F e d e r a l    D e p o s i t o r y    L i b r a r y    P r o g r a m

[ From Administative Notes, VOL. 16, #13 (October 15, 1995). ]

California Depository Librarians
University of California, Irvine
September 14, 1995

[This speech is updated from one which appeared in JurisDocs, v. 8 #1 (1985), pp. 5-10.]

History of Inspection Program

To better understand the inspection program, I will briefly summarize its short history. Since the Printing Act of 1895, later codified as Section 1909 of Title 44, the Superintendent of Documents has been authorized to make "firsthand investigations of conditions for which need is indicated." Until 1972, depository libraries were infrequently visited. Instead, GPO relied on the "Biennial Survey", inaugurated in 1947, for data.

The first inspection form, a 12-question checklist, was developed in late 1971 and used in 1972. Bookstore managers, GPO staff on travel, as well as specific examiners, "dropped in" on depositories without warning. The examiners would visit several libraries in a day. The form was filled out and placed in the depository library's permanent file at GPO. No copy was mailed to the library or the regional. Often, the documents librarian was not available and other staff answered the questions.

By the mid-1970's, GPO, on advice from GODORT (GOvernment DOcuments Round Table of the American Library Association) and the Depository Library Council to the Public Printer, concluded that depository libraries needed systematic and formal inspection to insure the effectiveness of the Federal Depository Library Program. Our job in Depository Services is to determine that libraries receiving government documents paid for by the taxpayers are fulfilling the not too onerous responsibility of making government publications freely available to the public.

In 1974, the first full-time inspector, a professional librarian, was hired. A second librarian was employed in 1976. The inspection form was evolving with more questions on bibliographic control, housing, and public access. By 1977, the Depository Library Council had developed standards to "provide an inspection tool for the Superintendent of Documents, a guide for education of documents librarians, and a tool for communication with library administrators." These Guidelines for the Depository Library System (Guidelines) were distributed to all depositories and became the basis for the next version of the Inspection Report. In conjunction with issuing the Guidelines, a wholesale revision of the Instructions to Depository Libraries, the rules and regulations of the Program, took place.

Since 1972, the inspection process has evolved from a cursory examination to an all-day comprehensive review. At first, inspections were unannounced and the inspector visited two or more libraries per day. With no advance warning, our staff found interesting surprises, such as piles of unopened boxes, material in locked rooms, no one in charge of the collection, etc. On occasion, we still find that today.

Preparing for the Inspection

Since 1978, we have notified depository staff of the specific inspection date from 4-6 weeks in advance and request an appointment for an oral exit interview with the library director in order to summarize our overall evaluation and recommendations. The regional librarian is also notified of our trip and invited to accompany us, if possible, because he or she can provide valuable insights about funding sources, cooperative networks, disposal guidelines, etc.

The inspectors have always been professional librarians. We help to identify areas of strength and weakness by rating the entire operation, not judging the documents librarian. We are fully aware that librarians and administrators cannot totally control their working environment, architecture, or funding. After inspecting nearly 500 libraries, I am very familiar with the challenges and difficulties facing most depository libraries.

Libraries are generally inspected in chronological order by date of last inspection. Geography and climate are also considered. For these reasons, Arizona is not visited in the summer nor Minnesota in January. The American Automobile Association tour books and the Rand-McNally Road Atlas are invaluable since we make our own hotel reservations and work with a travel agent to obtain airline tickets and rentals cars. The elapsed time between inspections is about six years due to staff turnover and lengthy hiring procedures. The three inspectors travel about 40% of the work year and each examines about 70 libraries annually. Because of my other responsibilities, I examine about 25 libraries a year.

I would like to explain briefly how the inspection itinerary is prepared. Once a portion of a state has been selected, the library staff is contacted by telephone. After we identify ourselves, there is usually 5 seconds of dead silence at the other end. We run down the inspection routine to calm the documents librarian. The appointment is later confirmed by letter. Accompanying the letter is a pamphlet entitled "Preparing for a Depository Inspection," which is actually Chapter 8 of the Federal Depository Library Manual. We also recommend that the librarians perform a self-study using the draft which was announced in the November 25, 1994 issue of Administrative Notes, pp. 27-37. Such an evaluation can often anticipate the inspector's findings and be communicated to the library administration before we arrive. This internal review may make the inspection process less stressful as there are fewer "surprises" when we orally summarize our findings with the library administration.

With the uniform set of written questions in the self-study, the documents staff can review critically what they are doing and have the opportunity to comply with the law and GPO regulations in advance of the inspection. The self-study can be a strategic assessment document and can steer the documents librarian toward issues such as collection development policy, ADA compliance, etc., which need careful consideration. Even with a self-study, the inspector still has a regulatory role to identify areas of strength and weakness in the entire depository operation and the educational role to act as a consultant and make recommendations based on experience. The communications role as the on-site audit is often the only way some documents staff and library administration interact with a GPO representative. We plan to issue a revised text of the optional self-study as another Federal Depository Library Manual Supplement in 1996.

In the intervening 4-6 weeks before the inspection, the documents librarian is urged to review the Guidelines for the Depository Library System, the Instructions to Depository Libraries, Superseded List, and the Federal Depository Library Manual and its Supplement, plus collect whatever materials would be useful, e.g., procedures manual, collection development policy, annual reports, promotional flyers, etc.

The Inspection

Before entering the library, we check outside the building for handicapped ramps and for the depository emblem on the entrance doors. Not only is the depository decal the focal point of our entire marketing campaign but it also states for all to see that "public access to the government documents collection is guaranteed by public law." We also look for the new "U.S. Government information ... electronically" decal given to those libraries which subscribe to GPO Access services.

All depositories are expected to serve the public, not just their institution's clientele, except the highest appellate court of each state which is exempt by Federal law. In reality, all appellate court depositories serve the public, except in California, because they receive state funding as public law libraries. Yet we have discovered various tactics, most often in law-related depositories and private institutions, which have a "chilling effect" on public access: charging a fee for a pass to enter the library; enforcing a dress code; age restrictions; actively referring patrons to other depositories; closing the library to all non-students and faculty, etc. Often door guards and student workers are unaware of the legal responsibility to ensure free, unimpeded, access by the public to the depository collection. Misunderstandings are less apt to occur in institutions which openly promulgate their access policies through signs, leaflets, and policy statements.

After entering the library, we look for adequate signs, a floor plan, or directory to locate documents in the building without having to ask a staff member. Some libraries have installed creative signage while others fail to mention the depository collection at all in library handbooks, pathfinders, newsletters, or brochures. We inquire about special procedures for those without the appropriate library card to insure that a guard or access services office will not detain anyone who wishes to use Federal documents in the building.

After meeting the documents staff, some time is spent answering GPO-related questions and becoming familiar with the library and the depository operation. A principal concern is who is in charge of the depository function. Is there a clear demarcation of duties? Is there one person reporting to the library administration on the Federal Depository Library Program? For example, if technical services processes the shipments, circulation shelves and retrieves the pieces, and reference provides access to the information, there should be one person, a professional librarian, coordinating the entire program. GPO needs a point of contact too.

The inspection follows the work flow of the depository operation. Access includes not only physical entry to the building but also record keeping and shelving and filing the materials in all formats in a timely manner and in an orderly fashion. The items do not have to be filed in SuDocs classification order but ought to be arranged in a recognizable scheme such as Dewey, LC, or shelving Army Lawyer with law reviews, Statistical Abstract in the reference collection, etc.

Processing

Initial processing is examined first. Federal documents should be handled in a similar fashion as "regular" materials. Is there a shelflist or holdings record for the complete bibliographic control of all monographs, serials, microfiche, CD-ROMs, and maps? Have written criteria been formulated for determining which titles are fully cataloged, rebound, replaced, and security-plated to insure preservation and uniform decisions? It is always surprising to discover the lack of a specific written collection development policy for Federal documents in view of the public service responsibilities of depositories. To that end, in 1994 GPO issued the Federal Depository Library Manual Supplement to aid in formulating a written collection development policy. We urge the creation of a procedures manual which specifies internal policies and work flow as well as incorporates GPO's requirements found in the Instructions to Depository Libraries. Too often we meet new documents librarians groping for direction.

The library is expected to assure that the depository collection is used and not merely stored or placed in a remote location. If microfiche, periodicals, and maps are housed separately, we check whether there is a location note on the shelflist. Since many libraries integrate some of their documents into the main book collection, we verify that the call number or location is noted on the kardex, shelflist files, or automated records to speed retrieval. If some material is in storage, have the appropriate shelflist notations been made and can the publications be retrieved promptly (preferably within 24 hours)?

There is a noticeable and encouraging trend to fully catalog documents via a profiled tape load into on-line catalogs using the SuDocs classification system. Another approach to increase visibility and to relieve overcrowding is to selectively house material at another campus library or other local institution. Under GPO Access, depositories may provide up to ten Internet Protocol (IP) addresses to GPO for the on-line services. We also allow selective housing of excess IP addresses at a gateway site, e.g., Portals in Oregon, Ocean FreeNet in Rhode Island, etc. Should a depository library adopt either or both of these methods, a "Memorandum of Agreement" outlining the host institution's responsibilities toward public access and retention should be signed and forwarded to GPO and the regional librarian. A sample agreement for traditional products can be located in Chapter 2 of the Federal Depository Library Manual. The model agreement for on-line services appeared in the December 15, 1994 issue of Administrative Notes on pp. 18-19; in the booklet entitled GPO Access: Information for Depository Libraries dated January 1995, and on U.S. Fax Watch (202) 512-1716 as document number 3357.

As mentioned earlier, the primary role of the inspector is to insure that Title 44 is followed. Our secondary role is advisory. In that capacity, we urge documents librarians to conduct an annual zero-based item selection review with the goal of building a quality collection not only to meet the informational needs of a library's primary clientele but also of the surrounding congressional district. The "Suggested Core Collections" in the Federal Depository Library Manual is a useful selection tool. The List of Classes in ASCII format is available for downloading from GPO's Federal Bulletin Board.

Weeding the collection of extraneous material after the five-year statutory retention requirement has been met is a key component of collection development. When I hear complaints about the onerous weeding process, I respond by asking whether some of the items in question would have been purchased with acquisition funds. If the answer is no, then I ask why the staff has "purchased" the document with Federal revenues. Setting up a weeding schedule and following the Regional's guidelines for disposition is preferable and more comprehensive than weeding isolated overcrowded shelves.

Public Service

One of the most important categories in the Inspection Report is "Public Service." Whether institutions are publicly or privately funded can color their perception of the public. Some private institutions are more open than some publically supported ones. The privilege of depository status imparts more than custodial maintenance and an open door. Depository libraries are expected to provide skilled reference staff, research aids, and equipment. If the reference librarian cringes when someone asks for Federal material or tells a patron to return another day or at another time, the remedy is to conduct "in-service" seminars. The reference staff can then serve as auxiliary documents librarians to insure that government information is an integral part of their search strategy and not an afterthought.

During our tour of the library, we check for supplementary commercial indexes and databases which have been purchased to facilitate use. Is the Publications Reference File and the Monthly Catalog, in CD-ROM, on-line, or GPO iterations, near the reference desk if that is the only service point? We want to see all of the microfiche readers, reader/printers, and storage cabinets. We want to see the map cabinets, CD-ROM work stations, jukeboxes, photocopiers, fax machines, etc., and when necessary recommend that more be purchased. Is interlibrary loan service provided or referrals made to other depositories or to a GPO bookstore?

Does the public even know that the library is a depository? GPO's marketing staff has developed a campaign for publicizing depository libraries via posters, bookmarks, and brochures to help you get started. We have recently distributed more order forms so that you can obtain folders, "Federal Publication" stickers, and we now have a new electronic logo on diskette and on decals.

Bibliographic guides, book displays, and library newsletters are basic means to spotlight the collection. Consider using the campus radio station, local cable television, plus speaking before the Rotary or Chamber of Commerce on business tools, the Sierra Club on the environment, or law and education before the League of Women Voters. When reprinting your bookmarks and student and faculty handbooks, add a note about being a depository. Many of you, I am sure, have received urgent long-distance telephone calls from alumni who must have specific information located on the shelves between the second and third window on the left and the book is tan. They think only your library can provide the answer. They have completed their education without ever finding out about the nearly 1,400 libraries in the depository network.

Contacting City Hall, the planning board, and county government officials, plus informing the local office staff of your Member of Congress and state legislator to inform them of depository services available to their constituents are additional public awareness tactics. Conducting a workshop which includes faculty, non-depository librarians, and even campus branch librarians to teach them the nuances of locating government information is another idea. Other ideas can be found in Chapter 7 of the Federal Depository Library Manual or in the Proceedings of the 3rd Annual Federal Depository Library Conference (1994).

Administration

Have you talked with your boss lately about the Federal Depository Library Program? Tips of communicating depository needs to the library administration also appeared in the Proceedings of the 3rd Annual Federal Depository Library Conference on pp. 149-158. I hope you are not waiting for six years until we act as your advocates.

Does your library administration appreciate the monetary value of materials added to the collection in return for the obligation to provide public access? Occasionally, we are asked about the value of materials shipped to an individual depository, especially after a new library administrator is hired. It is impossible for GPO to accurately determine the figure because only about 20% of what we distribute is available for sale, 60% is in microfiche, and, except for the regionals, all other depository profiles are different. We recommend that staff locate prices for essential documents including costly CD-ROMs in the U.S. Government Subscriptions catalog, Publications Reference File, Census Catalog and Guide, etc., to approximate value.

Are sufficient statistics maintained on the number of titles and pieces added and withdrawn from the collection to accurately reflect your workload? Maintaining statistics on the number of questions answered by documents, or not answered because material was lacking, can validate that increased needs of patrons require a larger staff, added space and equipment, etc. Counting the number of pieces circulated is a standard practice and since so many Federal documents never leave the library, you may wish to count and mark documents, maps, CD-ROMs, and microfiche prior to reshelving.

Rating

After bombarding the documents librarians with questions such as the ones I have just enumerated, completing the questionnaire is the next step. Each library is rated in seven categories: Collection Development; Bibliographic Control; Maintenance; Human Resources; Physical Facilities; Public Service; and Cooperative Efforts. Regional libraries are rated in an additional area.

In February 1993, the nearly 20-year practice of assigning point scores for each question and ratings of Excellent, Good, Satisfactory, and Unsatisfactory in each category was abolished because they so often created unnecessary tension, negotiation, and competition among libraries. Instead, we substituted Compliance and Noncompliance. We are interested in the basics of access, custody, maintenance, and service, not whether a library scored a 71 or 83 on the day of the inspection. After the compliance review, the Inspection Report and recommendations are forwarded to the library director, documents librarian, and regional librarian.

Ratings among the over 200 libraries inspected in a year approximate the Bell curve. Few receive compliance in all categories and the majority fail in one or two areas. However, if a library earns noncompliance ratings in three or more categories, which is about 3% per year, it is placed on probation for the legally mandated probationary period of six months. A re-inspection is scheduled at a later date. The majority of probationary depositories make significant improvement in the deficient areas and are removed from probation. Some others have voluntarily relinquished depository status. In my 13 years, I can count on one hand the number of libraries GPO has terminated from the program.

At day's end, the inspector meets privately with the library director in an exit interview to provide an oral summary of the inspection findings. Inspectors use the ratings as a skeleton. Our narrative comments elaborate certain findings plus offer suggestions and positive strategies to strengthen the depository operation.

From the beginning of the program in 1972, inspections were viewed by both GPO and the library community as a positive supportive experience. Each library is different. Its patrons' needs and operating constraints are unique. However, every director of a depository library signed a contract entitled "Acceptance of Designation as a Depository Library for United States Government Publications."

The pertinent paragraph states in part "it is hereby agreed that this library and its staff will abide by the law governing depository libraries and such regulations and instructions as have been or may be issued by the Superintendent of Documents in administering the law."

It is a fact that a library requests depository designation in its own self-interest. Precious acquisitions funds can be allocated elsewhere now that a source for free material has been found. It is unfortunate that some depositories are under the misapprehension that they are not required to comply with sections 1909 and 1911 of Title 44 which the Superintendent of Documents is entrusted with safeguarding. Libraries which cannot or will not comply with the stipulation of being accessible to the public should voluntarily relinquish depository status.

To sum up, GPO monitors depository libraries through the inspection program which has also proven beneficial to GPO. Regularly scheduled examinations are cost-effective and valuable for this agency since continuing problems in a depository usually mean an increased investment of time and resources on GPO's part. An efficient and effective Federal Depository Library Program is in everyone's best interest. Our investigation offers the documents librarian a chance to exchange information, make suggestions for improvements at GPO, and reinforce our mutual commitment to provide the American public with easy access to Federal Government information.