of Federally Owned and Administered Archaeological Collections (36 CFR
Archeological artifacts appropriately stored in archival
quality bags and boxes, then placed in baked-enamel metal museum
cabinets. From the photograph collection of the U.S. Army
Corps of Engineers, St. Louis District.
Government-wide regulations for the curation and care of federal archeological
collections required by NHPA, the Reservoir Salvage Act, and ARPA were
issued in 1990 as "Curation of Federally Owned and Administered Archaeological
Collections" (36 CFR 79). These regulations establish procedures and guidelines
to manage and preserve collections. They also include terms and conditions
for federal agencies to include in contracts and Memorandums
of Agreement (MOA) with non-federal repositories.
36 CFR 79 is the
first set of regulations to produce standards for determining a viable
repository for archeological collections and guidelines for acceptable
access, loans, and collections use. Unfortunately, these regulations
contain no deadlines for compliance and no enforcement powers. Nor do
they provide a process to identify or accredit repositories that meet
the standards set forth. Furthermore, a regulation on deaccessioning
proposed in 1990 was not issued due to considerable controversy. It
has yet to be issued.
Below are some of
the main points of the regulations.
What 36 CFR 79 Covers
Excavations done under the authority or in connection with Federal
agencies, laws, and permits (Antiquities Act, Reservoir Salvage Act,
Section 110 of NHPA, ARPA).
Applies to both new and preexisting collections.
- Applies to the collections and the generated data as permanent records.
A federal agency is responsible for reviewing and evaluating preexisting
collections and the repositories that manage them.
An agency is responsible for working with both federal and non-federal
repositories to eliminate inadequate collections care or to move the
collections to a repository that meets the standards.
An agency is responsible for placing new collections in repositories
that meet the standards.
For each collection, an agency must keep a copy of administrative
records on its location, contents, contracts, reports, etc.
A federal agency is financially responsible for collections care.
Federal agencies may use monies appropriated by Congress to: purchase/maintain
their own repository; enter into a cost-sharing agreement with a repository;
reimburse a grantee for curatorial costs; reimburse a state for curatorial
costs; and conduct inspections and inventories.
When a repository can no longer care for a collection, a federal agency
may provide funds for deficiencies or transfer the collection to another
A federal agency may charge permittees and licensees for curation
Funds provided to a repository should include funds for storage, inspection/inventory,
and maintaining, conserving and providing access to collections on
a short and long-term basis.
Where and How Federal
Agencies Secure Curatorial Services
Agencies may use a federally owned repository, non-federal museums,
educational/scientific institutions, state, local, or tribal repositories,
or transfer the collection to another federal agency.
Guidelines for repositories holding collections permitted under ARPA
or the Antiquities Act include location in the state where the collection
originate, stores or maintains other collections from the same site/location/geographical
region, does not subdivide a collection, and deposits artifacts and
associated records in the same place.
A federal agency should consult with an expert in archeological collections
management and preservation when assistance is needed (e.g., State
Historic Preservation Officer [SHPO], state archeologist, National
Park Service [NPS], Tribal Historic Preservation
Officer [THPO], Smithsonian Institution [SI], American Association
of Museums, local or regional museum, etc.).
materials present additional storage problems. All too often,
they are rolled or stacked, thus creating obstacles to both their
ultimate survival and accessibility. From the photograph collection of the U.S. Army Corps of Engineers, St. Louis District.
Terms and Conditions
For Contracts, etc.
Requires statements that identify the collection, its ownership and
jurisdiction, work to be done by a repository, responsibilities of
federal agency, costs, special procedures, instructions/terms for
access and use, records needs, publication needs, inventories and
issues, and some deaccessioning issues (i.e., repository won't sell
collection; won't transfer or discard collection without permission).
Able to accession, label, catalog, store, maintain, inventory, and
conserve a collection on a long-term basis in accordance with professional
museum and archival standards.
Complies with maintaining acquisition records, catalog and inventory
lists, descriptive information, photographs/images, locational information,
condition information, loan information, monitoring records, records
on lost or damaged/destroyed objects, and records on deaccessions.
Has adequate equipment and space for storage, study, and conservation.
Needs to physically secure collections by use of safety codes, fire
systems, intrusion systems, emergency management plan, additional
security when needed, limited access, and periodic inspections of
Requires staff to be qualified professionals.
Handles, stores, cleans, conserves, and exhibits collections in a
way that is appropriate to the nature of the materials, protects the
objects, and preserves data.
Stores forms and records in a protected manner (locked, fire resistant
container with duplicates in a separate location).
Regularly inspects collections.
Provides access to collections.
Use of Collections
Requires federal agencies to ensure that the repository makes federal
collections available for scientific, educational, and religious uses.
Limits access to information on the specific location, character,
etc. of objects or collections that may create risk of theft or destruction.
Does not allow destructive uses or analysis unless it is important
for scientific or educational purposes.
Does not allow loans without a written agreement that includes the
collection or object to be loaned, the purpose of the loan, length
of the loan, restrictions, insurance, and handling requirements.
Allows a repository to charge fees for use of its collections.
- The repository has to give a copy of
the catalog list to the federal agency when a collection is received,
periodically inspect and monitor their physical plant, inspect the
collection for condition, and periodically inventory the collection.
- The repository has to have qualified
professionals do the inventory and inspection work and give copies
of results to the federal agency.
- The repository has to make the collection
accessible to the federal agency or applicable Indian tribes for periodic
- The repository must prepare a written
notification of the discovery of and circumstances behind any loss,
theft of, deterioration or damage to, or destruction of all or part
of a collection within five days to the federal agency owner.
- A federal agency shall have qualified
professional staff who investigate reports of lost, stolen, deteriorated
or damaged collections and periodically inspect the repository that
houses its collections to determine its compliance with these minimum
- Fragile/perishable items should be inspected
for damage or deterioration on a more frequent basis than stable items.
- Objects and associated records should
be handled as little as possible during inspections.
- More valuable artifacts should be inventoried
- Multiple federal agencies should have
interagency agreements for coordinated inspections and inventories
when they have collections at the same repository.
Introduction to Curation
Relevant Laws, Regulations, Policies, and Ethics
laws into the 1970s
for Archeology & Historic Preservation
tribal & local laws & policies
& university policies
Today's Key Issues
Curation Prior to the Field
Curation in the Field and Lab
Access and Use