FIRM is a voluntary association of Federal Information and Records Management professionals dedicated to improving the efficiency and effectiveness of information management throughout the Federal government. We, the Board of Directors of the FIRM Council, hereby urge you to ensure adequate and ongoing institutional support to maintain, enhance, and broaden the implementation and scope of DoD STD 5015.2. It is our professional opinion that STD 5015.2 is a critical enabler of a "government that works better and costs less." In our view, no information technology investment is more important.

On April 11, 1997, a DoD Directive was issued which mandated that components acquire only certified electronic records management software in compliance with the specifications outlined in STD 5015.2. The STD 5015.2 sets forth mandatory and optional baseline functional requirements for Records Management Application (RMA) software in the implementation of records management programs. The Defense Information Systems Agency's Joint Interoperability Test Command testing facilities in Fort Huachuca, AZ have been providing the testing and certification of RMA software. The abilities and capabilities of the testing laboratories and the upkeep of the STD 5015.2 are essential functions and require continuous funding, support, and maintenance.

It is important to note that STD 5015.2 has importance outside of DoD. Other Federal agencies utilize this standard as the baseline requirement for managing records. The National Archives and Records Administration (NARA) officially endorsed the use of STD 5015.2 for use by other Federal agencies in November 1998. The Association of Records Managers and Administrators (ARMA), International, is pursuing an enhancement of STD 5015.2 as an industry standard. Australia has proposed the adoption of a similar set of specifications as an international standard for records management. The advantages of using certified RMA's are undeniable and the establishment of the DoD standard 5015.2 by OASD C3I has been well justified. Therefore, continuous support and adequate funding are critical for the maintenance, improvement and development of the standard; the testing/certification facility; and the necessary personnel.

As the pace of commerce and governmental business processes quickens in the new millennium, it is essential that we capitalize and continue to build upon the baseline established in STD 5015.2. We urge you to exercise the authority vested in your office through statutory mandates such as those highlighted in Attachment A. With reference to OMB Circular A-11, we also urge that "Records Management and Public Access" be established as an essential Mission Area for all agencies in Exhibit 53 and that STD 5015.2 be identified in Exhibit 300B as a standard for which noncompliance should be expressly justified.

The FIRM Council is deeply concerned about the consequences of inadequate funding for the STD 5015.2 and testing facility. Some of those consequences include: a) reduced capabilities to evaluate, test and certify RMA products, thereby making it more difficult for agencies to comply with Raines' Rules; b) loss of the ability to implement necessary updates and desirable enhancements to the Standard; and, c) ultimately, the acquisition by Federal agencies of systems that fail to meet the logical, legal, and technical requirements for records management. To avoid those consequences, we urge continuous support for STD 5015.2 and suggest an immediate review of current and future funding allocated to this initiative. Management of electronic records is an important issue today and will be increasingly critical in the future. Effective leadership and adequate funding are essential.

We issue this challenge and offer these suggestions respectfully and sincerely in the hope and expectation of continuous improvement on behalf of our common stakeholders, the citizens of the United States of America.

Sincerely,
 

Some Statutory Provisions Relevant to Institutional Support for the 5015.2 Standard for Electronic Records Management Systems

The Secretary of Commerce shall:

... promulgate standards and guidelines pertaining to Federal computer systems... [and] ... shall make such standards compulsory ... to the extent ... necessary to improve the efficiency of operation or security and privacy of Federal computer systems... [40 USC 1441(a)(1)]

... develop uniform standards and guidelines for Federal computer systems ... [15 USC 278g-3(a)(2)]

... have responsibility ... for ... technical, management, physical, and administrative standards and guidelines for the costeffective security and privacy of sensitive information ... [15 USC 278g-3(a)(3)]

... any information, the loss, misuse, or unauthorized access to or modification of which could adversely affect the ... conduct of a Federal program... [15 USC 278g-3(d)(4)]

... any equipment ... used in the automatic ... storage ... of data or information ...  [15 USC 278g-3(d)(1)(A)]

... a computer system ... that processes information ... to accomplish a Federal function ... [15 USC 278g-3(d)(2)]

... as requested, to provide to operators of Federal computer systems technical assistance in implementing the standards and guidelines ... [15 USC 278g-3(b)(2)]

... to coordinate closely with other agencies ... including, but not limited to, the Departments of Defense ... to assure ... that standards ... are consistent ... with .. procedures ... for the protection of information ... [15 USC 278g-3(b)(5)(B)]

... effective controls over the creation and over the maintenance and use of records in the conduct of current business ... ⁽¹⁾ [44 USC 3102(1)]

... cooperation with the Administrator of General Services and the Archivist in applying standards, procedures, and techniques designed to improve the management of records, promote the maintenance and security of records deemed appropriate for preservation, and facilitate the segregation and disposal of records of temporary value ... ⁽²⁾  [44 USC 3102(2)]

... all ... documentary materials, regardless of physical form or characteristics, made or received by an agency ... in connection with the transaction of public business and preserved or appropriate for preservation ... as evidence of the ... activities of the Government or because of the informational value of data in them ... ⁽³⁾ [44 USC 3301]

... the production or reproduction of any record ... ⁽⁴⁾ [44 USC 2901(3)]

... disposal of temporary records no longer necessary for the conduct of business ... ⁽⁵⁾  [44 USC 2901(5)]

establish standards for the selective retention of records of continuing value, and assist Federal agencies in applying the standards to records in their custody...  [44 USC 2905(a)]

... assist the Administrator for the Office of Information and Regulatory Affairs in conducting studies and developing standards relating to record retention requirements imposed on the public and on State and local governments ... [44 USC 2905(b)]

2. The distinction between records deemed "appropriate for preservation" and those of "temporary value" highlights the fact both are records. Even the most ephemeral records are records for as long as they exist.

3. Note the distinction between "preserved" and "appropriate for preservation". Information is a record for whatever period of time it persists, regardless of whether it is appropriate for preservation or not. The mere fact that it exists makes it a record. Furthermore, information that is appropriate for preservation does not lose its record status just because it has been destroyed.

4. Copies of records are themselves records and should be treated as such, particularly if they are sensitive.

5. Length of retention does not determine "recordness"; business requirements do, including the need to protect the interests of all parties to the conduct of Federal programs.