NDC Declassification Process – Quality Assurance

Quality control review is one of the most important parts of the NDC process. In the early days of Executive Order 12958, agencies began to expand review programs to ensure that sensitive information was not released when the automatic declassification deadline arrived. To accomplish their goals, programs were established before sufficient government wide equity recognition training had been developed. Federal agencies became concerned that their equity in documents held by other agencies was not adequately identified . Because of the concerns raised by these agencies, NARA was unable to complete declassification processing on the records. To begin addressing these concerns, the Director of the Declassification Division at NARA, Jeanne Schauble, pushed to establish an interagency Quality Assurance Review Team (QART) in 2006 to address quality issues in historical records at NARA.

The original vision of the QART was for participants to perform a sampling review to assess the quality of the original agency review. Unfortunately this process quickly devolved into another time-consuming page-by-page review of the records. This was one piece of the old process that needed to change. During the interagency discussion on the new NDC process, agencies took seriously the President’s direction to apply risk management approaches to the declassification process. Do not misunderstand, the meetings were long and the discussions were challenging. In the end we all recognized that any records that failed the evaluation step required a more detailed examination, but no agency had the resources to perform another full review of the records. We again adopted the sampling approach that Jeanne Schauble had introduced. The standards are strict; the error rate for a QART review is less than 1% for Human Intelligence and key design concepts of weapons of mass destruction. Any records that fail the QART review are returned to the original owning agency for a complete re-review.

In theory it seems like we added another step to the process. In practice, however, we are finding that only a small percentage of records are going to the QART, and of the records reviewed by the QART an even smaller percentage are being remanded to the originating agency . This has significantly reduced the amount of time reviewers are spending performing page-by-page quality assurance (QA) review, and increased the flow of records through the process. The success of this process is a credit to each agency’s willingness to employ risk management and to accept the fact that we will not identify all classified equities. The only way we can meet the President’s goal and protect sensitive information is to focus our QA efforts on those records that contain the most sensitive National Security equities.

The last review step in our process is a review by DOE to ensure compliance with the Kyl-Lott amendment. This will be the topic of my next post.

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