Public Comment of APG opposing the proposed 65-year destruction authority for long-term analog federal civilian Official Personnel Folders (OPFs)
24 August 2026
On 24 August 2026, the Association of Professional Genealogists submitted public comments to the U.S. National Archives and Records Administration (NARA) opposing the proposed 65-year destruction authority for long-term analog federal civilian Official Personnel Folders (OPFs) of individuals separated on or after January 1, 1974.
The comments were submitted under Docket No. NARA-26-0331 / NARA-2026-028, Records Schedule DAA-GRS-2026-0001, General Records Schedule 2.2: Employee Management Records Revision.
“We oppose the destruction of historically and genealogically valuable personnel records and urge NARA and OPM instead to expand the transfer of older OPFs into archival custody and public access," said APG's comments. "At present, OPFs of many employees whose federal service ended before 1952 are archival records available through NARA, while OPFs of employees separated after 1951 remain nonarchival records in OPM's legal custody and are subject to considerably greater access restrictions. APG members have encountered substantial difficulty obtaining these later records, including OPM's administrative closure of FOIA requests as “misdirected” because the OPFs are physically held by the National Personnel Records Center.”
The comments continued to say that "[t]he historical value of an Official Personnel Folder does not turn on whether an employee left federal service in December 1951 or January 1952. An administrative filing boundary established more than seventy years ago should not remain the boundary of archival public access today. APG strongly supports the permanent disposition reflected in DAA-GRS-2025-0003-0004. We urge NARA to ensure that this preservation authority is approved and issued, if it has not already been, to move those records into archival custody on a reasonable rolling schedule, and not to accelerate destruction of later long-term analog OPFs without first resolving the legal-rights and preservation questions identified above.”
Read APG's complete statement at https://www.apgen.org/docs/APG_Public_Comment_OPFs_24_Aug_2026.pdf.