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Subject: Re: WAS: Austin Chapter hosts Workshop,NOW: Topics re:Destruction , etc.
From: "Broud, Trish" <[log in to unmask]>
Reply-To:Records Management Program <[log in to unmask]>
Date:Wed, 4 Dec 2002 09:18:52 -0500
Content-Type:text/plain
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text/plain (94 lines)


Lee,

I, too, have worked as a government contractor in a Federal agency.  In my
situation, in this case the agency procurement records followed the GRS
requirements (which, by the way, the two different retention periods
depended on dollar value/type of vehicle) and our contract's procurement
records followed the FAR.

The thoughts expressed here are my own.

Trish Broud
SRA, International
Rockville, MD
[log in to unmask]

-----Original Message-----
From: Michael, Lee [mailto:[log in to unmask]]
Sent: Tuesday, December 03, 2002 5:51 PM
To: [log in to unmask]
Subject: Re: WAS: Austin Chapter hosts Workshop,NOW: Topics re:Destruction ,
etc.


Trish,

I work in an environment where I am a government contractor and am required
to comply with both the GRS and the FAR.  I contend there is a conflict.


Lee Michael, CRM
National Renewable Energy Laboratory
(A US Department of Energy laboratory, operated by a contractor)

-----Original Message-----
From: Broud, Trish [mailto:[log in to unmask]]
Sent: Tuesday, December 03, 2002 3:13 PM
To: [log in to unmask]
Subject: Re: WAS: Austin Chapter hosts Workshop,NOW: Topics
re:Destruction , etc.


Lee,

Your example of 'conflicting' requirements are discussing two different
things.  The FAR reference talks about "contractor records", i.e.: the
retention requirements for government contractors.  See quote below:
"Subpart 4.7-Contractor Records Retention
4.700 Scope of subpart.
This subpart provides policies and procedures for retention
of records by contractors to meet the records review
requirements of the Government. In this subpart, the terms
"contracts" and "contractors" include "subcontracts" and
"subcontractors.""

and the GRS reference is for government agency records:
"Agency procurement and supply records document the acquisition of goods and
non-personal services, controlling the volume of stock on hand, reporting
procurement needs, and related supply matters which are part of daily
procurement operations."

(This shows the importance of reading up to the top of the relevant
section.)

The thoughts expressed here are my own.

Trish Broud
SRA, International
Rockville, MD
[log in to unmask]

-----Original Message-----
Lee said:

In support of Peter's scenario, I am fairly sure of a direct conflict
between the NARA-issued General Records Schedule 3 and the Federal
Acquisition Regulation regarding the retention of routine procurement files.
GRS Schedule 3, item 3 is available for review at:
http://ardor.nara.gov/grs/grs03.html  The FAR citation of part 4.705-3(f) is
available for review at:  http://www.arnet.gov/far/current/pdf/FAR.book.pdf

Basically, the GRS has identified retention to be either 3 years or 6 years
and 3 months.  The FAR states a retention of 4 years.  So, who takes
precedence, NARA or OMB?  Both are federal agencies, both have
responsibility to set retention policy, and both have.  But they contradict
each other...

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