption of critical agency operations. To effect that insurance policy Federal agencies must take appropriate action to achieve the aims of continuing operations, reconstituting normal business operations, protecting legal and financial rights, and recovering damaged records. Consequently, agencies need to determine their most critical functions and identify those records needed for the performance of those functions. Equally important is the identification of recorded information that protects the legal and financial rights both of an agency and of the individuals affected by that agency's actions and the measures required to protect such information. Finally, agencies need to develop a plan of action to respond to emergencies or disasters that may damage an agency's records and to provide for the recovery of needed information, regardless of the medium on which it is recorded. Agency officials should keep in mind that both vital records and records disaster recovery programs occur in the context of emergency preparedness.
The Federal vital records program originated in the 1950's as part of the continuity of Government program. Bureau of Budget Bulletins No. 51-14, May 22, 1951, and No. 52-5, September 6, 1951, established requirements for vital operating records protection programs. Subsequently, the President issued Executive Order 10346 on April 17, 1952, making each Federal department and agency responsible for carrying out its essential functions in an emergency. Later Presidents have issued various Executive orders that have modified Federal continuity of Government and emergency preparedness responsibilities. Currently, Executive Order 12656 defines agency responsibilities during a national security emergency.
The initial focus of the vital records program was the continuation of Federal agency operations under national emergency conditions, including a possible enemy nuclear attack upon the United States, and the reconstitution of normal agency activities at the emergency's conclusion. The cold war created a need to prepare for national mobilization in case of an actual war breaking out. With the decline of diplomatic tensions over time and the recent end of the cold war, the vital records program has increasingly been dedicated to meeting the challenges that Federal agencies face in continuing their operations and protecting their records in the face of natural disasters and the threat of terrorism.
Technological advances affecting the management of recorded information have had an increasing impact on vital records programs also. The Federal Government frequently relies on electronic information systems to conduct its business and to document its essential transactions. Because information in electronic form may be changed or deleted more easily than information on other media, special measures are required in the creation and preservation of electronic records needed for operational and informational purposes.
The vital records and records disaster mitigation and recovery programs relate to emergency preparedness. Contingency planning is critical to laying the foundation for both programs, and appropriate agency staff should be involved in this process. The planning provides a forum for dealing with the following issues: (1) determining the most critical activities that the agency must perform if it must operate under other than normal business conditions and in a facility other than its normal place of business; (2) identifying which records are required to support those critical activities and the reconstitution of normal operations; (3) identifying which records series or electronic information systems contain information necessary to protect the legal and financial rights of the agency and persons affected by the agency's actions and preserving copies of such records; and (4) establishing and implementing a plan to recover records (regardless of the medium of recording) that are damaged in an emergency or disaster.
To determine what might constitute critical agency functions some guidance is already available. Executive Order 12656, issued in November 1988, defines particular functions certain agencies must continue under a national security emergency declared by the President. This Executive order assigns the Federal Emergency Management Agency (FEMA) lead responsibility in providing guidance to Federal agencies about emergency preparedness. FEMA has supplemented the requirements outlined in EO 12656 by issuing Federal Preparedness Circulars (FPCs) 60 and 64. Those circulars further show which agencies have the most critical and the least critical functions in terms of a declared national security emergency. (Appendix A, Further Guidance and Assistance, provides information on obtaining copies of FPCs from FEMA.)
Agency staff participating in contingency planning may include those from such functional areas as emergency coordination or preparedness as authorized by E. O. 12656, information resources management (IRM), automatic data processing (ADP), records management, security, and facilities management. Officials from all these areas have their roles in the continuity of operations should disaster strike. Therefore, their participation in the planning process and their contribution to the development of continuity of agency operations and records disaster recovery programs are crucial.
Planning must address actual and potential risks that could adversely affect agency operations and the preservation of records. Possible threats include fires, hurricanes, earthquakes and floods, sabotage, civil disturbance, terrorism, and infestation of vermin or other pests. In terms of natural disasters, regional conditions should be considered. Federal agencies located on the east coast of the United States must consider the possible effect of hurricanes on their operations and their records. Those in the South and Midwest may be subject to tornadoes. Those on the west coast may be subject to earthquakes. All regions are subject to the possibility of flood and fire. Recent examples of disasters affecting Federal facilities include the hurricane that hit Homestead Air Force Base in Florida, a flood that invaded the Defense Mapping Agency in St. Louis, an earthquake that damaged a Department of Veterans Affairs hospital in Los Angeles, a volcano eruption that caused the evacuation and abandonment of Clark Air Force Base in the Philippines, as well as the bombing of the Federal facility occupied by several agencies in Oklahoma City.
In planning to meet actual and potential risks to agency operations and the records needed to support them, agency officials should identify the types of risks to which each of its facilities may be subject. They should also assess the level of each type of risk to determine the type of protection or response that may be required. Some emergencies may require only limited response, while the President might declare others to be national security emergencies. Emergencies may affect one office within the agency or an entire facility. They might be local or regional in scope. For example, forewarning of an imminent terrorist attack on an agency facility might be characterized as a top level emergency and preplanned action taken to evacuate agency staff from the threatened facility and continue agency operations from another site until the threat is resolved or ceases. Alternatively, a minor flood causing minimal damage to agency records and space would be assigned a lower magnitude of importance requiring a less disruptive response. Additional detail on level of emergencies is provided in the section RECORDS DISASTER MITIGATION AND RECOVERY.
The vital records program is intended to do two basic things. First, the program provides an agency with the information it needs to conduct its business under other than normal operating conditions and to resume normal business afterward. Second, the program enables agency officials to identify and protect the most important records dealing with the legal and financial rights of the agency and of the persons affected by the agency's actions. Consequently, vital records have been traditionally identified as being of two types: emergency operating records and records needed to protect rights (see 36 CFR 1236.14 in appendix B of this guide for the formal definitions of vital records). The various components required to implement the program follow.
Agency officials responsible for coordinating the vital records program serve a most critical function. It involves working with other appropriate officials throughout the agency to identify, inventory, protect, store, make accessible, and cycle (update, as needed) the copies of vital records required in an emergency including records that document legal and financial rights.
The records officer plays a crucial role in providing guidance and assistance in inventorying records and determining appropriate maintenance practices for copies of vital records. The cooperation of agency program managers is important throughout the life cycle of vital records. Based on the contingency planning analysis and identification of emergency operating records and those needed to protect legal and financial rights, program managers must determine which records within their physical or legal custody are vital. Program managers, in consultation with the records management office, should then take steps to ensure that copies of those vital records are properly managed throughout their life cycle, as they are updated, stored, and cycled. In addition, original vital records must be properly maintained until their authorized disposition.
Earlier in this guide, in the discussion of contingency planning and risk assessment, certain functional areas were cited as important to those processes. Officials within those areas would have critical roles should an emergency or disaster strike their agency. IRM, ADP, and records management officials would carry out their duties in ensuring adequate telecommunications and information resources were available to conduct critical agency business.
Each agency should develop a vital records plan. The first part of the plan is a description of records that are vital to continued agency operations or for the protection of legal and financial rights. The plan also includes specific measures for the appropriate storage and periodic cycling (updating) of copies of those records.
The description of the vital records is based on identification and inventorying. Federal agencies may take the following steps to identify and inventory vital records:
Agencies must exercise caution in designating records as vital and in conducting the vital records inventory. A review of the available literature suggests that from 1 to 7 percent of an agency's records may be vital records. Only those records series or electronic information systems (or portions of them) most critical to emergency operations or the preservation of legal or financial rights should be so designated. Agencies must make difficult and judicious decisions in this regard.
The inventory of vital records should include:
The Nuclear Regulatory Commission directive on vital records found in appendix C provides an example of an approach for identifying and managing vital records.
Records likely to be selected as vital include:
Emergency operating records
This list is not inclusive.
Records needed to protect rights include:
This list is not inclusive.
After completion of the inventory, agencies must choose protection methods and storage sites for vital records. The former may include using existing duplicates of the records designated as vital or duplication of the original recording medium, whether it be paper, microform, magnetic tape or cartridge, or another medium. If performing duplication, it is generally most economical to duplicate the original medium to the same medium, that is duplicate microfiche to microfiche or magnetic tape to magnetic tape. Appropriate equipment should be selected to ensure the continued preservation of copies of the vital records until they are cycled. In addition, proper environmental conditions should be provided for copies of vital records, particularly for those recorded on such fragile media as microfilm or magnetic tape or disks, until they are replaced.
Given the importance of vital records, agencies should arrange for offsite storage of copies in a facility not subject to the same emergency or disaster but still reasonably accessible to agency staff. The storage site for copies of vital records varies according to its designated type. Whenever feasible, an agency should store copies of emergency operating records in a properly equipped and environmentally controlled emergency operations center. If an agency has not established such an operations center, it may store emergency operating records at a Federal records center (FRC) operated by NARA (see 36 CFR 1236.26 in appendix B of this guide). The agency should contact the FRC serving it to determine if the FRC has sufficient space to store the emergency operating records and, if frequent cycling of the records is required, what costs the agency may have to incur. An FRC is likely to initiate a reimbursable agreement with Federal agencies whose records require frequent cycling. Agencies should also be aware that if an emergency or disaster effects them, an FRC may not be able to make their emergency operating records available in as timely a fashion as if such records were stored in an emergency operations center.
Records needed to protect legal and financial rights may also be stored at any FRC. If such vital records are recorded on a medium other than paper, agencies should check with the center before initiating a transfer to ensure that environmentally controlled space is available.
Periodic cycling (updating) of copies of vital records is essential. The agency decides the frequency of cycling, based on how current its emergency operating records and records needed to protect rights must be to meet its information needs and responsibilities. Depending on those needs and upon the medium on which the vital record is maintained, cycling may occur daily, weekly, monthly, annually, or at longer intervals.
All agency employees assigned responsibilities in the vital records program should receive appropriate training. Periodic briefings should be given to senior managers, especially those new to the agency, about the status of their records in relation to the vital records program. Appropriate agency officials should ensure that employees receive training commensurate with the duties that they have been assigned in the program. Such training would generally focus on the identification, inventorying, protection, storage, and cycling of copies of the agency's vital records. Wherever possible it should be integrated with existing agency training initiatives, particularly in such areas as records management and emergency coordination.
The agency official(s) responsible for managing the vital records program should conduct a periodic review of it with other appropriate agency program managers. This review is intended to determine whether the agency's vital records are adequately protected, current, and accessible to the staff who would use them. This is particularly important should the agency's functions or activities change significantly. Such changes might require a modification of the vital records plan.
Federal agencies should periodically test their emergency plans and procedures to determine if the appropriate records have been identified to allow agency staff to function effectively in case of emergency. The agency official responsible for managing the vital records program should work with other agency test participants to assess the results of the test and to make appropriate modifications, where needed.
Agencies should develop suitable protective measures for their records and copies of their vital records to respond to actual or potential emergencies or disasters identified in contingency planning. This is the records management aspect of emergency management. Vital records are emphasized as they tend to have the greatest value in case of emergency or they require extra protection because they document legal or financial rights. The type and level of value determines the amount of protection agencies should provide. Special protective measures for vital records may include the use of fire-rated filing equipment for storage; on-site vaults; transferring records to offsite storage; duplicating the records at the time of their creation, such as computer "backup" tapes; using existing duplicates as vital record copies; or, microfilming vital records.
Additional protective measures are needed for Federal records maintained on a medium other than paper. These "special records" require specific environmental conditions and careful handling throughout their life cycle to ensure their preservation. Agencies must institute and maintain temperature and humidity controls for special records such as photographs and negatives, microforms, audio and video tapes and disks, and electronic tapes and disks.
When emergencies or disasters occur, however, even the best of protective measures may not prevent damage to records. Consequently, agencies need to develop records recovery plans to provide a means of responding quickly and economically to records disasters in order to salvage or replace damaged records and the information that they contain.
Agencies must be able to continue operations in case of emergency or disaster. Availability of critical information is key to continuation of operations. Consequently, agencies should ensure that responsible personnel are familiar with the records disaster mitigation and recovery program. Each agency should document the policies, authorities, responsibilities of agency officials, and the procedures governing the records disaster mitigation and recovery program in appropriate issuances such as functional statements and procedural manuals. These issuances should clearly assign responsibility for coordinating disaster recovery plans and activities. They should also designate other members of a disaster recovery team which would be activated in time of need. Agencies should ensure that this records disaster recovery program information is distributed to all appropriate staff members. Figure 1. provides a list of steps that agencies may find useful in planning for potential disasters.
In developing the records disaster recovery plan, agency officials should assess the varying intensity of each risk to which their records may be subject. Risks may range from minor flooding affecting perhaps only one or two offices in a facility to a major fire that may cause significant damage to the entire facility and its contents. Generally, water, fire, and smoke damage should receive particular attention as they are the likely agents that will damage records stored in an agency facility. If chemical agents are either stored in the building or are contained in its operating systems, the potential damage these might cause should also be addressed during the planning. For example, certain chemicals used in fire extinguishers adhere to records. Although use of these types of extinguishers may be effective in smothering the fire, they should not be used in areas where records are exposed. Agency staff participating in this planning should be those cited earlier in this guide under Contingency Planning and Risk Assessment.
The agency official responsible for managing the records disaster recovery program serves as its coordinator. This coordinator should work with other appropriate officials throughout the agency on the development and implementation of protective measures to mitigate potential records disasters. This official will also have primary responsibility for ensuring that an up-to-date records recovery plan is in place and available to all concerned personnel.
Program managers are crucial to the process of mitigating potential records emergencies or disasters. They should work closely with the official responsible for coordinating the records disaster recovery program and other appropriate agency officials in ensuring that agency staff are aware of and are executing appropriate protective measures for the records under their control. This is particularly important for electronic information systems where creation of backup data is an essential protective measure, or for other nonpaper records such as audiovisual records and microfilm. It is more economical to duplicate many of these media (particularly magnetic tape or cartridges) at the time of creation than to attempt to recover the sole copy of such items damaged in an emergency or disaster. Making copies of undamaged records also ensures that all data in the records will be available.
Each agency should prepare a records recovery plan to establish specific procedures for personnel to follow in the event that an emergency or disaster occurs. (See appendix D for an example.) The official responsible for coordinating the records disaster recovery program should work with such agency officials as the emergency coordinator, the IRM and ADP staff, facilities managers, and security staff in developing the records recovery plan. In addition, all other agency staff should be briefed on their general responsibilities should such an emergency or disaster occur.
The records recovery plan should provide details about the following processes: (1) instructions on whom to notify immediately in case of emergency to relate details about the nature of the emergency and the level of vulnerability of the records; (2) assessing the damage to records as soon as possible after the emergency and taking immediate steps to stabilize the condition of the records so further damage will not occur; (3) assembling a records recovery team of agency staff members to help in stabilizing the condition of the records (generally only for major records disasters); (4) consulting with contractors that provide records disaster recovery services if the damage assessment indicates the need for their expertise; (5) recovering the records and the information that they contain, or providing replacement of any lost recorded information when recovery is not feasible; and (6) resuming normal business using the recovered records and information. Figure 2. provides an outline of the components of such a plan.
Some additional points should be made about these steps. In assessing the damage done to records, determine what recording medium has been affected. Photographic negatives and microfilm that are water-damaged require different treatment than water-damaged paper records. Also, find out if the records carry any access restrictions. Only personnel with proper clearance should be allowed to handle them. Before beginning the actual recovery process, separate any damaged records from undamaged records, wherever possible, to speed up the process of repair and recovery.
A list of records disaster recovery specialists with their areas of expertise, addresses, telephone numbers, and an individual point of contact should be prepared and available before a records emergency or disaster happens. This list should be checked periodically to ensure that it remains accurate and current. Agencies should be aware that disaster recovery specialists often concentrate on assisting their clients with very specific problems. One recovery specialist may focus on the process of recovering water damaged paper records, while another may concentrate on recovery of water-damaged magnetic tape. Consequently, agencies should develop as broad a list of records disaster recovery specialists as possible in order to be able to respond to all the potential risks to which all their recorded media might be subject.
Agencies should also consider maintaining on-site certain equipment to help mitigate water damage to records. An example of such a list is found in appendix J of appendix D of this guide. Agencies may consult with NARA's regional Federal Records Centers and/or Regional Archives to obtain information about records disaster recovery plans. See Appendix A, Further Guidance and Assistance for a list of these facilities.
All agency employees should receive training appropriate to their records disaster recovery responsibilities. Briefings about the program should be directed to all employees and combined with other emergency preparedness activities devoted to such topics as fire drills or building evacuation drills.
Training should also be given to members of the records disaster recovery team, and any designated alternate members, so they may assist the official coordinating disaster recovery in time of need. At the minimum, team members could help in assessing the nature and extent of the records disaster, which records were affected, and the record media, so the recovery manager can report accurately on the disaster and recommend specific recovery steps for approval by the agency's senior managers. For example, if the volume of paper records damaged by water is manageable, the recovery team members may be able to take preliminary steps themselves to mitigate further damage and speed the recovery process.
The official responsible for coordinating the records disaster recovery program should conduct a periodic review of the records recovery plan with the assistance of selected agency officials to determine its adequacy and accuracy. This review should included the list of vendors (with telephone numbers, addresses, and other relevant data) that may have to be called upon in case of an actual records emergency or disaster.
The plan should also be periodically tested, much as are fire drills and building evacuation procedures. The test should involve members of the records disaster recovery team and include an evaluation of their activities as well as the usefulness and thoroughness of the recovery plan. Modifications to either the plan or to the responsibilities of the team should be made, as needed.
Appendix A. Further Guidance and Assistance
Appendix B. Regulations - 36 CFR 1236
aPpendix C. Sample Vital Records Directives
NARA does not mandate the format, organization, or design of agency issuances that implement the vital records and records disaster mitigation and recovery programs. The following vital records directives from two Federal agencies are provided as recent examples of agency internal issuances. Other agencies will decide how and where to incorporate the requirements specified in NARA regulations (appendix B) into their operations, and how to authorize and document these programs.
Appendix D. Sample Records Recovery Plan
As indicated in the introduction to appendix C of this guide, NARA does not mandate either the organization or format of agency issuances that implement vital records or records disaster mitigation and recovery programs. The following draft disaster plan recently formulated by the staffs of NARA's Southwest Regional Archives and Fort Worth Federal Records Center is provided as an example of a recent internal agency issuance. Other agencies will decide best how to document and implement their own records disaster recovery
Appendix E. Self-Evaluation Guide
Appendix F. Glossary