Dr. BAHMER. This listing tells the public (a) what records must be kept, (b) who must keep them, and (c) how long they must be kept. As a result of this publication and our consultation with Federal agencies, the published listing has been made more complete and retention periods have been established or shortened. These measures directly benefit the public and the industry.

GSA is also working with the Department of Defense on the problem of records retained by defense contractors. Provisions of cost-type contracts require contractors to maintain certain records the cost of which is ultimately passed on to the Government. Our objective is to reduce the cost of maintaining contractors' records and to prescribe the shortest possible retention periods. Similar steps are planned for the records of contractors of nondefense Federal agencies.

This concludes our prepared statement, Mr. Chairman, which has been a rather quick summary of those activities of the General Services Administration which are closely related to the objectives of this subcommittee. However, we shall be happy at this time to answer any questions which you or the members of your subcommittee may wish to ask or furnish the desired information for the record.

Mr. OLSEN. Thank you, very much, Dr. Bahmer, and your assistants, for coming here. We find your statement to be most enlightening and valuable.

Doctor, we had somewhere in our hearings objections to the fact that some corporations must retain records for the purposes of the Internal Revenue Service for 30 years. Do you folks have any authority to advise IRS?

Dr. BAHMER. We do not have any authority to require any Federal agency to change what it has imposed as a retention requirement. We do have some skill in the arts of persuasion, however, and as a result of our exposing to public view the retention requirements, in the last issue of the Federal Register publication I gave you, many of these retention requirements have been shortened.

Mr. OLSEN. We certainly want to commend you and your organization for what you have been doing in this program in form simplification.

I am not clear from your statement who has the overall responsibility for forms clearance and review in the Federal Government.

Dr. BAHMER. The basic responsibility for development of forms lies with the individual agencies except for two categories_called standard forms and optional forms. The Bureau of the Budget under Executive Order 8248 of September 8, 1939, provides official clearance for standard and optional forms. These are forms used by more than one agency.

Many forms are in fact public reports. They are covered under the Federal Reports Act of 1942 and are administered by the BOB. Bureau of the Budget Circular A-17 of November 14, 1959, covers both standard and optional forms. We do play a part in this process. The Bureau of the Budget does the clearance, but our contribution has been in the development of optional forms where we feel they are required. These are forms which serve administrative purposes and which can be standardized. For instance, that two-way memorandum that I mentioned that was furnished for the record is a type of optional form. It is not required for use by agencies but encouraged, if you will.

Mr. OLSEN. Before a form can be adopted by an agency for reporting by the private citizen, must that form be approved?

Dr. BAHMER. Yes, if it imposes on the public a reporting requirement, both a form and a report, it is covered by the Federal Reports Act. This is a Bureau of the Budget responsibility.

Mr. OLSEN. Yours is always advisory responsibility?

Dr. BAHMER. Yes, and developmental to the extent that we are working in a number of areas to develop optional forms to eliminate the added expense of every agency having its own individually designed form.

Mr. OLSEN. When you develop an optional form for several agencies, is there any authority in the Federal Government to impose that form on all of the agencies?

Dr. BAHMER. Not unless it would be in the Bureau of the Budget. We have no authority to impose use of that kind of form on Federal agencies.

Mr. OLSEN. I think we ought to research that out with the Bureau of the Budget on how much authority they have to impose a form on the several agencies that might be using the same material.

Mr. ABELE. Mr. Chairman ?

Mr. OLSEN. Yes.

Mr. ABELE. Has your Department made a study on this-I see you have one on the administrative procedures-where they sent out their requirement for the retention form? Have you also made a study on the statute requirement?

Dr. BAHMER. You mean for the keeping of records?

Mr. ABELE. Yes.

Dr. BAHMER. Yes; this is a very important item in the disposal of a great quantity of Federal records and the statute of limitations comes in particularly where there is any fiscal record being kept. Mr. ABELE. How long has it been since that study was made?

Dr. BAHMER. We are practically continually in that business. Take the matter of canceled Government checks, which are now held I believe 7 years. The statute of limitations, I think, is 6. GAO, the Treasury Department, and we have agreed that we will hold them 1 additional year, just to be safe. This is taken into account when disposal periods or retention periods, whichever you call them, are being studied for particular lots of records; this is important at all times. Now if your question is directed as to whether the statute of limitations ought to be changed, this we have not studied. This is not really within our field of jurisdiction.

Mr. ABELE. There are probably quite a few statutes on the books now that require retention of forms that probably set the period of time.

Dr. BAHMER. Not as many now as there were 12, 15 years ago. Mr. ABELE. Since 1946?

Dr. BAHMER. We made an analysis about 10 years ago of all statutes that had to do with retention. We found, for instance, that inspection of grain appeal certificates were to be held, the connotation was, permanently. All of this has been changed within the last 10 years, but we cannot say that we have covered them all.

Mr. ABELE. Perhaps you would still have a copy of that order or study?

Dr. BAHMER. I am sure that we could find it. It is probably about 12 years ago.

Mr. ABELE. I imagine that would be very interesting to see.

Dr. BAHMER. There were a great number that we covered in that study.

Mr. ABELE. Thank you.

(The results of the study were largely incorporated in H. Rept. 1102 82d Cong., 1st sess.; S. Rept. 786, 82d Cong., 1st sess; and Public Law 209, 82d Cong., 1st sess.)

Mr. OLSEN. In that regard, it would perhaps be well if we had another study now, once every 10 years; that would probably be that kind of a study.

Dr. BAHMER. We probably could well afford it, sir.

Mr. OLSEN. Well, you would look to the Appropriations Committee. You have the authority and the money. You could make such a survey again.

Dr. BAHMER. Yes; we have the authority to make that kind of study, of course. In the end we would recommend action to the Congress. Mr. OLSEN. Certainly.

Mrs. St. George?

Mrs. ST. GEORGE. Dr. Bahmer, my attention has just been called to a sentence here in this Federal Register which you have sent up to us. It calls attention to the requirements on page 3055 and it states in the third column:

* * * retention periods, so long as the contents thereof may become material in the administration of any Internal Revenue Law, 26 CFR, 16001 (see also 14461– 14531), dealing with accounting methods and periods.

It seems to me as I read that, and I must say it is a little hard to read but it can be done, that this would almost mean an indefinite period, would it not?

Dr. BAHMER. I am not familiar with that particular item, but from the way you quoted it, I am sure that it would confuse me and probably the average citizen. Probably it might mean almost permanently. Mrs. ST. GEORGE. I would think so.

Dr. BAHMER. Perhaps not permanently in an archival sense. Mrs. ST. GEORGE. Obviously there is not a statute of limitations on that, which I must say I find a little surprising, Mr. Chairman. Mr. OLSEN. I agree with you.

Dr. BAHMER. Mr. Chairman, I would also like to point out that the Federal Register publication that I sent up to you is simply a special edition. The actual legal publication of each one of those requirements occurred in daily Federal Registers and is codified in the code. This in itself does not represent anything but an index and a quick guide. If any individual or business wants to find out what the actual wording and requirements are, he should go to those references. thought it desirable to bring them all together where they could be looked at.

We

Mr. OLSEN. That is a very valuable publication, all that information in one edition.

Mrs. ST. GEORGE. I think so.

Dr. BAHMER. Mr. Chairman, just exposing the requirements to the public affected a considerable number of forms in the retention and disposal stipulations.

Mr. OLSEN. The other thing I would like to have from you is the sketch of other paperwork savings programs, for example, streamlined letter writing, mail flow, and files practices. Could you do that? You would probably be helping my office, never mind everybody else's. Dr. BAHMER. Mr. Chairman, we have handbooks in both of these fields which enunciate principles and practices, procedures, techniques and doctrine, which we feel are desirable in these areas. We have also developed workshops that are practical, as I said, in how to do such things as the handling of mail, the writing of plain letters, the preparation of guide letters, form paragraph, the actual maintenance of files, and that sort of thing. I would be happy to furnish those for the committee's files.

Mr. OLSEN. I would like to have a set of them for myself.

Dr. BAHMER. I will be very happy, Mr. Chairman, to do that. Beyond that, we have a series of publications which we supply to Members of Congress on request for actual technical assistance of the type that we give to other Federal agencies. We have two congressional handbooks that deal with the organization and maintenance of the records that have accumulated in the offices of the Members of Congress. We have one member of our staff who, I believe, gives almost full-time assistance in the establishment of the records in the offices of Representatives and Senators. One of the handbooks deals with records of congressional committees; one on the records of Representatives and one on the records of Senators.

Mr. OLSEN. I am interested and certainly would like to have all of those handbooks.

Dr. BAHMER. I will see that they are sent to you. I do not believe we have them with us here today.

Mr. OLSEN. Mr. Abele and Mrs. St. George say they want them,

too.

Dr. BAHMER. We will be more than happy to furnish them to members of the committee.

Mr. OLSEN. Thank you very much, Dr. Bahmer, and thanks to your staff for coming here.

We have to hurry along to our other presentation for this morning, but we find what you have presented to us most valuable and very heartening indeed, to find an agency working hard at this problem of eliminating paper work.

We are interested, of course, in stopping the forms before they develop.

Dr. BAHMER. We are, too.

Mr. OLSEN. Of course, after they are developed we should attempt in every way to either eliminate them or certainly simplify them, consolidate them and make as little paperwork as possible. Thank you very much.

Dr. BAHMER. Thank you, Mr. Chairman.

Mr. OLSEN. Our next witness is Dr. Harry C. Trelogan. Do you have some folks with you?

Dr. TRELOGAN. Yes; I do.

Mr. OLSEN. Please bring them to the table.

If you will please introduce the people with you in the order in which they are seated from your left to your right and then proceed as you wish.

Dr. TRELOGAN. I would like to first introduce the gentleman on my left, Mr. J. Richard Grant, who is with the Statistical Reporting Service and who serves as Department clearance officer for statistical surveys and reports requested of the public; on my right I would like to introduce Mr. Nathan M. Koffsky, Administrator of the Economic Research Service, who will present the Economic Research Service statement; on his right is Dr. Kenneth E. Ogren, Director, Marketing Economics Division, Economic Research Service; and on the extreme right is Mr. Melvin L. Koehn, who is Secretary, Crop Reporting Board, Statistical Reporting Service.

Mr. OLSEN. Thank you very much.

You may proceed now as you will; present your statement in any way you wish.

STATEMENT OF HARRY C. TRELOGAN, ADMINISTRATOR, STATISTICAL REPORTING SERVICE, DEPARTMENT OF AGRICULTURE; ACCOMPANIED BY NATHAN M. KOFFSKY, ADMINISTRATOR, ECONOMIC RESEARCH SERVICE; MELVIN L. KOEHN, SECRETARY, CROP REPORTING BOARD, STATISTICAL REPORTING SERVICE; KENNETH E. OGREN, DIRECTOR, MARKETING ECONOMICS DIVISION, ECONOMIC RESEARCH SERVICE; AND J. RICHARD GRANT, DEPARTMENT CLEARANCE OFFICER, STATISTICAL REPORTING SERVICE

Dr. TRELOGAN. I would like to make the point, Mr. Chairman and members of the subcommittee, that as Administrator of the Statistical Reporting Service, I am here in a kind of dual capacity. By delegation from the Secretary of Agriculture, I am responsible for the coordination of statistical work throughout the Department, and was asked by the Secretary to make arrangements for the presentation requested here today for the Economic Research Service as well as the Statistical Reporting Service. I now also report for the Statistical Reporting Service.

Mr. OLSEN. Fine.

Dr. TRELOGAN. Mr. Chairman and members of the subcommittee, I believe it will be helpful to the committee's understanding of our response to your request if I take a few moments to outline the responsibilities and functions of the Statistical Reporting Service. As the general-purpose statistical agency for the Department of Agriculture, SRS has as its primary function the collection of basic data on a wide range of subjects, frequently referred to as "crop and livestock estimates" which include agricultural production, inventories, prices paid and received by farmers, and farm labor and wages. Over 700 statistical releases are issued each year, their general purpose being to enable farmers, agri-businessmen, legislators, and policymakers to make more intelligent decisions. The data are collected, for the most part, through the facilities of 43 State statisticians' offices covering all 50 States. Data collection techniques used include mail, telephone, and personal interview surveys, but to a large degree we are dependent on the voluntary return of mailed inquiries by farmers, merchants, dealers, food processors, and others concerned with agriculture.