[Nhcoll-l] Information Collection Request -Documenting, Managing and Preserving DOI MuseumProperty....

[Norris, Christopher]

I want to echo the comments made by many others on the list regarding the need to read and comment on Information Collection Request (ICR) entitled "Documenting, Managing and Preserving DOI Museum Property Housed in Non-Federal Repositories." Comments on this are due on 5 March. This is an important issue for the US collections community.

Before you do this, you should read the documents - including the supporting materials - carefully and understand why the information is needed and what you might be asked by agency staff or their contractors if this request is approved. There's still quite a lot of confusion in some quarters. For example, this is an information request, not a new regulation, or a law. It doesn't place any legal obligations on you that you didn't have before, and while there are real issues regarding ownership of certain categories of specimen, this ICR will not change the situation with regard to ownership.

Most of the comments published to date have focused on the negative aspects of this information request in terms of increased reporting burden... appropriately so. But you need to understand exactly what that burden will be for you; remember, you almost always have the opportunity to say that you don't have, or cannot easily obtain the information. You should also take some time to weigh the burden against the ways in which your collections might benefit from this exercise. Can it be used to highlight problems or challenges that you face? Will it let you begin a dialogue with your colleagues in the agencies about the need for additional resources for curating the collections held at your institution? Will it help them make a better argument to their own management for these resources?

Something else that might not be clear from the documents is that once an ICR is approved, it must be reapproved by OMB every 3 years.  That means that everyone concerned can evaluate what has happened over the intervening years and then comment on it when the ICR reapproval is again published in the Federal Register.  So If the process turns out to be excessively burdensome in practice, there's another opportunity to have it amended.

Within SPNHC we've been taking time to review the documentation and talking to our colleagues in the agencies and other non-federal organizations. We''ll be making a formal response later this week and I would urge anyone with an interest in seeing these collections better documented and managed to do the same.

Chris


PS: if you haven't seen DOI's supporting documentation for this request, here's how to access it:

Go to http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201412-1084-001

Once there, click on the "View Information Collection (IC) List" link to access the Checklist and other materials and the "View Supporting Statement and Other Documents" link to access the Supporting Statement (it's the first item in the "ICR Documents" list on that next page).

=============================
Dr. Christopher A. Norris
Division of Vertebrate Paleontology
Yale Peabody Museum of Natural History
170 Whitney Ave.
PO Box 208118
New Haven, CT 06520-8118

Past President
Society for the Preservation of Natural History Collections
www.spnhc.org<http://www.spnhc.org/>

Tel. +1(203)-432-3748
Fax. +1(203)-432-9816
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