Update on Questions about GPO’s Regional Discard Policy

In December of last year, sixteen librarians wrote an Open Letter to GPO regarding the Regional Discard Policy in which we asked twelve questions about the approved version of the Regional Discard Policy.

Now that GPO has released several new “informational resources” about progress of the “testing phase” (now referred to as “implementation phase one”) of the implementation process, we have some answers to some of those questions.

More than half of the open letter’s questions focused on one of the five titles originally slated for use during the testing phase, the “GAO Reports and Comptroller General Decisions” (GAO/C-G). We chose that collection because it is a relatively small and well defined collection and is easily browsed on FDsys. It provided an easy opportunity to address broad questions with specific examples.

GPO has now released a new and growing spreadsheet list of titles eligible for discard (strangely dated September 2016!) that includes four of the original five test titles, but not the GAO/C-G collection. So, several of our questions that were specific to those reports remain unanswered and, as far as we know, unaddressed by GPO. Many of the “answers” that we now have to our questions are preliminary because GPO has not addressed them directly. Rather, what we have below is what we can glean and infer from a series of policy documents and draft procedural documents released by GPO in July.

Below, we list the answers we infer from the new documents released by GPO. In a second post, we further analyze and go into the details of what we’ve learned from those documents and the reasoning behind the inferences below.

1. What formats currently qualify as meeting the standards of the Superintendent of Documents? PDF? PDF/A? Other?

Apparently, GPO is imposing only 2 criteria on the “formats” that constitute what GPO calls a “preservation copy of record for digital content.” These are:

1. that the digital copy of record must be “produced to specifications that will allow the creation of a printed facsimile version” and
2. that it must contain “the digital signature of the Superintendent of Documents.”

Our interpretation of this is that, since digital signatures are currently only provided by GPO to PDF documents, this “signature” criterion requires that the document must be a PDF, but that makes no other claims about the PDF format.

2. If a title in FDsys only has a digital file in plain text format, will it be eligible for discard?

   Apparently not. The requirement described above seems to mean that documents that are stored in FDsys only as text files without a signed PDF version are ineligible for discard. GPO has not released any analysis or data on how many volumes meet this criterion.

3. Will digital copies have to be certified by the Superintendent of Documents with a PKI certificate issued by VeriSign?

As noted above, the requirement is that the PDF version of the document has a digital signature.

4. If not, what other form of “digital signature” will make a title eligible for discard?

None are mentioned, though GPO is storing digital hashes of text files.

5. In the GAO/C-G collection on FDsys, will titles that have a plain text digital copy but no PDF copy be eligible for discard? (See for example: 1992 Bank Resolutions: FDIC Chose Methods Determined Least Costly, but Needs to Improve Process, GAO/GGD-94-107, May 10, 1994.)

Apparently not. See #2 above.

6. In the GAO/C-G collection on FDsys, will titles that have only a text file without full text be ineligible for discard? (See for example: 1992 Thrift Resolutions: RTC Policies and Practices Did Not Fully Comply With Least-Cost Provisions, GAO/GGD-94-110, June 17, 1994. “We regret that the full text of this item is presently unavailable.”)

Apparently not. See #2 and #5 above. Presumably, a title with a signed PDF and an incomplete text file would be eligible for discard.

7. Have all the different kinds of reports listed within the GAO/C-G collection on FDsys been cataloged in the Catalog of Government Publications (CGP) and deposited in FDLP Regionals? (The kinds of reports include: Briefing Report, Chapter Report, Comptroller Decision, Comptroller General Decision, Correspondence, Fact Sheet, Letter Report, Oral Presentation, Other Written Product, Staff Study, and Testimony.)

unanswered.

8. What is the overlap between deposited GAO/C-G titles and titles in the GAO/C-G collection on FDsys? For example, are there titles that were deposited that are not in FDsys?

unanswered

9. How many titles in the GAO/C-G collection on FDsys are in the qualifying format?

unanswered

10. How many titles in the GAO/C-G collection on FDsys currently have the appropriate “digital signature”?

unanswered

11. Does GPO intend to add digital signatures to documents in this collection that do not yet have them?

unanswered

12. How many of the titles in the GAO/C-G collection on FDsys are eligible for discard now?

unanswered

Authors: James A. Jacobs and James R. Jacobs

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