Working Files
- What are working files?
- Are working files records?
- Are supporting materials the same as working files?
- What types of documents are found in working files?
- Are working files the same as personal papers?
- What is the best way to manage working files?
- Are working files subject to the Freedom of Information Act (FOIA)?
- How can I get additional guidance?
The National Archives and Records Administration (NARA) defines working files as: "rough notes, calculations, or drafts assembled or created and used to prepare or analyze other documents. Also called working papers."
Everyone creates working files, and they are very often a mixture of record and nonrecord materials. How to manage them is the question. If working files are poorly organized and inscrutable to anyone but the creator, identifying record material to document program activity is difficult. If records and nonrecords are mixed in one voluminous working file, the Agency is forced to manage an even larger volume of material than is necessary.
Basically, you need to make sure that records needed to document Agency activity are filed in official files and working files are maintained separately and kept to a minimum.
NARA's regulations (36 CFR 1222.12(c)) say that working files are records if:
- They were circulated or made available to employees, other than the creator, for official purposes such as approval, comment, action, recommendation, follow-up, or to communicate with agency staff about agency business; and
- They contain unique information, such as substantive annotations or comments included therein, that adds to a proper understanding of the agency's formulation and execution of basic policies, decisions, actions, or responsibilities.
Each FDA office is responsible for establishing procedures that identify which documents are part of the official files, who is responsible for maintaining them, and when they are placed in the recordkeeping system. Staff can then determine which documents in their possession need to be filed and retained as records, and which documents can be safely recycled or destroyed.
3. Are supporting materials the same as working files?
No, true supporting materials are documents that are necessary to substantiate the final document or decision trail. Supporting materials are part of the official record, although they may be filed separately if volume warrants.
4. What types of documents are found in working files?
Unfortunately, many people keep a substantial amount of their project documentation in working files. Here is a list of the types of documents that may be found and what should be done with them.
- Record materials: Develop a plan to organize the materials and file according to your office file plan. If the file is large, consult with your Center/Office Assistant Records Liaison Officer (ARLO) on whether it makes sense to set up a file for the major documents and a separate one for supporting materials.
- Nonrecord materials: Extra copies of articles, journals, reports, studies, vendor catalogs, and similar materials that are needed for convenience or reference but are not part of the official file should be destroyed as soon as they are no longer needed.
- Suspense or tickler copies: Extra copies of documents to remind persons of actions to be completed by a certain date should be destroyed once the action has been completed.
- Telephone slips, notes, e-mail messages that are facilitative and not substantive (e.g., "Mike, please call Ann about the project."): Destroy when no longer needed.
- Drafts that are not circulated for comment or review: Destroy when no longer needed.
- Drafts that contain substantive changes: These need more analysis. If the changes are important, you may need to keep them as supporting materials. In most cases, it is sufficient to summarize the comments in a memo for the record. In the case of documents circulated for comment, you can always keep an original full copy and then retain only the annotated pages of the copies with comments. The bottom line is: your office needs to determine which drafts need to be kept and the method to use.
5. Are working files the same as personal papers?
No, personal papers are nonofficial, or private, papers relating solely to an individual's own affairs. Working files, by definition, relate to Agency business and are not personal papers.
6. What is the best way to manage working files?
There are two common approaches to manage working files:
- Create an official file when an action is initiated and file the official records, and only the official records, in it. This works especially well for repetitive actions where approvals are required, such as the issuing of permits, travel vouchers, purchase requests, or the approval of directives.
- Retain most or all of the papers until a specified milestone is reached or the activity or task is completed. At that time, compile an official file. This works well when several individuals are contributing to one product or result, or when projects are unique. Some programs also use this approach in compiling administrative records.
7. Are working files subject to the Freedom of Information Act (FOIA)?
The FOIA does not exclude working files. If there are documents in the files that are exempt from the FOIA under one of its exclusions, those documents are withheld from disclosure. However, the fact that they are working files does not, in itself, exempt them from disclosure.
8. How can I get additional guidance?
If you have policy questions about your working files, you should contact the appropriate Center/Office Assistant Records Liaison Officier (ARLO).