INTERAGENCY RECORDS ADMINISTRATION CONFERENCE REPORT OF FIRST MEETING, 1953-1954 SEASON OCTOBER 16, 1953
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INTERAGENCY RECORDS ADITINISTRA.TION CONFERENCE
Report of First Meeting, 1953-1954 Season
October lo, ;1953 ,;
RECORDS MANAG-CTMENT IN AGENCY LIQUIDATION OR REDUCT TON
Presiding: Mr. Arthur E..Young, General Services Administration
Panel Speakers:
Mr. Charles F. Fridrich, National Production Authority
Mrs. Dorothy M. Luttrell, Internal Revenue Service,
Treasury Department
Mrs. Alice Ritter, Recpnstruction Finance Corporation
Mr. Joseph F. Vaughan, Office of Defense Mobilization
This report is distributed for the Interagency Records Administration Con-
ference by the National Archives and Records Service, General Services
Administration. For further information write or call James E. Cole, Jr.,
Conference Secretary, Code 1.51, Ext. 5183.
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INTRODUCT ION
Mr. Arthur E. Young
Good morning ladies and ,gentlemer. We welcome you to the first regu.llnr
meeting of the Interagency Records Administration Conference for the 193-54
season. We would like to remind rou that we have been attempting to brim-, our
mailing list up-to-date. '.',We would like for you to send in any revisions as soon
as possible to the Secretary, so that our mailing" list will be accurate.
Changing conditions in government will continue to impose varying degrees
of adjustment upon most Federal agencies. Many agencies are even now faced with
problems of one phase or another of liquidation or reduction. As a means of
assisting such agencies to prepare for prompt, orderly, and economical liquidation
or reduction of their activities, the IRAC steering committee has planned today's
meeting, "Records Tolana gement in Agency Liquidation or Reduction."
want to keen this mmorning's discussion devoted to consideration of
principles, policies and procedures. In selecting our panel we tried to get
persons who either currently are in the process of having liquidation problems
or have been through the mill. The device we are going to use is to have one
panel member interrogate the other three panel members who will attempt to
answer the questions. O r interrogator is, IIrs. Alice Ritter, Records Officer
for the Reconstruction F i.nance Corporation, an agency in the process of liquida-
tion. The first panel member Mr, s. _P.' '1ter will question, w i_ll be r:"rs. Dorothy
Luttrell, who is with us this morning in her capacity as former Records Officer
of the Office of Price Stabilization which was liquidated last June 30th.
Questions w:i.ll than be directed to T~Tr. Charles Fri_drich, of the Nal-,ion:al Pro-
duction Au.tllority, repr!:'.: Cnt i.ng a grealtl~,y reduced agency l%hi=Ch is being trans-
ferred to the Business and Defense Services Administration of the Commerce
Department. Then we have ,'rlth us the l ormer chairman of ISAC, Mr. Joseph ?au.ghan.
He is with the Office of Defense T.Tobi.li.zation, which has become a recipient agency
of liquidated functions and records from NSRB, Office of Rent Stabilization, and
DPA. At this time I, would like to turn the discussion over to our interrogator,
Mrs. Alice Ritter, of Reconstruction Finance Corporation.
ITrs. Alice Ritter
Thank you, Mr. Young.
I should like to preface this morning's discussion ,,rith a little e-.rcerpt
from a recent Reader's Digest article entitled, It as a Long V-- "Perhaps
it will be files, not insects that tiri_ll destroy the human race. it has been
estimated that the salaries of Federal Employees who are engaged in records
handling totals more than 1?;680,000,000 a year. The records themselves occupy
space equivalent to 6 Pentagons. T understand that it tales 10 tones of paper
to build a battleship, purchase orders, bluelrints, :=roricing papers, prcgress
reports, priorities, etc. The sad thing is that when they scrap the battleship
they don't s ink the file wl th it." That was good news for us in RFC, since we
don't have any battleships.
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To start, must we assume plans for liquidation or reduction can be carried
out most rapidly and economically only if bac'k:lo;s of work have been eliminated
in advance and if program and administrative functions are operating on a current
basis--in short, only if an effective management program is already in working order?
Mrs. Dorothy M. Luttrell
You are entirely correct, this. Ritter.
Mrs. Alice Ritter
What is our first step, in a liquidating agency, that the records officer
must take to discharge his responsibilities. In RFC I have felt that, first,
a prospectus must be developed by the records management staff of what will have
to be done with some indication of the timing contemplated. Just what would
your approach be with the agency operating and housekeeping officials?
Mrs. Dorothy M. Luttrell
Yes, the general plan must be developed early. Since we are talking about
a hypothetical agency I would like to speak in generalities for just a moment.
This hypothetical agency that is going out of business is faced with four major
problems, the separation of people, the closing out of fiscal accounts, the
liquidation of property, and the retirement of records. In my opinion, the dis-
position of records is the most complex, the most time-consuming and its impor-
tance least understood. The property and the people may go, the accounts trans-
ferred intact to Treasury, but a substantial portion of the records must live on
as concrete evidence of the programs and functions of the agency. I would. hope
that this hypothetical agency v,m uld have realized long before the blow falls
that it is the type of agency which might not live on forever and that preliminary
planning for the end would have started near the beginning. This is especially
true in the records management area. A comprehensive records management program
for an agency, which is marked for liquidation, should consider the ultimate
disposition of all records at the beginning of the program and their plans
should be made accordingly.
Regardless of whether or not preliminary planning has been done, when the
ax falls, you must immediately develop a comprehensive program of records
liquidation. Of necessity this program must be a comprehensive plan for the
disposition of all records of the agency by some pre-determined date. I believe
that the initial approach of records management people should be to present to
the top management officials, to the director, or to a liquidating officer (if
one has been appointed) a concise summary of just what records liquidation means,
what are the problems, what is the scope of the records liquidation and just how
you would go about it. This plan should include a concise statement of legal
and regulatory requirements--not only laws governing records but also laws under
which the agency operates. It should also include a list of necessary agency-
wide pre-liquidation activities, such things as a freeze order which will control
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the unauthorized disposal or removal of Federal records, the selective preserva-
tion of valuable records, the disposal of temporary records Which have outlived
their usefulness, the retirement and storage of the balance and also the transfer
of certain records to a successor agency which is absorbing specific functions.
This summary should also include a statement of personnel requirements; agency-
wide personnel requirements for the records liquidation job--not only the number
of people but the number of people for different kinds of progressive liquidation
of records. You should also attempt to include target dates, i.e., dates by which
certain stages of the records liquidation program should be completed.
After this summary has been presented to the top officials and has their bles-
sing and approval, you should an.nproach the program and housekeeping officials in
exactly an opposite manner. In the approach to program officials, you should
emphasize the necessity for the preservation of the valuable records that they
have created as the result of their important part of the program. With house-
keeping officials you emphasize disposal. In dealing with these officials, of
course, welcome their suggestions and welcome their contributions to the records
liquidations program., but very early in the game I would su^gest that you make it
clear to them beyond the shadow of a doubt that the final decision of the liqui-
dation of records rests with the records management people,, not the operating
officials.
Having established this coordination of effort within your own agency,
wouldn't it be well then to bring in those other Government agencies zvaho must
give us clearance and assistance in the retirement of the records, that is GSA
which provides custody for them and later disposes of scheduled material, and the
General Accounting Office, which must give clearance for the handling of the
fiscal records?
Mrs. Dorothy M. Luttrell
Most definitely bring them in at the earliest possible date. They can give
you invaluable assistance both from the standpoint of advice and actually helping
you. They should be consulted in connection with this records liquidation plan
that I have mentioned. If at all possible it would be a good idea to have them
review that plan before you ever present it to the top officials. Most definitely
bring them into the picture just as quickly as you can. T!r . Vaughan, you have
been on both sides of the fence. I am wondering whether or not you would agree
with me.
Mr. Joseph F. Vaughan
Yes--and any other agencies which might have responsibilities. If I may
move away a little bit from our hypothetical agency, and be rather specific and
perhaps personal, there are a number of instances where the Office of the Defense
Mobilization, although it has not been the successor agency in the true sense
of the word, Apprbecause or Release overriding -D'70-0021' Rfoffo uu 3-~ planning
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including the stabilization area, has had a definite concern. In the last month
or so that OPS was liquidating, for example, we had an occasion to get together
on a number of specific instances. Then quite recently in the co.se of the ORS
and its predecessor, the Office of the Housing Expeditor, we were asked to concur
in the disposal schedules that had been prepared in previous -periods and we did
that, as the agency having the greatest concern in the records, although we were
not the successor.
llr-s. Alice Ritter
Mr. Fridrich, how about those cases where there is a successor agency to
liquidate the rag tag end of this almost defunct organization? It must fit in
this picture somewhere, both from the standpoint of courtesy and the job that
it will have to pick up.and carry on to completion.
Mr. Charles F. Fridrich
There are, of course, all kinds of successor agencies, ranging from those
which succeed. to most of the functions the first agency had, to those who get
only a segment of the original charter.
I think we can generally assume that a new organization will be unfamiliar
with the substantive problems and with the records. As a general rule the new
agency should start its new files, and not try to add to those it inherits. Of
course; it would want to use the older files, but try to get a new set established.
I also think the old agency should provide the successor with an inventory
of its records. As many of you knowrr, I have been allergic to inventories of
files. I have considered them necessary to prepare records disposal schedules,
being always able to make my schedules directly.
Along with that inventory you will want explanations of some of the
procedures under which the records were created so the successor group can
adequately review the files and make determinations as to disposal. With this
information at hand executives can sit down and adequately review and determine
how and where the ends come together. Not until you have completed the records
inventory should you go to the liquidating group and expect to make sense to
them. You cannot talk to them with any knowledge and brief them in any gray
without such a background as it would provide.
Mrs. Alice Ritter
1,7W'ell, truthfully I think if I follow your advice in RFC that you will work
me to death.. How about telling me more of the selling job needed for the top
echelon? They have got to give us the green light. The plan could bog down if
they are not going to cooperate. Is there anything we can do in this area?
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T-Ir s.Dorothy M. Luttrell
Yes, there are many things we can do. 1V r personal experience along this
line was a very pleasant one. I had no selling job to do with the top echelon
at the time of liquidation, since the selling job was done at the time the
? agency was created. A comprehensive records management program was recognized
by top officials of the agency as a necessary tool of administrative management
from the very beginning. So we didn't have to sell records liquidation. It
? was just a part of the over-all records management prop-ram. The selling job
that I had to do' wasn't the top echelon but selling the second echelon. Dur-
ing the liquidation period the agency director was hacking, me up completely.
That was true thoughout the program. Not only did our records management pro-
gran have complete backing from top manag ement, but we also lh?ad then blocking for
us--their were right out in front when the going was rough. As I say, my exper-
iences were very pleasant, but if you have not been that fortunate and are facer'
with selling the entire program at the time of liquidation you will have to make
top echelon aware of the importance of the job, aware of the enormity of the
job, the huge volume of records, the vast amount of time that it takes to handle
the records. They will need to become aware of the legal and regulatory re-
quirements--the requirements of law which must be met. Then you will have to
impress upon them the relationship of cessation of activities to the liquidation
of records. That was the hardest job that we had to do. You cannot have
business as usual, with everybody creating records and everybody using the
records when you are retiring those records. They must schedule the cessation
of program activities so that you can schedule the retirement of the records of
those various programs. One of the best ways of selling records liquidation
(and this was as I mentioned, selling to the second echelon) was ?,o develop
a schedule of records linui.dation_ projects in ,rhich :re listed every individual
records liquidation tas'::, estimated the man days required to complete the project,
and established tentative completion dates. When operating officials saw this
schedule, they were amazed at the enormity of the problem. Then we carried this
presentation one step further. ',7e prepared a chart of these individual projects,
listing their completion dates and showing the progress made week by week. That
chart was taken to the D irdctor's office every Monday morning and he oiled his
top staff people to discuss it. I night say that on sellins' the records liqui-
dation program to what I call the second echelon, we had two types of people to
deal with. We had the ostrich type--the Division Director who stuck his ',,lead
in the sand and said, "z+re are not going to be liquidated in spite of what the
President said."' There were a great many people like that, who refused to
recognize and cope with the nasty word liquidation; And then we had the other
type, the overly enthusiastic type--the well meaning. I am sure that most of
them were sincere snit a few of them were anxious to climb on the records
management band wagon. They felt that records liquidation would continue
long after the program ended and if they could help the records people they
would have a job for 2 or 3 morths longer. So if you have that trouble, it
is more complicated than just a selling job. After you have the program sold
you have to control it.
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Mrs. Alice Ritter
Well, let us say we are in the business now of going out of business. Sev-
eral of the programs are being transferred to another agency. The law says
nothing about what records shall be transferred. I knun some of these receiving
agencies don't want anything but strictly current records. Mr. Vau;han, did
you ever. come up against anything like that?
Mr. . Joseph F . Vaughan
There is one point we must face if we are to be realistic. That is the
rather astonishing relationship betty: on the retirement of records and reduction
in force.
In some cases agency "X" has been abolished, and its records, functions,
property, etc., transferred intact to another agency - "Y". And that makes
sense. It is generally agreed that functions will be continued. And then
agency "Y" suddenly is alerted to the fact that these people are going to
bump their people. They say, we won't let this happen." And so you do have
a very tough job ahead of you. The terminology of executive orders on reorgan-
ization plans usually read: "that portion of the records or personnel, that
shall be mutually agreed upon as being necessary to carry on the functions
that are to be carried on are hereby transferred." You get records, but fre-
quently you don't get any records people or anybody that knows anything about
records. All of this complicates the situation. Of course it depends on how
big your volume is and so on. In a number of cases with which 0DM has been
concerned we have had the advantage, at least temporarily, of securing the
services of people who maintained and managed the records in the predecessor
agency. In other cases records have been transferred to us along with the
operating people for the function. I cite particularly the Stock Pile opera-
tions program of the Munitions Board which came to 0DM by Reorganization Plan
Number 3. By and large your management and administtati.ve people want only
current records. I will grant you that. These days it is true more than ever
before, because you find most agencies running on a shoesi;r_ng budget and
although functions are transferred ;Are find it necessary to carry on all of the
functions or part of them with fewer people.- So vre don't want to be encumbered
with noncurrent records or records which have no bearing upon that portion of
the program which may be in our hands for liquidation of for indefinite con-
tinuation. After all, GSA is set up to take noncurrent files. I don't think
there is anything more that I could say on that particular thing, except once
more to emphasize the relationship of this problem and that of economy. There
is a reluctance on the part of agencies recieving functions to have to reckon
with a records problem that- seems in the far distanct past. In the case of
the Office of Rent Stabilization, for example, we were certainly delighted to
find out that most of its records had been scheduled and had been picked up by
our GSA friends in Region 3 so when we sent a team over to "case the joint" at
Midway Hal:L we found that most of the rooms were empty and ^re all came back and
Fewer than 70
said the problem wasn't anything like what we thought it was.
file cabinets were actually transferred. As it looks now, the rent operation
will be entirely in the hands of GSA in a matter of a few months.
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Mrs o Alice hitter
"What about the active records of unliquidated assets? They undoubtedly
will have activity for a long period of time and a decision has to be made
about their fate. r ?r, Fridrich, can you help me on that one?
Mr. Charles F. Fridrich
The most helpful aid in this area I found to be an old Bureau of the
Budget management bulletin, "Agency Liquidation or Reduction: h Procedural
Guide," published in 1945. 1 would like to see the Records"T:anagement Division
of GSA work it over and bring it up-to-date. Perhaps as an exhibit to the
proceedings of this meeting that portion of the pamphlet dealingwiLti fiscal
activities could be reproduced. (See t'DTIBIT 1)
1,1r, q. Alice Hitter
Do we have any problems with records of programs which are liable to be
reactivated at a later date?
`Jr. Charles F. Fridrich
There are two problems here, it seems to me, with which we will have to be
specifics For example, the I.1PL, organization has evolved to the point where th.c
Defense activities program has gone down hill, ',There we formerly had 5,000
people carrying it on, we now have ap;-)rox{inately 300. There are, however, some
new activities in the %cfer:se , ro ra a., These new programs must use the records
built up under the former Defense programs. Therefore, you have to go further
to determine what records should be kept or should be retired.
Iv ow we talk "program" very loosely. It is a term people throw around, re-
gardless of level, hut I want to impress one thing: a program to one part of
an organization may merely be an activity in another. So you have got to get
down to the activity level to determine what records are to be kept. In order
to analyze that you have got to first of all determine what are the activities,
Then, which are going to be continuing, what records must be transferred to the
succeeding group or what records must be preserved in retirement for an event-
uality that may or may not come; namely, in our case, another war and the re-
su.lting need for data on our Whole industry. Getting down to the activities,
I found it best to list them on one side of a piece of paper, and opposite them
list the pertinent records. For example, we have a priority program. 4e also
have priority policy records. sje need not keep, probably, the case files of
individual firms, Then you must go into your other areas. ?vhen we conduct
select critical deficiency studies, there is a big statistical operation. In
our last effort we had millions of records concerning requirements. How much
steel a clan needed, how much columbium? The answers to questions like those
will determine the types of records you must keep in the event a requirements
program should be reactivated by the Congress.
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Mrs. Alit Ritter
You are overlapping a little into mygnext question. This is one that I
had for Mr. Vaughan. I wanted to discuss with him the records of programs
that have :Long since been completed and tI'n again maybe the liquidating agency
wouldn't need them. There are no assets tb be disposed of and they have been
stored because they have been valuable for research purposes. Who will deter-
mine their fate? The abolished or the li.grii_dati_ng agency?
117. Joseph '. Vaughan
?sell, I think wherever possible the abolished agency, prior to its aboli-
tion, should make a decision on records of that kind. They are the people
who created them and know something about them. If all had been well as far
as the records situation in agency "X" is concerned one would assume that pro-
visions for the eventual retirement of these records would have been made. It
is very difficult for a third agency, even when it is a successor agency to do
as good a job with that sort of a thing as the initial agency. What does compli-
cate the matter though, is that you have some programs that are being carried
on. My inclination at the moment (and frankly I haven't come to a firm decision
nor have I developed a way to meet it) is this: As you take on a certrein program
and are charged with carrying out certain functions, those records needed by the
successor agency you merely inventory and identify in their new home as "records
of the new agency and its predecessor agency" (agency "X"). I think all of those
that are not necessary to carry on a function should have their fate determined
by the liquidating agency.
Mrs. Alice Ritter
I am sure being inventoried to death this morning. Mrs. Luttrell, You
helped a little while ago on the GAO people. It us bring fiscal records in the
discussion again--those needed and required for an "on site" audit. Wliat dis-
position is made of these since according to GAO regulations they cannot be
placed in Records Centers without GAO permission. What do we do about that?
Mrs. Dorothy Luttrell
You are referring to GAO Regulation 115. As I recall, GAO Regulation 115
provides that when an agency is under site audit, records of the fiscal year
which have not been audited plus the records of the previous fiscal year which
have been completely audited shall be retained by the agency. In other words,
you will always have two fiscal years' records on the floor. The regulation
further states that records which have been site audited and for which you have
written notification that the site audit is completed, may be transferred to a
Federal Records Center with the written approval of the Comptroller General.
-8-
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You may have this written approval on a continuing basis. li'Well, obviously if
you go out of business something must be done about the records which still await
completion of the GAO audit. The only thing to do is to arrange a conference
with GAO and Treasury officials just as soon as possible and decide what is to
be done about such files. They are most cooperative and they will be very real-
istic about your problem.
Mr. Arthur E. Young
We have experienced with several agencies difficulty in getting the house-
keeping people to realize that such an arrangement was necessary. It is es-
pecially important where you have an agency with a far flung empire with field
offices. Now we know that, especially with OPS, the field office fiscal records
have poured down in an avalanche and now they are available for the GAO auditors.
That is why it is important to get your instructions out to your people carefully
prepared on how to get the records so they are just not tossed into a box and
sent unarranged to the Center. So it is very important to get that agreement.
Al Humphrey of GAO and Everett Alldredge in the National Archives and Records
Service can help on it.
Mars. Alice Ritter
We will now have to buckle down to some actual retirement. The records are
all inventoried. By diligent application of the general schedules, we could
make orderly retirement to the Records Center of a large number of housekeeping
files labeled for disposal after a certain retention'period. Mr. Fridrich,
what about these Centers and their facilities space wise and tl~eir assistance
in labeling and boxing preparation of the shelf lists and the actual moving of
the records?
Mr. Charles Fridrich
As to their facilities and space, I cannot give you concrete figures, but
I can assure you they have taken everything we could shoot at them, even to
the extent of several thousand cubic feet at one shot. Evidently they have the
space. It is available. It can be used. As for the assistance in labeling
and packing, you will find GSA most cooperative, at least that has been my
experience. Records Center personnel have been detailed to us when we were in
jams and had to work fast to do the boxing and labeling. The actual moving was
very easy. We made our shelf list and we called the Federal Records Center to
pick un the records. We got our accession number and I immediately forwarded
copies of the shelf lists that they desired, usually an original and two copies.
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That is going to help a lot. Now, we have got to develop new schedules
for those substantive categories that we have never before considered for dis-
posal or retirement. Our staff probably by this time will be insu 'fi_cient to
cope with it. I-dhat could we do about than Mrs. Luttrell?
Mrs. Dorothy Luttrell
Mr. Fridrich's injunction on inventorying applied to a specific case. Gen-
erally, one thing you don't have to do is inventory. I would su-igest that you
enlist the aid of the Records Management Division of the National Archives and
Records Service, and get help particularly from the Records Scheduling Branch in
developing your schedules. They have been through this before for the same situ-
ation in many other agencies. They know a lot of short cuts and they will be
very helpful to you. They will assist- you and even do some of your work for you.
Then also you will want to enlist the aid of your top officials, those who can
make final decisions. Don't bother with the lesser lights at this time; you
don't have time. Working in this manner you can have a joint effort of the
records management people, program people, and the people from the Records
Management Division. I would also suggest that you develop your schedules on
a functional basis. Don't bother with lists. Stick to schedules on a broad
functional basis and start from the point of what must be preserved, then pro-
vide that everything else can go after a predetermined time. Don't start from
the point of what could be destroyed; start with what must be preserved.
Mrs. Alice Ritter
That is the kindest thing that you have said. I was worried about all the
rest of it. In line with my last question; I was emphasizing an insufficient
staff. Are there any steps that. can be taken to assure the retention of a records
liquidation staff until the termination of an agency, Mr. Fridrich:
Mr. Charles Fridrich
I think: what is vitally necessary is to bring the problem, and that has
already been emphasized, before top officials and point to the specific legal
requirements. For instance, orders of the agency which are actually on the
books may require that industry keep records a specific length of time. Natur-
ally the Government, in order to answer any questions, is going to have to keep
its counterpart records at least the same length of time. You will find in your
aggency that there will still be legal activity with pending suits and other
action that your agency may control. Basic industry data which in time of an
emergency would be extremely valuable must be kept. If these kind of arguments
won't convince them that the last people to be let go in an agency are the records
management staff members, everyone must simply prepare for a bad time. The
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experience of !SSA is certainly germane to this point--liquidating a.~,encies
which kept their records staffs longest have had the least difficulty.
Tars. Alice Ritter
I hope your point is generally recognized as valid.
Charles Fridrich
11ay I inject something there? You probably will find considerable inter-
est in retaining records and agree :.hat somebody should be on hand to do the
job. I think also these days you run up against a problem concerning the
character of your records liquidating staff. I have heard so much talk of
just rounding up people to do this job; there is a feeling; that any reasonably
intelligent person can be thrown into a records liquidation job. In some cases
that is true, but in most cases it is not true. It was suggested to me once
that the way to get over the htunp on this records business would be to hire
college students during the vacation period. Well, now that looks good to
many people and sometimes it works. You can use college students and high
school students on certain kinds of work, but I think you, have to be careful
before accepting the assi.imption that that sort of an operation will work out
satisfactorily in records liquidation.
11rs. Alice Ritter
I have another qu^stion for you, 71r. Vaughan. All agencies have certain
records that they think should be kept permanently for historical purposes,
the pure gold records. How is that situation handled?
Mr. Charles Vaughan
Well, I am not quite sure what we mean by the pure gold records. Could
you give me an example of that?
J:rs. Alice Ritter
Well, recor.r s that xea?..l and truly .should be kept permanently. Right now
I am thinking of the minutes of our agency and its subsidiaries. The permanent
records of all of our activities.
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Mr. Joseph Vaughan
The sort of thing that sometimes gets bound in leather binders? The
property people I think will assist you in insuring the permanent preservation
of records of that kind. But seriously, though that is the sort of thing which
one would expect to be on a comprehensive schedule, the sort of a thing that
would be definitely earmarked for permanent retention. 'Z'hether your object is
to direct items of that kind, (your pure bold items) to the National Archives,
or whether it is to pass them through the purgatory of the Records Center along
with the other records depends of course upon a number of circumstances. By and
large, the policy of GSA is to funnel everything through the Records Center, and
that can be done and still insure the permanent retention of these pure gold
records. There are exceptions to that rule which are spelled out in the regula-
tions of GSA and I am sure that most of you are acquainted with them. For ex-
ample, records of Presidential Boards and Committees; records of the Executive
Office of the President, cartographic records, photographic records of one kind
or another. In our own case we do have some problems in that we are a part of
the ixecuti.ve Office of the President but also have become the custodian of
records created in other agencies not in the Executive Office of the President.
As a practical matter, I doubt that we could attempt to send all of our retained
records directly to the National Archives because, frankly, under the circum-
stances that exist now, a great many of them should not be retained except for a
certain period of time. '7`e have been working with the people of the EARS and the
NA proper on the disposal of some records in our custody, pure gold records let
us say. The bulk of our holdings should follow the normal procedures.
Mrs. Alice Ritter
How about the personnel records and related records?'
Mr. Joseph Vaughan
You told me you were going to ask me that one. I don't know if I am going
to be in the position to answer it too well. The status of personnel files, such
as RIF registers, is pretty much determined by your personnel staff. In the
agencies that we have noticed in the liquidation period and the agencies over
which we have had some jurisdiction, our personnel people have jumped in promptly
and as part of the general liquidation team and have seen to it that the records
that should go to the Federal Records Center at St. Louis are promptly sent there
and others to be retained are brought into our immediate custody for such
processing as is necessary. In the case of the stabilization agencies it was
necessary to create a liquidating unit that had responsibility just for the
personnel records as well as certain fiscal records. Of course, you have last
minute decisions as to who is going to stay on; I think you mentioned this the
other day, Dorothy. A decision was made at 5:00 or 5:30 in the afternoon that
John Doe will be continued another month, so you had to run out to the St. Louis
truck and pull off his personnel file. Somehow I don't get too concerned. about
personnel records because there seem to be so many rules and regulations written
about them and a general recognition of the fact that they are identifi3 Gle and
manageable.
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I.Trs. :!lice Ritter
I will run to my Personnel Office and waive those rules and regulations
then. Mr. Fridrich, we have gone through all this work now and we will aswne
that everything has been boxed and stored or transferred one -place or another
in very orderly fashion. That procedures have the Records Centers setup for
handling the reference and research work on these records and how do you determine
restrictions to impose on these records as to who can see what?
Mr. Charles Fridrich
As for reference and research, the Records Center has a very competent
staff who have been able to locate our records within 24 hours, except on rare
occasions; I can think of about 4 times when I had to wait a week. But that
is going to happen in any well organized ggroup. By proper preparation of your
lists, you ensure better service. I have been able to get my records back by
spotting them immediately and even telling then the bin and location they are
in. If you keep an adequate record in your own of'f'ice you can assist them.
However, they have been able to actually detormi_ne the character of the records
needed and to make a lot of searches for me when I couldn't actually put my finger
on what document I wanted. Now as to the restrictions, there are several things
to be considered--principally laws, executive orders and regulations pursuant
thereto. In the classification of records you determine whether they are confi-
dential or secret or top secret. Your restriction should be determined on that
basis. If functions have been transferred to other organizations you will "ant
to include in your restrictions statements that the new organization can use the
records. There is another ,problem: restrictions involving records of interest
to business because of the competitiveness in industry. There are a lot of
"company data" records in the Commerce Department which industries would like
to get their hands on to see what their competitor did. The Federal Reports
Act of 1912 and the Defense Production Act of 1950 have restrictions which have
to be abided by in this area.
Iir. Joseph Vaughan
Then, of course, you will have general records T h-i_ch T.. think can be turned
loose almost to anyone, possibly your history's etc. which will be of general
interest,
Mr. Arthur Young
I think I would like to hear I,7rs. Luttrell speak on this one, please. How
do you stop people from removing under the blind of quote ?'-personal papers"
quantities of material that are strictly official records?
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Mrs. Dorothy Luttrell
We didn't recognize nonrecord material in OPS; every paper in the agency
was considered record material. There was no such thing as a personal raper
or personal files. Any determination of nonrecord character was made by records
management people. At the beginning of liquidation the director issued a very
strong directive to all top assistants in the National Office and to all Regional
Directors which defined records. First it stated that all records are the property
of the Federal Government and as such they shall not be destroyed or removed from
the premises of the Agency without written authority. It also called to their
attention the penalties in the U. S. Code in this connection.
Mr. Arthur Young
Do you feel that you. got satisfactory results"
I rs. Dorothy Luttrell
I feel that we did. Of course, I won't say that some n eople didn't take
personal papers away, but they certainly were less i.nclinn !,o do so than they
would have been without this directive. I didn't pull any punches.
Joe, you would see that in a staff agency; especially where you have top
level officials. Hoer do you feel about that?
IM,r. Josenh Vaughan
We had an occasion where requests were made from an employee of the Office
of Defense Mobilization for a certain portion of the records of the Office of
Price Stabilization. This material was requested not as records but as the files
that were in a certain office. I was told "surely they must be duplicated else-
where", and "These were files that we had kept over there and we needed them
real badly." So I called Dorothy, and she said "Oh, no you don't", and we
agreed the ratter wot.i.ld have to be decided by higher authority. The higher
authority was a little di'ficult to determine, because the Director of Price
Stabilization was a subordinate of ESA, who at the time of this incident was
also the Director of 0DT7. The Deputy Director of ESA, '',as also the General
Counsel of 0D21 and this matter involved legal records. So I thought the lawyers
were going to give me quite a lot of trouble. I will admit that they seemed to
think this !.!as ter. pest in a teapot, but the got a decision :groan the Director of
ODI:T, ipso facto the Administrator of ESA to abide by the regulations.
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Mrs. Dorothy M. Luttrell
We worked that out as a transfer. We did not consider these files to be
solely extra copies since there were official records mixed in with reference
material. We worked it out as an official transfer of the records with the
approval of the Archivist of the United States.
Mr. Joseph Vaughan
Dorothy, you said awhile ago that you did not recognize nonrecord material.
WouldnTt it be more correct to say that you did not recognize nonrecord material
unless you determined that it was nonrecord material.
Mrs. Dorothy M. Luttrell
Mr. Arthur Young
Charlie, here is one for you. What about the problem of fugitive records,
those that have been charged out for a long time to the Government agencies or
authorized individuals outside of the Government? 11'hen these are ready to come
home where do they go?
Mr. Charles Fridrich
These fugitive records should go back to a liquidating group or to GSA.
If a successor agency has been appointed, taking over particular functions,
the files should then go to the successor agency. I think that is just about
as far as we can go. Ordinarily, I think if there is no successor agency, no
liquidating group, there is GSA again holding the bag. So I imagine that
would be the best place.
Mr. Arthur Young
One more question I would like to have Dorothy Luttrell answer. Should an
agency being liquidated require records in the field office to be forwarded to
the Central Office location or should the review and disposition of records be
accomplished at the field installation?
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Mrs. Dorothy Luttrell
It should be accomplished at the field installation. However, you may find
it cannot always be done; but you should not send to a central location any records,
except those which require centralization. That is why we have Federal Records
Centers in the field, why we should have field Records Management people there.
It would defeat the whole purpose of a planned retirement program, if we were to
flood all the records into the FRC in Alexandria. Disposition should be made at
the point where records are maintained if at all possible.
Mr. Arthur Young
I want to thank each member of the panel and Mrs. Ritter for participating
in this discussion this morning. We haven't attempted, of course, to solve all
of your problems and answer all your questions.
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EXfIBIT 1
FISCAL ACTIVITIES
1. Completely post and balance general ledgers.
2. Reconcile general ledger with last account current received and prepare
required appropriation and fund accounting reports. Consult the Treasury
Department, Bureau of Accounts, where necessary.
3. Completely post and reconcile all subsidiary ledgers and records with
general ledger.
4. Collect promptly all accounts receivable and make immediate deposit of
all collections.
5. Completely identify all items in the special deposit accounts and clear
as rapidly as possible.
6. Establish such special controls over incurring obligations as may be
necessary during the curtailment period.
7. Ascertain that all obligations have been covered by an obligating docu-
ment and posted to allotment ledgers.
8. Reconcile unliquid.ated obligation file with allotment ledger account bal-
ance of unliquidated obligations.
9. Analyze all unliquidated obligations to determine validity, adjusting
outstanding obligations as necessary.
10. Completely post and reconcile all subsidiary ledgers and records with
allotment ledger.
11. Obtain necessary supporting documents in order that all vouchers may be
audited and certified promptly by the agency or such other agency as may
be designated to handle such residue of accounts as may remain at the ex-
piration of the liquidation period.
12. Notify public carriers, vendors, and contractors where communications
should be sent during and after liquidation; send copy of instructions
to Records Management Division, National Archives and Records Service,
GSA.
13. Dispose promptly of all General Accounting Office inquiries, exceptions,
and disallowances.
14. Submit promptly to General Accounting Office For direct se %tlement all
uncleared vouchers, maintaining complete supporting data such as con-
tracts, purchase orders, receiving and inspection reports, invoices,
.explanatory statements, etc., so that inquiries from General Accounting
Office may be answered promptly.
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15. By letter immediately request the General Accounting Office to expedite
their audit of vouchers and settlement of claims.
16. Promptly cancel special authorities such as certifying authority, con-
tracting authority, etc., when an employee is separated.
17. Obtain immediate refunds of outstanding travel advances.
18. Completely post individual earnings record cards; reconcile amounts de-
ducted for taxes, bonds, and retirement with their respective control
accounts.
19. Prepare and furnish, as required, Forms W-l, W-2, and 17-3 to the Collec-
tor of Internal Revenue, giving applicable Form 17--2 to each employee.
Consult Treasury Department, Bureau of Internal Revenue,-on special prob-
lems.
20. Terminate bond allotment authorizations, promptly issuing all bonds com-
pletely paid for and clearing unapplied bond deduction balances.
21. Prepare, completely post and balance Form 2806, Retirement Record Card,
for each employee, forwarding such forms to Civil Service Commission as
employees are separated. Consult Civil Service Commission on special
problems.
22. Prepare and submit promptly to Civil Service Commission, Form 2807-2,
Annual Summary of Retirement Fund Transactions.
23. Transmit Form 3005, Application for Refund of Retirement Deductions, to
Civil Service Connission immediately upon receipt. To expedite payment
of retirement refunds, attach the pertinent Form 2806, Retirement Record
Card, if it has not already been forwarded,
24. Before issuing final salary check to an employee insure that necessary
adjustments have been made because of overdrawn leave, unliquidated
travel advances and unreturned accountable property charged to the indi-
vidual employee.
25. Refer to General Accounting Office for collection"9 all cases of former
employees who are or may be indebted to the Government; submit with each
case all available information.
26. Send to Treasury Department, Division of Disbursement, with suitable
explanation of each case, all government checks which have not been de-
livered.
27. Clear promptly unobligated or unexpended balances of funds provided under
special arrangements such as working funds, allocations, appropriation
transfers, and trust funds, when there is no further need therefor.
28. Prepare, as required io- internal agency use, reports of progress in
winding up the fiscal affairs of the agency.
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