Federal Records Are to Be Stored in Three Types of Facilities; NARA Does Not Have Reliable Data about All Agencies’ Use of Records Storage Facilities

Federal agencies are to store records in three types of facilities: federal  records centers that are managed by NARA, agency records centers, and  commercial records storage facilities. NARA Federal Records Centers

As of May 2013, NARA manages 18 federal records centers located  across the United States. Each facility includes storage areas,  which NARA refers to as bays. As of May 2013, NARA had identified 18 records centers that  were being operated by six federal agencies or offices: the Department of  Energy, the Department of Veterans Affairs, the Federal Bureau of  Investigation, the National Geospatial-Intelligence Agency, the National  Reconnaissance Office, and the Transportation Security Administration’s  Office of Law Enforcement – Federal Marshal Records Center. Nevertheless, until  NARA ensures that it has complete, current, and valid data on agencies’  records storage facilities, it cannot be certain that agencies are using one  of the three types of authorized facilities. NARA Has Approved Almost All of Its Federal Records Centers as Compliant with Applicable Standards, but It Has Not Inspected and Validated the Majority of Agency and Commercial Records Facilities

In carrying out its responsibilities to store and archive federal records,  Title 44 of the United States Code authorizes NARA to establish,  maintain, and operate records centers for federal agencies; approve  agency records centers; and promulgate standards, procedures, and  guidelines to federal agencies with respect to the storage of their records  in commercial records storage facilities. Part 1234, specify the minimum structural,  environmental, property, and life-safety standards that a records storage  facility must meet when the facility is used for the storage of federal  records. NARA conducted inspections of 23 of its 24 federal records center  facilities from February 2005 through January 2013 and determined that  20 of the facilities were compliant with 36 C.F.R. However, the plan does not include a schedule for  completing these tasks consistent with standard practices for program  management. While NARA has stated that it plans to bring all of its federal records  center facilities into compliance with applicable regulations, the agency  has not established a schedule for doing so at all facilities. NARA Has Not Inspected and Validated Compliance for the Majority of Agency and Commercial Records Storage Facilities

Agencies must obtain approval from NARA to store federal records at  their own or a commercial records storage facility and, to do so, must  provide documentation to show that the facility satisfies the requirements   After a facility is approved, agencies are able to  of 36 C.F.R. Documentation that we reviewed for 55 incidents that  NARA reported as occurring from January 2009 through March 2013  indicated that the agency had taken steps consistent with its Emergency  First Response for NARA Records checklist. As a result, NARA is not  positioned to fully report on the effectiveness and outcome of its actions  to minimize damage to records and does not have an institutional record  that a third party can use to validate the results of its efforts. Storage fees charged by NARA in fiscal year 2013 were comparable to  fees charged by commercial vendors on the GSA schedule in that same  time frame. As shown in the table, NARA’s fee of $0.23 per cubic foot was consistent  regardless of the storage quantity. Specifically, NARA’s fee was higher  than fees charged by vendors 1 and 2, although its fees were lower than  those of vendors 3 and 5. Conclusions

Although federal regulations call for records to be stored in one of three  types of facilities—NARA-operated federal records centers, agency  records centers, or commercial records storage facilities—the extent to  which agency and commercial facilities are used to store records is  uncertain because NARA does not know where all agencies store their  records. As a result, NARA does not have a basis for  determining progress toward correcting deficiencies in those facilities that  do not fully meet the standards  Additionally, although NARA has taken steps to prevent permanent  damage to records in their facilities on a total of 55 occasions over a  recent 4-year time period, the federal records centers did not always keep  track of the results of their efforts and were unable to provide  documentation confirming they were successful in 9 cases. Appendix I: Objectives, Scope, and Methodology

Our objectives were to (1) determine the types of facilities agencies use  to store federal records and the extent to which NARA’s data on  agencies’ use of storage facilities are complete, (2) evaluate the extent to  which NARA has determined these facilities to be compliant with  standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has  taken to minimize damage to records in federal records centers and the  extent to which it documents such efforts, and (4) determine how NARA  determines storage fees and whether fees differ among facilities. Part 1234.
Why GAO Did This Study

NARA manages the Federal Records Centers Program, which is to ensure the storage and preservation of federal records, including paper, photographic, audio, video, and film. Records storage facilities are required to meet certain minimum structural, environmental, property, and life safety standards set forth in federal regulations.
GAO was requested to conduct a study of key aspects of the program. GAO's objectives were to (1) determine the types of facilities agencies use to store federal records and the extent to which NARA's data on agencies' use of storage facilities are complete, (2) evaluate the extent to which NARA has determined these facilities to be compliant with standards in 36 C.F.R. Part 1234, (3) determine what actions NARA has taken to minimize damage to records in federal records centers and the extent to which it documents such efforts, and (4) determine how NARA determines storage fees and whether fees differ among facilities. To do so, GAO obtained, analyzed, and corroborated documentation on records storage facilities, identified and compared records storage fees, and interviewed NARA officials.

What GAO Found

Agencies are to store federal records in three types of facilities:
Federal records centers : The National Archives and Records Administration (NARA) operates 18 federal records centers that are comprised of 24 facilities (buildings) located across the United States. Each facility includes storage areas, referred to as bays.
Agency records centers : Agencies also establish and operate records centers for storing their own records. As of May 2013, NARA had identified 18 agency records centers that were operated by 6 agencies or offices.
Commercial records storage facilities : Agencies also use private sector commercial facilities. As of May 2013, agencies reported that 12 vendors provided 22 facilities, which were used by 11 agencies.
These facilities notwithstanding, NARA does not know where all agencies are storing records. NARA has solicited data from agencies about their use of agency records centers and commercial records storage facilities, but not all agencies have submitted data. Further, the data agencies submitted--mostly from 2008 and 2009--are now outdated. As a result, NARA cannot be assured that all agencies are using one of the three types of authorized facilities.
NARA determined that 20 of its 24 federal records center facilities were fully compliant with 36 C.F.R. Part 1234 because all of their bays satisfied the regulation; of the remaining 4, 2 facilities with inadequate shelving were partially compliant, 1 facility with insufficient protections against pipe leaks was not compliant, and the remaining facility was to be replaced. As of July 2013, NARA had plans to bring these 4 facilities into full compliance, but did not have a schedule for completing the plans at 2 of the facilities. As a result, NARA does not have a basis for determining progress toward correcting deficiencies in those facilities that do not yet fully meet the standards. Also, while NARA had approved 10 agency records centers and 22 commercial records storage facilities, it has inspected 1 of 18 agency records centers and 13 commercial records storage facilities. Until NARA completes planned inspections of all remaining facilities, it cannot be reasonably assured that agencies are storing records in facilities that meet standards.
To facilitate the protection of federal records from permanent damage, NARA had generally taken steps consistent with a checklist it requires federal records centers to follow when incidents (e.g., roof or sprinkler leaks) occur. However, it did not always document the results of its efforts to minimize damage because the checklist does not include a step for doing so. Specifically, of the 55 incidents that occurred from January 2009 through March 2013, NARA provided documentation about the final outcome for 46 incidents. For the remaining 9 incidents, it could not provide documentation that included the final results of its efforts. Without a process that includes documenting the results of its efforts, NARA is not positioned to fully report on the effectiveness of its actions to minimize damage to federal records and to provide a third party with information to validate the results of its efforts.
Storage fees are determined by NARA's Federal Records Centers Program and the Office of the Chief Financial Officer using the existing fee schedule, expense projections, and workload projections. The storage fees charged by NARA in fiscal year 2013 were comparable to fees charged by commercial vendors in that same time frame. For example, NARA's fee of $0.23 per cubic foot was higher than fees charged by two vendors and lower than fees charged by two other vendors.

What GAO Recommends

GAO recommends that NARA (1) obtain complete data on where agencies are storing records, (2) develop a schedule to bring noncompliant storage areas into compliance with 36 C.F.R. Part 1234, and (3) establish a requirement to document the results of efforts to minimize damage to federal records. NARA concurred with the recommendations.