I’ve recently read again the post by Don Lueders in AIIM Expert blog space and the counterpoint by Mark Mandel. Having attempted to post some rather long responses to both I found there is a word limit, so I had to edit them rather severly. This editing resulted in some lack of logical flow and loss of explanatory details, so I’m posting the entire set of comments here.
I love both Don Lueders’ detailed post on this subject, On Why I No Longer Support the DoD 5015.2 Standard, and Mark Mandel’s rebuttal, I Support DoD 5015.2; and Encourage ALL Federal Agencies to Adopt It, as I believe that a full debate on standards for IT systems creating and housing Official Federal Records is really needed. The have taken a position that others no doubt share; and both raise some really good points for discussion (both for and against), as other comments already posted indicate. I agree with many of Don’s arguments for throwing out 5015.2; but I do have a few pet peeves that these blogs brings to the fore:
1. Why are the discussions and serious work on standards for managing Government electronic records in the US always limited to DoD 5015.2, as though it is the only existing standard? As Don very convincingly points out, this standard is so outdated and inadequate in many ways. This is particularly noticeable when it is compared with others such as MoReq 2010, ISO 16175 and the Object Management Group’s Records Management Services (RMS) specification.
For MoReq 2010, I can only assume that it is the “NIH” factor (not the federal health institute) that keeps it out of wider adoption and even serious discussion in the US. In my view it addresses many of the problems cited with 5015. I don’t get why this is dismissed here as being just “the European standard”.
Likewise, the OMG RMS directly responds to one of the major problems Don raises with 5015 – i.e. it is essentially a standard for “stand-alone Records Management applications (which) haven’t existed for almost a decade”. As I understand it, the whole purpose of the DMS endeavor, which a consortium of NARA, federal agency Records & IT reps., and industry partners undertook, was to create a set of requirements and specifications for RM functionality that can be “baked in” to any system/application and that will run in the background as a service. For any standard/specification to be useful in today’s government IT/RIM environment, it must allow for a “manage in place” strategy that does not assume a centralized RMA repository for all electronic Official Records or valued information assets.
2. Why would anyone seriously interested in establishing a systems standard for federal government RIM/Information Governance (IG) think that DoD and their technology vendor community has all the answers? And why is it assumed that what may be required and workable for Defense will also be viable for the civilian federal government? Don’s piece cites several examples of where the 170+ functional requirements in 5015.2 are either irrelevant or over-engineered (particularly for civilian agencies). I’m obviously agreeing with Don on this one – and again making the argument for looking at other standards-making groups/endeavors rather than focusing so much on just this one, which was based on a couple of fundamentally false premises.
3. Why is the work and debate on systems standards for Record Information Management (RIM) in Federal Govt. dominated by EDM/ECM/ERM systems vendors and “industry analysts”? Correct me if I’m wrong, but don’t these analysts make their livings in large part by advising technology companies on how to position their products to maximize sales to government and private sector customers? I’m not directing this concern at Don, Mark and their industry colleagues, as their experience and insight is very much valued and needed. However, isn’t it about time that NARA and my colleagues (those of us who actually practice RIM & IG in government) step up and take the lead? I for one am very concerned that whatever standard emerges to replace 5015.2 (or even worse if 5015.2 should be mandated), must not be driven by what is in the best business interests of vendors, but rather by what is really required and what is workable for the government RIM/IG practitioners who will have to live with it and attempt to make it work. Further to this point, I fully agree with those who have earlier posted responses to your blog, that there was a huge opportunity missed when NARA and OMB did not take a more thoughtful and direct stance on these standards (including rescission of NARA’s prior “endorsement” of 5015.2 for use by civilian federal agencies) in the Managing Federal Records Directive (MFRD) issued August 2012. If they are not yet ready to adopt an existing standard (e.g. MoReq 2010, ISO 16175, or OMG-DMS), which I’m pretty sure they are not; then they should at least lay out a clear direction with milestone and deadline to get it done. Of course, I believe this new direction should require active participation by agency Records Officers/RIM/IG practitioners, while also continuing to involve industry/technology/consultant experts. By not addressing this in the MFRD NARA/OMB have perpetuated a huge dilemma for federal agencies – requiring in Federal Regulation (36 CFR 1236, Subparts B and C) the use of systems with “recordkeeping functionality” to effectively manage all electronic records, without clear definition of what that means and without guidance on how to implement it.
Thanks again Don and Mark for stimulating this discussion with your blogs! As indicated, I’m not ready yet to agree with every point in Don’s piece, but I definitely lean in the direction of doing away with DoD 5015.2 as a standard “endorsed” by NARA for use by civilian federal agencies. if time permits (and space on this AIIM Community site allows) I will follow this up with some point-by-point reactions to comments on the six specific requirements of Cutoff, Metadata, Email Records, Non-electronic documents, Record Relationships, and Metadata-based Security.