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Provincial Archives of Alberta response to RAD2
Descriptive Standards Committee, Provincial Archives of Alberta
Thank you for the opportunity to review the Rules for Archival Description Second Edition. RAD2 was reviewed by archivists at the Provincial Archives of Alberta as well as by the institution's Descriptive Standards Committee.
While the Provincial Archives views the inclusion of rules for describing collections and discrete items as positive additions to the rules, we have some concerns about the document that outweigh these positives. In particular, we have a number of concerns related to: RAD2's claim of compatibility with the present standard; what we perceive as theoretical inconsistencies within the document; and, ultimately, the new standards usability.
What follows is our perspective and commentary on several of the statements made in the Report to the Archival Community and the Rules for Archival Description Second Edition.
Backwards-compatibility
". . . based on principles similar to RAD but drawing from archival rather than bibliographic descriptive models, RAD2 is backwards compatible."
We found little actual evidence in the material we were provided that RAD2 is backwards-compatible with the Rules for Archival Description. In fact, we are concerned that the reality may be the opposite.
There are several new 'mandatory' elements in RAD 2 that do not exist in RAD: these include Reference code, Level of description code, and Relationships between Entities and Archival Materials. Our understanding of these "mandatory" elements is that they are significant in the context of RAD2, and as a consequence would necessitate major revisions to previously completed descriptions.
Inconsistencies
"This statement of principles was developed to serve as the basis for the rules in this standard."
We are frustrated by the document's inconsistencies as they pertain to the statement of principles and their relationship to the rules.
For instance, the statement of principles promotes the specification of creators of a records series as the immediate creator, in turn, referencing the branch or division, and not the organization as a whole. We believe this contradicts the document's own definition of a fonds. Moreover, allowing the series to be the highest level of description, and the focus on Authority Files as a replacement for the Administrative History/Biographical Sketch element of the fonds description, we believe, undermines the principle of respect des fonds as it has been traditionally applied in Canadian archives. In effect, the promotion of the "series" as the highest level of description is neither adequately reflected in the statement of principles nor any of the definitions provided.
Rule 15.2B2 of RAD2 notes that it is not mandatory to note the nature of the relationship between the subject of each authority file and the records. This diminishes the importance of the context of the creation of the body of records in our opinion. It places the creator - records relationship on the same footing as that of any ancillary subjects to the records. This we believe contradicts both the statement of principles and existing archival principles as they are presently practiced by professional archivists.
Finally, Chapter 12 in RAD2 states that it is possible to use the standard with a fonds-based arrangement system and not use authority records, while the rules themselves state that this method, in regard to documenting relationships between names of the entity described is "not a satisfactory substitute for an authority system" - which is it? Moreover, isn't the imposition of an arrangement that would accommodate an authority system contrary to the principle of respect des fonds?
Description of media
"Media-specific rules are included in the chapter for the element(s) to which they pertain."
- We are also concerned, due to the integration and exclusion of the media rules, with the usability of RAD2 when describing non-textual media.
- There is no indication whether a rule will include media rules or for what type of media until you view a specific rule and element.
- There is no index to search for specific media rules or elements.
- RAD2 suggests the reader look outside the proposed descriptive standard for a means to describe records because of type of media.
Conclusions
We are concerned for the impact that the revised descriptive standard will have on the Provincial Archives of Alberta and institutions like us that have used the present standard to describe the bulk of their holdings.
We conclude our response with a number of "Questions to Consider":
Is the stated goal of the proposed standard fully justified?
We challenge the stated justification of making RAD compliant with international standards: RAD is already compliant with ISAD(G) in our opinion - so much so that descriptions created using RAD were cited as examples in the ISAD(G) manual.
What impact will the proposed standard have on union lists?
We are concerned that technical problems of integrating Authority Records into existing union lists, such as ANA and CAIN, is not mentioned or considered. The costs in resources to change these systems would even further deflect from the primary goal of providing access to information about archival holdings to our users.
Should Describing Archives: A Content Standard (DS:CS) be used as the basis for revisions to the Rules for Archival Description?
By using DS:CS we believe the Canadian archival community at large has been excluded from contributing in the development of the second edition of the Canadian archival descriptive standard. We also question basing the driver for change on salvaging a failed attempt to reconcile the two North American standards.
Finally, we would suggest that any revisions to the Rules for Archival Description must fully support the archival descriptive work and archival information networks already based on RAD. Moreover, we believe that it is incumbent on the CCA and CCAD to demonstrate this compatibility more fully than it has.
We encourage the Committee to initiate a broader, more comprehensive and consultative process with larger institutions that will answer questions, address concerns and examine the basis and need for a revision.
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