Alkaline Paper Advocate

Volume 9, Number 2
Jul 1996


Final Report to Congress on the Joint Resolution to Establish a National Policy on Permanent Papers

This is an abridged transcription of the 32-page document of the same name. The two tables have been minimally edited for clarity. All the appendices and the first three of the tables have been omitted, along with some of the passages that probably mean more to government employees than to the readers of this newsletter.

The document does not bear a date or publisher, but it was supposedly issued in December 1995 by the three agencies. The National Archives can supply copies on request: contact Bonnie Rose Curtin in the Office of Records Administration (301/713-7100).

Executive Summary

This report to Congress is the last of three in which the Librarian of Congress, Archivist of the United States, and the Public Printer summarize the Federal Government's progress on implementing Public Law 101-423. Much has been accomplished since the law was passed in October 1990, particularly during the period 1994 through 1995. Highlights of these achievements, discussed in detail in the following report, include:

Submission of this report discharges responsibilities assigned to the Librarian of Congress, Archivist of the United States, and the Public Printer, as set forth in Pub. L. 101-423. However, since important work remains to be done, they have agreed to continue monitoring, on an ad hoc basis, progress in the implementation of the Government's permanent paper policy.

Introduction

Public Law 101-423, A Joint Resolution to Establish a National Policy on Permanent Papers (Section 3), states the following:

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 ... 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.

The Librarian of Congress, the Archivist of the United States, and the Public Printer (the monitoring agencies) have been working together to monitor implementation of the law since it was signed by the President on October 12, 1990. In addition, the agencies worked jointly to enhance the general level of knowledge in the Federal Government about the national policy on permanent paper, and to ensure that Federal agencies understand the criteria to be used to determine whether documents have enduring (i.e., long-term) value. This report is the last of three reports to Congress required by Pub. L. 101-423.

Progress in Monitoring Pub. L. 101-423

Definition of permanence

Pub. L. 101-423 recommends the use of "acid free permanent paper" using the specifications established by the Joint Committee on Printing (JCP). For purposes of clarity, this report adheres to the JCP specifications. Thus, an acid free permanent paper is defined to be a fully bleached sheet with a pH of 7.5 or above, an alkaline reserve of 2 percent or more, a minimum MIT folding endurance in either direction of 30 double folds, and a minimum tearing strength in either direction of 25 grams for a 30 lb paper and proportionately higher tearing strengths for heavier papers. This definition matches most closely the first specification for permanent paper, ANSI Z39.48-1984, developed by the National Information Standards Organization, which has strong support in the archival and library communities.

Standards and specifications

Federal. When Public Law 101-423 was passed five years ago, the Government had only one specification for permanent paper: JCP A270, uncoated permanent book, white and cream white. [In July 1994, four new permanent papers were made available for government use]: JCP G40, 25 percent bond; JCP G60, 25% opacified bond; JCP H30, imitation parchment, laser-finished; and JCP O-60, plain copier, xerographic. A number of alkaline papers have been added as option A to many existing specifications. The specification standards advise that option A should be specified if the printed product must have above average performance. The alkaline option is available in 16 paper grades.…

The monitoring agencies have been working with the GSA to ensure that some of the same papers available to Federal agencies in the Washington, DC area through the GPO will be available nationwide. GSA now offers three permanent papers and two alkaline papers [four copier grades and one bond grade].…

[ASTM's standards for the permanence of paper are briefly described.]

In the course of revising these ASTM specifications, the question arose whether an alkaline paper might still be considered permanent if it also contained more lignin (a component of wood that is almost completely removed by "traditional" chemical pulping and bleaching) than any of the specifications allowed. Because lignin-containing papers have traditionally been produced by an acidic process, no studies of historic papers exist to which scientists can refer in their search for an answer to that question. Valid methods for determining the potential longevity of alkaline papers with a high lignin content are needed because increasing quantities of these papers are now coming on the market. To facilitate this research, valid and reliable methods of artificial aging must be developed. The Library of Congress Research and Testing Office has been engaged in such research for the past three years, and has recently received support from ASTM to accelerate this effort.

To spearhead this effort, ASTM (under the auspices of their Institute for Standards Research (ISR)) held a workshop in 1994 on the effects of aging on printing and writing papers. From this workshop evolved a series of research proposals pertaining to the development of aging methods using light, pollutants, heat, and humidity; and to the fundamental chemistry of the aging phenomena. The proposed research was estimated to require 3 years and to cost over $2.5 million. Although the research is not yet fully funded, initial work is proceeding on two projects. One is an investigation of the fundamentals of light aging to determine how aging can be accelerated without altering the chemical reactions from those that occur during natural aging. The second is an investigation of the effects of aging in low levels of air pollutants (including nitrogen dioxide, sulfur dioxide, and ozone).

International. The body that develops standards for the international community, the International Organization for Standardization (ISO), works closely with NISO. Thus, it is no coincidence that the requirements of the standard, ISO 9706, "Information and Documentation - Paper for Documents - Requirements for Permanence," are similar to those of ANSI standard Z39.48-1992. ISO 9706 differs slightly from ANSI Z39.48-1992 in fiber content (lignin, ground woodpulp, and unbleached pulp) and tear resistance measurement. In 1995, ISO developed a standard for archival papers, ISO/DIS 11108, "Information and Documentation - Archival Paper - Requirements for Permanence and Durability" (Appendix 3).

A number of countries have developed standards for permanent papers that will probably be replaced by the ISO standard. The most debated of these is undoubtedly the German standard, DIN 6738, which has not met acceptance from either the archival or library communities, even within Germany. Like the United States, the Canadian Government has established a policy on the use of permanent paper. However, in trying to devise specifications for that paper, it met with even stiffer resistance than had NISO, ASTM, or ISO to the requirement that the paper not contain a significant quantity of lignin.

As a result, the Government of Canada, together with the Government of Alberta and a consortium of Canadian pulp and paper manufacturers, joined forces to fund and carry out its own research program on the effect of lignin on paper permanence. This research may supplement the ASTM/ISR program. However, it concentrates on Canadian pulps and does not address the problem of light aging, so cannot supply all the answers.

Guidance to Federal agencies

On September 8, 1995, the National Archives and Records Administration (NARA) issued NARA Bulletin No. 95-7, "Procurement of Writing, Copying, and Printing Papers for Federal Records" (Appendix 4 ). The bulletin advises Federal agencies to procure either permanent or alkaline paper grades when creating all federal records. Permanent paper is recommended for routine use in offices that create and file a high proportion of long-term and permanent records, whereas alkaline paper is recommended for routine use throughout agencies for all other documents.…

The NARA bulletin was completed after extensive discussions with records officers, printing officials, GPO, and GSA. NARA representatives met with records officers to discuss drafts of the bulletin in order to ascertain problems that could arise in the agencies upon issuance of this guidance. Representatives also worked with GPO and GSA to ensure that adequate quantities of permanent and alkaline papers, a list of which is attached to the bulletin, were available to agencies for purchase.

Ordinarily, NARA bulletins are distributed to agency heads and records officers only. Since this bulletin has wide-ranging implications for the Government in the printing and procurement field, copies were also distributed to printing and procurement officials as well as to State Governors and records officials.

During the past 2 years, representatives of the monitoring agencies also spoke at conferences, meetings, and training courses on implementation of the Public Law (Appendix 5). The monitoring agencies perceive that if agencies are to grasp the significance of preserving permanent documents through the use of permanent and alkaline papers, more was needed than mere words in a bulletin. It was important to get out and physically communicate with those Federal officials that will have a major part to play in the implementation of the law.

Information dissemination

Federal. In addition to advising and assisting the Federal community, the monitoring agencies are communicating with all those who have a part in making Pub. L. 101-423 work. In 1994, the Librarian of Congress, Acting Archivist of the United States, and Public Printer sent each State Governor the "Second Report to Congress on the Joint Resolution to Establish a National Policy on Permanent Papers" to acquaint them directly with the law's agenda and encourage their participation (Appendix 6). Recently, the Archivist sent NARA Bulletin No. 95-7 and information on accessing this and other Federal records guidance via Internet to each State Governor, archivist, and records officer as a model for State and local action.

Efforts of the monitoring agencies have been strengthened by other Federal components in addition to the Joint Committee on Printing (JCP) and GSA mentioned throughout this report. The National Library of Medicine (NLM) sponsored a Permanent Paper Task Force from 1987 to 1991 to advance the use of alkaline-based paper for biomedical literature. When the task force began, only 4 percent of 3,000 journals indexed by NLM were on alkaline paper. This figure rose to 91 percent by April 1995.1 The Environmental Protection Agency, Department of Agriculture, Department of Defense, Smithsonian Institution, and other Government agencies have participated in meetings concerned with the quality of paper for Federal records, including the September 28, 1994, meeting of the NARA Advisory Committee on Preservation. Also the National Endowment for the Humanities and National Historical Publications and Records Commission, which fund public and private projects in support of our Nation's documentary heritage, mandate the use of permanent and alkaline papers for documentary materials and additionally maximize their longevity by prescribing appropriate storage materials and conditions.

State and local. ... States that have developed legislation or administrative policy on permanent paper include: Arizona, Colorado, Connecticut, Florida, Illinois, Indiana, Kansas, Kentucky, Massachusetts, Missouri, Montana, Nebraska, New Mexico, North Carolina, Rhode Island, South Dakota, Tennessee, Virginia, Washington, West Virginia, and Wisconsin. Some States are working to establish or strengthen provisions in response to opportunities afforded by a decrease in comparative cost and an increase in the availability of permanent papers. This progress is significant and laudable. However, it remains that over half of the States have yet to establish a permanent paper policy.

Private. The private sector role was pivotal in establishing Pub. L. 101-423 and has continued to be instrumental in its implementation as a partner to the Federal Government.…

National and international organizations associated with the information, history, science, and cultural resource community, including the American Library Association (ALA), Association of American Publishers (AAP), Society of American Archivists (SAA), National Association of Government Archives and Records Administrators (NAGARA), International Federation of Library Associations and Institutions (IFLA), and the International Council on Archives (ICA) have issued statements to support Pub. L. 101-423 as well as taking steps to promote it.…

International. [Government action to mandate or encourage the use of permanent paper is described for Australia, Canada, and France; and attention to alkaline paper and papermaking in the industry and the national press is pointed out.]

Government Printing Office statistics

Procured printing. For fiscal years 1994 and 1995, the alkalinity of the paper stocks used in approximately 2,500 commercially procured printing jobs was monitored by GPO. These papers were tested for pH value and alkaline reserve content. Samples of these commercially procured printing jobs were selected by GPO's Quality Assurance Section and represented all work at quality levels 1 and 2, and 10% at quality levels 3 and 4 (level 1 being the highest reproduction quality and level 4 the lowest). The inspection samples represent a fraction of the more than 200,000 jobs purchased by the GPO annually. This testing will continue.…

... Quality level 1 and 2 jobs are typically produced on coated papers. A high percentage of these were alkaline papers. The majority of government publications are actually produced on uncoated JCP A60 offset book text paper....

Table 4: Comparison of [Selected Grades of] Alkaline Paper Purchased* in FY 1994 & FY 1995

Papers

Percent [of total for each grade]

1994

1995

Percentage Points Difference

A60 offset book

77

89

12

A80 opacified offset book

75

95

20

D10 writing

84

58

-26**

K10 index

23

27

4

L20 vellum-finish cover

53

67

14

Uncoated, overall

69

79

10

A170 publication-grade, gloss coated text

69

88

19

A180 gloss coated text

94

98

4

L10 litho coated cover

95

96

1

Coated, overall

93

96

3

* For stocking in GPO, direct shipments, open market purchases, etc. [Does not include high usage text and cover.]

**This figure is affected by the amount of colored paper purchased per year because many colors can only be produced in an acidic papermaking process.

Bulk Purchases. … Even though GPO did not specify that the paper must be alkaline, nearly all of the book papers received (JCP A25, A55, A60, and A80) were alkaline.

Of the bulk purchase of office papers, all of the 25 percent and 50 percent cotton cut-size bond/writing papers (JCP G-series papers) purchased were alkaline in the current year. All the bulk-purchased recycled (20 percent PC) copier papers (JCP O-65 paper) were alkaline. Colored JCP O-60 copier paper was about 50 percent alkaline and 50 percent acidic.

There were only a few grades of acidic paper. One was a map paper grade (JCP E40, GPO Lot 94) which was specified to be acidic for the purpose of improving the sheet's ink drying characteristics. Often, colored index (JCP K10) and vellum-finish cover (JCP L20) stocks are also acidic so some of the colors desired by the customer can be attained. Alkaline papers are available for index and cover stock, but in fewer colors.

Observations/Relevant Findings

Environmental issues

During the 5-year period covered by Pub. L. 101-423, a number of pertinent events have occurred. First, the trend has continued in the paper industry to convert mills from acid to alkaline papermaking. This conversion can be attributed primarily to EPA regulations 40 CFR 430 - "Pulp, Paper, and Paperboard Point Source Category" that govern the amount and kinds of effluent that paper mills can discharge.5 Once conversion was underway, the lower cost of raw materials for alkaline papermaking made the change a profitable one.

A second development within the monitoring period was the issuance of Executive Order 12873, "Federal Acquisition, Recycling, and Waste Prevention."… Section 504 sets minimum content standards for postconsumer recovered materials in printing and writing papers, with a 20 percent requirement as of December 31, 1994, and 30 percent as of December 31, 1998 (for most of these papers).…

Section 505 directs agencies to revise or eliminate sections of standards or specifications that contain brightness or other specific pulp requirements if these requirements are not needed for a particular grade of paper to be functional. These two requirements appear to conflict with the policy set out in Pub. L. 101-423. However, the Federal Environmental Executive in a July 19, 1994, letter to the Director of the New York Public Library (Appendix 7) stated that all agency environmental executives would be notified that "the requirements for use of recycled paper are not to conflict in any way with the concurrent requirement for permanent paper use." Thus, provided that the requirements for permanent paper are met, any amount of postconsumer recovered material can be incorporated.

The purpose of section 505 is to eliminate unnecessary requirements for paper that result in the production of harmful byproducts such as dioxins. Dioxin is of particular concern because it has been shown to be a byproduct of papermaking when pulp is bleached with elemental chlorine (chlorine gas). For those not versed in industry technology or recent research, section 505 might appear to eliminate the purchase of bleached paper. This interpretation is erroneous for two reasons.

First, in the absence of research that provides other options, fully bleached pulp is a necessary component of permanent paper at this time. Bleaching removes the lignin from the pulp, which is necessary for permanence because lignin-containing papers have been shown to darken with age and light exposure. Librarians, archivists, and records managers are concerned that such discoloration could impede future reformatting procedures. Thus, the requirement that permanent paper be fully bleached cannot be eliminated because it is directly related to its long-term performance.

Second, the paper industry is gradually using more elemental chlorine-free (ECF) bleaching, with the result that the dioxin levels in fish near pulp and paper mills have been dropping.6 …When pulp is ECF bleached, the process is not totally free of chlorine. Most manufacturers are using chlorine dioxide instead of elemental chlorine. Despite this continued presence of chlorine, the dioxin levels decline. This leads many U.S. producers to question the need to go "totally chlorine-free." Another factor in their reluctance is the cost [as well as a weak demand].…

During 1994, a paper made by an alkaline process, but containing a high percentage of groundwood, entered the Federal marketplace. This grayish paper, natural shade recycled plain copier xerographic paper (JCP O-70), was being used widely in copiers and laser printers, and, as a result, it was used to create some permanent records. Concern was first expressed about the paper in a "Meeting on Groundwood Paper in Federal Offices," sponsored by the Office of the Federal Environmental Executive on October 11, 1994.

The meeting discussed primarily how JCP O-70 would recycle when entering the waste stream (a topic outside the scope of this report), but concerns regarding the longevity of this paper were raised. In direct answer to these concerns, the USDA Forest Products Laboratory presented results of research done on this paper. They studied the optical and physical properties of three different paper mixes which they recycled.

The control mix was a fully-bleached paper which contained 50 percent recycled content, of which 10 percent was postconsumer fiber. The second paper was the grayish paper under discussion at the meeting, which had 100 percent recycled content, of which 50 percent was postconsumer fiber. The third was a 50/50 mixture of these two papers. The 50/50 mixture was studied to demonstrate what would happen when the higher percentage postconsumer fiber content became mixed with the white office paper and recycled.

This study showed, as might be expected, that the strength properties of the 50/50 mix paper were midway between those of the two papers from which it was made. However, the optical properties of the mixed paper were much closer to, not midway between, the properties of the 50 percent postconsumer fiber paper. Thus, they concluded that the introduction of a higher percentage postconsumer fiber paper into a recycling mix would "degrade both the physical strength and brightness of the final product."8 This could be overcome, of course, by adding stronger fiber, and additional bleaching steps, both of which appear counter to the intended purposes of the Executive Order.

Continuing changes in technology

Although the trend towards elemental chlorine-free (ECF) bleaching poses no problems to the production of permanent paper, other new technologies may. Driven by the rising cost of pulp, manufacturers are looking towards thermomechanical and chemithermomechanical pulping processes to increase yield and lower costs. At least for the short term, these new pulping processes pose a threat to the legibility of books and documents because much of the original lignin remains in the pulp, even after bleaching. The lignin causes the resulting papers to darken upon artificial aging by light or heat. Such discoloration is unacceptable in a paper used for printing or writing that is to be retained indefinitely.

With this knowledge, manufacturers of these pulps are researching additives that will prevent the pulps from darkening. This work is still in the research stage, but no doubt in the next few years chemicals will be found which, when added to these pulps, retard the color change. Some of the compounds currently under investigation are sulfur-containing, which could pose a problem to photographic records. The presence of increased amounts of reducible sulfur are excluded by some box and board specifications, but are not currently addressed in the existing specifications for permanent paper.

Cost issues

Both prior to and since enactment of Pub. L. 101-423 in October 1990, a challenge to its full implementation has been encountered because of the high cost of paper that meets the specifications of JCP A270 (uncoated permanent book)--the only permanent paper available through GPO prior to Government Paper Specification Standards (No. 10). Federal consumers argued that it could not be used as the prime paper for documents of enduring value because its high cost made it economically unfeasible, particularly if multiple copies were required. During consideration of the legislation, the cost of JCP A270 was estimated to be 30 percent above that of offset book paper (JCP A60), the predominant paper used in Government printing, regardless of whether JCP A60 was manufactured by an acidic or an alkaline process. In fact, investigation of GPO paper catalog prices of the time reveals that, for the quarter February through April 1989, A270 was 187 percent more expensive than A60.… Despite the general rise in paper prices during 1994 and 1995, the price differential between A270 and A60 had narrowed somewhat. The prices that GPO charged agencies during the first three quarters of 1995 are shown in Table 5.

Table 5: Prices Charged for A270 and A60

1995

Price/lb

A270 [Uncoated Permanent Book Paper]

A60 [Offset Book]

Percent Difference

January - March $0.591 $0.627 -5.74
April - June .749 .684 9.5
July - September .749 .607 23.39

…The monitoring agencies reaffirm their recommendation that, as stated in NARA Bulletin 95-7:

Federal agencies are advised to procure either permanent or alkaline paper grades when creating all federal records. Permanent paper is recommended for routine use in offices that create and file a high proportion of long-term and permanent records, whereas alkaline paper is recommended for routine use throughout agencies for all other documents.

This is in keeping with the intent of Executive Order 12873 ("Federal Acquisition, Recycling, and Waste Prevention," October 20, 1993) and Environmental Protection Agency (EPA) guidance. The bulletin also states that any paper is suitable for mass production as long as a record copy is produced on permanent or alkaline paper, microform, or electronic medium.

Availability and use

Procurement of blank paper. …Most paper suppliers do not, as a common practice, label their paper products. Thus, the consumer cannot identify them as alkaline, permanent, or acidic. Therefore, when Federal employees procure paper from sources other than GPO or GSA, in most cases they do not know the degree of permanence of the paper they are procuring. The monitoring agencies propose to continue working with JCP, GSA, and paper suppliers to develop common labeling practices, and to encourage GSA to continue their marketing efforts to promote procurement of paper through GSA's Federal Supply Service.

SF-1 and decentralized printing. Sections 501 and 502, title 44, U.S.C., state that:

All printing, binding, and blank-book work for Congress, the Executive Office, the Judiciary, other than the Supreme Court of the United States, and every executive department, independent office and establishment of the Government, shall be done at the Goverment Printing Office … unless approved by the Joint Committee on Printing.

Since a large amount of printing service is obtained through GPO, Standard Form 1, GPO Requisition for Printing and Binding, will include blocks indicating alkaline or permanent paper requirements when next revised. Once an agency indicates permanent or alkaline paper on the printing requisition, GPO or their contractors must comply with the request.…

Use of appropriate paper in agencies. …NARA statistics indicate that 3 percent to 5 percent of the records created by an agency are permanent. The majority of permanent records are created within a few distinct agency offices, usually policy-making offices. Because it is sometimes difficult at the time of creation to determine whether a document is permanent or temporary, the NARA Bulletin 95-7 recommends that permanent paper should be used routinely in offices that create a large majority of permanent records. Other offices should use alkaline papers as a normal practice. Permanent papers will last for several hundred years under normal conditions of storage and use and alkaline paper will last at least 100 years. These time frames are much longer than those associated with the longevity of acidic papers.…

Conclusion

…Even as we enter the electronic age on our way into the 21st century, the legacy of acidic paper from the 19th century still threatens the survival of our cultural heritage, and efforts to preserve existing collections still exceed the $100 million dollar cost Senator Pell cited [when he brought Sen. Joint Res. 57 to a vote in 1990]. The production and use of alkaline and permanent papers on a worldwide basis is the only sure way of stemming the tide of brittle paper records flooding government offices, libraries, and archives of this Nation.

Although much has been accomplished since Pub. L. 101-423 was signed in October 1990, important work remains to be done. For example, GPO's Standard Form 1, Printing and Binding Requisition, should be revised to enable designation of an alkaline option on agency printing requests. Also, appropriate labeling by paper suppliers of alkaline and permanent papers should be assured; continuing education programs about the use of permanent paper should be developed; and information about the procurement of alkaline and permanent papers should be distributed. Further, LC and NARA will continue to contribute to the important research being conducted by ASTM and will ensure that it is observed closely and reported widely.

Thus, although this report marks the end of our responsibilities as set forth in Pub. L. 101-423, the Librarian of Congress, Archivist of the United States, and the Public Printer agree to continue, on an ad hoc basis, monitoring the progress of the Government's permanent paper policy.

Notes

1 National Library of Medicine, "National Library of Medicine Board of Regents May 23-24, 1995," Tab VIII, NLM Preservation Program: Current Activities and Future Directions. [p. 1] April 1995, Bethesda, MD.

5 Proposed improvements to these regulations appear in the Federal Register, V. 58, No. 241 (December 17, 1993), under the authority of sections 301, 304, 306-308, and 501 of the Clean Water Act and 33 U.S.C. sections 1311, 1314, 1316, 1317, and 1361. The proposal identifies and describes previous studies and guidance that helped to propel mill conversion.

6 McDonough, T.J., Proceedings of the Fourth China Paper Technical Conference, TAPPI PRESS, Atlanta. 1995.

8 A Comparison of Upcycled and Recycled Paper," S. Abubakr and K. Cropsey (USDA Forest Products Laboratory, Madison, WI), presented at the "Meeting on Groundwood Paper in Federal Offices" Oct. 11, 1994.

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