Second Report to
Congress on The Joint Resolution to Establish a National Policy on
Permanent Papers
December 31, 1993
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LETTER OF TRANSMITTAL
To the Clerk of the United States House of Representative and the
Secretary of the United States Senate:
Pursuant to the provisiion of Public Law 101-423, the Librarian of
Congress, the Archivist of the United States, and the Public Printer
herewith submit the second report in accordance with section 3 of the
Joint Resolution to Establish a National Policy on Permanent Papers.
Respectfully,
James H. Billington
The Librarian of Congress
Trudy Huskamp Peterson
Acting Archivist of the United States
Michael F. DiMario
Public Printer
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I. Introduction
Public Law 101-423 (Permanent Paper) was passed by Congress and
signed by the President in October 1990. The law states in Section 1
that "It is the policy of the United States that Federal records, books,
and publications of enduring value be produced on acid free permanent
papers." In Section 3, the law further specifies that the Librarian of
Congress, the Archivist of the United States, and the Public Printer
shall jointly monitor the Federal Government's progress in implementing
the national policy declared in Section 1 regarding acid free permanent
papers, and shall report to the Congress regarding such progress on
December 31, 1991, December 31, 1993, and December 31, 1995. This is the
second of the three required reports. It summarizes actions and events
during 1992 and 1993 that have supported and assisted implementation of
the law, and also discusses actions and events that have the potential
for hampering the rate at which implementation moves forward.
As stated in the 1991 report, statutory authority for determining which
publications and records have enduring value is assigned to the Archivist
of the United States. The National Archives and Records Administration
(NARA) approves schedules drawn up by each Federal agency that define the
agency's records that have enduring value. Although some records can be
clearly identified at the point of creation as having enduring value, no
agency can identify at the time of creation all records that do, or will,
have enduring value.
The ideal solution, therefore, would be to create all Federal documents
on permanent paper. However, since the cost of procuring permanent paper
(paper that meets the standards of JCP A270) for all documents would make
across-the-board purchase of permanent paper unfeasible, the 1991 report
recommended an interim step. It suggested that all publications and
records that are clearly permanent at the time of creation should be
produced on permanent paper and all others should be produced on alkaline
paper.
II. Summary
Several steps were taken in 1992 and 1993 toward establishing a
government-wide alkaline paper standard:
- NARA developed a draft bulletin to heads of Federal agencies
advising them to use alkaline paper for all Federal records.
- The Joint Committee on Printing's (JCP) Advisory Council on
Paper Specifications added an alkaline option to several grades
of papers.
- The Government Printing Office (GPO) continued to monitor the
acid or alkaline composition of paper used in jobs procured
through GPO's printing procurement offices.
- The lead agencies decided to propose the development of an
education and training program that would present to Federal
employees the issues surrounding the use of permanent paper.
Issues for future consideration were identified:
- The possible difficulty in monitoring the Federal Government's
progress in increasing the use of permanent paper if Government
printing is decentralized.
- The anticipated difficulty of acquiring off-the-shelf papers
that are alkaline if they also contain higher levels of
postconsumer waste paper.
- The composition of "permanent" papers. How much lignin can be
present in paper without compromising permanence?
III. Implementation of PL 101-423
Dissemination of information. Working toward the goal of establishing
a governmentwide alkaline paper standard, NARA developed during 1993 a
bulletin (in the final stages of release) to the heads of Federal
agencies. The bulletin will advise agency heads of the permanent paper
policy established by Public Law 101-423, will suggest initial steps
agencies should take to implement that policy, and will advise agencies
to use alkaline paper for all Federal records.
Early in 1994, NARA plans to hold a roundtable meeting for records
management officials from representative Federal agencies for the purpose
of discussing the draft bulletin. The questions, suggestions, and
concerns advanced by participants will be used to refine the bulletin.
The completed bulletin is scheduled for dissemination to agency heads in
mid-1994 and is to be accompanied by guidance for procuring alkaline
papers for Federal records.
Paper standards and specifications. The 1991 report to Congress noted
that the Joint Committee on Printing's Advisory Council on Paper
Specifications had issued two additional cost-competitive alkaline-based
paper specifications. These were for a general printing paper and a
paper suitable for xerographic and laser printing. During 1992 and 1993
the Advisory Council added these lower-cost alkaline paper options to
many more grades of papers, including cover paper. It also provided that
coated papers can be specified to have an alkaline coating and base
sheet.
In 1991 only one permanent paper specification (JCP A270) was available
for Government publications and printing that required a paper stock
having maximum longevity potential and durability. Two new permanent
paper specifications are now available. They are JCP G-40 (Option A),
a 25% Bond paper suitable for letterheads; and JCP O-60 (Option A) a
plain copier, xerographic paper suitable for photocopiers and laser
printers. All three papers are typically much more expensive than the
simple alkaline sheet.
Monitoring GPO publications. In recent years the demand by Government
publishers and librarians for more "permanent" paper has increased.
Since contemporary permanent papers are alkaline, it is fortunate
that, primarily for economic reasons, the paper industry is gradually
switching from the production of acidic paper to the production of
alkaline paper. As a result, some Government publications and documents
have been produced on alkaline paper (with no increase in paper cost)
when alkalinity was not specified.
To monitor the Government's progress in implementing the national policy
for acid free permanent papers, the GPO's paper testing laboratory has
been routinely measuring the acid content of paper used in jobs procured
through the GPO printing procurement offices. In FY93 tests were
conducted on paper procured for 2,055 (out of 254,214) federal agency
jobs. The sampling plan included a 100% selection of printing jobs
procured at quality levels 1 and 2 (of five levels with level 1 being the
highest), and approximately 10% of printing jobs procured at levels 3 and
4. Samples for the latter tests were selected randomly. Results are
shown in Table 1. Table 2 shows the breakdown of the major grades of
papers included in the GPO survey by alkalinity, and by its distribution
among the total jobs examined.
Table 1. Results of acid/alkaline tests on randomly selected procured
printing samples (the coating on coated papers is typically alkaline).
Paper Type Percent of Samples
Uncoated, alkaline sheet 36
Uncoated, acidic sheet 15
Coated, alkaline base sheet 45
Coated, acidic base sheet 4
TOTAL 100
Table 2. Results of acid/alkaline tests, by paper type.
Type of Paper % Alkaline No. of samples
A60 77 514
A180 (coated) 93 288
D10 84 185
A80 90 82
A170 (coated) 73 62
L20 41 41
A240, A260, L10 (coated) 95 349
Other (coated, uncoated) 534
TOTAL 2055
Almost half of the publications monitored were printed on coated paper
because all level 1 and 2 jobs, which are typically produced on coated
papers, were part of the sample. Thirty-five percent of all monitored
coated paper is represented by the following grades of paper.
A170 (publication-grade, gloss coated text paper)
A180 (gloss coated text paper)
A240 (matte-finish, coated text paper)
A260 (dull-finish, coated text paper)
L10 (gloss-finish, cover paper)
Of the uncoated papers, 40% were printed on the following four grades of
paper.
A60 (offset book paper)
A80 (opacified offset book)
D10 (writing paper)
L20 (vellum-finish cover paper)
Bulk purchases. For the GPO's FY93 quarterly term (requirements)
contracts for bulk paper purchases, 83% of the paper supplied was
alkaline (compared to 81% in FY92). These figures show that GPO receives
a high percentage of alkaline paper when alkaline paper was not
specifically required.
In GPO's bulk purchases, the amount of alkaline paper received was
unaffected by the requirement that recycled fibers be included in the
paper's composition.
Typically, for those procurements that require a high percentage of
postconsumer (PC) recovered fiber content (10%, 15%, 20%, or higher) the
specification requirement for pH was revised upward to a minimum of pH
6.5. The pH value was intentionally raised to counteract possible
adverse effects of undesirable or unsuitable fibers (e.g., trace
groundwood or lignin-containing fiber) that may have entered a paper
mill's wastepaper source as a contaminant when it is purchasing
postconsumer recovered material to meet the Government's PC requirement.
The change in the minimum pH value to 6.5 from 4.5 on these highly
recycled grades has been a problem for only one Government paper supplier
thus far.
The GPO also buys a few grades of paper that require a minimum pH
7.0 value. On these grades, the quality of competition (e.g., number of
bidders) has not declined. These papers have also been available with
a highly sorted recycled fiber content (50% waste paper, as defined under
EPA's Guideline for Federal Procurement of Paper and Paper Products
Containing Recovered Materials). Thus far, GPO has not attempted to
purchase these papers with a postconsumer recovered material content.
IV. Education and Training
The GPO has demonstrated that alkaline paper costs should be no more
than acidic paper of the same grade. It has also shown that alkaline
papers are routinely furnished on Federal contract without being
specified. Such activity indicates that availability and the level of
competition for alkaline paper is substantial. GPO has, in at least one
instance, specified an alkaline paper, and discovered upon testing it,
that an acidic paper was furnished. If this experience repeats itself,
it may portend a pattern of "hit and miss" in contractual requirements
and deliveries that can only be overcome through the development of an
education and training program for both vendors and Federal procurement
officers.
The lead agencies plan to develop a short lecture/seminar format as the
ideal vehicle to relay to Federal users the issues surrounding permanent
records. Pertinent extracts of the lecture/seminar, in an easily
distributable form, will be made available to industry suppliers. The
objective of the education program through this format is to present
guidelines on a variety of subjects, such as how to identify records of
enduring value, how to select paper specification standards, and what
manner of documentation should be required of suppliers to assure that
the paper ordered is that which was specified. To preclude costly
administrative remedies in rectifying selection and acquisition
mistakes, it is imperative that mistakes be diminished or, preferably,
eliminated. This objective can only be accomplished through education
and effective monitoring.
V. Concerns
Impact of Executive Order 12873 of October 20, 1993: Federal Acquisition,
Recycling and Waste Prevention. In its individual update in Part V of
the first report to Congress, the Government Printing Office stated:
. . . the presorting of postconsumer waste would have to be
performed at a high degree of competence to exclude paper and
paper products that contain groundwood fibers. The
introduction of groundwood fiber into the source material
would be detrimental to the enduring qualities of the paper
and defeat the purpose for which it was manufactured.
Although it might appear from Section 505 (Revision of Brightness
Specifications and Standards) of the executive order that the concern
expressed for years is in danger of becoming reality, this is not the
case. The inclusion in standards or specifications of unbleached fiber,
other lignin-containing fibers, or groundwood, would be evaluated,
revised, or eliminated in circumstances related to performance. The lead
agencies interpret Section 505 of the executive order to state that
permanence is without a doubt a factor of performance and that the
Section will therefore have little or no effect on the acquisition of
permanent papers. The rationale behind this conclusion is embodied in
Federal Acquisition regulations and case law where:
Agencies shall prepare specifications and purchase
descriptions which reflect the MINIMUM NEEDS of the agency and
the market available to satisfy such needs. Specifications
and purchase descriptions may be stated in terms of . . .
performance, including specifications of the range of
acceptable characteristics or of the minimum acceptable
standards. (FAR 10.002) (Editor's note: emphasis added.)
The lead agencies agree that both permanence and the inclusion of a
recovered materials content can be achieved. There are, however, two
caveats. First, Federal agencies must be vigilant and rigorous in
determining and specifying their minimum needs for acid free paper.
Second, as the amount of postconsumer materials increases so must the
volume and degree of presorting for a suitable source material (e.g.,
compatible to permanence) increase. Increased presorting will result in
higher cost. In an effort to contain cost, the time will eventually come
when the Government will have to balance the costs associated with
requiring presorted recovered source material, suitable for use in
permanent paper without further processing, against those associated with
accepting unsuitable source material (groundwood) that requires further
processing.
SMALL-QUANTITY PAPER PURCHASES. While bulk or large-lot purchases of
permanent or alkaline paper containing postconsumer recovered materials
are not anticipated to be affected by the new executive order, the
acquisition of small quantities that contain higher levels of
postconsumer recovered materials will be difficult for the Government and
small commercial printers. Small quantities, defined as "off-the-shelf,"
approximate 200,000 tons (42%) of the Government's paper use per year.
Off-the-shelf quantities are used for printed materials produced by
agency printing plants or through commercial printing contracts.
Since the implementation of the Environmental Protection Agency's
Guideline for Federal Procurement of Paper and Paper Products Containing
Recovered Materials, GPO has been monitoring the paper usage in
commercial printing contracts. The data indicate that the EPA Guidelines
which define recycled fibers as waste paper have not affected the quality
or availability of the most common off-the-shelf paper grades (for
example, offset book paper). Manufacturers typically produce over 75%
of these common printing papers with an alkaline chemistry.
However, the new executive order encourages paper mills to produce paper
that contains higher percentages of postconsumer waste. The Government
may have difficulty purchasing paper that meets the new postconsumer
recovered materials content requirements. The two primary reasons for
this potential problem are: the Government's share of the market is
small; and few paper supply companies have the capacity to store small
quantities of the myriad brands and grades of paper that the Government
purchases.
DEFINITION OF PERMANENCE. Both the ANSI standard Z39.48-1984
(permanent paper) and the recently adopted International Standards
Organization (ISO) standard on permanent paper (ISO DIS 9706 -
Information and Documentation - Paper for Documents - Requirements for
Permanence) are in accord in defining a permanent paper as having several
properties.
These include an alkaline pH (pH 7.5-10), an alkaline reserve of at least
2%, minimum tear resistance requirements that are similar, and a paper
stock that is essentially fully bleached, which means that only a very
low level of lignin (the component of wood pulp that is removed by
bleaching) is acceptable in permanent papers. A standard guide drafted
by the American Society for Testing Materials (ASTM), Standard Guide for
the Selection of Permanent and Durable Offset and Book Papers also
permits a low percentage of lignin in permanent papers.
The low lignin requirement has generated opposition from the
papermaking industry, particularly those producers who use bleached
chemi-thermo-mechanical pulps (BCTMP, CTMP) or who are not bleaching
their pulps thoroughly. Papers currently produced by these manufacturing
processes contain a level of lignin high enough to cause the paper to
discolor significantly with exposure to light. The papermakers using
these processes argue that the properties essential for permanence are
not compromised by the presence of lignin. Neither the archival and
library communities nor the manufacturers producing paper that meets the
ANSI Z39.48-1984 and ASTM standards concur with this view.
The ANSI committee that revised the Z39.48-1984 standard has recommended
that a research program on the effects of lignin on paper properties be
undertaken prior to or in conjunction with the next revision of this
standard. ASTM has scheduled a seminar on the influence of fiber
composition on printing and writing paper permanence that will address
essentially the same questions as the proposed ANSI research program.
The lead agencies are watching these developments closely.
Currently, the methods of producing very low lignin paper or bleached
"free sheet" (groundwood-free) that minimize the production of dioxins
are to bleach without chlorine-containing compounds. Although paper
mills are experimenting with alternative bleaching methods, the needed
quantity of free sheet bleached without chlorine-containing compounds is
not available in the United States. At the present time, the inclusion
in specifications of increasing amounts of postconsumer waste and of
non-traditional methods of removing lignin will probably result in higher
cost for papers that must also have the strength and chemical properties
necessary to assure longevity.
DECENTRALIZED PRINTING. Changes in publishing technology and dispersal
of the printing functions in the Government may reduce ability to monitor
effectively the implementation of Public Law 101-423. In publishing, for
example, the use of desktop publishing software -- an increasingly
popular method of producing documents -- allows the individual creating
the document to select the paper on which the document will be printed.
The paper selected may or may not be the permanent bond paper that meets
or exceeds the requirements of JCP A270.
Similarly, if the Administration's proposed legislation is adopted that
the number of formal Government publications through GPO be reduced, the
selection of paper will be made by the procurement operation of the
publishing agency. Routine testing through the GPO has allowed the lead
agencies to monitor the use of alkaline and permanent paper, and some
effective, coordinated, and systematic method of monitoring the quality
of paper used in Government publishing must continue. Otherwise, control
over paper quality is likely to be left to the discretion of individual
printing officers and procurement officials without the aid of archives
and library preservation professionals whose special expertise must be
brought to bear on this critical issue.
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APPENDIX A
104 Stat. 912, Public Law 101-423 -- Oct. 12, 1990, Public Law 101-423,
101st Congress
JOINT RESOLUTION TO ESTABLISH A NATIONAL POLICY ON PERMANENT
PAPER
Whereas it is now widely recognized and scientifically demonstrated
that the acidic papers commonly used for more than a century in
documents, books, and other publications are self-destructing and will
continue to self destruct;
Whereas Americans are facing the prospect of continuing to lose
national, historical, scientific, and scholarly records, including
government records, faster than salvage efforts can be mounted despite
the dedicated efforts of many libraries, archives, and agencies, such
as the Library of Congress and the National Archives and Records
Administration;
Whereas nationwide hundreds of millions of dollars will have to be
spent by the Federal, State, and local governments and private
institutions to salvage the most essential books and other materials in
the libraries and archives of government, academic, and private
institutions;
Whereas paper manufacturers can produce a sufficient supply of acid
free permanent papers with a life of several hundred years, at prices
competitive with acid papers, if publishers would specify the use of such
papers, and some publishers and many university presses are already
publishing on acid free permanent papers;
Whereas most Government agencies do not require the use of acid free
permanent papers for appropriate Federal records and publications;
Whereas librarians, publishers, and other professional groups have
urged the use of acid free permanent papers;
Whereas even when books are printed on acid free permanent paper this
fact is often not made known to libraries by notations in the book or by
notations in standard bibliographic listings; and
Whereas there is an urgent need to prevent the continuance of the acid
paper problem in the future: Now, therefore, be it
RESOLVED BY THE SENATE AND HOUSE OF REPRESENTATIVES OF THE UNITED STATES
OF AMERICA IN CONGRESS ASSEMBLED,
SECTION 1. It is the policy of the United States that Federal records,
books, and publications of enduring value be produced on acid free
permanent papers.
SEC. 2. The Congress of the United States urgently recommends that --
(1) Federal agencies require the use of permanent papers for
publications of enduring value produced by the Government Printing
Office or produced by Federal grant or contract, using the
specifications for such paper established by the Joint
Committee on Printing;
(2) Federal agencies require the use of archival quality acid free
papers for permanently valuable Federal records and confer with the
National Archives and Records Administration on the requirements for
paper quality;
(3) American publishers and State and local government use acid free
permanent papers for publications of enduring value, in voluntary
compliance with the American National Standard;
(4) all publishers, private and governmental, prominently note the
use of acid free permanent paper in books, advertisements, catalogs,
and standard bibliographic listings; and
(5) the Secretary of State, Librarian of Congress, Archivist of the
United States, and other Federal officials make known the national
policy regarding acid free permanent papers to foreign governments
and appropriate international agencies since the acid paper problem
is worldwide and essential foreign materials being imported by our
libraries are printed on acid papers.
SEC. 3. The Librarian of Congress, Archivist of the United States, and
the Public Printer shall jointly monitor the Federal Government's
progress in implementing the national policy declared in section 1
regarding acid free permanent papers and shall report to the Congress
regarding such progress on December 31, 1991, December 31, 1993, and
December 31, 1995. In carrying out the monitoring and reporting
functions under this section, the Librarian of Congress, the Archivist
of the United States, and the Public Printer may consult with the
National Endowment for the Humanities, National Agricultural Library,
National Library of Medicine, other Federal and State agencies,
international organizations, private publishers, paper manufacturers, and
other organizations with an interest in preservation of books and
historical papers.
Approved October 12, 1990.
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APPENDIX B
STATE AND LOCAL ACTION ON ACID FREE PAPER
Most action by state governments began in 1990 immediately following
passage of Public Law 101-423. The Federal policy focused attention on
and helped articulate the importance and benefits of using permanent
paper for public records. From 1990 to the present, the law has provided
an impetus and foundation for state governments and their constituencies
to define policies of their own. This trend can be seen in published
articles and conference sessions sponsored by such organizations as the
National Association of Government Archives and Records Administrators
(NAGARA).
To date, many states have followed the government's lead in
establishing policy for the use of permanent papers. For example, the
state governments of Arizona, Colorado, Connecticut, Indiana, Montana,
Massachusetts, Nebraska, New York, North Carolina, Rhode Island, South
Dakota, Vermont, and Virginia have established legislative mandates for
the use of alkaline and permanent papers for public records. The Vermont
initiative, Bill 446, is particularly noteworthy because it has
successfully combined goals for enduring paper for public records and
environmental recycling. Several state governments have also pursued
administrative provisions to promote the use of alkaline papers. The
state of Florida, for example, has established alkaline paper
specifications and quality assurance testing that is applied by Florida's
General Services Department to state purchasing contracts.
