NDC Declassification Process – Evaluation

As I mentioned in my previous post, the biggest interagency issue related to the new process was to follow the President’s direction, issued in a memo that accompanied Executive Order 13526 (http://www.archives.gov/isoo/pdf/implementing-memo.pdf), and apply risk management to the declassification process. So why is risk management needed?

First, we need to examine who is performing the initial declassification review. Under Executive Orders 12958 (EO 12958) and 13526 (EO 13526), originating agencies are responsible for reviewing their classified records as they reach 25 years old, or allowing their equities to be automatically declassified. Should an agency choose to allow auto declassification only their equities are declassified, any information classified by another agency is still classified until that agency has a chance to review their information. To the best of our knowledge, all of the records in the 408 million page backlog have been reviewed by the originating agency. While originating agency reviewers are usually well versed in their own equities, they are not always well informed when it comes to identifying information that may be classified by another agency (or equity identification). This is mostly due to inconsistent or incomplete interagency equity recognition guidance, which leads to missed equities and over identification of equities (or over referral). For example, Agency A was concerned that Agency B was not accurately identifying A’s equity, potentially leading to the release of classified information. As you can imagine this led to concerns about what was being released. To address agency concerns and ensure the declassification process proceeded as required by EO 12958, the declassification unit of the National Archives (NARA) established a Quality Assurance Review Team (QART) in 2007. Unfortunately more quality issues were identified, and by September 2008 the QART process had devolved from sample reviews to a detailed page-by-page review. This added yet another layer of page-by-page review for records that had already been reviewed two to three times, and dramatically slowed the declassification process at NARA.

Faced with the requirements of EO 13526 and the President’s memo, the interagency group realized that this step was a major road block in the process. Applying the Lean Six Sigma (LSS) analysis we found that the process was repetitive and wasteful. This was clearly a key piece of the process for the group to address. First, we agreed that some records in the backlog did not have quality issues or were not at risk to contain the two categories specifically identified in the President’s memo (Human Intelligence Sources or Key Design Concepts of Weapons of Mass Destruction). Next we addressed how we sort out which records are high risk, from those that are low risk. The solution was interagency teams (or “Evaluation Teams”) that perform a quick examination in the stacks to determine if additional quality control (QC) review is required. This change was truly a risk management approach to the QC process and was a huge step for agencies that have sensitive information (for example: methods, technology, etc.) that does not fall into the two categories. Once implemented, the process allowed us to evaluate an average of 1,000 cubic feet (approximately 2,500,000 pages) of records per week. At the beginning we hoped 40-50% of the records would not require any additional QC, in reality 75-80% are bypassing additional QC. While these numbers are encouraging, they have put additional strain on our indexing/withdrawal/release teams.

At this point in our process we have three possible paths, the records can go to the QART, DOE QC review, or straight to indexing/withdrawal/release. As I mentioned 75-80% of the records are bypassing additional QC, but what happens to the rest? The QART will be the subject of my next post.