Cataloging Technician | The Society for the Preservation of Natural History Collections

National Museum of Natural History https://naturalhistory.si.edu/

CONTRACT POSITION: Cataloging Technician

UC Riverside: Davis, Green & MacGregor Kimberlite Xenolith Collection
Contractor shall provide professional, technical, non-personal services to the Smithsonian Institution’s National Museum of Natural History, Department of Mineral Sciences, Division of Petrology and Volcanology, National Rock and Ore Collections. Contractor will organize, catalog and capture specimen data for the Davis, Green and MacGregor Kimberlite Xenolith Collection, a gift from the University of California, Davis. The collection currently resides in 79 boxes in the room E433 of the Department of Mineral Sciences and consists of Kimberlite and Xenolith specimens, preparations and documentation from various localities. The estimated time frame to complete the contract is 42 weeks = 10.5 months.

Desirable qualifications include:

A bachelor’s degree in geology, earth science, or related physical science
Basic knowledge of geologic nomenclature
Experience working with museum specimens and knowledge of proper specimen handling
techniques.
Skills using word processing and spreadsheet software such as Microsoft Word and Excel
The work will take place at the Museum Support Center in Suitland, Maryland. The contractor
will have access to the facility between the hours of 8:00am and 5:00pm, Monday through Friday.
The contract will require an estimated 10.5 months of work, and the period of the contract shall
not exceed one year. Liability insurance through the Smithsonian Institution is required.
A copy of this announcement, including the Request for Quote, Statement of Work, and any
updates related to the announcement, is available at https://naturalhistory.si.edu/research/mineral-sciences/opportunities. To apply for this contract, please send your bid, along with a cover letter
that includes the project title, evidence of relevant experience and/or past performance as described
in the Request For Quote, and resume/CV to Cathleen Brown (brownc@si.edu before July 14,
2024.
The Smithsonian Institution is an Equal Opportunity Employer.
Smithsonian Institution Request for Quote: June 21, 2024
Museum of Natural History Request for Quotes (RFQ)- Curation of the UC Riverside Davis, Green & MacGregor Kimberlite Xenolith Collection
This Request for Quote (RFQ) is issued by the Smithsonian Institution’s Department of Mineral Sciences for a contractor to provide technical, non-personal services to the Smithsonian’s National Museum of Natural History, Department of Mineral Sciences, Division of Petrology and Volcanology, National Rock and Ore Collections. Contractor will organize, catalog and capture data for the Curation of the UC Riverside: Davis, Green & MacGregor Kimberlite Xenolith Collection. This collection consists of 79 boxes of specimens and their associated preparations and documentation. These services are in accordance with the Statement of Work (SOW)
I. SUBMITTING YOUR QUOTE
Price quotes must be submitted by electronic mail (email). Quotes are due by midnight July 14, 2024.
Email to: brownc@si.edu
II. DESCRIPTION OF REQUIRED SERVICES
The Collection pertinent to this advertisement is located at the Smithsonian Institution’s Museum Support Center in Suitland, Maryland. A contractor is required to unpack, collate, gather all sample specific information in a spreadsheet and label all specimens with NMNH catalog numbers. The Contractor will be required to:

Contractor shall organize the specimens and/or specimen lots by collectors’ field number in appropriately sized archival quality trays.
Contractor shall collate together by field number all preparation types (such as thin sections and powders with corresponding hand sample.
Contractor shall perform a literature search for all published papers relevant to the specimens already provided by the donor and print hard copies when possible.
Contractor shall perform preliminary identification of the lithology of each specimen, when it is not
available in the literature and/or field notebooks.
Contractor shall apply appropriately sized pant stripe to each specimen larger than a golf ball, and shall place smaller specimens in clear, plastic “ziplock” style bags as appropriate.
Contractor shall develop and appropriate numbering scheme, in consultation with the collection manager, and shall assign sequential, unique museum catalog numbers to each specimen or specimen lot according to the established field number order. Museum numbers shall be written directly onto the rock specimens, bags, thin section and their thin section holders, and any other preparations, using archival quality pens.
Contractor shall capture all relevant specimen data including, but no limited to, collectors (field) number, museum catalog number and suffix, quantity, the storage location, all known collecting locality information, preparation(s), reference(s) in the literature, lithology (identification), description (texture, structure), and metadata concerning the acquisition (donor, accession number).
Contractor shall create digital records for specimens, using batch-import spreadsheets and/or the Axiell EMu client.
Once cataloging has begun, contractor shall submit a copy of the cataloging spreadsheet to the COTR to review prior to receiving payment. A designated technical contact shall review and return the spreadsheet with comments and any necessary corrections. Payment shall be contingent on the contractor providing a written response to each comment and submitting a new copy of the spreadsheet with all requested corrections made.
Contractor shall follow departmental data standards and best practices when completing the above tasks. Contractor shall be provided with task-specific training but will mostly be expected to work with limited supervision.
III. EVALUATION
The SI plans to award based on a combination of relevant experience, past performance, qualifications, best value and lowest price. The SI plans to award without discussions, however, does reserve the right to conduct discussions if later determined by the Contracting Officer to be necessary.
All of the following factors are of equal importance. Evaluation factors are:
A. Relevant Experience/Past Performance Relevant experience is that obtained within the past 3 years providing or performing services of similar size, scope, complexity that indicates your suitability for this project.
a. Include a brief summary of your training and experience working with museum collections. Past Performance should be indicated by the following:
a. Provide a list of current or previous contracts with names of points of contract and their
current telephone numbers who can answer specific questions on quality, workmanship and
scheduling.
b. Provide contract periods of performance dates, dollar value, and brief description of the
work performed.
c. Include at least one reference for each work area of experience specified above: working
with museum collections and working as an independent contractor.
Smithsonian Institution Request for Quote: June 21, 2024
Museum of Natural History
B. Qualifications/Technical Competence
Relevant experience working with geologic rock and ore samples.
a. Bachelor’s degree in geology, earth science or related physical science.
b. Basic knowledge of geologic nomenclature.
c. Knowledge of proper specimen handling techniques.
d. Skills using word processing and spreadsheet software (for example, Microsoft Word and
Microsoft Excel).
e. Ability to follow both verbal and written instructions and record data accurately and
precisely.
C. Price Please provide a firm, fixed price that includes all costs. This project is estimated to take
42 weeks/10.5 months to complete.
IV. INSURANCE REQUIREMENTS
Prospective contractors are required to have General Liability Insurance for (e.g. $5,000,000 and/or a
Fidelity Bond for $1,000,000) and/or (auto insurance is required if the contractor will be required to
bring a vehicle onto SI property or SI leased property, and/or transport SI-owned property). Insurance must cover the duration of the contract period. The SI must be listed as additional insured for the General Liability insurance. Proof of insurance must be submitted with quotes. Coverage may be purchased through the Smithsonian.
V. SYSTEM FOR AWARD MANAGEMENT (SAM) REGISTRATION
It is a requirement that current and prospective recipients of contracts and purchase orders awarded by the SI must have an active SAM registration to be eligible for awards, and maintain an active record in SAM throughout the period of time the SI award will be in effect. The SAM requires a one-time business registration, with annual updates, and allows vendors to control the accuracy of the business information they enter. The financial data you enter, which includes the electronic funds transfer (EFT) data collected by SAM, will assist the SI with correctly directing payments on your invoices and complying with the Federal Debt Collection Improvement Act of 1996.
Within thirty (30) calendar days after your SAM registration is activated you must mail a notarized
letter to SAM. You will receive guidance on this procedure throughout the SAM registration process
and again after your SAM registration is activated. Federal agencies, including SI, have been assured
that once an entity’s SAM registration is activated, agencies may engage that entity. Notarized letters from registered entities will need to contain specific language. OCon&PPM has provided the preferred language for letters with our form memo OCon 120 – Mandatory Registration in the System for Award Management (SAM) that accompanies this RFQ.
Smithsonian Institution Request for Quote: June 21, 2024
Museum of Natural History
If yours is the acceptable price quote and you are selected for award, your organization’s active
registration with SAM must be verifiable by SI staff managing this procurement prior to contract or
purchase order award being executed, and at the time any modifications or amendments to awards
might be required.
You may complete or update your SAM registration information anytime online at http://sam.gov.
Questions regarding the process may be directed to the Federal Service Desk online at www.fsd.gov or via toll free call to 1-888-606-8220. There is no charge for registering in SAM.
VI. UNIQUE ENTITY IDENTIFIER (UEI) NUMBER
A UEI number is a unique twelve-digit alpha-numeric identifier that will be assigned to you when your SAM registration is completed. A UEI is available for each physical location of your business (see Section V. of this RFQ). You will need to maintain your assigned UEI(s) in a safe location where they may be easily accessed. Your UEI will be required whenever you need to annually update your SAM registration or make changes to your SAM registration information at any time.
VII. LEGISLATIVE AND/OR ADMINISTRATIVE REQUIREMENTS
A. Service Contract Act of 1965, as amended
If services to be performed are covered by the Service Contract Act (SCA), as amended, the SCA
shall apply to all work performed under the contract, purchase order, or GSA schedule task order
to be issued. Individuals and companies submitting quotes are encouraged to verify the wages
and fringe benefits determined by the U.S. Department of Labor to be payable for the Labor
Category and in within the location that work performance will occur as cited in the Statement
of Work. The SCA wages and fringe benefits payable shall be part of the order award.
Individuals and companies awarded a contract, purchase order or GSA schedule contract task
order for SCA covered services are responsible, and required by law, to deliver to its employee(s)
or post a notice of the required compensation in a prominent place at the worksite. The SCA
provides authority to contracting agencies to withhold contract funds to reimburse underpaid
employees, terminate the contract, hold the contractor liable for associated costs to the
government, and debar from future government contracts for a period of three (3) years any
persons or firms who have violated the SCA. The contracting officer awarding this order, or the
Smithsonian Inspector General, may periodically require contractors to provide information that
verifies compliance with the SCA for services provided under the awarded contracts, purchase
orders or GSA schedule contract task orders.
B. E-Verify
If at award, or anytime during contract performance, the dollar amount of the contract award
exceeds $150,000 or $5,000,000 under GSA Schedule, with a period of performance over 120
days, the successful bidder is required to register in the E-Verify System and verify that all
individuals to be hired under the contract award are eligible for employment within the U.S. This
Smithsonian Institution Request for Quote: June 21, 2024
Museum of Natural History
requirement is not applicable to work that will be performed outside the U.S. or for Commercial
Off the Shelf (COTS) items.
E-Verify is an Internet-based system operated by the Department of Homeland Security (DHS),
U.S. Citizenship and Immigration Services (USCIS). It allows employers to verify the
employment eligibility of their employees, regardless of citizenship. For more information on everify and when, why and how to register and use the system please go to the USCIS site on the
World Wide Web at: E-Verify.gov.
Executive Order 13465 and Homeland Security Policy Directive 12 (HSPD-12)
C. Background Investigations
If a contractor employee assigned to the SI under this contract will have an association with SI
that will be greater than thirty (30) days, determined either at time of contract award or anytime
during contract performance, and will need access to staff-only areas of SI controlled facilities
and leased spaces, the employee shall be required to receive an SI Credential. Contractor
employees who require an SI Credential shall be required to undergo and pass an appropriate
background investigation and complete security awareness training before an SI Credential is
issued. Employees whose associations with the SI will be less than 30 days shall not receive a
background investigation or SI Credential, however, they must be escorted by Credentialed
personnel at all times when in staff-only areas of SI facilities. If relevant to this RFQ, a form
OCon 520, Background Investigations and Credentials for Contractors’ Personnel, is included.
The following actions shall be required to be completed by the SI Contracting Officer’s Technical
Representative (COTR) and successful vendor:
The COTR shall provide an OF-306, Declaration for Federal Employment form, for each
of the Contractor’s employees who will be assigned to the SI for 30 days or longer. The
OF-306 forms must be completed by each person and returned by the Contractor to the
COTR, or other designated SI employee, within ten (10) workdays from receipt of the
forms by the Contractor.
For contractors to SI organizations outside the Washington DC and New York City areas,
forms SF-87, Fingerprint Cards, shall be provided to the Contractor by the COTR or other
designated SI employee. Each form SF-87 must be returned to the COTR, or other
designated SI employee, within ten (10) workdays from receipt of the forms by the
Contractor When necessary, the forms SF-87 shall be submitted by the Contractor with the
OF-306.
Homeland Security Policy Directive 12 (HSPD-12)
VIII. INFORMATION TO BE SUBMITTED WITH QUOTES
Quotes submitted must include the following information to be deemed responsive to this Request for
Quote and accepted by the SI:
Smithsonian Institution Request for Quote: June 21, 2024
Museum of Natural History
A. Documentation of your current active SAM registration with the date it will expire.
B. Project Title.
C. Relevant Experience and Past Performance as described in Section IIA above.
D. A resume with work and education experience.
ATTACHMENT(S):

Statement of Work: NMNH Curation of the UC Riverside Davis, Green & MacGregor Kimberlite
Xenolith Collection
Smithsonian Institution Purchase Order Terms & Conditions (SI-147A)
Smithsonian Institution Privacy and Security Clause (SI-147B – March 13, 2024 [Rev.])
Smithsonian Rights-In-Data Clause (June 2001)
Smithsonian confidentiality and Disclosure Clause (OCon 140 – January 2002 [Rev.])
Smithsonian Background Investigations and Credentials for Contractor’s Personnel (OCon 520 –
October 2009)
Smithsonian Notice of Mandatory Registration in the System for Award Management (SAMS)
(Ocon 120 – December 2023)
Statement of Work (SOW) for Project
National Museum of Natural History
Collections Program
Statement of Work (SOW)
Curation of Davis-Green-MacGregor Kimberlite Xenolith Collection
PROJECT SUMMARY: This project seeks an independent contractor to process and catalog the UC
Riverside: Davis, Green, & MacGregor Kimberlite Xenolith Collection. The collection consists of 79 boxes
of mantle specimens and related documentation and is estimated to take approximately 10.5 months of fulltime work to complete. This rock collection from the University of California-Riverside documents the
geologic research of Drs. Harry Green and Ian MacGregor. Dr. Green’s specimens encompass mantle rocks
from around the world and typically includes thin sections. Dr. MacGregor’s primary interest was xenoliths
collected from South African kimberlites.
SCOPE OF WORK
The Contractor will inventory, catalog, organize, rebox, and conduct a literature and data search (including
maps) for this collection of 1700+ rock specimens. The organized specimens will be labeled with an
NMNH catalog number and placed into storage in pod 2 at MSC. The Contractor will create a Microsoft
Excel spreadsheet containing the Collector’s field number, NMNH catalog number, collecting locality,
number of specimens and preparations, latitude, and longitude (if included), associated references (and
maps) for each specimen for addition to a provided template spreadsheet, which will be uploaded into the
NMNH data base by the Mineral Sciences Data Manager.
OBJECTIVES
At the end of this contract, accessibility and discoverability of the UC Riverside: Davis, Green, &
MacGregor Kimberlite-Xenolith Collection will be greatly enhanced through the accurate inventory of the
specimens and capture of all relevant specimen data and metadata for the creation of digital catalog records.
TASKS & DELIVERABLES
The Contractor shall provide the following services:

Contractor shall organize the specimens and/or specimen lots by collectors’ field number in
appropriately sized archival quality trays.
Contractor shall collate together by field number all preparation types (such as thin sections and
powders with corresponding hand sample.
Contractor shall perform a literature search for all published papers relevant to the specimens
already provided by the donor and print hard copies when possible.
Contractor shall perform preliminary identification of the lithology of each specimen, when it is
not available in the literature and/or field notebooks.
Contractor shall apply appropriately sized pant stripe to each specimen larger than a golf ball,
and shall place smaller specimens in clear, plastic “ziplock” style bags as appropriate.
STATEMENT OF WORK
–
NMNH CURATION OF DAVIS-GREEN-MACGREGOR KIMBERLITE XENOLITH COLLECTION
Contractor shall develop and appropriate numbering scheme, in consultation with the collection
manager, and shall assign sequential, unique museum catalog numbers to each specimen or
specimen lot according to the established field number order. Museum numbers shall be written
directly onto the rock specimens, bags, thin section and their thin section holders, and any other
preparations, using archival quality pens.
Contractor shall capture all relevant specimen data including, but no limited to, collectors (field)
number, museum catalog number and suffix, quantity, the storage location, all known collecting
locality information, preparation(s), reference(s) in the literature, lithology (identification),
description (texture, structure), and metadata concerning the acquisition (donor, accession number).
Contractor shall create digital records for specimens, using batch-import spreadsheets and/or the
Axiell EMu client.
Once cataloging has begun, contractor shall submit a copy of the cataloging spreadsheet to the
COTR to review prior to receiving payment. A designated technical contact shall review and return
the spreadsheet with comments and any necessary corrections. Payment shall be contingent on the
contractor providing a written response to each comment and submitted a new copy of the
spreadsheet with all requested corrections made.
Contractor shall follow departmental data standards and best practices when completing the
above tasks. Contractor shall be provided with task-specific training, but will mostly be expected
to work with limited supervision.
DELIVERY
The Contractor shall be paid at the agreed upon rate and may submit invoices on a monthly basis. Each
payment will be contingent upon the Contractor’s submission of a corresponding invoice that references
this purchase order by number, and the Smithsonian’s acceptance of the work. In lieu of her own invoice,
the Contractor may request payment for services by completing Smithsonian invoice form SI-3726.
PERIOD OF PERFORMANCE
All work under this purchase order shall begin upon award of the contract and be completed by December
31, 2025.
GOVERNMENT FURNISHED PROPERTY
The Smithsonian will supply all necessary supplies and a template spreadsheet to complete the work.
Contractor will supply own laptop. At the completion of the project, the Contractor shall return all unused
supplies and leftover materials.
CONTRACTOR TRAVEL EXPENSES
Not Applicable
SECURITY REQUIREMENTS
Not applicable beyond Contractor having SI badge with general NMNH access.
STATEMENT OF WORK
–
NMNH CURATION OF DAVIS-GREEN-MACGREGOR KIMBERLITE XENOLITH COLLECTION
PLACE OF PERFORMANCE
The Contractor shall perform all work required at the following locations:
Smithsonian Institution
Museum Support Center (MSC)
4210 Silver Hill Road
Suitland, Maryland 20746
The Contractor shall perform work on the Contractor’s premises or at the Smithsonian Institution, Museum
Support Center (MSC)
WORK HOURS
Contractor shall perform all work Monday through Friday during normal business hours, excluding Federal
holidays and specific office closures.
The work schedule may be subject to adjustment upon mutual agreement of the parties. Considerations of
change will be dependent upon satisfactory performance of duties and other extenuating office setting
circumstances, as determined appropriate by the COTR. All matters related to time and attendance shall be
reported to the COTR daily, for recordkeeping relative to payment.
APPENDIX I: POLICIES, PROCEDURES AND STANDARDS

SD600 SI Collections Management Policy
National Museum of Natural History Collections Management Policy Revision 13 Dec 2017
STATEMENT OF WORK
–
NMNH CURATION OF DAVIS-GREEN-MACGREGOR KIMBERLITE XENOLITH COLLECTION
SI 147A – Purchase Order Terms and Conditions Page 1 of 3
February 2018 (Rev.)
SMITHSONIAN INSTITUTION
PURCHASE ORDER TERMS AND CONDITIONS

COMPLETE AGREEMENT – The purchase order and all
documents attached represent the entire agreement between the
Smithsonian Institution (SI) and the Contractor. Any modification,
alteration or amendment to this purchase order must be in writing and
signed by an authorized agent of the SI.
INSPECTION AND ACCEPTANCE – The Contractor shall tender
for acceptance only those items that conform to the requirements of this
contract. The SI reserves the right to inspect, test or evaluate any
supplies or services that have been tendered for acceptance. The SI may
require repair or replacement of nonconforming supplies or reperformances of nonconforming services at the Contractors expense. The
SI must exercise its post acceptance rights- (a) Within a reasonable
period of time after the defect was discovered or should have been
discovered; and (b) Before any substantial change occurs in the
condition of the item, unless the change is due to the defect in the item.
Inspection and acceptance will be at destination, unless otherwise
provided in writing. Until delivery and acceptance, and after any
rejections, risk of loss will be on the Contractor unless loss results from
negligence of the SI. Final acceptance by the SI will be conditional upon
fulfillment of the above requirements.
OVERPAYMENT – If the Contractor becomes aware of a duplicate
invoice payment or that the SI has otherwise overpaid on an invoice
payment, the Contractor shall immediately notify the Contracting Officer
and request instructions for disposition of the overpayment.
USE OF SMITHSONIAN NAME or LOGO PROHIBITED – The
SI owns, controls and/or has registered the trademarks /service marks
“Smithsonian,” “Smithsonian Institution” and the Smithsonian sunburst
logo. Except as may be otherwise provided herein, the Contractor shall
not refer to the SI or to any of its museums, organizations, or facilities in
any manner or through any medium, whether written, oral, or visual, for
any purpose whatsoever, including, but not limited to, advertising,
marketing, promotion, publicity, or solicitation without written consent.
WARRANTY – The Contractor warrants and implies that the goods
and services furnished hereunder are merchantable, fully conform to the
SI’s specifications, drawings, designs, and are fit for intended use
described in this contract. The Contractor agrees that the supplies or
services furnished under this contract shall be covered by the most
favorable commercial warranties the Contractor gives to all customers
for such supplies or services, and that the rights and remedies provided
herein are in addition to and do not limit any rights afforded to the
Government by any other clause of this contract. Contractor agrees to
pass through all warranties from other manufacturers.
TITLE – Unless otherwise specified in this contract, title to items
furnished under this contract shall pass to the SI upon acceptance,
regardless of when or where the SI takes physical possession.
EXCUSABLE DELAYS – The Contractor shall be liable for default
unless nonperformance is caused by an occurrence beyond the
reasonable control of the Contractor and without its fault or negligence,
such as acts of God or the public enemy, acts of the SI, acts of the
Government in either its sovereign or contractual capacity, fires, floods,
epidemics, quarantine restrictions, strikes, unusually severe weather, and
delays of common carriers. The Contractor shall notify the Contracting
Officer in writing as soon as it is reasonably possible after the
commencement of any excusable delay, setting forth the full particulars
in connection therewith, shall remedy such occurrence with all
reasonable dispatch, and shall promptly give written notice to the
Contracting Officer of the cessation of such occurrence.
DISPUTES – Any dispute arising under this contract that the
parties are unable to resolve shall be decided by the Contracting
Officer. All disputes must be submitted to the Contracting Officer in
the form of a written claim supported by evidence within twelve (12)
months following accrual of the claim. The Contracting Officer will
provide a written decision to the Contractor, and that decision is the
final and conclusive decision of the Smithsonian Institution, which is
effective on the date the Contractor receives the decision. The
Contractor retains all rights to subsequent judicial review to which it
is entitled under federal law. The Contractor shall comply with any
decision of the Contracting Officer and otherwise proceed diligently
with performance of this contract pending final resolution of any
request for relief, claim, or action arising under the contract.
TERMINATION FOR CAUSE – The SI may terminate this
contract, or any part hereof, for cause in the event of any default by
the Contractor, or if the Contractor fails to comply with any contract
terms and conditions, or fails to provide the SI, upon request, with
adequate assurances of future performance. In the event of
termination for cause, the SI shall not be liable to the Contractor for
any amount for supplies or services not accepted, and the Contractor
shall be liable to the SI for any and all rights and remedies provided
by law. If it is determined that the SI improperly terminated this
contract for default, such termination shall be deemed a termination
for convenience.
TERMINATION FOR THE SMITHSONIAN’S
CONVENIENCE – The SI reserves the right to terminate this
contract, or any part hereof, for its sole convenience. In the event of
such termination, the Contractor shall immediately stop all work
hereunder and shall immediately cause any and all of its suppliers
and subcontractors to cease work. Subject to the terms of this
contract, the Contractor shall be paid a percentage of the contract
price reflecting the percentage of the work performed prior to the
notice of termination, plus reasonable charges that the Contractor can
demonstrate to the satisfaction of the SI, using its standard record
keeping system, have resulted from the termination. The Contractor
shall not be required to comply with the cost accounting standards or
contract cost principles for this purpose. This paragraph does not give
the SI any right to audit the Contractor’s records. The Contractor shall
not be paid for any work performed or costs incurred that reasonably
could have been avoided.
CHANGES – The SI may at any time, in writing, make changes
within the general scope of this purchase order to include. (a)
Technical requirements and descriptions, specifications, statements of
work, drawings or designs; (b) Shipment or packing methods;
(c) Place of delivery, inspection or acceptance; (d) Reasonable
adjustments in quantities or delivery schedules or both; and, (e) SIfurnished property, if any. If any such change causes an increase or
decrease in the cost of or the time required for performance of this
purchase order, the Contractor shall inform the SI in writing within
thirty (30) days after receipt of change request. Any additional
charges must be approved in writing by the SI authorized
procurement officer executing this purchase order. Contractor shall
not make any changes without the written consent of the SI authority
executing this purchase order.
CONFIDENTIALITY and DISCLOSURE – Confidential
Information. Confidential Information consists of trade secrets,
product concepts, customer information, marketing communication
material, marketing strategies, and other commercial or financial
information that if affirmatively used by a competitor of the
disclosing party would cause the disclosing party substantial
competitive harm or information the release of which would violate
the privacy rights of a third party with no overriding public interest.
If Confidential Information is disclosed in tangible form, it shall be
SI 147A – Purchase Order Terms and Conditions Page 2 of 3
February 2018 (Rev.)
clearly designated in writing as such by the disclosing party. If
Confidential Information is disclosed other than in writing, the
information deemed to be Confidential Information shall be
confirmed in writing as such within thirty days of such disclosure.
Limited Disclosure — Each party agrees that it will not disclose
Confidential Information provided to it by the other party to others
except to the extent that it is necessary to disclose such Confidential
Information to its directors, officers, representatives, legal and
financial consultants, and employees having a need to know such
Confidential Information (“authorized parties”) for the purpose of
pursuing a business and contractual relationship between the parties.
The parties shall use at least the same degree of care that each party
uses to protect its own Confidential Information of similar
importance, but no less than a reasonable degree of care. Further, the
parties may disclose Confidential Information if required by law,
subpoena, order or request of a federal governmental authority or
court of competent jurisdiction, and further, provided that the party
obligated to disclose such Confidential Information shall (a) assert
the confidential nature of the Confidential Information to be
disclosed, (b) use reasonable efforts to obtain confidential treatment
for any Confidential Information so disclosed, and (c) immediately
notify the other party of the requirement, order, or request to disclose
in advance of such disclosure in order to afford the other party the
opportunity to contest disclosure. No other use or disclosure of
Confidential Information may be made by any party without the prior
written consent of the disclosing party.
INDEMNITY – The Contractor shall defend, indemnify, and
hold harmless the SI, its Regents, directors, officers, employees,
volunteers, licensees, representatives, agents and the United States
Government (hereinafter referred to as “Indemnitees”) from and
against all actions, causes of action, losses, liabilities, damages, suits,
judgments, liens, awards, claims, expenses and costs including
without limitation costs of litigation and counsel fees related thereto,
or incident to establishing the right to indemnification, arising out of
or in any way related to:
Any breach of this Agreement, Terms and Conditions, and the
performance thereof by Contractor, Subcontractor, other third parties,
or any activities of Indemnitees, including, without limitation, the
provision of services, personnel, facilities, equipment, support,
supervision, or review; any claims of any kind and nature whatsoever
for property damage, personal injury, illness or death (including,
without limitation, injury to, or death of employees or agents of
Contractor or any Subcontractor).
Any claims by a third party of actual or alleged direct or contributory
infringement, or inducement to infringe any United States or foreign
patent, trademark, copyright, common law literary rights, right of
privacy or publicity, arising out of the creation, delivery, publication
or use of any data furnished under this contract or any libelous or
other unlawful matter contained in such data or other intellectual
property rights and damages. The contractor shall notify the SI
immediately upon receiving any notice or claim related to this
contract.
HAZARDOUS MATERIAL – The Contractor shall inform the SI
in writing at the correspondence address listed on the purchase order
prior to shipment and delivery of any hazardous material. Any materials
required by this purchase order that are hazardous under federal, state or
local statute, ordinance, regulation, or agency order shall be packaged,
labeled, marked and shipped by the Contractor to comply with all
federal, state and local regulations then in effect.
OTHER COMPLIANCES – The Contractor shall comply with all
applicable Federal, State and local laws, executive orders, rules and
regulations applicable to its performance under this contract.
SECURITY CONSIDERATION – OPS, OCon 520 Contractor’s
conducting work on the SI premises are required to obtain a temporary or
long-term identification badge. Contractor’s employee (s) requiring a
long-term identification badge is subject to a fingerprint review. An
adverse finding during the fingerprint review may prohibit a contractor’s
employee (s) from working on the contract. The SI will inform the
contractor if a long-term identification badge is required.
INSURANCE and BONDS – Contractor shall maintain at all times
during the performance of this contract Commercial General Liability
Insurance. Contractor shall maintain Worker’s Compensation Insurance
in accordance with statutory requirements and limits. If during the
performance of this contract, a vehicle is required, contractor shall
maintain business automobile insurance. If this contract relates to any
type of media exposure, then Contractor is required to have professional
errors and omissions coverage. If this contract requires Contractor to
handle Smithsonian funds or guard or protect Smithsonian artifacts,
Contractor will also be required to obtain a fidelity bond or crime
insurance. Limits of such bonds or insurance policies are to be
determined. SI shall be listed as an “additional insured” under the
comprehensive general liability and business automobile policies. Proof
of insurance shall be in the form of a binder, policy, or certificate of
insurance and this is to be submitted to the SI’s Procurement Officer
prior to work being initiated.
INVOICE INSTRUCTIONS – Invoices shall be submitted to the
bill to address on the face of the purchase order after delivery of supplies
and/ or services, and shall contain the following information:
(a) Contractor’s name, address, and taxpayer identification number
(TIN). (b) Invoice date and number. (c) Purchase order number
including contract line item number. (d) Item description, quantity, unit
of measure, unit price, and extended price. (e) Name, title, telephone and
fax number, and mailing address of point of contact in the event of an
invoice discrepancy. (f) Invoice total, payment discount terms and
remittance address. (g) Shipping and payment terms (e.g. shipment
number, date of shipment, and discount terms). Bill of lading number
and weight of shipment should be included when using Smithsonian
Institution bills of lading. Prepaid shipping costs shall be indicated as a
separate item on the invoice. (h) Any other information or
documentation required by other provisions of the contract.
Travel – (a) If travel is specified under this purchase order; it must
be pre-authorized by the Contracting Officer’s Technical representative
(COTR) prior to occurrence. The Contractor shall be reimbursed for
such travel upon receipt of documentation that the expenses were
incurred. (b) Rail or air transportation costs shall not be reimbursed in an
amount greater than the cost of economy class rail or air travel unless the
economy rates are not available and the Contractor certified to this fact
in vouchers or other documents submitted for reimbursement. (c) Room
and meals (per diem travel allowance) shall be reimbursed in accordance
with the Contractor’s established policy, but in no event shall such
allowances exceed the rates Contractor’s established in the Federal
Travel Regulations. (d) The contractor shall be reimbursed for the cost of
the out-of-town travel performed by its personnel in their privately
owned automobiles at the rates established in the Federal travel
Regulations, not to exceed the cost by the most direct economy air route
between the points so traveled. If more than one person travels in the
same automobile, the Contractor for such travel shall incur no
duplication of or otherwise additional charges. (e) The Contractor shall
be reimbursed upon receipt of appropriate documentation that the
expenses were incurred. Total travel cost will not be reimbursed for an
amount that exceeds the estimated amount stated in this purchase order.
RESPONSIBILITY OF SMITHSONIAN PROPERTY –
Contractor assumes full responsibility for and shall reimburse and
indemnify the SI for any and all loss or damage whatsoever kind and
nature to any and all SI property, including any equipment, supplies,
accessories, or parts furnished, while in the Contractor’s custody and
care, or resulting in whole or in part from the negligent acts,
omissions of the Contractor, any subcontractor, or any employee,
agent, or representative of the Contractor or subcontractor.
SI 147A – Purchase Order Terms and Conditions Page 3 of 3
February 2018 (Rev.)
INTERNET PROTOCOL VERSION 6 (IPV6)
COMPLIANCE – In the event that the Contractor will be
developing, acquiring, and/or producing products and/or systems
pursuant to this Contract that will be connected to a network or that
will interface with the World Wide Web, the following provisions
shall apply: OMB Memo M-05-22, dated August 2, 2005, and OMB
guidance, dated July 2012 September 28, 2010, that requires
procurements of networked IT comply with the USGv6 Profile and
Test Program for the completeness and quality of SI IPv6
capabilities. The Contractor hereby warrants and represents that such
products and/or systems to be developed, acquired, and/or produced
pursuant to this Contract will be IPv6 compliant. These products
and/or systems must be able to receive, process, and transmit or
forward (as appropriate) IPv6 packets and must be able to
interoperate with other systems and protocols in both IPv4 and IPv6
modes of operation. If the product or system will not be IPv6
compliant initially, the Contractor will provide a migration path and
express commitment to upgrade to IPv6 for all application and
product features. Any such migration path and commitment shall be
included in the Contract price. In addition, the Contractor will have
available contractor/vendor IPv6 technical support for development

and implementation and fielded product management.

CLAUSES INCORPORATED BY REFERENCE -This contract
incorporates one or more clauses by reference with the same force
and effect as if they were given in full text. The applicability of these
clauses is effective upon the date of the actual contract award. Upon
request the Contracting Official will make the full text available. The
full text of the following FAR clauses may be viewed at the Federal
Acquisition Regulation (FAR) website. For the full text of
Smithsonian Institution clauses contact the procurement official. The
Contractor shall comply with the FAR clauses incorporated by
reference, unless the circumstances do not apply: References herein
to the “Government” shall be deemed to mean the Smithsonian
Institution.
SMITHSONIAN Clauses

Minimum Insurance
Smithsonian Institution Privacy and Security Clause
(form SI 147B, SI Privacy and Security Clause )
FAR Clauses
52.222-3 Convict Labor
52.222-19 Child Labor – Cooperation with Authorities and
Remedies
52.222-20 Contracts for Materials, Supplies, Articles, and
Equipment Exceeding $15,000
52.222-21 Prohibition of Segregated Facilities
52.222-26 Equal Opportunity
52.222-35 Equal Opportunity for Veterans
52.222-36 Equal Opportunity for Workers with Disabilities
52.222-41 Service Contract Labor Standards
52.222-50 Combating Trafficking in Persons. (non-commercial
services awards that do not exceed $500,000)
52.222-56 Certification Regarding Trafficking In Persons
Compliance Plan (when applicable)
52.223-1 thru 4 Bio-based ProductCertification/Affirmative
Procurement of Biobased Products Under Service and
Construction Contracts/Hazardous Material Identification and
Material Safety Data/Recovered Material Certification
52.223-5 Pollution Prevention and Right-to-Know Information
52.224-1 Privacy Act Notification
52.225-1 Buy American Supplies
52.225-13 Restrictions on Certain Foreign Purchases
52.232-11 Extras
52.239-1 Privacy or Security Safeguards (see form SI 147B)
52.233-3 Protest After Award
52.244-6 Subcontracts for Commercial Items
Additional FAR clauses that apply when applicable:
52.204-6 Universal Numbering System (DUNS)
NumberUnique Entity Identifier
52.204-7 System for Award Management
52.208-4 Vehicle Lease Payments
52.208-5 Condition of Leased Vehicle
52.208-6 Marking of Leased Vehicles
52.208-7 Tagging of Leased Vehicle
52.211-6 Brand Name or Equal
52.211-17 Delivery of Excess Quantities
52.222-54 Employment Eligibility Verification (E-Verify)
52.228-8 Liability and Insurance Leased Motor Vehicles
52-233-4 Applicable Law for Breach of Contract Claim
52.236-5 Material and Workmanship
52.247-29 F.o.b. Origin
52.247-34 F.o.b. Destination
Smithsonian Institution
Privacy and Security Clause
SI 147B – SI Privacy and Security Clause
March 13, 2024 (Rev.)

Smithsonian Data: (a) The Smithsonian Institution
(“Smithsonian”) retains sole ownership of, and unrestricted
rights to, any and all physical or electronic information
collected, processed, or stored by or on behalf of the
Smithsonian (“Smithsonian Data”), which is defined to
include personal information, also referred to as personally
identifiable information (PII), i.e., information about
individuals, which may or may not be publicly available, that
can be used to distinguish or indicate an individual’s identity,
and any other information that is linked or linkable to an
individual, such as medical, educational, financial or
employment information, online identifiers such as IP address,
device IDs, and cookie data, and any other information
defined as “personal information,” “personal data” (or other
analogous variations of such terms) under the applicable
privacy, security and data protection laws (“PII”). (b)
Contractor shall maintain, transmit, and retain in strictest
confidence, and prevent the unauthorized duplication, use and
disclosure of Smithsonian Data. (i) Contractor shall only
access, maintain, use, and disclose Smithsonian Data to the
extent necessary to carry out the requirements of this contract,
and shall not use Smithsonian Data for any other purposes,
including testing or training purposes. (ii) Contractor shall
only provide Smithsonian Data to its authorized employees,
contractors, and subcontractors and those Smithsonian
employees, contractors, and subcontractors who have a valid
business need to know such information in order to perform
duties consistent with this contract. (iii) Contractor shall
ensure that all Smithsonian Data is protected from
unauthorized access, disclosure, modification, theft, loss, and
destruction and will provide assurance and evidence of such
protections upon the Smithsonian’s request. (iv) Contractor
shall not disclose Smithsonian Data without the Smithsonian’s
advance written authorization. If Contractor receives a legal
request (such as a subpoena), or becomes subject to a legal
requirement or order to disclose Smithsonian Data, Contractor
shall (1) immediately notify the Contracting Officer’s
Technical Representative (“COTR”) of it and afford the
Smithsonian the opportunity to contest such disclosure, (2)
assert the confidential nature of the Smithsonian Data, and (3)
cooperate with the Smithsonian’s reasonable requirements to
protect the confidential and proprietary nature of Smithsonian
Data. (v) Contractor shall not transfer access to any
Smithsonian Data in the event of a Contractor merger,
acquisition, or other transaction, including sale in bankruptcy,
without the prior written approval of the Contracting Officer.
(c) Contractor shall provide the Smithsonian reasonable
access to Contractor facilities, installations, technical
capabilities, operations, documentation, records, databases,
and personnel, and shall otherwise cooperate with the
Smithsonian to the extent required to carry out an audit for
compliance with the requirements in this contract. Contractor
shall, as requested by the COTR, complete, or assist
Smithsonian staff with the completion of, a privacy and/or
security review which might include providing requested
information and documentation about how Smithsonian Data
is used, collected, maintained, stored, or shared. (d) Contractor
shall make any Smithsonian Data accessible to the COTR as
soon as possible, but no later than ten calendar days of
receiving a request from the COTR, and shall transfer all
Smithsonian Data to the COTR no later than thirty calendar
days from the date of such request from the COTR. Contractor
shall, when required to transfer Smithsonian Data to the COTR
under the terms of this contract, provide that Smithsonian Data
in one or more commonly used file or database formats as the
COTR deems appropriate. (e) Unless otherwise specified in
this contract, Contractor shall purge any Smithsonian Data
from its files and shall provide the COTR a Certificate of
Destruction (“COD”),confirming the purging of the
Smithsonian Data within forty- five calendar days of receiving
a request from the COTR or at the expiry of this contract. (f)
Contractor shall only be permitted to use non-Smithsonian
provided information technology resources to access or
maintain Smithsonian Data if Contractor provides, and the
COTR approves, the following written certifications about the
non-Smithsonian provided information technology resources:
(i) Contractor shall maintain an accurate inventory of the
information technology resources; (ii) Contractor shall keep all
software installed on the information technology resources,
especially software used to protect the security of the
information technology resources, current and free of
vulnerabilities; (iii) Contractor shall encrypt all Smithsonian
Data stored or accessed on non-Smithsonian provided mobile
devices and back-up devices (e.g., phone, laptop, tablet, or
removable media) using a Federal Information Processing
Standards compliant encryption method; (iv) Contractor shall
utilize anti-virus software on all non-SI information technology
resources used under this contract; and (v) Contractor shall
encrypt all transmissions of PII using Transport Layer Security
1.2 or higher with secure cyphers. Secure Sockets Layer shall
not be used. (g) Unless more substantial requirements are
provided for herein, Contractor is responsible for, at a
minimum, applying industry best practice background
screening, security and privacy training, and other appropriate
personnel security safeguards to the services performed under
this contract. (h) Contractor shall, if requested by the COTR,
require its employees to sign a nondisclosure agreement, sign a
conflict of interest agreement, and/or sign an acknowledgement
of the requirements in this contract.
Privacy Breach or IT Security Incident: In the event of
(i) any action that threatens or is likely to threaten the
confidentiality, integrity, or availability of Smithsonian IT
resources (including computer hardware and software, data,
communication links, mobile devices, digitized assets,
automated processes, physical computing environments, and
associated personnel, whether located inside or outside of the
Smithsonian); (ii) any activity that violates Smithsonian IT
Security policies provided by the COTR; (iii) any suspected
or confirmed loss of control, compromise, unauthorized
disclosure, unauthorized acquisition, unauthorized access, or
situation where persons other than authorized users or for an
Page 1 of 4
Smithsonian Institution
Privacy and Security Clause
SI 147B – SI Privacy and Security Clause
March 13, 2024 (Rev.)
other than authorized purpose have access or potential access
to Smithsonian Data or PII in a usable form, whether physical
or electronic; or (iv) any suspected loss of control,
compromise, unauthorized disclosure, unauthorized
acquisition, unauthorized access, or situation where persons
other than authorized users or for an other than authorized
purpose have access or potential access to PII in a usable
form, whether physical or electronic (collectively,
“Incident”), Contractor shall: (a) Immediately, but no later
than 24 hours after discovery, report the Incident to the
designated COTR and Smithsonian Office of the Chief
Information Officer (“OCIO”) Service Desk by calling 202-
633-4000 and, if the OCIO Service Desk does not answer the
telephone, leaving a voicemail which includes the name of
Contractor, a brief summary of the Incident, and a return
telephone number; (b) The Contractor shall cooperate with
Smithsonian investigations and response activities for
breaches or incidents that include the Contractor’s IT
resources or personnel; (c) Follow industry standard best
practices to preserve evidentiary information to support
forensics analysis, correct and mitigate any damages resulting
from the Incident, provide a final report or summary of the
incident to include lessons learned and corrective actions
taken and planned; (d) Contractor shall acquire applicable
forensics services in the event the Contractor does not have
adequate resources or capabilities to respond to the Incident;
and (e) Indemnify and hold the Smithsonian harmless from
any costs incurred by the Smithsonian in connection with
such Incident or corrective actions the Contractor must
deploy to safeguard SI information.
Public-Facing Software: (a) Any application, system,
software, or website used to fulfill the terms of this contract,
which can be accessed by members of the public (PublicFacing Software) shall comply with Smithsonian’s Privacy
Statement (located at Smithsonian Institution’s Privacy
Statement | Smithsonian Institution (si.edu) and the
Smithsonian Kids Online Privacy (“SKOP”) Statement
(located at http://www.si.edu/privacy/kids), and such PublicFacing Software shall provide the public with privacy notices
in locations that are acceptable in accordance with these
policies. (b) For kiosks and interactives developed by
Contractor, the Contractor shall take all reasonably necessary
steps to ensure they will be maintained with antivirus software
and routine patching. (c) If Contractor discovers that
information was collected from someone under the age of 13
in violation of the SKOP’s parental permission requirements,
Contractor shall provide notice to the Smithsonian Privacy
Office as soon as possible, but no later than 24 hours after
discovery, and delete that information as soon as possible, but
no later than 24 hours after discovery. (d) Any public-facing
software that employs tracking technology (such as a cookie,
pixel, web bug, or web beacon) or collects contact information
shall provide all users with legally-compliant notice of its data
collection and tracking practices, and any required consumer
choices (including the opportunity to opt-in or opt-out, as
required). as well as: (i) for those who opt-out or decline the
“opt-in,” reasonable access to the public-facing software; and
(ii) for those who “opt-in”, a subsequent and accessible
opportunity to request that the tracking or communications
cease (i.e., “opt-out”).
Cardholder Data and PCI Sensitive Authentication
Data: (a) Any Contractor that collects, processes, stores,
transmits, or affects the security of cardholder data or Payment
Card Industry (“PCI”) sensitive authentication data, either
directly or through a third party, in order to carry out the
requirements of this contract shall provide the COTR, before
this contract begins and annually thereafter, for the Contractor
and for any third party vendor that processes, stores, transmits,
or affects the security of cardholder data or PCI sensitive
authentication data, a current, complete, comprehensive, and
signed PCI Data Security Standard (“DSS”) Attestation of
Compliance (“AOC”), a template for which may be accessible
in the online document library of the PCI Security Standards
Council (“SSC”); (b) any Contractor that works as a PCI
Third-party Service Provider (“TPSP”), in order to carry out
the requirements of this contract, shall provide the COTR: (i)
the duly authorized contact responsible for the Contractor’s
maintenance of PCI DSS compliance; (ii) the PCI DSS
Requirement Management Form provided by the COTR,
which asks whether Contractor or a third party shall be
responsible for ensuring that certain key DSS requirements are
met; (iii) before this contract begins and for each bespoke and
custom software developed for the Smithsonian i.e.,
application, system, software, or website, the validation for the
use of the PCI SSC’s Software Security Framework standards
(the Secure Software Standard or the Secure SLC standard);
(iv) for each Payment Application hosted by the Smithsonian,
the listing from the SSC website’s Validated Payment
Software List of Validated Payment Applications or the
Report on Validation (“ROV”) from a PCI Secure Software
Assessor; (v) for each payment device, the listing from the
SSC website’s Approved Personal Identification Number
Transaction Security (“PTS”) Devices list; (vi) for each
system used to process Point of Sale card-present transactions,
the listing from the SSC website’s Point-to-Point Encryption
Solutions list; and (vii) if requested, any additional evidence
needed to determine the PCI compliance of activities related to
this contract; (c) Contractor shall provide the documents and
listings identified in Paragraph 4(b) before it shall be
permitted to use the relevant technology and shall provide
updated documents and listings to the COTR for review and
approval before a system change results in one or more of the
required documents or listings becoming inaccurate.
IT Systems and Cloud Services: (a) Contractor is
responsible for applying industry best practices to secure their
systems and services provided to or used for the Smithsonian.
(b) For any Cloud Service (i.e., computing service provided
on-demand via a shared pool of configurable resources instead
of via separate dedicated computing resources or information
technology system) or IT system Contractor develops,
operates, or maintains on behalf of the Smithsonian, or which
Contractor uses to collect or store information on the
Page 2 of 4
Smithsonian Institution
Privacy and Security Clause
SI 147B – SI Privacy and Security Clause
March 13, 2024 (Rev.)
Smithsonian’s behalf, Contractor shall provide the requested
documentation, security control evidence/artifacts, and other
information needed to complete Security Assessment and
Authorization activities. (c) For Systems that have been
Federal Risk and Authorization Management Program
(“FedRAMP”) certified or have received other independent
third party assessments (e.g., SOC2, HITRUST, etc.),
Contractor shall provide FedRAMP documentation or
relevant third party assessment report(s) to the Smithsonian
for review and shall cooperate with Smithsonian requests for
clarification or further evidence. (d) For Systems which are
not FedRAMP certified, Contractor shall complete all
requested Smithsonian Assessment and Authorization
documentation and shall fully cooperate with the
Smithsonian’s security assessment process, including
providing requested security control evidence/artifacts and
access to interview appropriate Contractor personnel about
security controls. (e) For websites or web servers hosted
outside of the Smithsonian’s data center, the Contractor must
allow OCIO to perform vulnerability scanning and
penetration testing. Website owners should consult with
information technology security staff to determine specific
needs for their environment. (f) The Contractor shall maintain
all Smithsonian Data inside the United States. (g) For
Contractor custom developed (non-COTS) systems and
websites to be hosted at the Smithsonian, Contractor shall
complete all requested Smithsonian Assessment and
Authorization documentation for the components/aspects of
the system provided by Contractor, and shall fully cooperate
with the Smithsonian’s security assessment process,
including providing requested security control
evidence/artifacts and access to interview appropriate
Contractor personnel about security controls. (h) For
Contractor developed applications or Contractor built
interactive systems (e.g., public-facing exhibit technology
incorporated through digital signage, custom interactives,
content players, media players, audio streaming devices,
lighting or control automation systems), Contractor shall not
circumvent the security of the system (e.g., the use of
backdoor or maintenance hook provisions are prohibited) and
will ensure that the system can be protected from malware
and vulnerabilities while it is in use at the Smithsonian. (i)
Contractor shall not implement into live production or use for
the Smithsonian or any system containing Smithsonian Data
until security and privacy authorization has been granted in
writing by the Smithsonian OCIO via the COTR. Contractor
will resolve security deficiencies in order to successfully meet
the applicable requirements of this section. (j) Contractor
consents to and will cooperate with ongoing monitoring for
security, privacy, cyber supply chain risk management, and
contractual requirement compliance by the Smithsonian,
including providing periodic updated evidence/artifacts, third
party assessment reports, and questionnaire responses as
requested. Contractor will resolve findings from monitoring,
assessments, and Smithsonian web vulnerability scans in a
timely manner. The Smithsonian may use third party risk
intelligence tools to monitor risk and control compliance by
the Contractor. Contractor will address issues as necessary to
maintain an acceptable risk rating in these tools. (k)
Contractor will provide at least one point of contact to receive
and respond to requests related to these requirements.
Credentials and Network Access: (a) Contractor and
Contractor’s employees who have access to Smithsonian
network/systems shall, when requested by the COTR,
complete Smithsonian-provided privacy and security training
course(s), sign a nondisclosure agreement, sign a conflict of
interest agreement, sign an acknowledgement of the
requirements in this contract, provide fingerprints, pass a
Smithsonian background check, and/or provide notice of the
results of that background check to the COTR. The content
and timing of the course(s), agreement, or background check
shall be substantially similar to one that would be required of a
Smithsonian employee with access to similar Smithsonian
networks/systems. (b) Contractor shall notify the COTR at
least two weeks before any of Contractor’s employee
requiring a Smithsonian credential, network account or other
access, or other Smithsonian-furnished equipment stops
supporting the work of this contract. In the event that
Contractor is not provided two weeks’ notice by its employee,
Contractor will notify the COTR as soon as Contractor
becomes aware of the employee’s departure from the
contracted work. (c) Contractor shall, when any employee
requiring a Smithsonian credential, network account or other
access, or other Smithsonian furnished equipment stop
supporting the work of this contract, provide such employee’s
Smithsonian credential and any Smithsonian furnished
equipment to the COTR within three business days.
California Consumer Privacy Act: (a) The California
Consumer Privacy Act as amended by the California Privacy
Rights Act, including any regulations and amendments
implemented thereto (“CCPA”) shall apply to any
information collected from California residents on behalf of
the Smithsonian. (b) For purposes of the CCPA, Contractor
shall be considered a service provider and the Smithsonian is a
business. (c) Contractor shall not collect, maintain, store, use,
disclose, or share PII for a commercial purpose other than
providing the services or performing its obligations to the
Smithsonian. (d) Without limiting the foregoing, Contractor:
(i) will not sell or share PII (as “sell,” “sale,” or “share” is
defined by the CCPA); (ii) will not retain, use, or disclose
Personal Information outside of the direct business
relationship between Contractor and the Smithsonian; and
(iii) certifies that it understands the restrictions in this section
and will comply with them. (e) Contractor agrees: (i) that the
personal information disclosed is only for limited and
specified purposes; (ii) to comply with applicable CCPA
obligations; (iii) to grant the Smithsonian the right to take
reasonable and appropriate steps to help ensure that
Contractor uses the PII transferred in a manner consistent
with the Smithsonian’s CCPA obligations; (iv) to notify the
Smithsonian if it makes a determination that it can no longer
meet its obligations; and (v) to grant the Smithsonian the
right (upon notice) to take reasonable and appropriate steps to
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Smithsonian Institution
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SI 147B – SI Privacy and Security Clause
March 13, 2024 (Rev.)
stop and remediate unauthorized use of PII. (f) Upon request
by the Smithsonian, Contractor will assist the Smithsonian in
the Smithsonian’s fulfillment of any individual’s request to
access, delete, or correct PII. (g) Contractor will promptly
notify the Smithsonian following Contractor’s receipt of any
request or complaint relating to any PII (unless applicable
law prohibits such notification). Contractor will not respond
to any such request or complaint, other than to redirect to the
Smithsonian, unless expressly authorized to respond by the
Smithsonian.
European Economic Area. This contract does not
include the collection or processing of Personal Information
relating to individuals located in the European Economic
Area.
Terms: The bolded headings at the start of each
section of this Smithsonian Institution Privacy and Security
Clause are included only to assist the reader in navigating
this Smithsonian Institution Privacy and Security Clause.
The Parties intend the bolded headings to have no legal
effect, and agree that the bolded headings are not intended to
limit or modify any other language in this Smithsonian
Institution Privacy and Security Clause.
Page 4 of 4
Office of Contracting Page 1 of 2
SI Rights-In-Data Clause 21 June 2001
SMITHSONIAN INSTITUTION
RIGHTS-IN-DATA CLAUSE
As used herein, the term “Subject Data” includes, but is not limited to, literary works; musical
works, including any accompanying words; dramatic works, including any accompanying music;
pantomimes and choreographic works; pictorial, graphic and sculptural works; motion pictures
and other audiovisual works; sound recordings; and architectural works, as each of those terms
are used and defined by the Copyright Act of the United States (17 USCS §101, et. seq.) (the
“Copyright Act”) and works of any similar nature (whether or not copyrighted) which are
included in the material to be delivered under this contract.
(a) Work for Hire. All Subject Data first produced, composed, or created in the
performance of this contract, where such Subject Data consists of a work: (i) specially ordered or
commissioned for use as a contribution to a collective work; (ii) as part of a motion picture or
other audiovisual work; (iii) as a translation; (iv) as a supplementary work; (v) as a compilation;
(vi) as an instructional text; (vii) as a test; (viii) as answer material for a test; or (ix) as an atlas,
as each of those terms are used and defined by the Copyright Act, shall be considered a “work
made for hire,” as that term is defined under the Copyright Act. The copyright to such Subject
Data shall be the exclusive property of Smithsonian and may be registered by the Smithsonian
Institution in its own name.
(b) Other Copyrightable Works. All Subject Data first produced in the performance
of this contract, where such Subject Data consists of copyrightable materials that do not fall
within the enumerated categories for work for hire, shall become the property of Smithsonian.
Contractor hereby transfers to Smithsonian full legal title and all right, title, and interest in the
copyright to all such Subject Data, including without limitation, all preliminary renditions of the
Subject Data whether or not such renditions are actually delivered to Smithsonian. The
copyright to such Subject Data shall be the exclusive property of Smithsonian and may be
registered by the Smithsonian Institution in its own name.
(c) Except as specified herein, no Subject Data first produced in the performance of
this Agreement may be published or reproduced by Contractor in whole or in part, in any manner
or form, without Smithsonian’s prior written consent. Contractor agrees that no right at common
law or in equity shall be asserted, and no claim to copyright by statute shall be established by
Contractor in any such Subject Data without Smithsonian’s prior written consent. Contractor
shall secure Smithsonian’s legal title and interests in and to all Subject Data that is produced for
Contractor by third parties pursuant to this Agreement.
(d) License for Other Subject Data. Excluding the Subject Data which Smithsonian
owns or has already obtained a license for, Contractor hereby grants to Smithsonian a royaltyfree, non-exclusive, perpetual, and irrevocable license in all copyrighted or copyrightable Subject
Data not first produced, composed, or created in the performance of this Agreement, but which is
incorporated in the material furnished under this Agreement. Such license includes, without
limitation, the rights to reproduce, publish, translate, broadcast, transmit, distribute, exploit,
display, use, sell, and/or dispose of such Subject Data in any manner, and to authorize others to
do so. In the event that Contractor does not have the right to grant such a license with respect to
any such Subject Data, Contractor shall immediately notify the Smithsonian of this fact and
Office of Contracting Page 2 of 2
SI Rights-In-Data Clause 21 June 2001
obtain Smithsonian’s prior written permission to incorporate such Subject Data in the work.
Without this notification, Smithsonian will be acting in reliance on this contract and will
presume that it possesses all necessary rights and is free to make whatever use of the Subject
Data that Smithsonian determines is in its best interests.
(e) The Contractor hereby warrants that the Subject Data delivered to Smithsonian
pursuant to this contract does not infringe statutory copyrights or common law literary rights of
Contractor or others and contains no matter libelous or otherwise unlawful. Contractor agrees to
indemnify the Smithsonian Institution, its Board of Regents, officers, agents, and employees
against any liability, including costs and expenses, for: (i) violations of copyright or any other
property rights arising out of the use, reproduction, or disposition of any Subject Data furnished
under this contract; or (ii) based upon any libelous or other unlawful matter contained in said
Subject Data.
(f) The Contractor agrees to report in writing to the Smithsonian Office of the
General Counsel, promptly and in reasonable detail, any notice or claims of copyright
infringement received by Contractor with respect to any Subject Data or other material delivered
under this contract.
OCon 140 – SI Confidentiality Clauses OCon&PPM
May 2024 (rev)
SMITHSONIAN CONFIDENTIALITY AND DISCLOSURE CLAUSES
The Smithsonian Institution is a trust instrumentality of the United States and has adopted a written policy for responding to
requests for Smithsonian Institution records, including paper documents, electronic data, email, contracts, and other information stored
or maintained by the Smithsonian, consistent with the principles of disclosure under the Freedom of Information Act, 5 United States
Code (U.S.C.), § 552 and available at http://www.si.edu/OGC/Records-Requests:
Confidential Information. Confidential Information consists of trade secrets and commercial or financial information that is
customarily treated as private and provided under an assurance of privacy, as well as information the release of which would
violate the privacy rights of the disclosing party or a third party with no overriding public interest. Confidential Information shall
be designated in writing by the disclosing party as confidential. To have information disclosed other than in writing treated as
Confidential Information, the disclosing party must confirm the status of that information as Confidential Information within
thirty (30) calendar days of the original disclosure.
Exceptions to Confidential Information. Confidential Information shall not include any information, whether or not designated
in writing as Confidential Information, which:
(a) was publicly available at the time of disclosure to the receiving party;
(b) was known by the receiving party prior to such disclosure;
(c) becomes publicly available after disclosure to the receiving party through no fault of the receiving party;
(d) is obtained by the receiving party from a third party who acquired the information without committing a wrongful or tortious
act; or
(e) is developed independently by the receiving party without reference to or use of Confidential Information.
The receiving party shall notify the disclosing party promptly in writing of any misappropriation, unauthorized disclosure, or use
by any person of the Confidential Information disclosed to the receiving party which may come to the receiving party’s attention.
The receiving party will take all steps reasonably requested by the disclosing party to stop, limit, or otherwise remedy such
misappropriation, unauthorized disclosure, or use.
Limited Disclosure. In maintaining Confidential Information, each party shall use at least the same degree of care that it uses to
protect its own confidential information of similar importance, but no less than a reasonable degree of care. Each party agrees
that it will not disclose Confidential Information provided to it by the other party to others except to the extent that it is necessary
to disclose such Confidential Information to its Regents, directors, officers, representatives, legal and financial consultants, and
employees having a need to know such Confidential Information (“authorized parties”) for the purpose of pursuing a relationship
between the parties. Further, the parties may disclose Confidential Information if required by law, subpoena, order or request of a
federal governmental authority or court of competent jurisdiction, and provided that the party obligated to disclose such
Confidential Information shall (i) assert the confidential nature of the Confidential Information to be disclosed, (ii) use reasonable
efforts to obtain confidential treatment for any Confidential Information so disclosed, and (iii) immediately notify the other party
of the requirement, order, or request to disclose in advance of such disclosure in order to afford the other party the opportunity to
contest disclosure. In the event disclosure of Confidential Information is requested in accordance with Smithsonian’s records
disclosure policy, Smithsonian will provide the Disclosing Party the opportunity to identify Confidential Information for
redaction prior to release. To the extent the Smithsonian Institution determines that the records requested contain Disclosing
Party’s Confidential Information, the Smithsonian will redact and withhold such Confidential Information from release, but final
decisions regarding release shall be made by Smithsonian in accordance with its policy. No other use or disclosure of Confidential
Information may be made by any party without the prior written consent of the Disclosing Party.
Return of Confidential Information. The receiving party will either return or destroy all tangible materials embodying
Confidential Information within ten business days of receipt of the disclosing party’s written request to do so. Notwithstanding
the preceding sentence, the receiving party (i) may retain one copy of any portion of the Confidential Information that the
receiving party is required to retain by applicable law, rule or regulation, or their internal compliance policies and (ii) shall not be
obligated to erase Confidential Information contained in an electronic archiving or backup system operating in the ordinary course
of business.
5.
Contractor’s Name:
Purchase Order #:
Individual’s Name:
Individual’s Signature: Date:
OCon-520, Background Investigations and Credentials for Contractors’ Personnel
October 2009
Background Investigations and Credentials for Contractors’ Personnel
This information applies to the Contractor’s employees and subcontractors, who provide services for the
Smithsonian Institution (SI). All contractors are subject to SI security directives in effect during the duration of their
contracts with the SI.
Background Investigations. Specifically, all Contractor’s employees to be assigned to the SI under this
contract shall be required to receive an SI Credential if their association with SI will be greater than thirty (30)
days and they will need access to staff-only areas of SI controlled facilities and leased spaces. Prior to being
issued this SI Credential, the Contractor’s employees shall be required to undergo and pass an appropriate
background investigation and complete security awareness training. The Contractor’s employees whose
associations with the SI shall be less than 30 days shall not receive a background investigation or SI Credential,
however, they must be escorted by Credentialed personnel at all times when in staff-only areas of SI facilities.
Upon successful completion of a background investigation, the Contractor’s employees to be assigned to SI
shall be issued an SI Credential that must be worn and visible at all times while on duty and within staff-only
areas of SI facilities. If the nature of the work does not require escorted access to SI facilities, or when SI
Credentialed staff can accompany contractors at all times, the Contractor and/or Contractor’s employees may
begin work prior to receiving an SI Credential. Contractor’s and subcontractor’s employees shall not be
allowed unescorted access to SI staff-only areas until they undergo an adjudicated background check and
receive an SI Credential.
Forms, Information and Reviews Required. The Contracting Officer’s Technical Representative (COTR), or
other designated SI employee, shall furnish the Contractor with an OF-306 (Declaration for Federal
Employment form). An OF-306 must be completed by each person employed by the Contractor who shall be
assigned to SI. Completed forms OF-306 must be returned by the Contractor to the COTR, or other designated
SI employee, within ten (10) workdays from receipt of the forms. Upon notification from the COTR or
designated SI employee the Contractor shall send each employee to be assigned to this contract to the SI
Personnel Security and ID Office for fingerprinting. For contractors to SI organizations outside the Washington
DC and New York City areas, SF-87 Fingerprint Cards shall be provided to the Contractor by the COTR or
other designated SI employee. If necessary, the forms SF-87 shall be submitted by the Contractor with the OF306. Based on the information furnished, the SI shall conduct a background investigation referred to as Special
Agreement Checks (SAC). The SAC includes but is not limited to:

Security Agency Checks (record of previous suitability determinations)
FBI National Criminal History Check
Law Enforcement Checks
SI shall review the investigation results and determine if the contractor and contractor’s employees did not
provide their true identities, or are otherwise not suitable for an SI Credential. SI shall provide the contractor
with reasonable notice of the determination, including specific reason (s) the individual(s) has been determined
to not have provided his/her true identity or is otherwise unsuitable for an SI Credential. The contractor or
subcontractor has the right to answer the notice in writing and may provide documentation that refutes the
validity, truthfulness, and/or completeness of the SI initial determination. After consideration of the initial
determination and any documentation submitted by the contractor for reconsideration, the Director, Office of
Protection Services (OPS), SI, or his/her designee, shall issue a written decision. The reconsideration decision
by the Director, OPS, shall be final.

Term Requirement for SI Credentials. Throughout the life of the contract, the Contractor shall provide the
same data for each new employee(s) or subcontractor(s) who will be assigned to this contract. The Contractor’s
SI Credentials shall expire annually and must be renewed, if necessary. It is the Contractor’s responsibility to
initiate the renewal process. The Contractor is not required to submit another set of background investigation
forms for the Contractor’s employees who have already been through this process.
Relinquishing SI Credentials. Upon expiration of the contract, or removal or termination of the Contractor’s
employees assigned to SI facilities, the Contractor shall return all SI Credentials issued to the Contractor’s and
/or subcontractor’s employees to the COTR or other designated SI employee.
OCon 120, Notice of Mandatory Registration in the System for Award Management
December 2023
Notice to all Current and Prospective Smithsonian Institution Contractors
Subject: Mandatory Registration in the System for Award Management (SAM)
Individuals and companies that want to do business with U.S. government agencies, including the
Smithsonian Institution, are required to maintain active and valid registrations in the System for Award
Management (SAM). We are informing you of this requirement because you are a vendor who has been
requested to present pricing and/or proposals for goods or services, is currently participating in a
Smithsonian solicitation for goods or services, or is already providing goods or services to the Smithsonian.
Registration with SAM is free and accomplished via https://www.sam.gov. Included with this letter are
tips on how to register in SAM. These have been written by the Smithsonian Office of Contracting and
Personal Property Management and are intended to convey specific information on how to register with
SAM to do business with the Smithsonian. Full guidance on how to register in SAM is available from the
Federal Services Help Desk (FSD) and Professional Technical Assistance Centers, as described in the tips.
Thank you for your attention to this matter. If you received this letter in conjunction with a solicitation
or Request for Quote, please address any questions you may have to the Smithsonian point of contact
whose name and telephone number are provided therein.
Sincerely,
Thomas E. Dempsey
Director
OCon 120, Notice of Mandatory Registration in the System for Award Management Tips Page 1
December 2023
General Tips for Businesses To Register in SAM
There is assistance directly on the SAM website to start registration. Look for quick start guides and
the SAM user manual using the Help tab on the SAM.gov website. These guides are helpful for vendors
in completing the SAM registration process.
Registration in SAM is Free. If you search online for SAM registration your search might return
businesses that will assist you with SAM registration for a fee. You are not required to utilize these
services, and the Smithsonian does not reimburse for their use. The easiest way to ensure you are in
the right location is to navigate directly to www.SAM.gov.
Free assistance with SAM registration is available via the Federal Service Desk (FSD). This is available
at http://www.fsd.gov, or at the toll-free number 1-866-606-8220
APEX Accelerators offer free assistance with SAM registration. These offices are non-profit, nongovernmental organizations established to assist you with doing business with the government. You
must use the local or regional office closest to your business address. Locate the center nearest at
https://www.apexaccelerators.us/#/.
You control all information entered into SAM, and may opt out of public searches. If you choose to
opt out of public searches, please notify the Smithsonian employee you are working with and provide
confirmation of your SAM registration.
Be sure to keep your SAM registration up-to-date. After you have completed registration you will be
required to update your information if it ever changes (such as mailing address or banking records)
and notify Smithsonian staff as soon as possible. Keep your Unique Entity Identifier Number in a safe
place, you will need it to renew or update your registration.
Tips on Valid Registrations:
Your registration must be active before the purchase can be made. Obtaining a Unique Entity
Identifier only is only the first step to a complete registration. You must complete all steps thereafter
and be listed in SAM with a record labeled “Active.”
If you have a registration that inactive, then your registration must be made active before you can
receive a procurement. Inactive records cannot be used for a purchase. Your SAM registration must
be active throughout the term of the award.
If you have a registration that requires updates then your updates must be complete before you can
receive a procurement. Changes to information including (but not limited to) company or contact
names, banking information, and addresses must be completed before you may receive an award. If
changes to any information in your SAM registration must be made during the timeframe of an award
then you must notify the Procurement Officer who issued the award within two business days of the
change in information.
You must register as eligible to receive “All Awards” to qualify for Smithsonian Awards. In the SAM
registration process, you will be asked for your purpose of registration. The question is “Why are you
registering this entity to do business with the U.S. Government?” You must answer this question with
“I want to be able to bid on federal contracts or other government opportunities. I also want to be
able to apply for grants, loans, and other financial assistance programs.” This option will allow you to
accept procurements issued by the Smithsonian. Do not select “I only want to apply for federal
assistance opportunities like grants, loans, and other financial assistance programs.” If you register for
assistance opportunities only then procurements may be delayed until your record is corrected.
OCon 120, Notice of Mandatory Registration in the System for Award Management Tips Page 2
December 2023
The name of your business (entity) that you enter in SAM must match your IRS Tax Payer Consent
Name. This will be the name that Smithsonian will use to register your entity in our internal payment
and tax reporting system. If your SAM entity name and your Tax Payer Consent Name differ this can
create problems during the Smithsonian vendor enrollment and tax reporting processes, as well as for
you when paying taxes. (These two names may be allowed to differ only if you are a single member
LLC, and you report and pay taxes to the IRS using the owners name and tax id. In this case, IRS will
count the owners name and tax id as the legal business name while disregarding the legal business
name of the LLC registered in SAM.)
Tips on Entity Administrators
SAM requires each non-federal entity to have someone with the role of Entity Administrator. SAM will
appoint the Entity Administrator role to the first individual who registers a new business entity. They will
have the capability to update, renew and end your registration. They will also have the authority to
appoint administrative roles with SAM to your entity’s staff and to assign other users within your entity to
become an Entity Administrator. This administrator must be an employee of your entity. Information for
new Entity Administrators and on role assignment is found in the FSD knowledge base.
It is important that your entity always have a current Entity Administrator. If, for any reason your, Entity
Administrator leaves your entity before appointing a replacement and you do not have a current
administrator, then you must follow the process to appoint a replacement. This process includes
submitting a notarized Entity Administrator Appointment Letter and may take several weeks to complete.
Your SAM registration will not be editable or renewable until you have a new Entity Administrator.
Information on appointing a replacement Entity Administrator is found in the FSD knowledge base.
1
SMITHSONIAN DIRECTIVE 600,
May 12, 2022
COLLECTIONS MANAGEMENT
Purpose 2
Background 2
Applicability 3
Authority and Responsibilities 3
Ethics 6
Financial Accounting for Collections 7
Acquisition and Accessioning 7
Deaccessioning and Disposal 10
Preservation 13
Collections Information 14
Inventory 16
Risk Management, Safety, and Security 16
Access 18
Loans 19
Intellectual Property Rights 21
Specific Legal and Ethical Issues 22
Smithsonian Collecting Unit Requirements 27
Exceptions 34
Appendix A: Smithsonian Collecting Units
Appendix B: Related Directives and References
Appendix C: Definitions
SD 600 — 5/12/22
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PURPOSE
Smithsonian Directive (SD) 600, Collections Management, is the principal policy document
guiding Smithsonian collections management. As the Smithsonian’s collections management
policy, SD 600 guides collections stewardship to ensure proper management, preservation, and
use of the Institution’s collections and items in its care and custody.
This directive covers all aspects of collections management, including acquisition and
accessioning, deaccessioning and disposal, preservation, documentation, life-cycle
management, inventory, risk management, safety and security, access, storage, loans, and
intellectual property management. This directive also addresses specific legal and ethical issues
that pertain to collections, including shared stewardship and ethical returns, Native American
and Native Hawaiian human remains and objects, cultural property, biological material, and
objects unlawfully appropriated during the Nazi era.
SD 600 establishes and implements policies consistent with the Smithsonian Collections
Management Guidelines approved by the Board of Regents and issued by the Secretary in
May of 1999.
Additional policy and procedural guidance implementing the provisions of this directive is
available on the National Collections Program SharePoint site.
BACKGROUND
The stewardship of collections is fundamental to the Smithsonian’s mission to increase and
diffuse knowledge. Smithsonian collections are a national and global resource accessed each
year by millions of visitors and researchers who use traditional methods and digital platforms
to explore every subject, from aeronautics to zoology. Through its collections, the Smithsonian
expands knowledge through high-impact research, documents our national identity, values,
and cultural diversity, and increases public understanding of the world, its history, and our
shared future.
Assembled throughout the Institution’s history, the national collections are fundamental to the
Smithsonian’s mission, strategic priorities, and programmatic goals and serve as the
intellectual base for scholarship, discovery, exhibition, and education. Smithsonian collections
have a unique and vital role in documenting and addressing challenges facing society, such as
the effects of climate change, structural racism, global pandemics, and the loss of biological
and cultural diversity and its impact on global ecosystems and cultures.
Smithsonian collections represent a diverse range of materials and disciplines, including works
of art, historical artifacts, natural and physical science specimens, living animals and plants,
images, archives, libraries, audio and visual media, and born-digital material. Together, these
collections preserve the past, increase our understanding of society and the natural world, and
support the research that expands human knowledge in the arts, humanities, and sciences.
To properly manage collections, the Institution must deliberately develop, acquire, document,
SD 600 — 5/12/22
3
steward, preserve, use, and refine its collections. The Smithsonian carries out its collections
stewardship responsibilities through systematic collections management policies, procedures,
and plans based on professional and discipline-specific best practices to ensure strict
adherence to legal, ethical, and professional standards related to the Smithsonian’s diverse
collections management activities. Smithsonian collecting units share responsibility for the
stewardship of the national collections, with each unit maintaining collections unique to its
purpose, character, and role in achieving the Smithsonian’s mission.
As stewards of the national collections, held in trust for the public, the Smithsonian has a
unique responsibility to properly manage, preserve, and make accessible the collections in its
care for current and future generations to appreciate, enjoy, and study. Through SD 600 and
the collections management policies of individual collecting units, the Smithsonian affirms its
commitment to communities represented in our collections and a shared future regarding
knowledge-sharing, collaborative engagement, and ongoing stewardship.
APPLICABILITY
This directive applies to all Smithsonian units authorized to acquire and manage collections
(hereafter, “collecting units”). To formally be designated as an authorized collecting unit, the
unit must obtain the recommendation of the National Collections Program (NCP), the Under
Secretary for Museums and Culture, the Under Secretary for Science and Research, the
Deputy Secretary and Chief Operating Officer, and the approval of the Secretary.
All Smithsonian collecting units must adhere to the policies set forth in this directive. Newly
designated collecting units are subject to the principles of this directive to guide their
collections-related activities until a unit collections management policy is developed and
authorized in consultation with the NCP and the Office of General Counsel (OGC).
AUTHORITY AND RESPONSIBILITIES
The acquisition and possession of collections impose legal, ethical, and professional
obligations to provide proper management, preservation, and use of the collections and their
associated information. Smithsonian collections management responsibilities are delegated as
follows.
4.1. Board of Regents
The Act of August 10, 1846, codified at 20 United States Code (U.S.C.) §§ 41, et seq.,
established the Smithsonian and vested authority for conducting the business of the Institution
in the Smithsonian Board of Regents. The Board of Regents retains ultimate oversight
authority and responsibility for Smithsonian collections while delegating to the Secretary
overall collections management authority.
4.2. Secretary
The Secretary is responsible for overseeing the establishment of appropriate policies and
programs, through which the Smithsonian ensures compliance with applicable laws,
SD 600 — 5/12/22
4
regulations, and professional standards concerning collections. The Secretary delegates to the
Deputy Secretary and Chief Operating Officer, collecting unit directors, and other appropriate
staff, the responsibility to implement established policies and carry out the direct, day-to-day
management and care of Smithsonian collections.
The Secretary requires compliance with this directive by directing that development and
implementation of collections-specific policies and plans be incorporated into the performance
plans of the collecting unit directors, and that the Deputy Secretary and Chief Operating
Officer and the Under Secretaries regularly review unit compliance with their policies and
plans.
4.3. Deputy Secretary and Chief Operating Officer
The Deputy Secretary and Chief Operating Officer (hereafter, “Deputy Secretary”) supervises
the Under Secretaries for Administration, Education, Museums and Culture, and Science and
Research. In this capacity, the Deputy Secretary is responsible for supporting and holding
accountable the Under Secretaries and their Smithsonian collecting units, research centers,
and educational organizations’ implementation of their major strategic initiatives and
programmatic goals.
4.4. Under Secretaries
The Under Secretaries for Administration, Education, Museums and Culture, and Science and
Research share responsibility for ensuring Smithsonian collections are managed in
compliance with this directive by providing central oversight to collecting unit directors.
While each Under Secretary is responsible for overseeing specific collecting units, the Under
Secretary for Museums and Culture and the Under Secretary for Science and Research
oversee the vast majority of collecting units and have the most direct responsibility for
supervising collections management activities.
4.5. Director, National Collections Program
The NCP director provides central leadership, policy oversight, strategic planning, and support
for Institution-wide collections initiatives.
The NCP director exercises these responsibilities by:

serving as a principal advisor to Smithsonian senior leadership and collecting unit
directors and staff on matters related to collections management policies, standards,
and best practices;
communicating, administering, and implementing this directive, and the issuance of
additional guidance, as necessary, to implement the provisions of this directive and the
review and revision of existing policy guidance;
advising the Under Secretaries on the implementation of this directive, including the
compilation of an annual report;
SD 600 — 5/12/22
5
coordinating the development, review, revision, and approval and monitoring of unit
collections management policies and collections stewardship plans to ensure that
Smithsonian collections are maintained according to Smithsonian policy, legal
obligations, and professional standards; and
working with senior management and collecting unit directors to develop
long-term strategies and priorities to address Institution-wide collections needs,
including collections care and space, and the allocation of central collections care
resources.
4.6. Collecting Unit Directors
Each collecting unit director is responsible for:
providing unit policy guidance, program direction and planning, and budgetary support
to carry out the requirements established by this directive;
establishing, approving, and implementing an up-to-date unit collections management
policy;
establishing, approving, and implementing an up-to-date unit collections stewardship
plan to establish an intellectual framework and implementation strategy for collections
development, acquisition, refinement, and resource allocation decisions;
approving unit inventory plans and ensuring plans are appropriate to the nature,
characteristic, and size of the unit’s collections, staff resources, and any unit-specific
requirements, and receiving reports on the results of inventories;
approving and implementing an up-to-date unit digitization plan in accordance with SD
610, Digitization and Digital Asset Management Policy; ensuring unit strategic plans
include collections-specific elements;
delegating authority and assigning collections responsibilities to appropriate unit staff;
implementing and monitoring the unit’s collections management policy, procedures,
goals, and reporting on collections-related information, such as the Collections and
Digitization Reporting System (CDRS) and the Collections Space System (CSS);
allocating resources for and aligning training of unit collections staff with the
requirements of unit strategic plans, professional standards, job descriptions, delegated
authority, and assigned responsibilities; and
ensuring unit compliance with this directive and unit collections management policy,
including the submission of an annual report.
4.7 Collecting Unit Advisory Boards or Commissions
A collecting unit may have an advisory board or commission, created by the Board of
Regents, pursuant to federal law, or by agreement, to provide advice and assistance to
the Board of Regents, the Secretary, and collecting unit directors.
SD 600 — 5/12/22
6
The role of advisory boards or commissions with respect to collections shall be specified in
bylaws approved by the Board of Regents or the applicable approval authority.
By statute or legal agreement, the boards of the Archives of American Art, the Hirshhorn
Museum and Sculpture Garden, the National Museum of the American Indian, and the
National Museum of African American History and Culture have authority for specified
collections management decisions. This authority shall be carried out in accordance with the
general policies of the Board of Regents and applicable directives established by the
Secretary, including this directive.
4.8 Collecting Unit Staff
Collecting unit staff are responsible for carrying out assigned collections management
responsibilities to ensure:
implementation of this directive and unit collections management policies, procedures,
and plans;
adherence to applicable laws and professional ethics and practices;
proper acquisition, management, preservation, and responsible use of collections
throughout their life cycle; and
the integrity of collections information.
4.9 Smithsonian Collections Advisory Committee
The Smithsonian Collections Advisory Committee (SCAC), chaired by the NCP director and
composed of representatives from across the Institution, assists the NCP, senior leadership,
and collecting unit directors in implementing this directive by advising on policies, priorities,
initiatives, and funding strategies for collections management.
4.10 Other Central Offices and Directives
Other central offices providing collections management functions include the OGC the Office
of Finance and Accounting (OF&A) Risk Management Branch, the Office of the Chief
Information Officer (OCIO) and the Digitization Program Office (DPO), the Office of
Contracting and Personal Property Management (OCon&PPM), the Office of Protection
Services (OPS), Smithsonian Facilities (SF), the Office of Safety, Health, and Environmental
Management (OSHEM), and the Office of Emergency Management (OEM).
Additional program-level guidance may be provided by other Smithsonian directives on
matters related to collections management and the specific function and purpose of the other
directive (see Appendix B: Related Directives and References).

ETHICS
The Smithsonian recognizes and accepts its responsibility to provide proper management,
resources, preservation, access, and use of the collections and associated information it holds
for the benefit of the public.
SD 600 — 5/12/22
7
Smithsonian staff have legal, ethical, and professional obligations to discharge their official
duties with honesty, integrity, and loyalty to the Institution, as set forth in the Smithsonian
Institution Statement of Values and Ethics and SD 103, Standards of Conduct. Smithsonian
staff are expected to be aware of the standards of conduct issued by professional associations
relevant to their disciplines and general responsibilities.
FINANCIAL ACCOUNTING FOR COLLECTIONS
Smithsonian collections are held for public exhibition, education, and research in furtherance
of public service rather than financial gain. Collections are protected, kept unencumbered,
cared for, and preserved, and they are subject to the requirement that proceeds from sales of
collections are to be used for the acquisition of additional collection items or the direct care of
existing collections. Accordingly, the Smithsonian does not treat its collections as assets for
purposes of reporting in its financial statements. The Smithsonian adheres to the applicable
financial reporting standards governing collections held in public trust.
The NCP is responsible for submitting to the OF&A the information required for disclosure on
the Smithsonian’s financial statement.
ACQUISITION AND ACCESSIONING
Acquisition is the act of gaining legal title to a collection item or group of items.
Accessioning is the formal process used to legally acquire and record a collection item or
group of items into a collection.
The acquisition of collections is fundamental to ensuring the continual development and
refinement of collections in support of the mission and programmatic goals of the Smithsonian.
The acquisition of collections imposes legal and ethical obligations on the Smithsonian and its
collecting units to provide proper planning, management, documentation, preservation,
storage, and use of collections and their associated information. The Smithsonian observes
the highest legal, ethical, and professional standards in the acquisition and care of collections.
Acquisition and accessioning procedures are designed to ensure thoughtful, well-documented
consideration of such decisions based on responsible stewardship planning and the long-term
interests of the Smithsonian, the public, and the collection item.
Accessioned collections are subject to a high standard of care and comprise items the
Smithsonian intends to keep, preserve, protect, steward, and document for an indefinite period
for public exhibition, education, research, and/or other mission-enabling activities. Some
collection items may be acquired and designated for non-accessioned status for exhibit,
education, research, or consumptive use.
Non-accessioned collections still require the same acquisition documentation as accessioned
collections for accountability and use.
SD 600 — 5/12/22
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7.1. Policy
The Smithsonian adheres to the following policies regarding the acquisition and accessioning
of collections:
1) The Smithsonian may only acquire collections in accordance with established
authority and only when consistent with established acquisition criteria, applicable
law, and professional and Institutional ethics. All applicable federal, state, local, and
international laws, treaties, regulations, and conventions will be observed and
compliance documented.
2) The Smithsonian observes the highest legal, ethical, and professional standards in
the acquisition and care of collections. The Smithsonian shall exercise due diligence
in the acquisition and care of collections, including making reasonable inquiries into
provenance to determine that the Smithsonian can acquire a valid title to the item(s)
and that the acquisition will conform to all legal and ethical standards, including the
Smithsonian Institution Policy on the Acquisition of Art, Antiquities, Archaeological
and Ethnographic Material, and Historic Objects.
3) The Smithsonian must gain legal title, or its equivalent, to all items acquired and
recorded as accessioned or non-accessioned collections. The only exceptions to this
policy are for (i) certain transfers of federal scientific collections, formally titled in the
United States, for which the Smithsonian retains permanent custodial responsibility,
and (ii) certain transfers of biological material from foreign countries, formally titled in
the foreign country, for which the Smithsonian retains permanent custodial
responsibility.
4) As a general rule, collections are acquired and accessioned only when there is a
good-faith intention to retain them for an indefinite period of time. Certain types of
collections, such as those acquired for consumptive use, fall outside of this rule.
5) If collections are acquired with a specific intent at the time of acquisition not to add
them to the collections but rather to sell, exchange, or use them for financial gain, the
NCP and OGC must be notified in advance.
6) As a general rule, the Smithsonian only acquires unrestricted collections. Common
restrictions, such as retention by the donor of intellectual property rights, may be
accepted following appropriate review and approval. Restrictions that would
substantially limit the Smithsonian’s ability to use or dispose of an acquisition may be
accepted only after consultation with the NCP and OGC. Under no circumstances,
however, may the Smithsonian agree to conditions requiring the retention or display
of a collection item in perpetuity.
7) The Smithsonian may acquire collection items by a variety of methods, including gifts,
bequests, purchases, exchanges, transfers, field collecting, and, in certain instances,
through propagation or birth.
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8) The Smithsonian provides responsible collections management through disciplined
acquisition and accessioning procedures consistent with established Institutional
standards of long-term stewardship, preservation, care, and use.
9) Potential acquisitions must undergo a rigorous evaluation process based on the
following criteria:

consistency with the mission, strategic plan, and programmatic goals of the
Smithsonian;
quality, physical condition, intellectual value, and significance;
documentation of legal title, provenance, and any restrictions on use;
size, volume, or quantity;
ability and resources to provide appropriate management, care, and
accessibility, including documentation, conservation, long-term preservation,
digitization, and storage; and
potential for exhibition, education, and research use.
10) Deeds of gift, gift agreements, bequest documents, and other documents evidencing
a gift to the Smithsonian should be signed by the donor or, in the case of a bequest,
their executor or personal representative, and by the appropriate collecting unit
director or the director’s designee, or another authorized Smithsonian official. The
OGC must review and approve all standard deeds of gift or gift agreements and any
substantial alterations to these standard forms. Collecting units must also obtain the
review and approval of the OGC for any bequest documents requiring signatures.
11) When acquiring collections by gift, the Smithsonian shall provide written
acknowledgment of the gift with a letter to the donor within 30 days following the
completion of the gift. The letter must acknowledge receipt of the donation, state
whether or not any goods or services were provided to the donor in return for the gift,
and include appropriate tax disclosures. The OGC has established standardized
acknowledgments and may be consulted regarding tax requirements.
12) The Smithsonian may only acquire collections after considering the obligations of
long-term stewardship to determine that it can reasonably anticipate the ability to
meet such responsibilities with existing and projected resources over the life cycle of
the collection. The appropriate Under Secretary or Under Secretaries, following
consultation with the NCP, must approve the acquisition of any collection item that
would require substantial resources beyond a collecting unit’s allocated budget or
substantial resources of other Smithsonian units for the management or preservation
of the collection.
13) When determining whether to acquire collections, the Smithsonian will consider
sharing existing, renovated, or new collections storage spaces based on space, type,
and environmental needs.
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14) While overlap in collecting among Smithsonian collecting units is inevitable,
competition for a particular acquisition is inappropriate. When more than one
collecting unit seeks to acquire the same collection item, the respective unit directors
must agree on which unit will acquire the collection item or consider pursuing a joint
acquisition/ownership agreement. In those rare cases when the placement of a
collection item cannot be resolved by the directors, the Deputy Secretary will decide
after consultation with the NCP and the appropriate Under Secretary or Under
Secretaries.
15) On occasion, collecting units may jointly acquire collections with other museums,
educational organizations, or other Smithsonian collecting units with which they agree
to share ownership and management. In such circumstances, a written agreement
that stipulates the terms and conditions of the joint acquisition/ownership
arrangement and the responsibilities of each party must be formalized and approved
before final acceptance. The NCP and OGC must be consulted in advance of such
cases, and in certain circumstances the collecting unit(s) must obtain approval from
the appropriate Under Secretary or Under Secretaries, who may consult with the
Deputy Secretary as appropriate.
16) The Smithsonian will avoid competitive bidding with federal organizations for
collection items of common interest and will seek mutually acceptable agreements
whenever the potential for competitive bidding with such organizations becomes
apparent.

DEACCESSIONING AND DISPOSAL
Deaccessioning is the process used to formally approve and record the removal of a
collection item or group of items from an accessioned collection.
Disposal is the act of physically removing a collection item or group of items from a collection.
Deaccessioning and disposal are legitimate components of responsible collections
management. The periodic review, evaluation, deaccessioning, and disposal of existing
collections is intended to refine and improve the quality and relevance of collections with
respect to the Smithsonian mission. The Smithsonian acquires collections only when there is a
good-faith intention to retain them for an indefinite period of time. Collections are retained as
long as they can be properly maintained and used and align with the collections stewardship
objectives of the Institution.
The acquisition and possession of collections impose legal and ethical obligations founded on
public trust. For this reason, decisions concerning the deaccessioning and disposal of
collections require careful planning and analysis, an appropriate justification, and due
diligence. Deaccessioning and disposal procedures are designed to ensure thoughtful, welldocumented consideration of such decisions in the context of the long-term interest of the
Smithsonian, the public, and the collection item.
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8.1. Policy
The Smithsonian adheres to the following policies regarding deaccessioning and disposal of
collections:
1) The Smithsonian may deaccession and dispose of collections only when consistent
with deaccessioning and disposal criteria and approvals, applicable law and
professional and Institutional ethics, and any other applicable restrictions. All
applicable federal, state, local, and international laws, treaties, regulations, and
conventions will be observed and compliance documented.
2) Deaccessioning and disposal may occur for a variety of reasons, including:

Lack of capacity to provide proper stewardship;
Deterioration of collection items beyond repair or usefulness;
Duplication or redundancy of collection material;
Insufficient relationship between an item(s) and the mission, programmatic
goals, or collections stewardship plan of the collecting unit, such that the item
would be better placed elsewhere;
Ethical returns;
Repatriation;
Collection items containing hazardous materials which present threats to other
items or create significant health and safety risks to staff or the public;
Selection for educational or consumptive use; and
Reconciliation of collections accessioned in error.
3) The Smithsonian may dispose of collections by a variety of methods, including
donation, transfer, exchange, sale, repatriation, return, educational or consumptive
use, destruction, destructive analysis, and, in certain instances, disposal by
euthanasia or death.
4) Disposals resulting in a transfer of ownership to a third party must be documented in
a written agreement approved by the OGC.
5) Disposals of deaccessioned collection items to foreign entities must comply with SD
611, Export Compliance and Trade Sanctions Related to Research, Export and
Museum Activities.
6) If the estimated value of a single collection item or a group of collection items
considered for disposal is:
More than $10,000 — requires a written, independent appraisal or informed
estimate of fair market value.
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More than $100,000 — requires two written, independent appraisals or
informed estimates of fair market value and approvals from the NCP, OGC, the
appropriate Under Secretary, and the Secretary.
More than $500,000 — requires two written, independent appraisals or
informed estimates of fair market value and approvals from the NCP, OGC, the
appropriate Under Secretary, the Secretary, and the Board of Regents.
7) Documentation of proposed deaccessions may refer to any of the following valuation
sources: written, independent appraisals; sales histories of the collection items or
comparable items; or other standard valuation sources, including informed estimates
by staff.
8) The deaccession and disposal of collection items that, notwithstanding their monetary
value, have significant research or historical value, or when the deaccession might
create significant public interest, must be approved by the NCP, OGC, and the
appropriate Under Secretary, who may consult with the Deputy Secretary and seek
higher levels of authorization as appropriate.
9) The disposal of non-accessioned collections does not require the same appraisal and
approval processes as deaccessioning accessioned collections. Nevertheless, the
disposal of non-accessioned collections should be conducted thoughtfully and
consistent with the nature and importance of the items. The disposal of certain
non-accessioned collections may warrant the same appraisal and approval
procedures as accessioned collections. Collecting units shall consult with the NCP
and OGC when considering the disposal of significant non-accessioned collections.
10) Significant collection items manufactured by or for government entities, having no
commercial or secondary markets, do not require appraisals of fair market value for
deaccessioning and disposal. Deaccessioning and disposal of such collection items
are subject to the following procedures:
Transfer of a duplicate collection item to a U.S. Government agency requires
consultation with the NCP and OGC.
Transfer of a collection item to a Government agency or non-profit organization
in the United States requires approvals from the NCP, OGC, and the
appropriate Under Secretary, who may consult with the Deputy Secretary as
appropriate.
Transfer of a collection item to a Government agency or non-profit organization
outside the United States requires approvals from the NCP, OGC, the
appropriate Under Secretary, and the Deputy Secretary.
11) Smithsonian collecting units shall have a right of first refusal for collection items
proposed for disposal, except as otherwise stipulated by authorizing legislation or
other restrictions, or in the case of hazardous materials that present a health or safety
risk. Such transfers are made without financial compensation, except when a
collecting unit disposes of a collection item acquired through purchase. If required,
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compensation shall be based on the fair market value of the collection item at the
time of disposal or the value negotiated by the involved collecting units.
12) Under no circumstances may the ownership of any collection item that has been
removed from a collecting unit be transferred, either directly or indirectly, to any
employee, volunteer, officer, trustee, or affiliated person of the collecting unit or of the
Smithsonian Institution.
13) Any proceeds realized from the sale of collection items may be designated only for
collections acquisitions or the direct care of existing collections. Direct care may
include:
Collections assessments and preservation surveys;
The purchase of collections storage equipment, housing materials, and
supplies;
Conservation treatment and stabilization, and preservation of collections; or
Collections reformatting, re-housing, processing, documentation, inventory,
cataloguing, and digitization.
14) Proceeds realized from the sale of deaccessioned collection items may not be used
for operating expenses. Collecting units should consult with the NCP and OGC
regarding the appropriate use of proceeds for direct care.
15) Collecting units that are members of the Association of Art Museum Directors (AAMD)
may limit the use of sale proceeds for the acquisition of collections only as stipulated
by the AAMD’s policies on deaccessioning.

PRESERVATION
Preservation is the protection and stabilization of collections and their associated information
through a coordinated set of activities aimed at minimizing chemical, physical, and biological
deterioration and damage and preventing loss of intellectual, aesthetic, cultural significance,
and monetary value.
Preservation, preventive care, and remedial conservation are integral components of
collections management, ensuring collections are available for use. The ability of the
Smithsonian to carry out its mission directly relates to its ability to preserve and safeguard
collections, collections records, and other documentary materials for public benefit. Given the
diverse nature and educational significance of Smithsonian collections, it is imperative to
balance use and access with preservation needs.
9.1. Policy
The Smithsonian adheres to the following policies regarding the preservation of collections:
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1) The Smithsonian shall provide the appropriate preservation, care, protection, and
security for all collections and their associated information acquired, borrowed, or in
the custody of the Institution.
2) The Smithsonian will balance current exhibition, educational, and research, use with
the preservation requirements of collection items to ensure collections are properly
maintained and rightfully serve their intended purpose.
3) Preservation policies, plans, and standards shall be developed in accordance with the
intended purpose and use of collections and based on the principles of preventive
conservation to ensure protection from the agents of deterioration. The Smithsonian
should consider the American Institute for Conservation (AIC) Code of Ethics and
Guidelines for Practice when developing preservation policies, standards, and
procedures.
4) The Smithsonian is responsible for developing and implementing preservation
strategies, policies, procedures, and plans for collections and collections information
which respect the diverse nature and purpose of collections, including providing
access.
5) The Smithsonian is committed to sustainability in the preservation and management
of its collections, including the design, management, and maintenance of collections
space and preservation environments in accordance with SD 422, Sustainable
Design of Smithsonian Facilities.
6) The Smithsonian aims to provide and actively manage optimized preservation
environments based on a balance of scientific research, engineering capability,
collections management protocols, and environmental impact. Collecting units,
Smithsonian Facilities (SF), and the NCP shall support collaborative, evidence-based,
decision making processes among the professional disciplines and stakeholders who
share responsibility for establishing and implementing sustainable collections
environments, as outlined in the Smithsonian Institution Declaration on the
Collections Preservation Environment.
7) Any conservation intervention, restoration, destructive sampling, or consumptive use
of collection items must be authorized, documented, and justified for the purpose of
preservation or professional scholarship.
COLLECTIONS INFORMATION
Collections information is the incremental, cumulative documentation of the intellectual
significance, physical characteristics, legal status, use, provenance, and history of collection
items, and the collections management processes and transactions they undergo. Collections
information can be in analog or digital form and include text and images.
The Smithsonian relies on the well-documented results of scientific, historical, and aesthetic
research to fulfill its mission. The Smithsonian acquires, develops, and maintains collections
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information systems that enhance access to and accountability for its collections and research
findings to ensure the long-term preservation of the resulting information in analog and digital
formats. The value of collections information rests in its quality, integrity, availability, and
potential for use and public access.
10.1. Policy
The Smithsonian adheres to the following policies regarding collections information:
1) Collections information systems must support the mission and public access goals of
the Smithsonian.
2) The systems of record for Smithsonian collections data include unit collections
information systems (CIS) for information, the Smithsonian’s enterprise-wide Digital
Asset Management System (DAMS) for digital media assets, and the Smithsonian’s
enterprise-wide 3D repository for 3D data.
3) The Smithsonian is committed to placing collections information in publicly accessible
digital platforms, implementing professional documentation practices and standards,
and sharing collections information through collaborations among collecting units,
other educational and research institutions, and the public. The Smithsonian
maintains its digital assets to advance the Smithsonian’s mission, support its strategic
and programmatic goals, and facilitate access.
4) The Smithsonian seeks to provide the widest dissemination of its digital assets
consistent with the stewardship, management, and preservation responsibilities for its
collections. Following SD 609, Digital Asset Access and Use, these obligations take
into consideration a wide range of legal, ethical, and practical factors, and reflect the
staff and financial resources to generate, maintain, and render digital assets publicly
accessible.
5) In its commitment to increasing access to collections as broadly as possible, the
Smithsonian launched the Open Access Initiative, dedicating eligible digital assets
into the public domain with a Creative Commons Zero (CC0) license. Certain digital
assets are not part of the Smithsonian’s Open Access Initiative because their use is
restricted, and they carry a Usage Conditions Apply designation. Use of digital assets
can be restricted for various reasons specified in SD 609. These reasons include, but
are not limited to, copyright restrictions, restrictions imposed by donors, restrictions
imposed by contracts, and restrictions due to the cultural sensitivity of the collection
item.
6) The Smithsonian may restrict access to sensitive information involving privacy,
collecting localities, security, storage location, value, intellectual property restrictions,
and culturally sensitive content.
7) Business or financial records (e.g., vendor enrollment forms) containing personally
identifiable information (PII) or sensitive PII (sPII) about individuals associated with a
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collection item (i.e., artists, donors, collectors, or researchers) are subject to SD 118,
Privacy Policy.
8) Collections information, including all records of collections-related decisions and
activities, must comply with established Smithsonian and collecting unit standards
and be maintained according to accepted professional practices.
9) The Smithsonian is responsible for the development, maintenance, preservation, and
retention of collections information. All media containing collections information are
maintained for long-term use and must be preserved according to current
professional standards.
INVENTORY
Inventory is an itemized listing of collection items, groups, or lots that identifies the current
physical location of each item, group, or lot; the process of physically locating all or a selection
of items for which the collecting unit is responsible; and appropriate information to facilitate
research, collections management, security, and access.
Effective collections management requires an inventory system to support decisions regarding
the management, use, growth, storage, intellectual control, value, condition, physical
information, and security of collection items. Inventory records serve as a tool for
accountability and are useful in supporting other Smithsonian programs when augmented with
additional documented information.
11.1. Policy
The Smithsonian adheres to the following policies regarding the inventory of collections:
1) Inventories of collections are conducted in accordance with established authority,
inventory processes, and a written inventory plan appropriate to the purpose,
character, and size of the collections in the collecting unit’s care and staff resources.
2) Inventories of collections shall be conducted according to a predetermined schedule.
Inventories may include a complete inventory, a specific percentage or sampling of
the collection, or project-oriented inventories conducted during collections moves, rehousing, or digitization, using predetermined, statistically sound inventory methods.
3) Inventory control requires creating and maintaining reliable information about the
identification, location, and presence of collection items. Inventory is a critical
component of ongoing collections documentation.
RISK MANAGEMENT, SAFETY, AND SECURITY
Risk Management is the process of identifying and evaluating risk to prevent or minimize
exposure to factors which may cause loss or damage to collections or injury or illness to staff
and the public.
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Safety encompasses occupational health and safety, industrial hygiene, and environmental
management.
Security encompasses an entire range of activities concerned with the protection of life,
facilities, and property, including collections, from direct or perceived threats.
The programmatic activities of the Smithsonian naturally expose collections to certain levels of
risk of damage or loss during exhibition, loan, transit, storage, research, treatment, or
handling. Collection items may also contain a wide range of chemical, biological, and physical
hazards, whether inherent in the nature, composition, or construction of the item itself or as a
result of preparation, treatment, alteration, or degradation.
Certain collections-related activities may expose staff and affiliated persons to residual
hazardous materials associated with a collection item, storage equipment, or exhibit case
materials. The Smithsonian has adopted an integrated risk management assessment program
to mitigate exposure to a variety of risks by requiring the thoughtful review of potential
hazards, including natural and human-made emergencies; climate change; vandalism and
theft; disease; space and environmental deficiencies; human error; mechanical or operational
system failures; deterioration; and collections-based hazards.
12.1. Policy
The Smithsonian adheres to the following policies regarding the risk management, safety, and
security of collections:
1) The Smithsonian shall minimize and control the level of risk of damage or loss to
collections and injury and illness to staff, affiliated persons, and visitors through
established risk management practices.
2) The Smithsonian will provide hazard awareness and establish safe work practice
information in accordance with SD 419, Smithsonian Institution Safety, Health, and
Environmental Program. OSHEM is responsible for the direction, planning, and
technical supervision of occupational safety, health, and environmental protection at
the Smithsonian.
3) All Smithsonian staff have an obligation to be aware of the Institution’s risk
management, safety, and security directives.
4) Except in extraordinary circumstances, the Smithsonian has chosen not to insure its
own collections while in Smithsonian-owned facilities, either in storage or on display,
and in the care and possession of the Institution. However, during transit between
Smithsonian units and facilities, insurance can be placed on collection items.
5) Collections on loan to the Smithsonian and Smithsonian collections on loan to or in
the custody of others will be insured as stipulated by an authorized loan agreement or
negotiated contract. The OF&A Risk Management Branch coordinates Smithsonian
risk management and insurance in accordance with SD 108, Insurance and Risk
Management.
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6) Insurance proceeds from the settlement of claims for damage to Smithsonian
collection items may be used only for the conservation and restoration of the affected
collection item. Insurance proceeds received due to a total loss of a collection item or
in excess of the cost of conservation and restoration of a damaged collection item
shall be designated only for collections acquisition or the direct care of existing
collections.
7) In accordance with SD 420, Security Operations and Policies and Collections Space
Security Standards, collecting unit directors, in collaboration with OPS, shall define
the protection policy and goals for collections and ensure that such policies are
implemented. Policies are based on risk assessments and consultations with unit staff
and central offices such as the NCP and SF. The OPS is responsible for providing
physical security and protection of personnel, visitors, collections, facilities, and
property of the Smithsonian.
8) All Smithsonian facilities, owned or leased, must have a written, comprehensive
emergency plan and procedures as required by SD 109, Smithsonian Emergency
Management Program. The OEM is responsible for the management and oversight of
the Smithsonian Emergency Management Program.
9) The Preparedness and Response in Collections Emergencies (PRICE) team is
responsible for providing Institution-wide training, policy, procedural, and logistical
support in collections emergency preparedness, response, and recovery, promoting
improved communication and collaboration across Smithsonian units.
ACCESS
Access is the opportunity for the public, scholars, and staff to explore and use the diverse
collections and associated information resources of the Smithsonian.
The Smithsonian promotes access to its collections and associated information through
research opportunities, traditional and digital exhibitions, educational programs and
publications, reference systems, loans and exchanges of collections, and digital platforms.
13.1. Policy
The Smithsonian adheres to the following policies regarding access to collections:
1) The Smithsonian will provide access to its collections and associated information in a
manner consistent with its stewardship, management, and preservation
responsibilities. Physical and intellectual access to the collections must be balanced
with preservation concerns.
2) The Smithsonian will control, monitor, and document physical access to and use of its
collections.
3) The Smithsonian may be required to restrict access for various reasons, including
resource limitations, security and safety, preservation constraints, object availability,
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concerns related to cultural sensitivity and privacy, and legal restrictions (such as
copyright and restrictions imposed by contract). Collecting units should consult with
the OGC regarding access requests involving restrictions such as privacy and
intellectual property rights.
4) The Smithsonian generally provides access to Smithsonian information under SD
807, Requests for Smithsonian Institution Information, through the OGC. SD 807
applies to transactional documents related to collections, such as gift and purchase
agreements, but it does not apply to requests for other kinds of collections
information. For requests for collections information other than transactional
documents, the collecting unit responsible for the maintenance of the requested
information handles the request in accordance with the unit’s collections management
policy and in consultation with the OGC, as necessary.
5) Requests for information citing SD 807 or the Freedom of Information Act (FOIA)
must be referred to the OGC.
6) The Smithsonian may charge fees to provide digital assets in response to access or
use requests in accordance with SD 609.
LOANS
A loan is the temporary transfer of possession of collection items for an agreed-upon purpose
and on the condition that the collection items are returned at a specified time. Loans are not
generated with the intent to result in a change of ownership.
Fundamental to the Smithsonian’s strategic plan and programmatic goals, the lending and
borrowing of collection items between Smithsonian units and other cultural, educational, and
scientific organizations for public exhibition, research, and education is an integral part of the
Institution’s mission.
14.1. Policy
The Smithsonian adheres to the following policies regarding loans of collections:
1) All loans to or from the Smithsonian must adhere to applicable federal, state, local,
and international laws, treaties, regulations, and conventions, including the
Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and
Ethnographic Material, and Historic Objects.
2) Smithsonian collection items may be lent or borrowed only in accordance with a
written, authorized loan agreement and established authority, and only when
consistent with applicable law and professional and Institutional ethics.
3) As a general rule, Smithsonian collections will only be lent for public exhibition,
research, and other educational, scientific, or preservation purposes. Smithsonian
collections may not be loaned for commercial purposes or private pecuniary gain.
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4) The Smithsonian adheres to individual collecting unit guidelines for developing
exhibitions and procedures for planning public programs, in accordance with
SD 603, Exhibition, Program Planning, Research, and Educational Content, and with
the Guidelines for Exhibiting Borrowed Objects issued by the American Alliance of
Museums (AAM).
5) All loans are for a specified period of time and may contain an option for renewal, if
appropriate. The Smithsonian does not permit indefinite or permanent loans, whether
as a lender or borrower.
6) Collections on loan to the Smithsonian and Smithsonian collections on loan to, or in
the custody of others, will be insured as stipulated by an authorized loan agreement.
7) Requests from lenders for absolute liability — terms and conditions requiring the
Smithsonian to agree to accept liability for damage or loss potentially in excess of
insurance coverage — are subject to the following procedures:

Requests concerning a loaned collection item(s) with an insurance value of
$10 million or less require approval from the appropriate Under Secretary and
the Under Secretary for Administration, in consultation with the OGC and the
OF&A Risk Management Branch.
Requests concerning a loaned collection item(s) with an insurance value of
more than $10 million require approval from the Deputy Secretary, who may
consult with the Secretary as necessary.
8) In addition to actual expenses, the Smithsonian may charge loan fees to borrowing
organizations in accordance with approved collecting unit policies.
9) The Smithsonian may lend collection items for display in the offices of high-ranking
U.S. Government officials, in accordance with the Loans to High-Ranking
Government Officials Guidance.
10) The Smithsonian may lend collection items to for-profit entities in accordance with the
Loans to For-Profit Entities Guidance.
11) The applicable provisions of the Board of Regents Ethics Guidelines govern loans to
the Smithsonian from members of the Board of Regents.
12) The applicable provisions of the Smithsonian Advisory Board Ethics Statement
govern loans to the Smithsonian from members of Smithsonian advisory boards.
13) Loans to foreign entities must comply with SD 611, Export Compliance and Trade
Sanctions Related to Research, Export and Museum Activities.
14) Regardless of the length or type of outgoing loans, the Smithsonian retains ownership
and stewardship responsibility of its collections.
15) Smithsonian collecting units may accept items for temporary custody in accordance
with unit collections management policies and under a temporary custody agreement.
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16) The internal lending of collections for exhibition and public display among collecting
units is fundamental to cross-unit collaboration and increasing public access to
Smithsonian collections. Collecting units will, to the extent possible, facilitate and
subsequently expedite exhibition and public display loans to other Smithsonian units,
including newly designated collecting units, in accordance with the Smithsonian Unitto-Unit Object Loan Guidelines.

INTELLECTUAL PROPERTY RIGHTS
Intellectual property rights are protections based on federal or state statutes or common law
such as patent, trademark, copyright, privacy, and publicity.
Distinct from the right to possess a collection item, intellectual property rights arise from the
content of a collection item. The Smithsonian’s ability to use and provide access to collections
and their associated intellectual property may be subject to copyright, privacy, and publicity
rights held by others, which may restrict access to or use of the material.
As both a holder and a user of intellectual property, the Smithsonian seeks to protect the
intellectual integrity of collections and the rights of creators and owners of intellectual property,
including the Institution itself as a rights holder, to promote the broadest possible access to
collections for research and educational purposes.
15.1. Policy
The Smithsonian adheres to the following policies regarding intellectual property rights and
collections:
1) Smithsonian collections may be subject to intellectual property rights that may be
owned by the Smithsonian or others. The Smithsonian shall manage its collections
and collections in its custody in a manner that avoids any infringement of intellectual
property rights. The Smithsonian will protect the intellectual property rights of creators
and intellectual property owners, including the Institution itself as a rights holder.
2) The Smithsonian may charge fees to outside organizations and individuals to use and
reproduce images of collection items, in accordance with SD 609.
3) The Smithsonian may rely on the doctrine of fair use in making reproductions of
collections for standard museum purposes, such as for archival, research,
educational, exhibition, and other similar uses. Fair use assertions must be made on
a case-by-case basis, taking into consideration the legal parameters of the fair use
doctrine, and the OGC should be consulted as necessary concerning fair use
determinations.
4) Smithsonian collections may be used consistent with the current Smithsonian Terms
of Use.
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SPECIFIC LEGAL AND ETHICAL ISSUES
Certain collections present specific issues because of applicable legal and ethical standards.
Smithsonian collecting units that acquire, hold, or manage collections must take these legal
and ethical issues into account, including incorporating appropriate standards into unit
collections management policies. The following sections address six specific legal and ethical
issues raised by Smithsonian collections that fall within the scope of the following.
Section 16.1 addresses shared stewardship and ethical returns of tangible and intangible
cultural heritage collections; Section 16.2 addresses repatriation and other issues related to
Native American and Native Hawaiian human remains and objects covered by the National
Museum of the American Indian Act; Section 16.3 addresses provenance requirements for
acquiring art, antiquities, archaeological and ethnographic material, and historic objects;
Section 16.4 addresses requirements for borrowing, collecting, and managing biological
material; and Section 16.5 addresses issues related to objects that have been or may have
been unlawfully appropriated during the Nazi era.
16.1. Shared Stewardship and Ethical Returns
Over the course of its long history, the Smithsonian has acquired collections originating from
national and international sources, from individuals, communities, and indigenous peoples,
from non-profit, for-profit, and governmental entities, and through a variety of methods and
circumstances. During this time, ethical norms and professional best practices related to
collecting have changed, particularly with respect to collecting cultural heritage (tangible and
intangible) from individuals and communities. As a result, the Smithsonian has collections that
it would not have acquired under present-day ethical and professional standards.
Although the Smithsonian has legal title or custody of collections it holds in trust for the benefit
of the public, continued retention or sole stewardship of such collections may cause harm to
communities and be fundamentally inconsistent with the Smithsonian’s ethical standards and
Institutional values. In these unique circumstances, shared stewardship or ethical return may
be necessary to fulfill the Smithsonian’s custodial obligations.
The Smithsonian recognizes the value of community representation in Smithsonian
collections, the benefit of preserving and making available to the public, with honor and
respect, a diverse range of collections, stories, and histories, and the role of museums as
collaborative custodians of cultural and historical legacies. The Smithsonian is committed to
working transparently and in consultation with descendants, communities, and relevant
governmental and regional stakeholders to consider matters of shared stewardship and the
potential return of collections, based on ethical considerations. These circumstances, which
may vary depending on the nature and scope of a unit’s collections, may include but are not
limited to the manner in which a collection was originally acquired and the context of its
acquisition. A review of the circumstances may demonstrate unethical acquisition through
means such as coercion, duress, assertion of power, or forcible taking.
The Smithsonian adheres to the following policies regarding shared stewardship and ethical
return of objects in its collections.
SD 600 — 5/12/22
23
1) Collecting units may enter into shared stewardship arrangements with communities
represented in the unit’s collections in appropriate circumstances, based on ethical
considerations. Collecting units must establish authority and evaluation criteria and
assign responsibility to approve, document, and implement such arrangements within
the unit’s collections management policy. Shared stewardship arrangements may
include, but are not limited to, collaborative consultations for the respectful attribution,
documentation, interpretation, display, care, storage, access, use, or disposition of
collections. Shared stewardship arrangements must be documented in a written
agreement approved by the appropriate Under Secretary in consultation with the
OGC and NCP.
2) Collecting units may deaccession and return collections in appropriate circumstances,
based on ethical considerations. Collecting units must establish authority and
evaluation criteria and assign responsibility to approve, document, and process such
deaccessions and returns, including transfer of associated collections information,
within the unit’s collections management policy. Before collections may be
deaccessioned and returned for ethical reasons, collecting units must consult with the
appropriate Under Secretary, the NCP, and the OGC and must obtain all approvals
for deaccessioning and returns required under Section 8 of this directive. Before a
collecting unit can deny a claimant’s request for return of a collection for ethical
reasons, the collecting unit must consult with the appropriate Under Secretary.
3) Collecting units must establish and implement readily accessible processes for
descendants, communities, and other parties with claims to request shared
stewardship or return of collections based on ethical considerations. These processes
shall prioritize transparency, respectful engagement, meaningful consultation, and
prompt responses to requests.
16.2. Native American and Native Hawaiian Human Remains and Objects
The 1989 National Museum of the American Indian (NMAI) Act, 20 U.S.C. §80q et seq., as
amended in 1996, requires the Smithsonian to return culturally affiliated human remains,
funerary objects, sacred objects, and objects of cultural patrimony to Indian tribes and Native
Hawaiian organizations. Under the NMAI Act, the Smithsonian is required to prepare
inventories and summaries about such objects, and to disseminate the information to and
consult with Indian tribes and Native Hawaiian organizations about human remains and other
cultural objects that may be eligible for repatriation under the NMAI Act.
The NMAI Act established the Smithsonian Institution Repatriation Review Committee, which
serves as an advisory body to the Secretary or the Secretary’s designee on the application of
the NMAI Act with respect to the collections of the National Museum of Natural History.
Additionally, the NMAI Act also established the NMAI Board of Trustees, which, subject to the
general policies of the Board of Regents, has sole authority over certain collections decisions,
including final resolution of repatriation claims submitted to the NMAI.
In addition to the applicable requirements of the NMAI Act, Smithsonian collecting units with
Native American and Native Hawaiian collections should be aware of and sensitive to other
SD 600 — 5/12/22
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issues that arise out of cultural concerns of Native American Tribes, Native Hawaiian
organizations named in the NMAI Act, and other Native American and Native Hawaiian
groups. Such concerns may relate to appropriate standards for the use, management, and
care of culturally affiliated human remains and cultural objects and protections for interests in
the intellectual content associated with these objects. Collecting units are encouraged to
consult with Native American Tribes, Native Hawaiian organizations named in the NMAI Act
and other Native American and Native Hawaiian groups associated with the human remains
and objects in their collections, and to take their interests into account in establishing policies
for the use, management, and care of these collections, provided that such policies are
consistent with applicable law and the Smithsonian’s responsibilities for the care and
management of its collections.
The Smithsonian adheres to the following policies regarding Native American and Native
Hawaiian human remains and objects:
1) Smithsonian repatriation of Native American and Native Hawaiian human remains
and objects is governed by the requirements set forth in the NMAI Act, 20 U.S.C. §
80q, as amended.
2) Final repatriation decisions are made by the Secretary or the Secretary’s designee,
except for the collections of the National Museum of the American Indian. In
accordance with the NMAI Act, the NMAI Board of Trustees has sole authority to
dispose of any part of NMAI collections, which includes repatriation. All NMAI
repatriation decisions are subject to the general policies of the Board of Regents.
3) Any Native American or Native Hawaiian collections whose return or repatriation is
not required by the NMAI Act shall be managed in accordance with this directive.
Decisions to return collection objects outside the scope of the NMAI Act (e.g., to
indigenous people in other countries) will be managed in accordance with this
directive and unit collections management policies.
16.3. Cultural Property
The Smithsonian Board of Regents first adopted a policy on the acquisition of art, antiquities,
and other specimens in 1973. Updated and revised by the Board of Regents on April 13, 2015,
the Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and
Ethnographic Material, and Historic Objects reaffirms the Smithsonian’s support for efforts of
local, state, national, and international authorities to protect art, antiquities, national treasures,
and ethnographic material from destructive exploitation. The policy establishes rules for the
acquisition and borrowing of art, antiquities, archaeological and ethnographic material, and
historic objects.
The Smithsonian repudiates the illicit traffic in art and cultural objects that contributes to the
despoliation of museums and monuments and the irreparable loss to science and humanity of
archeological remains. Objects and specimens which have been stolen, unscientifically
gathered or excavated, unethically acquired, or unlawfully exported from their country of origin
should not be made part of Smithsonian collections.
SD 600 — 5/12/22
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The Smithsonian adheres to the following policies regarding cultural property:
1) All Smithsonian collections management policies and activities will comply with the
Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and
Ethnographic Material, and Historic Objects.
2) Before acquiring or borrowing a collection item, the Smithsonian must conduct due
diligence sufficient to ascertain, from the circumstances surrounding the transaction
or knowledge of the item’s provenance, that the collection item was not stolen or
wrongfully converted and is not illegally present in the United States.
3) Before acquiring or borrowing a collection item, the Smithsonian must ascertain
through provenance research that the collection item was not unethically acquired
from its source or unscientifically excavated.
4) Before acquiring or borrowing a collection item, the Smithsonian must ascertain
through provenance research that the collection item was outside its country of
probable modern discovery before November 17, 1970, or was legally exported from
its country of modern discovery and lawfully imported into the United States after
November 17, 1970. For collection items lacking a complete documented provenance
history, the Smithsonian Institution Policy on Acquisition of Art, Antiquities,
Archaeological and Ethnographic Material, and Historic Objects provides guidelines,
based on professional museum standards, for collecting unit directors to make an
informed decision as to whether the collection item can be acquired or borrowed.
5) The provenance of collection items shall be a matter of public record.
16.4. Biological Material
The Smithsonian has long been a leader in the effort to halt the continuing degradation of the
world’s natural history and environmental resources. Smithsonian research and collecting
activities must be undertaken with sensitivity to the continued protection of biological diversity
and in compliance with applicable federal, state, local, tribal, and international laws, treaties,
regulations, and conventions protecting animal and plant species, especially those that are
threatened or endangered.
Field studies and collecting of biological material should be preceded by disclosure and
consultation with the proper authorities and interested scientific institutions in the location of
the fieldwork. Field activities must be conducted lawfully, support educational and scientific
purposes, and not cause undue detriment to the biodiversity and ecological conditions in the
location or region of the activity.
Biological material (e.g., ivory, feathers, blood, and bone) embodied in art or other objects or
acquisitions must comply with all applicable laws relating to import, export, and possession of
the embedded biological material.
The Smithsonian adheres to the following policies regarding biological material:
1) Biological material may be acquired by or on behalf of the Smithsonian through field
collecting only when such collecting is legally authorized in advance; the biological
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material is obtained solely for the purposes of scientific research or conservation, to
add to the Smithsonian collections, or for other educational purposes; and the
Smithsonian’s collecting activities will not cause undue detriment to the biodiversity
and ecological conditions in the area of the activity.
2) Nothing in this directive shall prevent collecting units, when acquiring international
biological material, from also considering international conventions governing the
transfer of biological materials even if such conventions are not legally applicable to
the Smithsonian.
3) The Smithsonian name may not be used to justify or support permit applications for
activities that have not been authorized by or on behalf of the Smithsonian in
accordance with this directive and unit collections management policies.
4) The Smithsonian may acquire or borrow biological material collected or obtained by
others, including when embodied in art and other objects, only when consistent with
established collecting unit criteria for the transaction and applicable international,
national, state, local, and tribal laws.
5) Biological material in Smithsonian collections or in its custody will be managed in
accordance with all applicable legal requirements.
16.5. Unlawful Appropriation of Objects During the Nazi Era
Between 1933 and 1945, the Nazi regime and its collaborators orchestrated a system of
confiscation, coercive transfer, looting, and destruction of cultural property and artwork
throughout Europe on an unprecedented scale. Millions of objects were unlawfully
appropriated from their rightful owners, including private citizens, victims of the Holocaust,
public and private museums and galleries, and religious, educational, and other institutions.
Some of these objects were ultimately transferred, in good faith and without knowledge of their
prior unlawful appropriation, through the legitimate market and may have been acquired by
museums. Postwar restitution efforts to return unlawfully seized objects to their rightful owners
did not lead to complete and comprehensive restoration.
Guidance issued by the AAM and the AAMD concerning objects that may have been
unlawfully appropriated during the Nazi era recommends museums identify objects in their
collections that were created before 1946, acquired by the museum after 1932, underwent
changes in ownership during the Nazi era, and were or may reasonably be thought to have
been in continental Europe between 1933 and 1945. The Smithsonian is committed to
implementing the AAM and AAMD guidelines by researching, identifying, and making public
any objects that fall within their scope.
The Smithsonian adheres to the following policies regarding unlawful appropriation of objects
during the Nazi era:
1) The Smithsonian shall not knowingly acquire collection items unlawfully appropriated
during the Nazi era without subsequent restitution.
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2) If the Smithsonian has in good faith acquired a collection item subsequently
determined to have been unlawfully appropriated during the Nazi era without
restitution, the Smithsonian will take prudent and necessary steps to resolve the
status of the collection item.
3) The Smithsonian shall apply the applicable provisions of the AAM Guidelines
Concerning the Unlawful Appropriation of Objects During the Nazi Era and the AAMD
Report on the Task Force on the Spoliation of Art during the Nazi/World War II Era
(1933–1945) to its collection management activities.
SMITHSONIAN COLLECTING UNIT REQUIREMENTS
Smithsonian collecting units must adhere to the policies of this directive, including the following
policies regarding unit collections management.
A well-managed collection is governed by specific documents that guide collections-related
decisions based on strategic planning goals and priorities. In accordance with this directive,
each Smithsonian collecting unit must develop, implement, and maintain the following.
17.1 Collections Stewardship Plans
A collections stewardship plan provides an intellectual framework for collections that
establishes well-defined goals and priorities to guide collections-related decisions regarding
acquisition, deaccessioning, resource allocation, institutional and community partnerships, and
other activities related to the growth and refinement of collections.
Each collecting unit must develop, implement, and adhere to an authorized, up-to-date
collections stewardship plan to guide collections-related activities that are consistent with
strategic planning objectives.
Collections stewardship plans should be reviewed and updated every five years to align with
unit strategic planning and require written approval from the collecting unit director and review
by the NCP and the appropriate Under Secretary.
17.2 Unit Digitization Plans
Unit digitization plans support the Smithsonian’s commitment to promote access to collections
and collections information in databases and online platforms to maximize the application of
networked technologies, implement professional documentation standards, and share
collections information through collaborations among collecting units and with other cultural,
educational, and research institutions.
In accordance with this directive and SD 610, Digitization and Digital Asset Management
Policy, each collecting unit must develop, implement, and maintain an authorized, up-to-date
unit digitization plan that establishes unit-specific goals, priorities, and standards for the
digitization of its collections. Unit digitization plans should be reviewed and updated every
three years.
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17.3 Unit Collections Management Policies
Collections management policies establish general principles and standards to govern the
collections-related activities and operations of a collecting unit to achieve its mission,
programmatic goals and objectives, and responsibilities regarding collections. Unit collections
management policies define areas of authority and responsibility for collections, establish
decision-making criteria, and provide guidance on collections management activities that carry
out the unit’s legal, ethical, and professional obligations for collections in its care.
Each collecting unit designs policies specifically tailored to the nature, scope, character, and
intended purpose of its collections. Collections are defined by each collecting unit within their
collections management policy.
In accordance with this directive, each Smithsonian collecting unit must develop, implement,
and adhere to an authorized, up-to-date collections management policy consistent with the
policies established by this directive.
The Smithsonian is increasingly acquiring diverse types of collections, collected for vastly
different purposes and uses, and composed of various kinds of materials, which are most
appropriately stewarded in accordance with discipline-specific standards of management and
care. These discipline-specific standards may in some cases deviate from the standards
outlined in this directive. Therefore, the NCP may approve, in consultation with the collecting
unit director and the appropriate Under Secretary, to exempt specific types of collections from
specific provisions of SD 600. Such exemptions must be specified in the collecting unit’s
collections management policy, and the unit’s policy must specify the national or international
discipline-specific standards which will instead apply to the type of collection granted the
exemption.
Unit collections management policies must be reviewed every five years and, if necessary,
revised and reauthorized as appropriate. Revised collections management policies must be
approved by the collecting unit director, the NCP, the OGC, the appropriate Under Secretary,
and the Secretary. If a collecting unit reviews its collections management policy and chooses
not to revise its policy, the unit director must notify the NCP and appropriate Under Secretary.
In certain circumstances, collecting units may make minor amendments to their existing
collections management policy in advance of a full review and revision. Written approval is
required from the collecting unit director, the NCP, the OGC, and the appropriate Under
Secretary. Any approved amendments are addressed through the formal review and approval
process during the unit’s next periodic review and revision of its collections management
policy.
Certain collecting units may have varying levels of authority that limit the unit from adhering to
certain policy requirements. Collecting units that do not have delegated authority to conduct
specific transactional activities must clearly articulate such restrictions in the unit’s policy.
Each unit collections management policy must include the following components:
SD 600 — 5/12/22
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1) Introductory Statements. Each collecting unit must clearly articulate the mission,
strategic priorities, programmatic goals, and role of the collecting unit within the larger
Smithsonian community in the following introductory statements:

Statement of purpose;
Statement of authority;
Definition of collections;
Collections scope; and
Description of applicable collections management activities.
2) Acquisition and Accessioning. Collecting units must include the following policy
components regarding the acquisition and accession of collections. Each unit must:
establish authority and assign responsibility to approve, document, and
process acquisitions and accessions;
develop and implement formalized evaluation criteria for potential
acquisitions;
establish appropriate methods of acquisition;
ensure the documentation of legal title and provenance for all collection items
acquired; and
ensure the creation and maintenance of permanent records for acquisitions
and accessioning.
3) Deaccessioning and Disposal. Collecting units must include the following policy
components regarding deaccession and disposal of collections. Each unit must:
establish authority and assign responsibility to approve, document, and
process deaccessions and disposals;
develop and implement formalized evaluation criteria for deaccessioning and
disposal decisions;
establish appropriate methods of disposal;
develop and implement disposal plans at the time of deaccession;
develop policies and procedures, in accordance with their professional
membership, for the appropriate use of proceeds realized from the disposal
of deaccessioned items — the acquisition of additional collection items or the
direct care of existing collections; and
stipulate authority and approval for the disposal of non-accessioned
collections.
4) Preservation. Collecting units must include the following policy components
regarding the preservation and care of collections. Each unit must:
SD 600 — 5/12/22
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establish authority and assign responsibility for the physical care, storage,
handling, preventive conservation, conservation treatment, restoration, pest
management, preservation environment, sustainability, and maintenance of
collections;
develop, implement, and adhere to established preservation policies,
standards, and procedures consistent with the mission of the unit and the
nature, purpose, and intended use of its collections;
ensure collections and their associated information are cared for and
maintained in conditions that preserve and extend their physical and
intellectual integrity for use in exhibitions, research, and education; and
ensure that all collections acquired, borrowed, and in the collecting unit’s
custody receive the appropriate level of care.
5) Collections Information. Collecting units must include the following policy
components regarding collections information. Each unit must:
establish authority and assign responsibility for the development,
management, preservation, and maintenance of collections information;
establish authority and assign responsibility for the implementation and
management of collections information systems;
establish authority and assign responsibility for the development and
implementation of a unit digitization plan that defines the unit’s digitization
program and its objectives and priorities for collections digitization;
establish documentation standards to ensure the quality, integrity, and proper
maintenance, management, and dissemination of collections information;
ensure the maintenance of collections information on the cultural, historical,
scientific, or aesthetic significance, legal status, provenance, and the use and
management of its collections and collections in the unit’s custody; and
promote the widest dissemination of collections information consistent with unit
stewardship responsibilities.
6) Inventory. Collecting units must include the following policy components regarding
the inventory of collections. Each unit must:
establish and assign responsibility for developing and implementing inventory
processes and standards, and a written inventory plan appropriate to the
purpose, character, and size of the collections in its care and staff resources;
establish authority and assign responsibility for conducting, supervising,
approving, and reporting on inventories and reconciliation of collection records;
and
SD 600 — 5/12/22
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ensure adequate separation of duties and other internal controls to minimize
the possible unauthorized removal of collection items and corresponding
records.
7) Risk Management, Safety, and Security. Collecting units must include the following
policy components regarding risk management, safety, and security of collections.
Each unit must:
establish authority and assign responsibility for unit risk management, safety,
and security activities to identify, eliminate, or mitigate conditions which may
create the potential for damage or loss to collections, risks of personal injury,
or legal, reputational, or financial liability;
establish authority and assign responsibility for the development,
implementation, and coordination of the unit’s emergency management plan
and program for its facilities housing collections;
develop policies and procedures for reporting and documenting damage, loss,
or possible theft of collections in its custody and on loan;
make reasonable efforts to identify, document, and promote the appropriate
communication of potential collections-based hazards in accordance with this
directive, SD 419, and applicable chapters of the Smithsonian Institution Safety
Manual; and
ensure collections are maintained in controlled areas which are adequately
protected to reduce exposure to risks such as fire, theft, vandalism, and natural
disasters.
8) Access. Collecting units must include the following policy components regarding
access to collections. Each unit must:
establish authority and assign responsibility to control, monitor, approve,
document, and provide access to physical collections, digital collections, and
collections information consistent with the specific type and purpose of the
unit’s collections and applicable access restrictions;
establish policies, criteria, and procedures for permitting responsible access to
collections, collections storage, and collections information consistent with the
unit’s mission and the purpose and intended use of the collections; and
make access policy statements available to the public.
9) Loans. Collecting units must include the following policy components regarding
lending and borrowing collections. Each unit must:
establish authority and assign responsibility to approve, process, document,
and monitor loans, including, where appropriate, temporary custody;
SD 600 — 5/12/22
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establish policies, criteria, and procedures for lending and borrowing
collections; and
apply the provisions of SD 603, the Smithsonian Unit-to-Unit Object Loan
Guidelines, and the AAM Guidelines for Exhibiting Borrowed Objects in unit
borrowing activities.
10) Intellectual Property Rights. Collecting units must adhere to the following policy
requirements regarding intellectual property rights. Each unit must:
establish authorities to approve permissible use of collections information and
images, and assign responsibility for rights management;
establish policies and procedures to ascertain whether collection items or
proposed acquisitions are encumbered by intellectual property rights or other
restrictions, and document any SD 609 restrictions for collection items in
collection records to determine, if possible, what steps are required to obtain
any rights necessary for the intended use of the item;
establish policies and procedures for handling and documenting outside
requests and permissions to publish or reproduce collections information and
images in accordance with SD 609;
determine permissible uses of collections information, metadata, and images to
ensure consistency with the mission of the Smithsonian and the collecting unit;
and
ensure that collection records are consulted for possible restrictions or
prohibitions to determine permissible image use and reproduction by the
Smithsonian and others in all media formats, such as print, digital, audio,
video, and the Internet.
11) Specific Legal and Ethical Issues. Each collecting unit must determine if it acquires,
holds, or manages any collections that fall within the scope of the following and
incorporate the appropriate legal and ethical standards in its collections management
policy:
Shared Stewardship and Ethical Returns
Each collecting unit must establish authority and evaluation criteria and assign
responsibility to approve, document, and implement shared stewardship
arrangements and ethical returns in appropriate circumstances, based on ethical
considerations. Each collecting unit must further establish readily accessible,
transparent, and consultative processes for descendants, communities, and other
parties with claims to request shared stewardship or return of collections based on
ethical considerations.
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Native American and Native Hawaiian Human Remains and Objects
Each collecting unit must determine if its collections include Native American or
Native Hawaiian materials to which the requirements of the National Museum of the
American Indian Act (NMAI Act), as amended, may be applicable. Any collecting unit
with Native American or Native Hawaiian collections must:
develop written policies and procedures consistent with the legal requirements
of the NMAI Act;
assign responsibility to complete inventories and summaries, and assess the
cultural affiliation of the collections in accordance with the provisions of the
NMAI Act;
establish authority and assign responsibility to review, evaluate, document,
and process repatriation requests and returns; and
establish authority and assign responsibility to review proposed acquisitions to
determine the applicability of the NMAI Act.
Cultural Property
Each collecting unit must establish authority and assign responsibility for
implementing and ensuring compliance with the Smithsonian Institution Policy on
Acquisition of Art, Antiquities, Archaeological and Ethnographic Material, and Historic
Objects, and other applicable laws and professional standards regarding the
acquisition, borrowing, and management of cultural property.
Biological Material
Each collecting unit with responsibility for biological material must establish authority
and assign responsibility to approve, document, and ensure compliance with legal
requirements for collections transactions involving biological material.
Unlawful Appropriation of Objects During the Nazi Era
Each collecting unit must establish authority and assign responsibility for
implementing and ensuring compliance with the Smithsonian policy on
Nazi-appropriated objects and the applicable professional guidelines issued by AAM
and AAMD.
12) Ethics. Each collecting unit must establish policies and procedures for implementing
the collections-specific requirements of SD 103 and other standards of professional
conduct, including personal collecting, appraisals, and authentication.
13) Financial Accounting for Collections. Each collecting unit must include a statement
on financial accounting for collections in compliance with the Smithsonian’s policy
regarding the non-capitalization of collections.
14) Monitoring and Revision of Unit Collections Management Policies. Each
collecting unit must establish authority and assign responsibility for monitoring and
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reporting on the implementation of SD 600 and the unit collections management
policy. Each collecting unit must establish authority and assign responsibility for the
development, revision, and implementation of the unit’s collections management
policy and establish procedures for the periodic review, and, if necessary, revise and
obtain reauthorization of the unit’s policy. Unit collections management policies must
be reviewed every five years to ensure the policy is up to date.

EXCEPTIONS
A collecting unit may seek an exception to the policies set forth in this directive or its
collections management policy if the application of such a policy directly hinders the unit’s
ability to achieve the mission objectives or programmatic goals of the Smithsonian. Requests
for any such exception must be submitted in writing by the collecting unit director for approval
by the NCP, the OGC, and the appropriate Under Secretary.
SUPERSEDES: SD 600, issued on October 26, 2001.
INQUIRIES: National Collections Program (NCP).
RETENTION: Indefinite. Subject to review for currency 36 months from date of issue.

National Museum of Natural History
Smithsonian Institution
Collections Management Policy
Rev. December 13th, 2017
Table of Contents
Section I. Introduction ………………………………………………………………………………………………………….. 1
A. Purpose ……………………………………………………………………………………………………………………….. 1
B. Background ………………………………………………………………………………………………………………… 1
C. Applicability ……………………………………………………………………………………………………………….. 2
D. Authority and Responsibility …………………………………………………………………………………… 3
E. Ethics……………………………………………………………………………………………………………………………. 9
F. Accounting for Collections …………………………………………………………………………………….. 10
G. Compliance ………………………………………………………………………………………………………………. 10
H. Exceptions ………………………………………………………………………………………………………………… 10
I. Policy Review and Revision …………………………………………………………………………………… 10
Section II. NMNH Policy Elements …………………………………………………………………………………….. 11
A. Acquisition and Accessioning ……………………………………………………………………………….. 11
B. Deaccessioning and Disposal ………………………………………………………………………………… 16
C. Preservation …………………………………………………………………………………………………………….. 19
D. Collections Information Management and Digitization ……………………………………. 20
E. Inventory ………………………………………………………………………………………………………………….. 21
F. Risk Management and Security …………………………………………………………………………….. 22
G. Access ……………………………………………………………………………………………………………………….. 23
H. Loans and Borrows …………………………………………………………………………………………………. 26
I. Intellectual Property Rights ………………………………………………………………………………….. 29
J. Shipping and Transportation ………………………………………………………………………………… 30
Section III. Specific Legal and Ethical Issues …………………………………………………………………… 32
A. Native American and Native Hawaiian Human Remains and Objects …………….. 32
B. Collections Made via Field Work ………………………………………………………………………….. 33
C. Unlawful Appropriation of Objects during the Nazi Era …………………………………… 33
D. Animal Welfare and Institutional Animal Care and Use Committee ……………….. 34
E. Human Subjects in Research and the Institutional Review Board ………………….. 34
F. Collections Posing Health and Safety Risks ………………………………………………………… 35

NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 1 of 35
Section I. Introduction
A. Purpose
This document sets forth polices and guidance for the acquisition, management, use, and disposal of the
collections of the National Museum of Natural History (NMNH). It is subordinate to Smithsonian Directive 600:
Collections Management (SD 600) and distinct from the NMNH Collections Management Policy
Implementation Plan.
B. Background
The NMNH is dedicated to the study of the natural world, including humans and the cultures they have
created. As part of the larger Smithsonian mission, the NMNH is committed to the increase of knowledge and
to disseminating that knowledge to the public. The NMNH collections serve as primary reference materials
for exploring and understanding Earth history, biological and cultural diversity, and global change. These
collections are international in scope and diverse in kind: ongoing and intensive scientific study of these
reference collections provides critical information and establishes the NMNH as an important international
user facility.
The Act of August 10, 1846 [20 USC §§ 41, et seq.] established the Smithsonian and vested authority for
management of the Institution in a Board of Regents. The Act establishes stewardship responsibility for
collections. The Smithsonian implements its stewardship responsibility through SD 600, the Smithsonian’s
Collections Management Policy.
In the Sundry Civil Act of March 3, 1879 [20 USC § 59], the following responsibility is charged:
“All collections of rocks, minerals, fossils, and objects of natural history, archaeology and ethnology, made
by the National Ocean Survey, the United States Geological Survey, or by any other parties of the
Government of the United States, when no longer needed for investigation in progress shall be deposited
in the National Museum.”
On this authority, the NMNH serves as a repository for collections made by or on behalf of other Federal
agencies and entities. These collections are managed under the terms of the agreements establishing the
repository arrangement, which are aligned with the same policies and standards of stewardship applicable to
all other NMNH collections.
The NMNH is committed to the growth, improvement, and long-term stewardship of its collections, and to
supporting their use by scholars and the general public. As the nation’s natural history museum, the NMNH
has a responsibility to conserve and protect its collections in a manner that assures their continued
accessibility by future generations, and to hold them in trust, ensuring fulfillment of their long-term potential.
The collections of the NMNH have grown in the dual context of the evolution of the Smithsonian Institution
and the development of federally funded science. The Smithsonian Institution began to acquire natural
history collections soon after it was founded in 1846. In 1858, specimens from the Wilkes Expedition were
moved to the Smithsonian Building (“the Castle”). The United States National Museum (USNM) opened in the
Arts & Industries Building in 1881 and moved to the Natural History Building (NHB) when it opened on the
north side of the National Mall in 1910. In 1969, the USNM became the NMNH. In 1983, the Museum Support
Center (MSC) opened in Suitland Maryland. The collections have grown to include anthropological, biological
and geological items and data, and archival items.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 2 of 35
Several Federal agencies maintain collections and employ staff at the NMNH. The collections and staff of these
agencies are embedded within the NMNH departments and are subject to SD 600 and this Collections
Management Policy. In some departments, affiliated agency scientists provide the curatorial oversight and
expertise for specific NMNH collections.
Collections holdings in each department are grouped into subcollections based on a characteristic such as
taxon, time period, or locality. A single individual is delegated the primary curatorial authority and
responsibility for each subcollection regarding acquisition, management, use, and disposal. That individual is
expected to consult and collaborate with other designated curators, collections experts, and committees in
the department when proposing and making decisions about the subcollections they oversee.
Documents relevant to NMNH collections management include:
 SD 600, Collections Management and companion SD 600 Implementation Manual
 Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological and Ethnographic
Material, and Historic Objects
 SD 103, Smithsonian Standards of Conduct, the Advisory Board Ethics Statement, and the Statement
of Values and Code of Ethics
 SD 108, Insurance and Risk Management
 SD 109, Disaster Management Program
 SD 118, Privacy Policy and Privacy Program Handbook
 SD 500, Smithsonian Libraries
 SD 501, Archives and Records of the Smithsonian Institution
 SD 502, Cellulose and Nitrate Still Picture and Motion Picture Film
 SD 503, Management of Archives and Special Collections in the Smithsonian Institution.
 SD 609, Digital Asset Access and Use
 SD 610, Digitization and Digital Asset Management Policy
 SD 611, Export Compliance and Trade Sanctions Related to Research, Export, and Museum Activities
 SD 807, Requests for Smithsonian Institution Information
 NMNH Collections Management Policy (this document) and companion Implementation Plan
 NMNH Strategic Plan 2016-2020
 NMNH Collections Plan
 NMNH Unit Digitization Plan
 NMNH Collections Information Access and Data Sharing at the NMNH Policy
C. Applicability
This policy applies to all the NMNH departments that have delegated authority to acquire, manage, and use
collections and associated collections information (analog and digital). These collecting departments
currently are: Anthropology, Botany, Entomology, Invertebrate Zoology, Mineral Sciences, Paleobiology,
Vertebrate Zoology, and the Collections Program which holds collections on behalf of Education and
Outreach. Archival materials are transferred to the Smithsonian Institution Archives (SIA), per Smithsonian
Directives 501 and 503 or are housed within their collection of origin. Books and journals intended for
permanent retention are accessioned and managed by the Smithsonian Libraries (SL) in consultation with the
NMNH, per Smithsonian Directive 500.
All the NMNH staff including retirees, research associates, fellows, interns, and volunteers as well as affiliated
agency staff who are officially stationed at the NMNH, (both the Natural History Building and the Museum
Support Center) and others with delegated collections management responsibilities or access to the NMNH
collections are required to adhere to this policy, SD 600, and SD 103.
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These policies also apply to any staff, academic appointees, volunteers, contractors or visitors who are
granted access to areas that house the NMNH collections, and to members of other Smithsonian units that are
co-located with the NMNH collections, or whose work may affect the collections or occurs in the NMNH
collections spaces, except as otherwise stipulated by other agreements.
Although the NMNH Advisory Board has no specific authority for the NMNH’s collections, Board members are
required to comply with Smithsonian rules regarding collections, including the Advisory Board Ethics
Statement and the Smithsonian Institution Statement of Values and Code of Ethics. The rules and monitoring
of compliance are managed by the NMNH Director’s Office.
D. Authority and Responsibility
The acquisition and possession of collections impose legal and ethical obligations to provide proper
management, preservation, and use of the collections and their associated information. Authorities and
responsibilities for collections management at the NMNH are subordinate to the authorities and
responsibilities at the Institution level, as defined in SD 600 and its companion Implementation Manual.
The Smithsonian Board of Regents holds ultimate oversight responsibility and fiduciary responsibility for
Smithsonian collections. This responsibility is carried out by the Secretary, Provost, Under Secretary for
Finance and Administration, and their designees. The Board of Regents through the Secretary and the Provost
delegates primary operational authority for the NMNH collections to the NMNH Director.
The NMNH Director provides written delegations of collections-specific authority to the NMNH and affiliated
agency staff on an annual basis via an official memo.
The stewardship of the NMNH collections requires an array of expertise and skills. In general, curatorial staff
are responsible for the composition and strategic growth of the collections and for authorizing acquisitions,
accessions, scientific use, loans, deaccessions, and disposals. Collections staff are responsible for the
processing, organization, digital preservation, and accessibility of each collection. Other staff may be
delegated these responsibilities based upon their individual qualifications. All of the NMNH’s staff members
work collaboratively to support collections stewardship ensuring objectivity, compliance with policy,
appropriate and efficient use of resources and alignment with agreed priorities.
The NMNH Director
is accountable for:
 Compliance with SD 600, the SD 600 Implementation Manual, and this policy.
 Adherence to applicable professional practices.
 Proper management, preservation, and use of collections.
 The integrity and accuracy of collections information.
is responsible for:
 Providing museum policy guidance, program direction and planning, and budget support to carry out
the collections management requirements established in SD 600, the SD 600 Implementation Manual,
and this policy.
 Designating authorized collecting departments.
 Implementation of established collections management policies and procedures by delegating
curatorial authority and assigning collections responsibility to the appropriate staff.
 Issuing an annual report on compliance to the National Collections Program and the museum.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 4 of 35
 Approval of this policy in consultation with staff with delegated collections management
responsibilities.
 Approval of any NMNH Collections Management policy exceptions.
 Approval of the NMNH Collections Plan.
 Approval of external agreements for partnerships and collaborations that impact accessibility and
accountability of collections.
 Directly authorizing any acquisition or loan that requires or risks more than $500,000 in museum
resources (as based upon purchase price, insurance value, and/or cost of care); any collections
purchase or disposal valued at more than $100,000; and any significant disposal as defined in the
NMNH Collections Management Policy Implementation Plan.
The Associate Director for Science (ADS) provides curatorial leadership to the NMNH, supervises the
museum’s departmental chairs and central science staff including the Assistant Director for Collections
(ADColl), and
is accountable for:
 The establishment and enforcement of department collections management policies, procedures, and
standards that comply with SD 600, the SD 600 Implementation Manual, and this policy.
 The establishment of the NMNH Collections Plan and the NMNH Collections Policy Implementation
Plan.
is responsible for:
 Recommending to the Director specific delegation of curatorial authority and responsibility.
 Reviewing, approving, and revising department collections management policies, procedures,
standards and priorities under the consultation of staff with delegated collections management
responsibilities.
 Recommending to the Director collecting department authorization.
 Reviewing agreements that affect the care and accountability of collections under the consultation of
staff with delegated collections management responsibilities and when appropriate, recommending
to the Director for approval.
 Approving any exceptions to department collections management policies, procedures, and
standards.
 Providing policy guidance, program direction and planning, and budget support to carry out the
collections management requirements established in this policy.
 Ensuring that Department Chairs are accountable for collections tasks and that their staff’s training is
aligned with delegated authority and responsibility.
 Enforcement of performance measures for monitoring and reporting progress towards
implementation of collections management policies, procedures, and standards.
 Directly authorizing any acquisition or loan that requires or risks between $100,000 and $500,000 in
museum resources (as based upon purchase price, insurance value, and/or cost of care); any
collections purchase or disposal valued between $50,000 and $100,000; and any significant disposal
as defined in the collections policy implementation plan.
The Assistant Director for Collections (ADColl) leads the Collections Program, oversees the Registrar, the
Conservator, and pan-museum collections work, serving as a resource on collections accessibility and
accountability for museum staff, and
is accountable for:
 Communication of the pan-museum collections management policies, procedures, standards, and
priorities.
 Monitoring and documenting compliance with SD 600, the SD 600 Implementation Manual, and this
policy.
is responsible for:
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 5 of 35
 Advising museum staff on collections accessibility and accountability in compliance with SD 600, the
SD 600 Implementation Manual, and this policy.
 Reviewing requested exceptions to SD 600, the SD 600 Implementation Manual, and this policy, and
providing recommendations to the ADS or Director for approval.
 Assisting the ADS and Director in the establishment, implementation, review, and revision of the
NMNH’s collections management policy.
 Establishing performance measures for monitoring and reporting progress towards implementation
of collections management policies, procedures, and goals.
 Leading the NMNH Collections Committee.
 Serving as Department Chair for Education and Outreach collections.
 Leading the process to develop the NMNH Collections Plan and the NMNH Collections Policy
Implementation Plan for review and approval by the ADS and Director.
 Preparation and approval of reports for the ADS’s and Director’s review, including annual reports on
collections use and transactions.
 Advising Department Chairs on collections stewardship priorities relative to available pan-museum
resources.
 Advising Department Chairs and Collection Managers on the development and implementation of
departmental collections management policies and procedures.
 Collating and review of all department collections management policies and procedures, providing
recommendations to ADS for final approval.
 Collaborating with the Assistant Director for Information Technology to maintain functional
information management systems and access to collections information.
 Providing support in obtaining and properly using permits that allow collections acquisition, use, and
transportation.
 Signing Internal Revenue Service forms for collections donations (IRS 8283 / 8282).
The Registrar
is accountable for:
 The documentation of collections transaction records, permits, and other agreements in compliance
with SD 600, the SD 600 Implementation Manual, and the NMNH and collecting department
collections management policies.
is responsible for:
 Maintaining the central registry of all collections transactions and associated analog and digital
records that document decisions and collections related activities as defined in the NMNH Collections
Policy Implementation Plan.
 Conducting a final review of documentation for all acquisitions, accessions, loans, deaccessions, and
disposals, and reporting any policy or procedural discrepancies to the collecting departments,
ADColl, ADS, and Director as appropriate.
 Maintaining a current knowledge of legal, policy, and ethical issues to advise the departments as they
acquire, accession, loan, borrow, deaccession, dispose, and otherwise use collections.
 Leading cyclical inventories in collaboration with collecting department staff that have delegated
curatorial authority and responsibility and maintaining the museum’s records of its inventories.
 Leading development, maintenance, and use of data standards of automated transaction
management systems in cooperation with the Assistant Director for Information Technology,
Informatics, and collections management staff.
 Managing specific aspects of transactions, including insurance, and coordinating with other NMNH
and central offices as defined in the NMNH and departmental collections management policies and
procedures.
 Responding to the Office of the Inspector General (OIG) on audits related to collections and
collections activities, and holding associated records including records of museum accreditation.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 6 of 35
 Managing museum-level permits for acquisition, possession, use or transport of items (e.g., Material
Transfer Agreements [MTA], Prior Informed Consent [PIC], Mutually Agreed Terms [MAT], Certificate
of Scientific Exchange [COSE], or Animal Plant Health Inspection Service [APHIS]).
 Signing and maintaining records of Internal Revenue Service forms for collections donations (IRS
8283 / 8282).
 Providing regular training on policies and procedures associating with all aspects of collections
transactions.
The Conservator
is accountable for:
 Establishing, maintaining and monitoring relevant professional standards with respect to care,
preservation and safety of the NMNH collections and collections users.
 Communication of the pan-museum physical collections care risks, policies, procedures, standards,
and priorities.
is responsible for:
 Advising staff with delegated collections responsibilities on the physical care of collections.
 Leading or collaborating on conservation initiatives including integrated pest management.
 Providing regular training that promotes the care of the collections.
 Providing conservation services related to exhibitions.
The Department Chairs manage scientific, curatorial, and collections management staff, and
are accountable for:
 The establishment, review, and revisions of the department collections management policy,
procedures, standards, and priorities.
 The implementation of collections policies, procedures, standards, and priorities at a departmental
level in compliance with SD 600, the SD 600 Implementation Manual, and this policy.
are responsible for:
 Providing policy guidance, program direction and planning, and budget to carry out the collections
management requirements established in this policy under advisement of the ADS and with
consultation with the ADColl.
 Approving the department collections management policy, procedures, and collections plan.
 Ensuring that their staff’s training is aligned with delegated authority and responsibility.
 Ensuring that collections-related responsibilities are reflected in annual performance plans.
 Approving travel for fieldwork that will result in collecting activities.
 Recommending appropriate staff to the ADS and Director for annual delegation of curatorial
authority.
 Appointing department members to the NMNH Collections Advisory Committee.
 Establishing and overseeing any departmental working groups or committees.
 Ensuring appropriate access to collections areas and managing collections activities and use within
the scope of resources.
 Management, preservation and use of any and all departmental archival holdings other than the
National Anthropological Archives (NAA) and Human Studies Film Archives (HSFA).
 Directly authorizing any acquisition or loan that requires or risks between $50,000 and $100,000 in
museum resources (as based upon purchase price, insurance value, and/or cost of care); and any
collections purchase or disposal between $25,000 and $50,000.
Department Curators are those individuals who have received the annual delegation of curatorial authority
for one or more subcollections from the NMNH director. Curators are typically federal or trust Research
Scientists; however, in certain cases, curatorial authority will be delegated to affiliated agency scientists or
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 7 of 35
other NMNH staff based on their particular expertise and experience. Curatorial authority is the authority to
make decisions on the composition and strategic growth of the collections and for authorizing acquisitions,
accessions, scientific use, loans, deaccessions, and disposals subject to all necessary approvals.
are accountable for:
 The composition, accessibility, composition, and use of collections under their delegated curatorial
authority as it relates to scientific research, outreach, education, and exhibition in compliance with
SD 600, the SD 600 Implementation Manual, and this policy.
are responsible for:
 Initiating and/or approving the acquisition, accession, loan, deaccession, and disposal of their
subcollections according to the deadlines set forth in this policy.
 Developing and implementing collections plans for their assigned subcollections.
 Initiating and/or approving requests for use of collections items; their surrogates and images, and
information; and promoting responsible use of the collections.
 Initiating any acquisition or loan that requires or risks less than $50,000 in museum resources; and
any collections purchase or disposal less than $25,000.
 Undertaking or pre-approving any fieldwork that results in collecting.
Department Collections Managers are responsible for the accessibility and accountability of one or more
subcollections, and may supervise collections staff. Collections managers
are accountable for:
 Monitoring and enforcing compliance with SD 600, the SD 600 Implementation Manual, and this
policy at the departmental level.
 Communication of the pan-museum and departmental collections management policies, procedures,
standards, and priorities.
are responsible for:
 Advising departmental staff on collections accessibility and accountability in compliance with SD 600,
the SD 600 Implementation Manual, and this policy.
 Ensuring all collections are registered, identified, processed, and maintained according to
departmental policy, procedures, and standards.
 Providing direct physical care and access for collections and collections information (digital and
analog) ensuring their safety and security.
 Assisting the Department Chair by leading the establishment, implementation, review, and revision
of the department’s collections management policy, procedures, standards, and priorities.
 Advising and collaborating with the Department Curators on the development and implementation of
department collections plan.
 Advising Curators on collections stewardship priorities relative to departmental resources and staff.
 Collaborating with Curators to improve the quality and use of collections according to departmental
procedures and priorities.
 Preparation and approval of reports for the Department Chair’s, ADColl’s, ADS’s and Director’s
review, including annual reports on collections use and transactions.
 Implementation, maintenance, and use of data standards for the collections information systems in
cooperation with departmental and Informatics staff.
 Assisting the Registrar with cyclical inventories and maintaining the department’s records of its
inventories.
 Timely processing of acquisitions, accessions, loans, deaccessions, and disposals jointly with the
Department Curator.
 Providing departmental support in obtaining and properly using permits that allow collections
acquisition, use, and transportation.
 Maintaining a current knowledge of legal, policy, and ethical issues to advise the department as they
acquire, loan, borrow, dispose, and otherwise use collections.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 8 of 35
 Documenting records of all collections transactions and associated records that document decisions
and collections related activities as defined in the NMNH Collections Policy Implementation Plan.
The Associate Director for Operations (ADO) oversees the planning, management and budget of the
Natural History Building and the Museum Support Center, staff who lead emergency planning and response,
and the financial and personnel functions of the museum. The ADO liaises with the Smithsonian Institution
Office of Protection Services, Smithsonian Enterprises, and Smithsonian Facilities. The ADO is accountable
and responsible for:
 Ensuring that the facility and its systems are appropriate for the care and use of the collections.
 Ensuring that emergency response plans and systems are appropriate for the protection of the
facility, its occupants, and the collections.
The Museum Support Center Program Manager provides oversight of the MSC facility. The MSC manager
is accountable and responsible for:
 Ensuring that the facility and its systems are appropriate for the care and use of the collections.
 Ensuring that emergency response plans and systems are appropriate for the protection of the
facility, its occupants, and the collections

The Assistant Director for Information Technology working with the ADColl, the ADS and the collecting
departments, is accountable and responsible for:
 Developing and maintaining collections information and transaction management systems that
support collections control and accessibility.
 Ensuring collections information security.
 Developing and maintaining the museum’s Data Access Policy, and providing information per its
terms as requested.
 Providing public access to collections data through online collections information systems.
The Assistant Directors for Education and Exhibition are each responsible for working with Department
Curators and Collections Managers to ensure that the NMNH collections borrowed for exhibitions or acquired
for use in educational programs are used in compliance with this policy.
The NMNH Collections Committee has representation from each collecting department and the NMNH
facility, led by the ADColl, and charged with advising the ADS and Director on larger issues of collections
policy and management. This committee leads significant collections initiatives and projects for the benefit of
the entire museum.
The NMNH Collecting Departments each establish Collections Advisory Committees to support the
Department Chair in the stewardship of the collections and the designated curators in their delegated
responsibilities. Collections Advisory Committees assist with reviews of potential collections transactions,
and may advise on significant sampling requests.
The NMNH may establish standing, temporary, or ad hoc committees to guide and advise on collections
management, or to perform services on behalf of the museum. Such committees will have a charter and will
operate under the oversight of the Department Chair, ADColl, ADS, or the NMNH Director.
Central Offices, such as the Provost, National Collections Program, Office of General Counsel, Office of
Protection Services, Risk Management of the Office of Finance and Accounting, Privacy Office, Digitization
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 9 of 35
Program Office, Office of the Chief Information Officer, and Smithsonian Facilities, provide a collections
management service oversight to the NMNH as specified in SD 600 and the SD Implementation Manual.
E. Ethics
The NMNH’s collections activities are conducted in compliance with The Smithsonian Institution Statement of
Values and Code of Ethics; SD 103: Smithsonian Institution Standards of Conduct, the Advisory Board Ethics
Statement; SD 600: Collections Management; and the SD 600 Implementation Manual. The NMNH recognizes
and accepts its fiduciary responsibility to provide proper management, preservation, and use of its collections
and of associated information for the benefit of the international scientific community and the general public.
The NMNH strives to exceed the applicable legal standards and to manage its collections to the highest
professional and ethical standards. The museum recognizes that we operate within national and international
spheres of interest regarding collections. We seek to maintain awareness of the changing landscape of legal
and ethical issues associated with collections, such as intellectual property rights, access and benefit sharing,
and other emerging areas of interest, nationally and internationally.
Smithsonian staff are expected to be aware of, and guided by, generally accepted ethics and professional
standards applicable in their fields as published by reputable professional membership societies and
organizations. If such standards are in conflict with those of the Smithsonian, the NMNH staff member must
abide by the Smithsonian’s standards. Such a conflict should be brought to the attention of the ADS.
Staff will consider and evaluate the concerns of indigenous source communities regarding collections items,
recordings, information, collecting activities and use.
Staff are required to avoid personal and institutional conflicts of interest in collections activities, including the
provisions of SD 103 related to personal acquisition of collection items. Only authorized staff may engage in
collections transactions on behalf of the NMNH. Staff will follow the provisions in SD 103 related to
appraisals of collection items, authentication of collection items, and dealing in collection items.
All affiliated agencies stationed at the NMNH are also bound by the ethical standards established by their
respective agencies. If such standards are in conflict with those of the Smithsonian, the affiliated agency
employee must bring this to the attention of the ADS.
External parties must warrant that collections they bring into the NMNH’s facilities are acquired or possessed
legally. If collections already in the NMNH’s custody are found to have been acquired improperly, the NMNH
will promptly and thoroughly resolve their status.
Personal Collections. The NMNH staff, research associates, interns, fellows, volunteers, visitors, and
affiliated agency staff (all hereinafter referred to collectively as “staff”) may not maintain personal collections
in the NMNH’s facilities without the express written approval of their Department Chair and the ADS. Once
the ADS gives approval for a personal collection to be kept on site, an inventory of the collection shall be
provided to the Department Chair. Personal book collections used for work purposes, and personal
collections determined to be reasonably outside the scope of the owner’s department and used primarily as
office decoration are excepted from this rule. Personal collecting may only be done on personal time. No
personal collecting may be done on the NMNH’s business or field trips unless written permission from the
Department Chair and the ADS is obtained in advance and subject to the requirement that any such collecting
be conducted on annual leave taken in the midst of business or field trips. Personal items remaining in the
NMNH’s facilities 90 days after the close of an academic appointment tenure or contract will be considered
abandoned. The NMNH will handle such items according to this policy.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 10 of 35
F. Accounting for Collections
Smithsonian collections are held for public exhibition, education, and research in furtherance of public
service rather than financial gain. Collections are protected, kept unencumbered, cared for, and preserved,
and they are subject to the requirement that proceeds from sales of collections are to be used to acquire other
collections items. Accordingly, the Smithsonian does not treat its collections as assets for purposes of
reporting in its financial statements. The NMNH adheres to the applicable financial reporting standards
governing collections held in public trust as set forth in the SD 600 Implementation Manual.
G. Compliance
All employees who work with collections in the course of their assigned duties will have an element in their
performance plan that affirms compliance with the NMNH and Smithsonian collections management policies
and any department procedures.
Each collecting department will report on its compliance with this policy. Curators, collections managers, and
other supervisors in the department will indicate areas in which the department has complied, and will
account for areas of noncompliance. The Department Chair will then provide a signed compliance statement
with checklist to the ADColl. The Director will periodically report on the NMNH’s compliance to the National
Collections Program and the NMNH community.
H. Exceptions
Prudent exceptions to the NMNH’s collections management policy may be permitted when in the best
interests of the NMNH. Exceptions to the NMNH Collections Management Policy must be approved by the
Director in writing and only after consultation with the National Collections Program and the Office of
General Counsel, and approval by the Provost. Requests should be submitted to the National Collections
Program, which will facilitate the required review.
I. Policy Review and Revision
This policy will be reviewed every five (5) years, unless the Director determines that a significant change in
circumstances or a collections issue has arisen that indicates a need for review.
J. Categories of the NMNH’s Collections
This policy applies to the following categories of the NMNH’s collections:
Accessioned (Permanent) Collections. Items that are significant for research or exhibition and important to
preserve for an indefinite period. These collections undergo the accessioning process managed by the
Registrar. Care of permanent collections is prioritized over other types of collections. Genetic resources
collections may be gradually consumed through research use but are still considered permanent. Archival
assets such as printed and digital collections of images, recordings, scientific reproductions and illustrations
(works of art), or digital surrogates that are representations of items or phenomena are collections items.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 11 of 35
Custodial or Repository Collections. These collections are a type of Accessioned Collections. They are items
transferred to the NMNH by another federal agency or entity for which the NMNH has long-term custody but
does not fully “own” because the items are owned by the United States. These items and associated
documentation are acquired only under specialized agreement, signed by the Director or at the Institutional
level. Agreement terms may vary with each collection, but in general the NMNH gains custodial
responsibilities and specific usage rights. These collections differ from permanent (accessioned) collections in
that the organization conveying custody and rights has established terms of use that retain some rights or
establish obligations that the NMNH must fulfill.
Acquired Unaccessioned Collections. Some items are not suitable for inclusion in the permanent
accessioned collections because of an agreement, impediment, duplication, or other consideration that leaves
them available for exchange, sampling, and destruction, or means that they must be maintained per
agreement. These items may be referred to in records systems simply as “acquired.” All of these collections
must be properly acquired, used, managed and disposed to the same level of accountability as the permanent
collections.
Educational or Teaching Collections. These collections are a type of Acquired Unaccessioned Collections.
They are items not desired for permanent accessioned collections, but appropriate for educational or other
outreach uses. Unlike the permanent collections, there is no expectation of permanence for educational or
teaching collections. The NMNH holds a defined Education Collection, managed by the Collections Program,
developed and maintained to support the museum’s educational programs. Other teaching collections are
held in scientific departments. All of these collections must be properly acquired, used, managed and
disposed to the same level of accountability as the accessioned collections.
Section II. The NMNH’s Policy Elements
A. Acquisition and Accessioning
Acquisition is the act of gaining legal title to a collections item or group of items.
Accessioning is the formal process used to acquire legally and to record a collections item or group of items into
the NMNH’s accessioned collections.
PRINCIPLES
The acquisition of collections is fundamental and critical to the mission, purpose, and programmatic goals of
the NMNH. The museum observes the highest legal and ethical standards in the acquisition of collections. The
NMNH requires responsible, disciplined acquisition of collections through the following principles:
 Acquisition of collections relevant to the mission, programmatic goals, and collections plan of the
NMNH.
 The establishment, utilization and regular updating of museum and departmental collections plans
to define the museum’s vision of the collection (intellectual framework), collecting goals and
priorities, and implementation strategies.
 Strict adherence to all applicable laws and regulations and to professional ethics relating to
collections acquisition and use.
 Written delegation of curatorial authority within the NMNH.
 Use of formalized, stringent acquisition evaluation criteria.
 Consideration and approval of the associated resource requirements and the lifecycle costs of longterm collections management, preservation, storage, and use.
 Acquisition and accession is initiated and approved only by individuals with delegated curatorial
authority
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 12 of 35
The Smithsonian repudiates the illicit traffic in objects and specimens that contribute to the despoliation of
museums, monuments, environments, sites and species resulting in irreparable loss to science and humanity.
Items that have been stolen, unscientifically gathered or excavated, or unethically acquired should not be
made part of Smithsonian collections.
The NMNH acquires collections items by a variety of methods, including gift, bequest, purchase, exchange,
transfer, field collecting, and propagation. Items are acquired for three main purposes: research, exhibition,
and education. The NMNH may acquire or otherwise have custodial responsibility for collections via a
repository or similar agreement.
POLICY
COVERAGE. All collections acquisitions are subject to this policy.
AUTHORITY. Primary collecting authority rests with the Director, who delegates general responsibility for a
subcollection(s) to appropriate staff via written memorandum. Any delegation of collecting activity to nonSmithsonian staff will be made in writing by the Director.
Each NMNH collecting department must recommend to the Director the staff to whom curatorial authority
will be delegated, and establish procedures for the formal review and approval of collections acquisitions.
Only those staff with written delegation from the Director may acquire collections. Collecting departments
shall not opportunistically or purposefully collect or acquire items outside of their recognized discipline on
behalf of another collecting department without the prior agreement of the designated curator of that
subcollection.
Authority to document and process acquisitions and accessioning is vested in the Director and delegated to
the Registrar. All staff with delegated authority to acquire must take training from the Registrar to ensure
compliance with all applicable laws and regulations.
The Director and specific designees, as identified in writing, are the only staff members authorized to sign
international or national agreements and permits regarding collections acquisition on behalf of the NMNH.
The ADColl and Registrar are the only staff members authorized to sign IRS forms 8283 / 8282.
LEGAL COMPLIANCE. Collections will be acquired only in accordance with established authority and only in
compliance with applicable laws, regulations, and professional ethics. The NMNH exercises due diligence in
complying with all applicable federal, state, local, and international laws, treaties, regulations, and
conventions. Compliance is documented by obtaining and providing all applicable collecting, transportation,
and use permits or agreements in writing to the Registrar. Collecting department staff shall obtain all
necessary authorizations and permits, in writing, prior to acquisition.
PROVENANCE. The concept of provenance refers to the history of ownership of a collection item. Collecting
departments shall exercise due diligence in the acquisition of collections, including making reasonable
inquiries into the provenance of collections items under consideration for acquisition consistent with
Smithsonian policy. Such inquiries are made to determine that the NMNH can acquire valid title to the
collections item and that the acquisition will conform to all legal requirements and ethical standards. For the
purposes of this policy, the scientific concept of “provenance” that relates to the locality where an item
originated will be referred to as the item’s “locality.”
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 13 of 35
The NMNH complies with the Smithsonian Institution Policy on Acquisition of Art, Antiquities, Archaeological
and Ethnographic Material, and Historic Objects, adopted by the Board of Regents on April 13, 2015, which
affirms the Smithsonian support for efforts of local, state, national, and international authorities to protect
art, antiquities, national treasures, and ethnographic material from destructive exploitation. It sets forth rules
for the acquisition and borrowing of art, antiquities, and other items. The text of the Policy is included in the
SD 600 Implementation Manual. The NMNH does not consider geological, paleontological, or mineralogical
materials in an unmodified state to be cultural property covered by this Policy. However, gems and items of
jewelry that have an historic or iconic nature will be subject to the Policy.
Before acquiring or borrowing a collection item, the NMNH must ascertain, from the circumstances
surrounding the transaction or knowledge of the item’s provenance that the collection item was not stolen or
wrongfully converted and is not illegally present in the United States. The NMNH must also ascertain,
consistent with Smithsonian policy, that the collections item was not unethically acquired from its source,
unscientifically excavated, or illegally removed from its country of origin after 1970.
The provenance of collections items shall be a matter of public record. Locality records and related
information may be reasonably protected from non-approved access if there is reason to fear any breach of
privacy or confidentiality, site vandalism, or theft.
Items related to named individuals or extant cultural groups shall be managed in a sensitive, respectful
manner.
EVALUATION. The NMNH collecting departments must establish evaluation criteria when reviewing
potential acquisitions. The following criteria must be considered during the review and evaluation of
potential acquisitions:
 Consistency with the NMNH’s mission, strategic plan, programmatic goals, collecting scope and
collections plan
 Documentation of clear and legal title, including compliance with all national and international laws
and regulations
 Fits within the collecting department’s existing storage space
 The NMNH and/or the collecting department has the ability and resources to provide appropriate
management, care, and accessibility, including documentation, long-term preservation, conservation,
digitization, and storage
 Does not require substantial care that would place undue hardship on the museum.
Consultation with the Director is required before acquisition of any collections that would require substantial
resources beyond the allocated budgets of the collecting department, space beyond the allotted footprint for
the department, or other substantial resources for the management or preservation of the collections.
Consultation with the Provost and National Collections Program is required before acquisition of any
collection that would require substantial resources, including collections storage space, beyond the NMNH’s
allocated budget and space or substantial resources of other Smithsonian units for the management,
preservation, or storage of the collection.
METHODS OF ACQUISITION
The NMNH acquires collections items by a variety of methods, including gift, bequest, purchase, exchange,
transfer, fieldwork, and propagation.
 Fieldwork: Field collecting activities must be undertaken in compliance with all applicable local,
state, federal, and international laws, regulations, and conventions, and compliance must be
appropriately documented at the time of acquisition, including all necessary governmental permits
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 14 of 35
and other applicable permissions. All the NMNH and research collaborators conducting scientific
field research and collecting as part of their official duties must be authorized in advance and obtain
all necessary collecting permits, export/import licenses, and other necessary permissions. Shipping
and handling of items acquired in the field must conform to the NMNH procedures and comply with
all applicable laws and regulations.
 Gifts: All gifts to the museum must be documented in writing by a deed of gift or gift agreement to
establish transfer of legal title to the NMNH and the Museum must comply with applicable IRS
regulations concerning acknowledgement of gifts to donors. All fractional gifts must be documented
in a fractional gift agreement which is reviewed and approved by the NMNH Director and the Office
of General Counsel.
 Bequests: the NMNH reserves the right to accept or decline any bequest, or a portion of a bequest, at
its discretion, or to negotiate with executors to obtain bequests of a clear and unrestricted nature.
The museum applies the same criteria to bequests as to gifts with respect to restrictions. All release
or receipt documents relating to a bequest must be reviewed and approved by the Office of General
Counsel. OGC is the sole signatory for bequests.
 Purchases: Wherever possible, purchases must be documented by use of a standard purchase order
or, if the terms of the purchase are complex, negotiated contracts written in consultation with the
Office of General Counsel and/or Office of Contracting. If necessary to purchase by petty cash or
credit card, the purchase must be documented by a standard invoice or bill of sale. These instruments
document the transfer of title and, if applicable, transfers of associated rights such as intellectual
property rights. The NMNH complies with the documentation requirements of SD 600 and the SD 600
Implementation Manual for determining that the proposed purchase price is fair and reasonable.
 Exchanges: the NMNH may engage in exchanges with other non-profit and educational organizations
documented by an exchange agreement as long as the general criteria for acquisitions are adhered to
for the proposed acquisition and the criteria governing deaccessions are adhered to for a collections
item selected for removal and exchange. Questions about exchange agreements will be referred to
the Office of General Counsel.
 Government Transfers: Transfers are documented by a transfer agreement between the NMNH and
the transferring entity that is reviewed and approved by the Office of General Counsel.
 Found in Collection: the NMNH collecting departments may acquire or accession a collection item(s)
by the discovery of its presence (found in collection) in the NMNH without connection to provenance
or loan status records or otherwise abandoned if written evidence of due diligence is approved by
the Registrar, who may consult with the National Collections Program and Office of General Counsel
as appropriate. Prior to transferring title to a “found in collection” item to a third party, the NMNH
will consult with the National Collections Program and the Office of General Counsel.
The NMNH may decline offers of collections items at its discretion as appropriate.
DOCUMENTATION. Collections records must show decision-making processes of acquisitions evaluation,
including proposal, review, approval and required donor acknowledgement, and must include all necessary
acquisition documents such as collecting authorizations/permits, import/export licenses, transportation
permits and manifests, indication of legal title and provenance, all legal documents associated with the
acquisition, intellectual property rights where applicable, and all other documentation required by the SD 600
Implementation Manual. Gifts must be acknowledged in writing by the collecting department within 30 days
of receipt. Records are managed by the Registrar.
PROCESSING. Receipt and processing of acquisitions is managed through a centralized log-in point in each
collecting department.
 Each transaction should be entered into the museum’s collections transaction management
systems within 15 business days of receipt, regardless of type of transaction
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 The accession process will be completed within the year of acquisition, unless there are
extenuating circumstances that result in an extension granted through the chain of command.
Extensions must be in writing and filed with the Registrar.
 Items should be catalogued promptly.
JOINT OWNERSHIP. The NMNH may acquire items jointly with other entities with which it agrees to share
ownership and management. In such cases, a written agreement must stipulate the terms and conditions of
the agreement and the responsibilities of each party. Joint ownership and management may also be
established for collection items subject to repatriation claims. Joint ownership agreements must be approved
by the NMNH Director and the Office of General Counsel. Fractional gifts may result in a joint ownership
situation, if only for a limited time. All fractional gifts must be reviewed and approved by the Director and the
OGC.
RETENTION. Items are acquired and accessioned with a good faith intention to retain them for an indefinite
period. Under certain circumstances (e.g., genetic resource samples), collections may be acquired that may
be subject to consumption in part or whole, or which may be culled in the course of identification and study. If
at the time of acquisition the NMNH intends to dispose of part or all of the collections, this decision should be
documented in museum records and communicated to the source or party conveying ownership.
RESTRICTION. The NMNH acquires unrestricted collections as a general rule. Certain restrictions are
routinely accepted, such as instances in which the country or agency of origin places restrictions on use and
disposal, in which a donor may place a limited term of restriction on archival materials to protect rights of
personal privacy, or on retention of intellectual property rights by an individual, community, or indigenous
group. Any restrictions must adhere to written policy, be documented in museum records at the time of
acquisition, and must be reviewed by the collecting Department Chair and Collections Advisory Committee,
Registrar, ADColl, ADS, and Director, as is appropriate in each case. Any restriction must be accepted by the
NMNH Director and set forth in the deed of gift or other transfer document.
In evaluating whether to accept a restriction, the NMNH will consider:
 the significance of the gift
 the future use(s) of the collections item(s)
 the nature of the limitations
 the precedent set by acceptance
 the ability to adhere to such restrictions immediately and long-term
If the museum decides to accept specific restrictions, it will attempt to have the restrictions binding only for a
set period.
RIGHTS. Where applicable, and as practically possible, ownership of copyright, artist’s rights, terms of use,
and other intellectual property rights must be established and documented at the time the collections are
considered for acquisition. The Conservator should be consulted for conservation implications. In considering
works of visual art, the moral rights of living artists (the right of attribution and the right of integrity) will be
taken into consideration at the time a work is proposed for acquisition, as delineated in the Visual Artists
Rights Act of 1990 and any subsequent revisions.
The NMNH agrees with the spirit of the Convention on Biological Diversity and the Nagoya Protocol, and
voluntarily implements certain procedures regarding access and benefit sharing of genetic resources and
traditional knowledge. Relevant agreements taking the form of Prior Informed Consent (PIC), Mutually
Agreed Terms (MAT), Memorandum of Agreement (MOA) or Understanding (MOU), terms expressed in
Material Transfer Agreements (MTAs), or similar documents are agreed in writing by the Director or
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 16 of 35
designee and associated with the collections transaction and item records. Signed agreements are managed
by the Registrar.
COMPETITION. Some overlap among Smithsonian collecting units or the NMNH collecting departments is
inevitable; however, competition for a particular acquisition is inappropriate. When more than one NMNH
collecting department seeks to acquire the same collections item, the parties concerned must agree on which
department will acquire the collections item. In those cases, when placement of a collections item cannot be
resolved by the collecting department chairs, the Director will decide.
The NMNH will avoid competitive bidding with federal agencies for collections items of common interest, and
will seek mutually acceptable agreements whenever the potential for such competitive bidding becomes
apparent. This applies to all collecting activity by any federally established institution or agency, including
any component of the Smithsonian.
B. Deaccessioning and Disposal
Deaccessioning is the process used to formally approve and record the removal of a collection item or group of
items from the NMNH’s accessioned collections.
Disposal is the act of physically removing an unaccessioned or deaccessioned collections item or group of items
from a NMNH collection. Types of disposal include donation, transfer, exchange, sale, repatriation, sampling for
destructive analysis, consumptive or educational use, and destruction.
PRINCIPLES
Deaccession and disposal are a legitimate part of responsible collections management. Prudent collections
management actions, including evaluation, deaccession, and disposal of existing collections, are intended to
refine and improve the quality and relevance of the collections with respect to the museum’s mission,
purpose, programmatic goals, and collections plan.
Deaccession and disposal occur for a variety of reasons, such as deterioration of collections items beyond
usefulness; lack of adequate information such as locality or other provenance data; duplication or
redundancy of collections material; insufficient relationship to the mission and programmatic goals of the
museum; repatriation; and consumptive research or educational use.
The NMNH Repatriation Office, in accordance with the NMAI Act, sets repatriation policy and procedures.
These supersede policy and procedures for all other forms of deaccessioning and disposal for affected
collections; reviews and approvals are specified with the guidelines of the Repatriation Office that is the
authority for repatriation of the NMNH collection items.
POLICY
COVERAGE. Once acquired and/or accessioned, all collections items are subject to deaccessioning and
disposal policy. Collection items proposed for removal must undergo the deaccession process unless they
meet the following criteria: They are unaccessioned or have no evidence of ever having been accessioned, and
have no associated accession or catalog number; and they lack data needed to associate them with a donor or
other records.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 17 of 35
AUTHORITY. Collections may be deaccessioned and disposed of only in accordance with established
authority, and only in compliance with all applicable laws and regulations, professional ethics, and terms
agreed upon at the time of acquisition.
Deaccessions and disposals, including destructive analysis or sampling may proceed only after establishing
unrestricted title to an item. In cases where title is in question, the collecting department must first seek
guidance from the Registrar, the National Collections Program, and the Office of General Counsel.
Only the following disposal methods may be used without the approval of the Director:
 Return to the rightful owner when the NMNH lacks title
 Transfer to another Smithsonian collecting unit, Federal agency, or an educational organization
 Loans which will require total consumption of the item or sample (with permission from the Lender)
 Transfer to another organization under the terms of an established collecting agreement or contract
 Routine destructive analysis as established by the approval procedures of the collecting department
 Routine destruction of items from teaching collections that have deteriorated past usefulness
 Repatriations as approved by the Secretary.
APPRAISAL. In accordance with SD 600, if the estimated value of a single collections item or a group of
collections items considered for disposal is:
 More than $10,000, collecting department staff must obtain a written, independent appraisal or
informed estimate of fair market value
 More than $100,000, the NMNH must obtain two written, independent appraisals or informed
estimates of fair market value and approval of the deaccession and disposal from the National
Collections Program, the Office of General Counsel, the Provost, and the Secretary
 More than $500,000, the NMNH must obtain two written, independent appraisals or informed
estimates of fair market value and approval of the deaccession and disposal from the National
Collections Program, the Office of General Counsel, the Provost, the Secretary, and the Board of
Regents.
DOCUMENTATION. All disposals and deaccessions will be documented in permanent files maintained by the
Registrar.
EVALUATION. Collections items shall only be deaccessioned in compliance with the criteria and procedures
established by the department’s Collections Advisory Committee.
METHODS OF DISPOSAL
The NMNH disposes of collections items by a variety of methods, including transfer, exchange, repatriation,
sampling, sale and destruction.
 Donations or External Transfers: The NMNH may donate or transfer deaccessioned collections items
to another non-profit or educational institution. The transfer agreement shall grant the NMNH the
right of first refusal in the event the recipient organization decides to dispose of the collections item.
 Internal Transfers: When collections items proposed for disposal are suitable for public teaching
purposes, such items should first be offered to the NMNH’s Office of Education and Outreach, or
considered for the collecting department’s teaching collections.
 Smithsonian Transfers: Smithsonian collecting units shall have right of first refusal of collections
items proposed for disposal. Such transfers are without compensation, except when the NMNH
disposes of a collections item acquired through purchase.
 Exchanges: All exchange of items must be made per written exchange agreements. Long-term open
exchange with recognized educational organizations having a similar mission, such as museums and
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 18 of 35
herbaria may be done with prior written approval by the Director or designee. Such agreements will
be reviewed periodically to ensure continuing alignment with the NMNH’s mission, policies,
programmatic goals, and collections plan.
 Repatriation: The NMNH may return collections items in accordance with provisions of the National
Museum of the American Indian (NMAI) Act [20 USC. § 80q (1989)], to lineal descendants of the
original individuals or owners, or to representatives of the culture of origin as defined by law.
 Sampling for Destructive Analysis: This refers to any of a number of procedures in which collection
items, or samples of those, are removed for research, entailing the use of analytical processes that
require the permanent alteration or destruction of part or all of an item in order to obtain
information. The NMNH encourages the uses of non-destructive analytical techniques where
feasible, and seeks to incorporate the findings of such analyses in permanent collections records.
 Sales: Collections may be sold only via public sale and when proceeds realized are designated for
additional collections acquisitions within the collecting department that disposed of the items. The
Director must approve all sales proposals in advance.
 Destruction: The Director’s approval is required before the destruction, including destructive
analysis, of any collection item(s) meeting one or more of the following criteria:
o Item is classified as a primary or name-bearing type specimen and sampling technique
would destroy a significant portion of it, or a Smithsonian iconic collection item.
o Item has been independently appraised as having a monetary value of over $10,000 and is
being considered for outright destruction rather than analytical sampling.
o Item is considered to have a very high public profile in the United States and/or in its
country of origin.
Routine destruction for disposal or destructive analysis does not require approval outside the
collecting department. The Conservator should be consulted regarding destructive sampling
methods. Destructions requiring a high level of approval must be witnessed by the Director or
designee.
HAZARDS. The collecting department disposing of collections items shall comply with all legal and regulatory
requirements that may be posed by hazardous or regulated materials. Compliance with those requirements
will be documented.
ACQUISITION OF DISPOSED ITEMS. Collections items disposed by means other than repatriation may not be
acquired through any means by the NMNH Board members, staff or research associates, affiliated agencies
staff, volunteers, interns, or fellows.
EXCEPTION: Repatriated human remains and objects may on occasion be legitimately transferred to
a Smithsonian employee, volunteer or other associate, but only in those instances in which: The
Smithsonian party is also a legitimately appointed representative of the affected tribal group or
nation, or the Smithsonian party is a lineal descendant of a named individual whose remains or items
are repatriated under the NMAI Act, or the Smithsonian party is a lineal descendant of a named
individual whose remains are held in the NMNH, and the Smithsonian party requests the returns of
those remains only, and the Smithsonian party has not participated in an official capacity in this
determination.
Such transfer of repatriated human remains or objects to the NMNH Board members, staff or
research associates, affiliated agencies staff, volunteers, interns or fellows must be approved by the
Office of General Counsel.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 19 of 35
C. Preservation
Preservation is the protection and stabilization of collections, as well as their associated information, through a
coordinated set of activities to minimize chemical, physical, and biological deterioration and damage and to
prevent loss of intellectual, aesthetic, cultural, and monetary value. Preservation is an ongoing process with the
goal of making collections and their associated information available for current and future uses.
PRINCIPLES
The NMNH’s ability to carry out its mission is directly related to its commitment and ability to provide for the
proper physical care and appropriate space for collections as well as preserving, managing, and enhancing
the information inherent in them. The NMNH’s mission balances the preservation of the collections with
promoting the use of the collections.
The NMNH is responsible for working with other Smithsonian collecting units and central offices to provide
appropriate collections spaces, environmental conditions, and housing. The NMNH strives to protect the
collections as best as possible against agents of deterioration.
POLICY
COVERAGE. The NMNH provides the necessary preservation, protection, training, and security for all
collections acquired, accessioned, borrowed, and in the custody of the NMNH, including associated
information.
AUTHORITY. The Director is responsible for ensuring that the NMNH and MSC facilities provide the basic
utilities and programs for safety and well-being of the collections. During periods of renovation or
construction, it is the responsibility of the Director or designee to coordinate collections security and care
efforts with the collecting departments and other Smithsonian offices in a clear and timely manner. When
collections develop by changing or growing in a way that significantly affects the resources necessary for
their housing and care, the collecting department should coordinate plans with the Director or designee so
that resources can be prioritized.
Conservation intervention, restoration, destructive sampling, or consumptive use of collections items shall be
carried out only as authorized by the Department Chair with advice from the appropriate collecting
department’s Collections Advisory Committee and in consultation with the museum’s Conservator.
The ADO and MSC Facility Manager have authority and responsibility for maintaining facilities that are
appropriate for collections preservation.
ASSESSMENT. Each collecting department shall assess the status of the collections within its oversight on a
cyclical basis. This cycle shall be established by the collecting department’s policy except when established by
the Director. This information will be reported to the Director or designee.
PREVENTION. The NMNH develops and maintains an integrated pest management policy and
implementation plan across all its collections facilities. The Integrated Pest Management Plan is developed by
the Conservator in collaboration with NHB and MSC Facility Managers. Every occupant of the facilities is
responsible for following procedures that reduce pest-related risks.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 20 of 35
The NMNH prohibits smoking and the consumption of food and drink in locations that place the collections at
risk. Special events held in the museum exhibitions that involve food and drink must have a risk management
plan approved by the Director.
The NMNH must balance current research and educational use with the preservation requirements of
collections items to ensure that collections items are maintained for future generations and rightfully serve
their intended purpose.
D. Collections Information Management and Digitization
Collections information documents the intellectual significance, provenance, physical characteristics, location,
and legal status of analog and digital collections items including transaction documentation, as well as the
collections management processes they undergo and their use in research, education and exhibitions. Gathering,
recording and managing collections information is part of an ongoing process, with some information taking the
format of items included in archival collections, or documentary files (e.g., field notes and logbooks, illustrations
and works of art, data sets, and photographs), electronic information systems, and multi-media formats. The
value of collections information lies in its quality, integrity, comprehensiveness, and potential for use for research
and educational purposes.
Digitization is the process by which collections information and the collections items themselves are
represented in digital form.
PRINCIPLES
The documentary value of a museum collection is a principal criterion for its excellence. Well-documented
results of scientific, historic, and aesthetic research enable the NMNH to fulfill its mission and programmatic
goals.
The primary purpose of collections information management systems is to provide access to the NMNH
analog and digital collections and associated information and documents. The NMNH has a responsibility to
acquire, develop, and maintain collections information systems that enhance access to and accountability for
its collections and research findings and to ensure long-term preservation in analog and digital formats.
The NMNH houses analog and digital collections information and surrogates in its Research and Collection
Information System (RCIS), commonly called “EMu,” which is the official NMNH database of record and
includes the research and collections database, transaction management, genetics sample processing (with a
server-level integration to the NMNH’s Biorepository Freezer Pro system), and multimedia management
(with a server-level integration to the SI-wide Digital Asset Management System – DAMS). This system of
record maximizes computerized technologies, workflows, professional documentation standards, and
supports the sharing of collections information through collaborations among the NMNH collecting
departments and with other educational and research institutions.
POLICY
AUTHORITY. The Assistant Director for Information Technology has authority over the RCIS as a system.
The ADS has authority over the collections data or content of the RCIS.

RESPONSIBILITY. Centrally supported collections information systems that document collections holdings
and transaction management must support and meet the NMNH goals for accountability and access.
ACCESS AND USE. Access to and, use of, digital or electronically maintained data is governed by the standards
established in the NMNH policy Collections Information Access and Data Sharing at the NMNH.
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Use of data for commercial purposes, by for-profit entities and organizations, or by individuals for profit
purposes, requires approval by the Director or designee, after consultation with the Office of General Counsel.
Acceptable usage and profit-sharing arrangements between the user and the NMNH must be stipulated in a
formal agreement approved by the Director or designee, Office of General Counsel, and Office of Contracting,
as appropriate. See also Section G.
The provenance of collections items shall be a matter of public record. Specific collecting localities may be
reasonably protected from non-approved access if there is reason to fear any site vandalism or theft, or
locality data is otherwise limited by regulation or documented agreement.
Decisions about restrictions must be documented in collections records. The collecting department shall
consult the Office of General Counsel and the Registrar when determining policy for restriction of access to
information. See also Section A.
RIGHTS. All original primary collections records created by the NMNH staff in the course of their duties (e.g.,
field notes, research-related notes, images, photographs, illustrations, correspondence, original card
catalogues, sound and visual recordings, and other records and documents directly or indirectly related to the
collections or collections activities of the NMNH) are the property of the NMNH.
All such original primary collections records are to be maintained in good order and must be accessible to
staff, in keeping with current archival policy and procedures.
Some collectors and governmental agencies may reserve the right to retain original primary collections
records for specimens donated or transferred to the NMNH. The NMNH will make surrogates of these records
when possible.
DIGITIZATION PLANS / PROJECT DIGITAL ASSET MANAGEMENT PLANS. The NMNH is responsible for
developing and maintaining a digitization plan and project digital asset management plans for collections
data development, maintenance, preservation, and retention per SD 609: Digital Asset Access and Use and SD
610: Digitization and Digital Asset Management Policy, in collaboration with the Digitization Program Office.
All media containing collections information are maintained for long-term use and must be preserved in
keeping with archival policy and standards.
E. Inventory
Inventory is a repeated and ongoing process for physically locating and verifying all, or a specified subset, of the
museum’s collections items. Results of this process are documented in the museum’s Research and Collections
Information System (RCIS).
PRINCIPLES
In addition to facilitating research, documentation, and storage, an ongoing inventory program is an essential
security device to deter and detect theft or misplacement of collections items. Inventory records serve as a
tool for accountability. The NMNH counts its collections at the item level for standard reporting purposes. For
some collections, these are qualified estimates. The collections also may be counted as “lots” or groups of one
or more items that have shared characteristics. The ADColl will recommend the appropriate method for
counting the collections on a case-by-case basis. The Director will make the final decision on how the
collections are counted.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 22 of 35
POLICY
AUTHORITY. The Registrar has authority to initiate an inventory in any collecting department. Others may
initiate an inventory per their delegated level of authority.
LOCATION RECORDS. Collecting departments must maintain and update accurate location records of all
collections items including those on loan or on exhibit.
CENTRAL CONTROL POINT. All collection items entering or leaving a collecting department must pass
through a control point designated by that collecting department. Records of movement of all collections
items will be documented in the collections department and available to the Registrar.
CYCLICAL INVENTORY. Collecting departments must establish and implement a cyclical inventory plan.
Results of cyclical inventories must be filed promptly with the Registrar.
F. Risk Management and Security
Risk management is the process of identification and evaluation of risk to prevent or minimize exposure to
factors that may cause loss, damage, or deterioration of collections, or risks to health and safety of persons
exposed to collections.
PRINCIPLES
The programmatic activities of the NMNH naturally involve an exposure of collections to risks of damage or
loss. This can occur to a collections item when it is on exhibition or loan, in transit, in storage, or while being
studied, treated, or handled. Potential hazards include natural disasters, vandalism, terrorism, theft, disease,
space and environmental deficiencies, human error, mechanical or operational system failure, pests, and
deterioration.
Prudent collections management requires identification, reduction, or elimination of risks to the collections
through a systematic risk management assessment program. Risk management requires thoughtful review of
potential hazards.
POLICY
AUTHORITY. The ADO and MSC Facility Manager have authority to take action to manage risks to the
collections as posed by deficiencies in the facility or in response to security matters. They are the primary
points of contact with the Smithsonian’s Division of Risk Management, Office of Safety, Health and
Environmental Management, and Office of Protection Services. The ADO and MSC Facility Manager
communicate and coordinate with Department Chairs, Curators and Collections Managers about facilityrelated risks and security matters.
PREVENTION. The NMNH minimizes and controls the level of risk of loss or damage to collections through
established collections management practices such as regular inspection, inventory, and integrated pest
management.
Living animals (except for service animals) that are not part of approved NMNH research projects or
educational programs may not be brought into any NMNH facility.
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MANAGEMENT CONTROLS. Effective management controls are the responsibility of all NMNH managers and
supervisors responsible for collections, who assure sufficient control and accountability in accordance with
SD 115: Management Controls.
All staff have the obligation to be aware of the Institution’s risk management and security process. Staff must
note and communicate to the appropriate office, including the Risk Management Division in the Office of
Finance and Accounting, the Office of Protection Services, the National Collections Program, the Office of
General Counsel, the Office of Contracting, the Director, the ADS, the ADColl, the Registrar, and the
Conservator of situations that create the potential for damage or loss to collections, personal injury, or legal
liability.
Risk management and insurance is coordinated at the Smithsonian by the Risk Management Division in the
Office of Finance and Accounting and governed by SD 108: Insurance and Risk Management. At the NMNH, risk
management and insurance is coordinated with Risk Management staff through the ADColl.
Security is coordinated at the NMNH by the Office of Protection Services through the Associate Director for
Operations. The NMNH will implement the collections space security standards outlined in the SD 600
Implementation Manual. Collecting department staff will use the Smithsonian Collections Pass to track and
verify movement of the NMNH collections from and between Smithsonian facilities.
INSURANCE. Except in extraordinary circumstances, the NMNH does not insure its own collections while they
are in the care and possession of the NMNH. Collections on loan to the NMNH and the NMNH collections on
loan to or in the custody of others will be insured as stipulated by authorized loan agreements or negotiated
contracts.
Insurance proceeds from the settlement of claims for damage or loss to the NMNH collections will be used for
collections acquisition within the affected collecting department.
REPORTING THEFT. Suspected or confirmed theft or loss must be reported promptly to the Registrar,
ADColl, ADS, Director, the Office of Protection Services (OPS), Division of Risk Management, Office of Finance
and Accounting, and the National Collections Program.
EMERGENCY PREPAREDNESS. All NMNH facilities, owned or leased, must have a written comprehensive
emergency preparedness plan as required by SD 109: Disaster Preparedness. The Director shall ensure that an
emergency preparedness and response plan is developed and maintained that includes planning, response,
and recovery from disasters as well as evaluation and assessment following an incident.
Emergency management at the Smithsonian is coordinated by the Office of Emergency Management in
accordance with SD 109: Disaster Management Program. Collecting departments must develop and maintain
plans for continuity of collections stewardship in the event of temporary, partial or full closure of museum
facilities.
G. Access
Access is the opportunity for the general public, scholars, and Smithsonian staff to use the diverse collections
resources of the museum.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 24 of 35
PRINCIPLES
To carry out its mission, the NMNH promotes access to its collections and associated information through
research opportunities, reference systems, loan and exchange of collections, electronic information services,
traditional and electronic exhibitions, and educational programs and publications.
POLICY
AUTHORITY. Approving access to the collections is delegated to the Collecting Department Chair or Curator
and is facilitated by the Collections Manager.
PRESUMPTION of ACCESS. The NMNH operates with the presumption of access to collections and associated
information. It will provide reasonable access to collections and collections information consistent with its
stewardship responsibilities. Physical and intellectual access to the collections must be balanced against
preservation and protection concerns. See also Section I.
PHYSICAL ACCESS. Staff responsible for providing physical access to collections, as authorized within each
collecting department, must be familiar with the collections and their preservation needs.
The NMNH collections users are required to demonstrate competence in handling collections, as appropriate,
and also willingness to comply with security precautions or other restrictions.
Access to the collections may be denied to individuals who fail to handle items in accordance with the
NMNH’s approved practices and standard professional guidelines.
The NMNH may deny access to collections and collections information if access would disrupt or compromise
ongoing research.
RIGHTS. The NMNH acknowledges that the right to reproduce a collections item may be held by another
individual or organization. In instances where such rights are believed to be held by a non-NMNH or
Smithsonian party, the potential user will be notified and required to take full responsibility for obtaining any
rights necessary for the intended use. The NMNH undertakes no responsibility for determining the nature of
such rights or for obtaining any permissions on behalf of the potential user.
The NMNH collecting departments may enter into agreements of restricted access at the request of Native
American tribes (see Section III. Specific Legal and Ethical Issues), in connection with the repatriation
process.
The NMNH reserves the right to refuse to furnish images or objects intended for reproduction, and also, to the
extent it may be entitled to do so, deny permission for such reproduction at its discretion, using criteria
including but not limited to:
o Whether the circumstances of the reproduction would alter the appearance of or otherwise
misrepresent the collections item involved;
o Whether the reproduction work would cause harm to the object;
o Whether the attribution, rights, or identification of the collections item are in question; or,
o Whether an agreement precludes granting permission for reproduction, or the NMNH’s rights
regarding the item are unclear
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 25 of 35
Electronic access to collections or collections information should be based on traditional principles guiding
access to original collections items and documents, comply with SD 609, and should serve to enhance the
mission of the NMNH.
The NMNH generally has items in its care that are not the property of the Smithsonian. These items may
include long-term loans; items borrowed for identification, evaluation, consideration of acquisition study, or
exhibition; or collections with shared custody and care. The NMNH is responsible for limiting access to these
items pending the permission of their owners.
ACCESS AND BENEFIT SHARING. These concepts are found in the Convention on Biological Diversity and
the Nagoya Protocol, and they guide use of collections from other nations. These include gaining Prior
Informed Consent (PIC) and Mutually Agreed Terms (MAT) regarding planned and future uses of collections
as associated information, respecting the terms of use made at the time of acquisition such as a limitation on
commercial uses, and the fair and equitable sharing of benefits resulting from the use of collections and
traditional knowledge regarding genetic resources. Such terms of use may also be expressed in Material
Transfer Agreements (MTAs.) Although the United States is not a signatory to the Convention on Biological
Diversity or the Nagoya Protocol, the NMNH voluntarily complies with these agreements when possible. The
NMNH has developed a statement regarding commitment to the principles of access and benefit sharing, and
procedures that guide and document the acquisition and use of relevant collections and associated
information.
RESTRICTIONS. Access to collections and collections information may be restricted or embargoed due to any
of the following: resource limitations, security, collections availability, cultural sensitivity, intellectual
property rights, applicable restrictions, chain of custody issues or evidentiary concerns, ownership or legal
question, approved research requests, loan agreements, and preservation constraints.
Members of the public are allowed access to the collections only when resources and conditions allow, for
specific legitimate reasons, e.g., to conduct selected research or to participate in prearranged formal
educational activities.
Only authorized staff from the collecting department may provide access to that collecting department’s
collections. All others must obtain approval in advance from authorized staff in the relevant collecting
department.
FOIA. The Smithsonian and the NMNH are not subject to the Freedom of Information Act (FOIA), which
governs access by the public to federal agency records. The Smithsonian has a policy based on FOIA,
Smithsonian Directive 807: Requests for Smithsonian Institution Information, which governs requests for
Smithsonian Institution information. All requests citing FOIA or SD 807 must be referred to the Office of
General Counsel.
FEES. The NMNH collecting departments may charge organizations or individuals from commercial and noncommercial entities access fees for NMNH-owned intellectual property or materials such as images,
recordings, digital surrogates, data and collections items only if such fees are established in accordance with
the SD 600 Implementation Manual and SD 609. Such fees may be in addition to fees charged for reproduction,
transportation, security, and conservation. Access fee schedules must be approved by the Director.
The NMNH may charge a fee or royalty for granting permission to reproduce collections objects in books,
journals, catalogues, magazines, and similar scholarly, commercial, or general publications. All reproductions
must be fully credited to the NMNH unless an alternate written agreement exists. Contracts for reproduction
of any collections item must be approved by the Director or designee.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 26 of 35
PRIVATE PHOTOS. Visitors are permitted to photograph collections items on display in public galleries for
personal use only when the collections item belongs to the NMNH so long as a hand-held camera with
guarded flash is used and the photographer stays outside of the exhibition barriers.
SAMPLING. The NMNH allows destructive sampling and analysis of collections items and the consumption of
genetic resource samples in the intent and spirit of the Nagoya Protocol; in accordance with established
collecting department policies and procedures; and in compliance with any documented restrictions on use of
the items. The importance of test results must be weighed against the total loss of the collections item or
sample and its potential for replacement. Information gained from the analysis shall be provided to the
collecting departments and included in the museum’s records.
CREDIT. Researchers and users of the NMNH collections must acknowledge or credit the NMNH for providing
information or collections access per collecting department procedures.
H. Loans and Borrows
Loan and Borrow transactions are the temporary transfer of possession of collections items for an agreed
purpose and with the agreement that the collections item is returned at a specified time and in a specified
condition. These transactions do not result in a change of ownership. A Loan of the NMNH’s collections may also
be referred to as an outgoing “loan.” Incoming loans from external parties may also be referred to as a “borrow.”
PRINCIPLES
Lending and borrowing collections items for research, public exhibition, and education are integral to
achieving the NMNH’s mission. Loan transactions between Smithsonian collecting units are fundamental to
Institutional programs, as are collections transactions to and from other educational and scientific
organizations. The NMNH is collegial when using loan mechanisms to manage the exhibition of its own
collections.
The NMNH adheres to the Guidelines for Exhibiting Borrowed Objects issued by the American Alliance of
Museums (AAM).
The NMNH adheres to Smithsonian Directive 611: Export Compliance and Trade Sanctions Related to Research,
Export and Museum Activities.
POLICY
AUTHORITY. A collections item may be loaned or borrowed only in accordance with established authority
and only when consistent with applicable laws, treaties, regulations, mutually agreed terms (MAT), and
professional ethics. The NMNH applies the Smithsonian Institution Policy on Acquisition of Art, Antiquities,
Archaeological and Ethnographic Material, and Historic Objects, adopted by the Board of Regents in 2015, to
incoming loans.
PURPOSE. As a general rule, the NMNH collections are lent for research, public non-commercial exhibition, or
non-profit educational purposes.
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Loans of the NMNH’s collections are made to institutions or organizations, and with rare exceptions to private
individuals. Loans may be made to private individuals when it is consistent with the community of practice
within a scientific discipline and if it is in the interests of the NMNH to do so.
The NMNH only loans items if it has the rights to do so. The NMNH does not allow third party loans.
The NMNH does not act as an intermediary of objects owned by Board members for loans or other use by
other museums or institutions.
In accordance with the Smithsonian Strategic Plan’s priority of cross-unit collaboration, the NMNH will
facilitate to the extent possible expeditious loans to other Smithsonian collecting units, including the
Smithsonian Travelling Exhibition Service, as well as to Smithsonian Affiliate museums. It is understood that
all loan protocols will be observed, including donor restrictions, collection availability and physical condition,
and preservation / security requirements. Prior contractual or other agreements or in-house exhibition
schedules may preclude such loans from time to time.
GAIN. The NMNH collections may not be lent for private pecuniary gain or commercial purposes
HIGH RANKING GOVERNMENTAL REQUESTS. The NMNH may lend collections items to high-ranking
government officials according to procedures and guidelines established in the SD 600: Implementation
Manual. Such loans may only be approved by the collecting department with notification to the Director and
the Office of Government Relations. Any such loan requires a written loan agreement signed by the collecting
unit and an official authorized to commit to the terms of the loan agreement on behalf of the high-ranking
government official.

In the case of loans to the White House, the Curator of the White House is the authorized official. In the case of
loans to members of Congress, the Senate Curator is the authorized official for loans to Senators and the Clerk
of the House is the authorized official for loans to members of the House. In the case of loans to Justices of the
Supreme Court, the Curator of the Supreme Court is the authorized official. In cases where there are no staff
representing the borrower that are specifically responsible for collections related activities, the authorized
official is generally the high-ranking government official’s Chief of Staff.
SAMPLING OR TREATMENT. Loaned NMNH collections items may only be sampled or consumed through
destructive analysis or undergo conservation treatment with the prior written permission of the collecting
department that made the loan, and if not precluded by terms of use agreed at the time of acquisition.
Collections items borrowed by the NMNH may not be sampled or consumed through destructive analysis or
undergo conservation treatment without the prior written permission of the owner or applicable PIC, MAT or
MTA.
DOCUMENTATION. All loans and borrows must be documented by a written loan agreement or contract,
with documentation of all aspects of the loan agreement maintained in the museum’s collections transaction
management systems, both digital and analog. These agreements must be reviewed and approved by the
collecting department and, depending upon delegated authorities, by others within the chain of command as
specified within this policy. Significant departures from standard Smithsonian loan terms and conditions
must be reviewed by the Office of General Counsel. Exhibition agreements or contracts must be reviewed by
the Office of Contracting (OCon).
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 28 of 35
Each collecting department shall assess and record the condition of collections items selected for loan to
others, whether internal or external, through the loan agreement at the time the loan is established.
TERMS. All loan and borrow transactions are for a specified time period, with a specified party, with option
for renewal as appropriate. The NMNH does not permit indefinite or permanent loans.
Formal long-term repository or off-site enhancement programs may be established as long-term loans having
defined renewal dates and clearly specified terms for early conclusion of the agreement. These must be
reviewed and approved by the Registrar, the Office of General Counsel and National Collections Program.
ACCESS. Access to collections or terms of use of items borrowed by the NMNH, as well as to the NMNH
collections on loan to or in the custody of others, must be stipulated in the transaction agreement or
applicable PIC, MAT, MOA, MTA, or similar document.
FEES. With the approval of the Director, the NMNH may charge fees to borrowing organizations, and may
recover actual expenses for making outgoing loans. All such fees shall go into the funds of the lending
collecting department to cover the associated collections management and conservation costs.
RESPONSIBILITIES. Regardless of the length and type of outgoing loan, the NMNH retains fiduciary
responsibility for the continued oversight of its collections.
The NMNH acknowledges its responsibility to provide appropriate physical safeguards for borrowed
collections items in its custody, for the full term of the transaction agreement or applicable PIC, MAT or MTA.
Responsibility for routine monitoring and preservation of loaned collections items must be established at the
time the transaction agreement is initiated. Typically, the responsible party is the Department Curator
delegated with responsibility for the collection, or the curator initiating the incoming loan.
DENIALS. The NMNH may deny loan requests at its discretion and may recall loans prior to the agreed-upon
date in accordance with the loan agreement. The NMNH may also deny loans if:
 the item(s) is being actively used by a NMNH researcher for a research project that has not yet been
published;
 the item(s) is on or scheduled for exhibition; the requestor cannot provide proper facilities or fulfill
standard preservation requirements;
 the item(s) is of great scientific or cultural value, is unique, or of highly limited quantity;
 the item(s) is in such a condition that loaning it would place it at risk;
 the requestor has previously violated the terms of a loan, including handling, sampling and/or return
requirements;
 issues related to cultural sensitivity and/or repatriation mandate a restriction in access;
 in the judgment of the collecting department, the loan would compromise privacy, safety, or
intellectual property rights;
 the loan would impose on the NMNH inordinate costs and resources to satisfy the request; or
 loans are restricted or prohibited per the terms of an agreement (e.g. PIC, MAT, MTA) made at the
time of the acquisition of the collection item(s).
ABANDONMENT. The status of loans to the NMNH which have expired, but for which the lender cannot be
found, shall be resolved in accordance with the due process, reasonable search, notification procedures set
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 29 of 35
forth in the SD 600: Implementation Manual, and with the advice of the National Collections Program and the
Office of General Counsel.
EXHIBITION. The NMNH makes its collections available to the public through loan for exhibition in a number
of venues.
No collections item will be exhibited to its detriment deliberately, or exhibited in such a way as to risk human
health and safety or the integrity and stability of the collection item.
The collecting department establishes which collections items may be lent for exhibition, and in consultation
with the Registrar and Conservator, also establishes the legal and physical conditions under which an item
may be lent.
The NMNH will be appropriately credited in the exhibition and in all supporting publications.
Condition reporting requirements for exhibition of collections items are established by the collecting
department with the Registrar and the Conservator.
INSURANCE. Insurance settlements for NMNH collection items that are lost or destroyed when on loan will
be used only for future collections acquisitions within the collecting department that experienced the
collections loss.
FORENSIC ANALYSES. The NMNH receives incoming loans of items for forensic identification and analysis
from medical, investigative and enforcement agencies. Such transactions are authorized, documented and
managed according to Memoranda of Understanding (MOU) or other formal agreements with the referring
agency.
Items on loan to the NMNH for forensic purposes are subject to the requirements of the applicable MOU or
agreement, which supersede routine transaction policy and procedures. These may include stringent
requirements regarding access to the item and all associated information as well as specialized requirements
for storage, handling and conservation.
I. Intellectual Property Rights
Intellectual Property Rights are rights and protections based on federal or state statutes or common law such
as patent, trademark, copyright, privacy, and publicity, as well as the rights of attribution and integrity of living
artists as delineated in the Visual Artists Rights Act of 1990 and any subsequent revisions thereof.
PRINCIPLES
The NMNH is both a holder and a user of intellectual property and therefore seeks to protect the intellectual
integrity of collections and promote wide access to collections for scientific and educational purposes. In
support of its mission, the museum strives to protect the intellectual property rights of creators and
intellectual property owners, including the museum itself as rights holder, and promote the responsible
dissemination of knowledge.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 30 of 35
Intellectual property rights are distinct from the right to possess the collections item itself and arise from its
content. Holders of such rights may limit the uses that may be made of a collections item. The museum’s
ability to use its collections or their associated intellectual property may be subject to intellectual property
rights held by others. When acquiring a collection item, the Museum will determine what steps are required
to obtain any rights necessary for the intended use of the item. The Museum further will document
intellectual property restrictions in collections records and ensure that those records are consulted for
possible restrictions or prohibitions before using an object in a manner which may implicate intellectual
property rights, including reproducing a collection item for use by the museum and/or others in any media
format (print, electronic, audio, video, the Internet, etc.).
The NMNH recognizes that under some circumstances and for some types of collections the establishment of
intellectual property rights may be unclear at the time a collection item is accepted. It also recognizes that
ownership of intellectual property rights may change over time for some collections items and under some
circumstances. As a consequence, the NMNH will make a good faith effort to identify the holder of those
intellectual property rights associated with a collections item at the time that collections item is accepted by
the Museum and to document ownership in collection records.
POLICY
NMNH PROPERTY. Collections and documentation created as a result of research conducted by staff and
non-Smithsonian staff working at the NMNH or under the aegis of the NMNH is considered the NMNH’s
property and, subject to any written agreement to the contrary with a third party, the NMNH is considered
the owner of any associated intellectual property rights.
RIGHTS. The NMNH will not knowingly permit infringement of intellectual property rights. The NMNH will
make a good faith effort to protect the intellectual property rights of creators and intellectual property
owners, including the museum itself as rights holder.
If the NMNH permanently transfers a collection item to another institution, the NMNH will deal with the
disposition of any intellectual property rights owned by the Museum in the transfer agreement.
FAIR USE. Reproductions of collections for standard museum purposes by the NMNH may be allowed by the
doctrine of fair use in appropriate circumstances in making reproductions of collections for standard
museum purposes, such as archival, research, educational, exhibition, and similar purposes. Fair use
assessments will be made on a case-by-case basis by the collecting department Collections Advisory
Committee, taking into consideration the facts and circumstances of the proposed use and the legal
parameters of the fair use doctrine. The Office of General Counsel should be consulted if there is any question
regarding whether an intended use may be considered a fair use.
J. Shipping and Transportation
PRINCIPLES
The NMNH strives to ensure the safety and integrity of its collections and the collections that are being
transacted with the museum, while complying with all relevant state, federal and international laws and
regulations.
POLICY
COMPLIANCE. Staff shall comply with state, federal and international laws and regulations when
transporting collections. The NMNH adheres to Smithsonian Directive 611 regarding Export Compliance.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 31 of 35
RECORDS. Collecting department staff and the Registrar shall maintain permanent records of transportation
events in association with the transaction and/or collections items. Staff shall promptly file United States Fish
and Wildlife Services (USFWS) electronic declarations (3-177 declarations) when transacting relevant
collections across international borders. Copies of cleared declarations must be included in transaction
records.
TRAINING. Department Chairs, Collections Managers, the NMNH Shipping Office, and the Registrar ensure
that staff members are trained in acceptable procedures and use appropriate materials for packaging,
labeling, and transporting collections locally, regionally, nationally and internationally.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 32 of 35
Section III. Specific Legal and Ethical Issues
A. Native American and Native Hawaiian Human Remains and Objects
PRINCIPLES
Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of
cultural patrimony are subject to the terms of the National Museum of the American Indian (NMAI) Act, as
amended, 20 USC. § 80q. Under the NMAI Act, the Smithsonian is required to compile information about such
material, to disseminate the information to and consult with tribes about collections that may be subject to
repatriation, and, in certain circumstances, to return such material to affiliated Native American tribes, Native
Hawaiian groups, or lineal descendants.
The Smithsonian Repatriation Review Committee, established by the NMAI Act, serves as an advisory body to
the Secretary or designee on application of the NMAI Act. The applicable NMAI Act standards and guidelines
for compliance are set forth in the SD 600: Implementation Manual.
In addition to the applicable requirements of the NMAI Act, collecting departments with Native American and
Native Hawaiian collections should be aware of and sensitive to other issues that arise out of cultural
concerns of Native American tribes or Native Hawaiian groups. Such concerns may relate to appropriate
standards for the use and management of Native American or Native Hawaiian objects and interests in the
intellectual content associated with such objects.
Collecting departments are encouraged to consult with Native American tribes and Native Hawaiian groups
associated with objects in their collections and to take their interests into account in establishing policies for
the management of these collections, provided that such policies are consistent with applicable law and the
Smithsonian’s duties for the care and management of its collections.
POLICY
The NMNH collections include Native American or Native Hawaiian materials to which the requirements of
the NMAI Act are applicable. The NMNH repatriation of Native American and Native Hawaiian human remains
and objects is governed by the requirements set forth in the National Museum of the American Indian Act, 20
USC. § 80q (1989), as amended.
The NMNH administers the Repatriation Office, which is the authority for the NMNH under the NMAI Act and
acts as the liaison between the NMNH and any and all groups or individuals seeking discussion about or
repatriation of any Smithsonian materials. The Repatriation Office evaluates all repatriation requests covered
by the Act, assesses their validity and responds accordingly. Any repatriation request received by any NMNH
collecting department should be referred to the NMNH Repatriation Office for advice and guidance.
Final repatriation decisions are made by the Secretary or designee. All repatriation decisions are subject to
the general policies of the Board of Regents.
Any Native American or Native Hawaiian collections whose repatriation is not required by the NMAI Act shall
be managed in accordance with this policy, SD 600, and the SD Implementation Manual. Decisions to return or
repatriate collections items outside the scope of the NMAI Act will be evaluated and processed in accordance
with routine and established deaccession and disposal policies and criteria.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 33 of 35
B. Collections Made via Fieldwork
PRINCIPLES
The Smithsonian has long been a leader in the effort to halt the continuing degradation of the world’s natural
history and environmental resources. Smithsonian research and collecting activities must be undertaken with
sensitivity to continued protection of cultural and biological diversity and in compliance with applicable laws
protecting animal and plant species.
Field collecting should be preceded by disclosure and consultation and under all appropriate permits. Field
activities must be conducted lawfully, support educational and scientific purposes, and not cause undue
detriment to the diversity and ecological conditions in the area of the activity other than in instances of
salvage collecting in areas which will be destroyed by development projects or other endeavors sanctioned
by the authorities of the country in question.
POLICY
Items may be acquired by or on behalf of the NMNH through field collecting only when such collecting is
legally authorized; the item is obtained solely for purposes of scientific research, or for other educational
purposes; and the Smithsonian’s field activities will not cause undue detriment to the diversity and ecological
conditions in the area of the activity.
The NMNH name may not be used to justify or support permit applications for activities that have not been
authorized by or on behalf of the NMNH.
The NMNH complies with Smithsonian Directive 611 regarding Export Compliance.
C. Unlawful Appropriation of Objects during the Nazi Era
PRINCIPLES
Between 1933 and 1945, the Nazi Regime caused the unlawful appropriation of millions of art objects and
other cultural property from their rightful owners, including private citizens; victims of the Holocaust; public
and private museums and galleries; and religious, educational, and other institutions. Some of these objects
ultimately were transferred, in good faith and without knowledge of their prior unlawful appropriation,
through the legitimate market and may have been acquired by museums. In recent years, public awareness of
the extent and significance of Nazi looting of cultural property has grown significantly.
The Smithsonian adheres to the Guidelines Concerning the Unlawful Appropriation of Objects During the Nazi
Era, issued by the American Alliance of Museums (AAM), and, where applicable, the Report of the Association
of Art Museum (AAMD) Directors Task Force on the Spoliation of Art during the Nazi/World War II Era. The text
of these documents is included in the SD 600: Implementation Manual.
POLICY
The NMNH shall not knowingly acquire collections items that were unlawfully appropriated during the Nazi
era without subsequent restitution.
If the NMNH has acquired in good faith a collections item that is subsequently determined to have been
unlawfully appropriated during the Nazi era without restitution, the NMNH will take prudent and necessary
steps to resolve the status of the collections item.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 34 of 35
Each collecting department shall apply the applicable provisions of the AAM and AAMD guidelines to its
collections management activities.
D. Animal Welfare and Institutional Animal Care and Use Committee
PRINCIPLES
The Federal Animal Welfare Act (AWA) and the Public Health Service (PHS) Policy set standards for the
responsible and humane treatment of animals captured alive in the field as well as those maintained in
captivity. This includes standards for capture, restraint, handling, marking, captive care, and euthanasia.
Demonstration of compliance with AWA provisions is increasingly required by societies and peer-reviewed
research journals.
The NMNH complies with the AWA in all collecting departments in which living animals are essential subjects
of research, both in the field and in captivity. It will establish and maintain an Institutional Animal Care and
Use Committee (IACUC) to review and advice on these issues, as required by Federal regulations.
POLICY
The NMNH staff will comply with Smithsonian Directive 605, Animal Care and Use. The NMNH will not support
or condone the use of any procedures that have been identified by the AWA and scientific discipline groups as
being inhumane in the capture, restraint, handling, marking, captive care, or euthanasia of living animals.
The NMNH will only maintain living animals for research or approved educational purposes in fully
acceptable captive care conditions, as determined by the IACUC and scientific discipline standards.
The NMNH will not knowingly accept specimens of animals collected for research purposes in violation of the
humane requirements of the AWA.
E. Human Subjects in Research and the Institutional Review Board
PRINCIPLES
The NMNH research involving human subjects compiles with all applicable federal, state or local laws,
regulations, and ethical principles, so that the rights and welfare of human subjects involved in research are
protected.
POLICY
The NMNH complies with Smithsonian Directive 606: Research Involving Human Subjects regarding research
involving human subjects, and all applicable legal and ethical requirements for responsible reliance on human
subjects in any form of research undertaken by the NMNH. It will establish and maintain an Institutional
Review Board (IRB) to review and advice on these issues, as required by Federal regulation. Any research
that uses humans, surveys of human subjects, or human subjects’ records requires IRB review and approval.
NMNH will not support or condone the use of any procedures that have been identified by the National
Institutes of Health, the National Science Foundation, and scientific discipline groups as being unacceptable in
relation to human subjects of research.
NMNH COLLECTIONS MANAGEMENT POLICY (REV. 12/13/2017) Page 35 of 35
The NMNH will not knowingly accept collections items or information derived from research conducted in
violation of laws relating to the use of human subjects.
F. Collections Posing Health and Safety Risks
PRINCIPLES
The NMNH owns and has custody of collection items that may pose some risk to health and safety, either due
to hazards that are their inherent original composition or fabrication, acquired over time through exposure to
hazardous materials in their environment, or acquired over time as a result of alterations from ageing or
treatment. The NMNH will promote awareness of the potential hazards and of established protective work
practices to those at risk. People at potential risk, who need to receive occupational hazard awareness
information, include Smithsonian employees, docents, interns, volunteers, visiting researchers, and
contractors who are in contact with these collections. In addition, people to whom the NMNH loans or
disposes objects with hazardous materials will also be notified. The visiting public will be protected from
adverse health or safety risk from objects on display or made available for research, tours or educational
programs. The NMNH protects the environment from undue contamination through proper disposal of waste
materials generated during curation, treatment, and management of NMNH collections.
POLICY
COMPLIANCE. The NMNH shall comply with the Smithsonian Hazard Communication Program (see SD 419),
Smithsonian authorities, and all applicable laws in the handling, storage, shipping, transport, fumigation, and
transacting of such items, and in the event of their disposal.
IDENTIFICATION OF HAZARDS. Collecting departments must make reasonable attempts to determine the
presence of hazardous materials within collections. Once a hazard is identified, employee health risk must be
determined through occupational exposure surveys conducted by the Office of Safety, Health, and
Environmental Management (OSHEM) and the results must be communicated to affected staff and users.
PROCEDURES AND METHODS. Written Safe Work Practices and storage procedures must be developed by
the Conservator, the collections management staff, and the relevant curators for the particular needs of the
collecting department or program. Storage methods must be appropriate to the risk.
COMMUNICATION. All staff and users or persons who come into contact with hazardous items will be
informed of any known risks, and must be provided with appropriate procedures, materials, and equipment
for mitigating the risks of working with those collections. Hazard notification, to the extent applicable, is
incorporated into transaction and repatriation documents. Communication of hazards must take the form of
written fact sheets, incorporation of collections-based hazards into the basic NMNH Hazard Communication
Training program, and/or information labels or signs on collections labels, storage cases, storage rows, or
entry doors to storage, or text in transaction documents.
SHIPPING. The NMNH Shipping Office or other properly trained staff is responsible for ensuring that
hazardous materials shipped on behalf of the NMNH are packed, shipped and transported as required by
applicable laws and international treaties. Incoming loan and accession agreements should also include a
description, from the sender, of any known or suspected hazardous material. Such documentation is to be in
accordance with applicable law or international treaties. The Shipping Office will establish written guidance
on the shipping and transport of hazardous/dangerous goods.

CONTRACT POSITION: Cataloging Technician

and implementation and fielded product management.

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