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SCHOLARSHIP VERSUS ECONOMY: RECORDS APPRAISAL AT THE NATIONAL

ARCHIVES

MARTIN I. ELZY

Scholars and genealogists often praise the

efforts of reference archivists who service the records available for research at the National Archives; occasionally even the archivists who describe the records in finding aids earn the plaudits of researchers. But those who use the nation's unique archival resources seldom consider the role of the appraisal archivists who determine which federal government records will be preserved as archives and which will be destroyed. The decisions of appraisal archivists determine irrevocably the raw materials from which the nation's past is reconstructed. Their decisions also reduce the amount of time spent by scholars shuffling through meaningless documentation. Yet few researchers are aware of the existence of a Records Appraisal Staff in the National Archives.1

'H. G. Jones, The Records of a Nation: Their Management, Preservation, and Use (New York, 1969), pp. 80-83; Paul Lewinson, "Archival Sampling," American Archivist 20 (1957): 291; Philip C. Brooks, What Records Shall We Preserve?, National Archives Staff Information Paper no. 9 (Washington, D. C., 1971), pp. 1-2, and "The Selection of Records for Preservation," American Archivist 3 (1940): 222; Theodore R. Schellenberg, The Appraisal of Modern Public Records, National Archives Bulletin no. 8 (Washington, D. C., 1956), p. 5. A valuable guide to records appraisal is found in Frank B. Evans, comp., The Administration of Modern Archives: A Select Bibliographic Guide (Washington, D. C., 1970), pp. 31-36. Evans also permitted the author to consult his manuscript of the revised edition of the bibliography, which will soon be published.

Records appraisers must serve two competing constituencies. Scholars and genealogists require that government records useful for their research be preserved; government cost analysts require rapid disposal of records that are no longer of use to the agency of origin. But appraisers must be sure that hasty disposal does not result in the loss of records that should be retained permanently.

By law "the head of each Federal Agency shall make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of the agency and designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities." While the agency is primarily responsible for designating such material for retention, appraisal archivists must monitor this agency function. Appraisers are further required by law to preserve records of "sufficient historical or other value to warrant their continued preservation by the United States Government." In 1956 archivist Theodore R. Schellenberg established the standards of records appraisal that still prevail in the National Archives system. In developing standards for appraisers,

2 United States Code, 1970, secs. 2103, 3101.

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Schellenberg suggested that records be chosen for preservation according to their evidential or informational value. Evidential value means that the records show the "organization, functions, policies, decisions, procedures, operations, and other activities of the Government." To judge evidential value archivists must know the place of each office in the administrative framework of the agency, the history of the agency, the functions of each office, and the national conditions with which the agency dealt. Records to be preserved by appraisal archivists' recommendations concern the origin of the agency, the formulation of substantive programs, and the execution of these programs.3

Records failing the test of evidential value might still be preserved for their informational value, Schellenberg argued, because government records contain data on persons, places, things, corporate bodies, and national conditions. He also maintained that if this information is unique and in an easily usable form, the records should be preserved. In general, the evidential value of records is easily determined; informational value is often the subject of dispute. It is imperative, therefore, that appraisal archivists be trained in historical methodology. Appraisers should also be familiar with current research interests and methods in order to estimate accurately the archival value of records.4

Schellenberg concluded that archivists must moderate between the scholar's desire to save records and the budget officer's desire to destroy records after their initial period of use. In order to do this work properly, appraisal, archivists must follow general principles rather

3 Schellenberg, Appraisal of Modern Public Records, pp. 146; Schellenberg, Modern Archives: Principles and Techniques (Chicago, 1956), pp. 133-160; Lewis J. Darter, Jr., "Data For Posterity: Objectives and Responsibilities of the NARS Records Appraisal Program" (paper delivered at the Interagency Records Administration Conference, Nov. 30, 1962, the National Archives), p. 5; Lewinson, "Toward Accessioning Standards-Research Records," American Archivist 23 (1960):

298.

4 Schellenberg, Appraisal of Modern Public Records, pp. 6-7, 22-44, and Modern Archives, pp. 139, 148-160; Meyer H. Fishbein, "A Viewpoint on Appraisal of National Records," American Archivist 33 (1970): 185-187; Fishbein, "The Archivist Meets the Records Creator," American Archivist 28 (1965): 195-197; Jones, Records of a Nation, p. 84; Darter, "Records Appraisal: A Demanding Task," Indian Archives 18 (1969): 3-4.

than exact standards, and even those principles must be flexible and must be applied with discretion. Nevertheless, any appraisal should be based on an extensive analysis of the records rather than on intuition of supposed contents. Schellenberg also suggested that appraisal archivists consult agency experts and independent scholars on the value of the records.5

Two sampling techniques were advocated by Schellenberg to reduce the volume of records: statistical sampling, which would result in retaining a representative sample of a large record series, and special selection, which would preserve uniquely important files from a series that could otherwise be destroyed. Paul Lewinson, a colleague of Schellenberg's, published in 1957 a more detailed explanation of the sampling techniques, pointing out that they were especially valuable in deciding whether to retain case files and regulatory agency information files. Usually, sampling records for their evidential value requires use of statistical sampling, while preserving records for their informational value requires special selection.6

Schellenberg's principles, which are based on the evidential and informational value of records, continue as the standard guide for records appraisal, and Lewinson's suggestions on sampling records are the basis of current sampling procedures. But appraisal of records is also influenced by the need to reduce the cost of records storage. During the past century the accumulation of federal paperwork has increased the pressure on appraisal archivists to destroy records of federal activities.

Throughout the first century of the nation's history no appraisal of federal records for possible destruction was allowed, but by 1872 the Treasury Department requested a hall of records in which to store its inactive files. Five years later a presidential commission decided that no federal records could be destroyed, and stiff penalties against destruction continued. In 1881, however, Congress for the first time

5 Schellenberg, Appraisal of Modern Public Records, pp. 44-46.

6 Schellenberg, Modern Archives, pp. 157-159; Lewinson, "Archival Sampling,” pp. 292-307. See also Carl J. Kulsrud, "Sampling Rural Rehabilitation Records for Transfer to the National Archives," American Archivist 10 (1947): 328-332.

authorized destruction of federal records. This departure from tradition was institutionalized in 1889, at which time Congress established a Joint Committee on Disposition of Useless Papers, to which agencies were to submit disposal lists describing the records to be destroyed. When the fledgling American Historical Association protested that scholars should have a voice in selecting the records to be preserved, the librarian of Congress was assigned the responsibility of reviewing the disposal lists, a task he carried out until the creation of the National Archives. The Bureau of Forestry proposed the first disposition schedule in 1907, a document permitting periodic destruction of selected record series by an agency without special authorization.7

Theodore Roosevelt was one of the first presidents to express concern about paperwork management within the government. His Presidential Committee on Department Methods suggested creating a national archival depository and seeking legislation to require appraisal of the historical value of documents before they could be destroyed. Both suggestions were finally adopted when the National Archives was established in 1934, and the archivist of the United States was authorized to investigate proposals to destroy government records and to present to Congress on the first day of each year a list of approved disposals.8

From 1934 to 1943 the National Archives appraised thousands of record series at the request of the rapidly multiplying New Deal agencies, but series-by-series appraisals without the benefit of generally accepted appraisal standards were inconsistent and time consuming. A 1935-37 survey of federal records by the National Archives also revealed that absence of uniform record-keeping practices in the government reduced its efficiency and made intelligent records appraisal almost impossible. The need for a comprehensive federal records management program was clear. In 1937 when members of the Society of American Archivists

"Henry P. Beers, "Historical Development of the Records Disposal Policy of the Federal Government Prior to 1934," American Archivist 7 (1944): 181-201; Emmett J. Leahy, "Reduction of Public Records," American Archivist 3 (1940): 28.

8 Harold T. Pinkett, "Identification of Records of Continuing Value," Indian Archives 16 (1965-66): 54-55; Leahy, "Reduction of Public Records," pp. 13, 29.

met for their first annual meeting in Washington, they regarded the appraisal of federal records as the most crucial archival problem confronting the profession.9

In October 1940 archivist Philip C. Brooks published an article that was to be the first major contribution to a comprehensive appraisal system. His most valuable suggestion was that archivists could greatly simplify the appraisal task by becoming familiar with the recordkeeping practices of each government agency. This idea won acceptance and has now become part of the procedure by which the National Archives and Records Service through its Office of Records Management supervises the creation, filing, and disposition of documents in each agency."

10

During World War II the volume of federal records multiplied and agencies sought relief by three methods. They raided the National Archives staff for records managers who could streamline agency record-keeping; they moved inactive files to warehouse storage; and they sought approval to dispose of masses of routine material. Congress assisted the agencies by passing the Records Disposal Act of 1943, which authorized the use of disposition schedules, such as had been proposed earlier by the Bureau of Forestry. Although the schedules were designed to save agency and appraisal time, few agencies took advantage of this new records disposal tool.11

To further promote the disposal of records, the Records Disposal Act was amended in 1945 to allow the archivist of the United States to use general schedules to dispose of certain types of records that are common to govern

9 Jones, Records of a Nation, p. 86; Robert W. Krauskopf, "The Hoover Commissions and Federal Recordkeeping," American Archivist 21 (1958): 372; Leahy, "Reduction of Public Records," p. 13.

10 Brooks, "Selection of Records," pp. 221-234; Brooks, What Records, pp. 1-4; Lewinson, "Toward Accessioning Standards," p. 297; O. Lawrence Burnette, Jr., Beneath the Footnote: A Guide to the Use and Preservation of American Historical Sources (Madison, 1969), P. 298.

11 Krauskopf, "Hoover Commissions," p. 373; Jones, Records of a Nation, p. 86; Isadore Perlman, "General Schedules and Federal Records," American Archivist 15 (1952): 27; Robert H. Bahmer, "Scheduling the Disposition of Records," American Archivist 6 (1943): 169-175; Pinkett, "Identification of Records," p. 55.

ment agencies. Twenty general schedules have been issued, which stipulate that certain records should be disposed of immediately, retained for a particular period of time and then destroyed, or retained permanently. Records that document the fiscal and administrative management of agencies can often be placed on general schedules, but agencies are permitted to decide whether to dispose of such records by this method. 12

The increasing emphasis on records disposal in the first decades of the existence of the National Archives was exhibited in a speech by G. Philip Bauer of the Division of Labor Department Archives at a National Archives conference on administration in 1944. Bauer questioned the very basis of appraisal standards by maintaining that appraisers should always consider the cost of retention when evaluating records. According to his cost-accounting guidelines no more than 1,000 cubic feet of the records in the National Archives Building were judged worthy of retention. Furthermore, Bauer criticized the existing procedure by which disposal had to be justified, saying that the burden of proof should rest instead on the advocates of retention. This proposal would have banished many valuable government records to oblivion. A number of archivists joined the discussion to dispute Bauer's contention that cost should be the major consideration in the appraisal of records. Herman Kahn, then chief of the Interior Department Archives Division, maintained that retaining records of the past was characteristic of civilized man and need not be justified by any monetary calculations. 13

After World War II the government turned its attention to the records management problem. The first Hoover Commission appointed a Rec

12 Krauskopf, "Hoover Commissions," p. 373; Pinkett, "Identification of Records," p. 55; Perlman, "General Schedules," pp. 27-29.

13 G. Philip Bauer, The Appraisal of Current and Recent Records, National Archives Staff Information Circular no. 13 (Washington, D. C., 1946), pp. 11-25; Minutes of Meetings of Open and Seminar Conferences on Administration, Aug. 28 and Sept. 11, 1944, Conferences, Councils, and Other National Archives Meetings, 1935-51, Records of the National Archives and Records Service, Record Group 64, National Archives Building.

ords Management Task Force that estimated in 1948 that 18,500,000 cubic feet of federal records had accumulated and that it was costing the government $1,200,000,000 per year to create and manage such records. As a result of the Hoover Commission report, the General Services Administration, which included the National Archives and Records Service almost from its inception, was created in 1949. A Records Management Division was immediately established within the National Archives, and the Federal Records Act of 1950 provided for a uniform, government-wide records management program and established federal records centers to receive deposits of semicurrent records. Archivists departed from the European tradition of dealing with records only after originating agencies were no longer using them and became actively involved in the entire life cycle of the records, as Brooks had suggested in 1940. Although the Korean War caused an increase in the creation of federal records, the National Archives and Records Service could claim that in fiscal 1953 the government's records management program had saved over $34,000,000. During fiscal 1954 the volume of federal records was reduced for the first time in the nation's history. And the optimistic report of records managers in 1955 was that disposal of 95 percent of all federal records was governed by disposition schedules or general schedules. 14

Despite these efforts to control the flood of government records, in 1961 the General Accounting Office issued a report stating that as of June 30, 1960, 24,500,000 cubic feet of federal records had accumulated, of which 18,000,000 cubic feet were being held by originating agencies. Of the remainder in the custody of the National Archives and Records Service, 5,000,000 cubic feet were in federal records centers, 800,000 cubic feet in the National Archives Building, and 300,000 cubic feet in unsatisfactory temporary space. The General Accounting Office suggested that a more selective appraisal policy be initiated and that large-scale microfilming of records be undertaken. Pointing out that microfilm requires only 8 percent of the

14 Krauskopf, "Hoover Commissions," pp. 377-379, 383386; Jones, Records of a Nation, p. 86.

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The response of the National Archives was the creation in January 1962 of the Office of Records Appraisal. That office immediately acknowledged that too many records were being retained permanently. It then reversed the former procedure of scheduling records for disposal by introducing the new device of records retention plans. Appraisers would now concentrate on identifying the less than 5 percent of federal records worthy to be kept permanently, and they would give prompt approval of agency requests to destroy the balance. 16

But over a decade later the General Accounting Office was still dissatisfied with the rate of disposal of federal records. A 1973 report revealed that government records holdings had reached 30,000,000 cubic feet, of which 11,500000 cubic feet were in federal records centers, where diminishing storage area had become a critical concern. The General Accounting Office found government agencies at fault either for placing records in the centers without setting a definite disposal date or for keeping them for unrealistically long periods. The National Archives and Records Service was criticized for permitting these practices on the part of agencies and for failing to destroy records promptly when retention periods expired. 17

The agency quickly reorganized to correct the problem. Part of the staff of the Office of Records Appraisal was transferred to a newly created Records Disposition Division under the jurisdiction of the Office of Federal Records Centers and located outside the National Archives Building. The primary function of this

15 General Accounting Office, Review of Certain Records Management Activities, National Archives and Records Service, General Services Administration, December 1961 (Washington, D. C., 1962), pp. 1-2, 5-6, 10-12, 16; Burnette, Beneath the Footnote, pp. 303-304.

16 Darter, 'Data for Posterity," pp. 1-4; Pinkett, “Identification of Records," pp. 55-56.

17 General Accounting Office, Ways To Improve Records Management Practices in the Federal Government, National Archives and Records Service (Washington, D. C., 1973), pp. 1-2, 5-6, 8, 18-29.

new division, indeed the reason for its existence, is to reduce government records holdings as speedily as possible in order to limit storage costs. Records Disposition Division officials are now the first to receive disposal requests from agencies, although their appraisal reports are forwarded to the five-member Records Appraisal Staff for approval. The Records Disposition Division staff also encourages agencies to review their records in federal records centers for more rapid disposal.

In addition to certifying the Records Disposition Division's disposal decisions, the Records Appraisal Staff also appraises records to decide which are to be kept permanently. This apparently awkward process by which one staff handles disposal and another handles retention is partially alleviated by daily contacts between staff members. The Records Appraisal Staff also has two other important functions. First, it disposes of records accessioned by the National Archives that are no longer worth preserving as archives. Second, it appraises papers offered to the National Archives by private individuals. Normally these offers are rejected because the National Archives function is to receive only federal records. The Records Appraisal Staff can often suggest a depository that is prepared to receive offered papers. Nevertheless, within the past few months at least two offers of private papers of American diplomats have been accepted by the National Archives by reason of their contribution to an understanding of related government records.

Because of the type of records they receive three archival units do their own appraisals, subject to the approval of the Records Appraisal Staff. They are the Cartographic Archives Division, the Audiovisual Archives Division, and the Machine-readable Archives Branch, which was created in response to scholarly demands that more statistical information be preserved. New technology has required new appraisal policies for automatic data-processing records. In 1963 the Social Science Research Council Committee on the Preservation and Use of Economic Data urged the National Archives and Records Service to preserve government economic data that is recorded on punched cards and computer tapes. A Data Archives Staff was created in 1969 and a temporary con

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