I've been thinking about the exchanges among Richard, Peter, Bruce and 
me.  I know it is easy to argue that NARA never can operate 
independently.  However, that does not mean that it cannot or should 
not admit to impairments.  Perhaps NARA should consider its 
responsibilities to the public by examining more closely the standards 
under which auditors operate.  Government Auditing Standards state that

"3.05 Auditors need to consider three general classes of impairments to 
independence—personal, external, and organizational.  If one or more of 
these impairments affects an individual auditor’s capability to perform 
the work and report results impartially, that auditor should either 
decline to perform the work, or in those situations in which the 
government auditor, because of a legislative requirement or for other 
reasons, cannot decline to perform the work, the impairment or 
impairments should be reported in the scope section of the audit 
report."

Go to http://gaoweb.gao.gov/guides.php and click on the link for the 
June 2003 edition of Government Auditing Standards (Yellow Book) and 
you can read more about how impairments are defined.  While I 
understand why NARA faces pressure and struggles with difficult 
balancing tests, I believe it can and should act forthrightly in 
discussing these issues.  That includes stating up front if there are 
any factors or internal or external impairments that affect the release 
of records (be they Federal, Presidential, etc.).

Most of the records in NARA's holdings deal with government activities, 
that is, management officials.  Should they be the ones to call the 
shots over what the public will see?   Here too it is worth looking at 
auditors' evidence standards.  "Evidence obtained from a credible third 
party may in some cases be more competent than that secured from 
management or other officials of the audited entity."  Also, 
"Testimonial evidence obtained under conditions where persons may speak 
freely is more competent than testimonial evidence obtained under 
compromising conditions (for example, where the persons may be 
intimidated)."

Since NARA handles what during Carlin's tenure was called "the 
essential evidence" of government action, it must act with integrity in 
all steps of the process.  Unfortunately, there are not enough 
standards and protocols in place to ensure that this always will 
happen.  And, of course, the archivists who actually do the work never 
should be viewed contemptuously by their managers.  Managers always 
should strive to protect them and, whenever possible, enable them to 
work ethically.

Maarja

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