Collections Management Policies and Procedures

Access Policy

• Physical access to the CAS facility is restricted through use of key-controlled entry.
• Access to CAS collections is monitored by the director and CAS staff.
• Physical access to all CAS collections is restricted to the CAS Archaeological Curation Facility staff and the directors. 
• Physical access to the collections by other individuals must be granted by the curator or director and supervised by the director or collections management staff.
• Research access by CAS staff and non-CAS individuals (i.e. visiting scholars/researchers) is dependent upon the research design and is granted by the curator or director.
• CAS Collections are available to individuals with research interests and access can be granted for the purpose of research and study conforming to the standards of the scholarly disciplines it represents. CAS also provides access to scholars and members of groups whose traditional culture is represented by the collections we care for.
• All access requests, including those for archaeological records, are submitted through the Access to CAS Collections Request Form. The following supplemental information will be required once the request has been processed:
  • Student researchers are required to provide a letter of support from a faculty member from their home institution who is familiar with their research.
  • Unaffiliated researchers should provide a brief CV with their statement of research objectives.
  • Requests for scientific analysis require a project proposal outlining the purpose need, expected results of analyses, and a description of analytical methods planned, and a current CV. CAS adheres to the CTA and THC’s policies for any destructive analysis.
  • Requests for access to human skeletal remains or collections covered by NAGPRA require the interested party to provide evidence of tribal consultation, a project proposal outlining the purpose need, expected results of analyses, description of analytical methods planned, and a current CV.
• Requests to publish photographs from CAS’s collection, or for original photography can be granted under certain conditions. Please see our Media Permissions, Policies and Fees document.
• For requests to borrow material, please see CAS’s loan policies and procedures.
• Requests to visit the CAS Archaeological Curation Facility can be arranged by emailing us at cas@txstate.edu or calling us at 512.245.2724

NAGPRA & Request for Access to Human Remains

CAS is committed to the repatriation of human remains, associated artifacts and other cultural property deemed important by descendant communities. CAS’s Archaeological Curation Facility houses human remains and cultural materials in compliance with Public Law 101-601, the Native American Graves Protection and Repatriation Act (NAGPRA). CAS will make every effort to notify affiliated Native American tribes and comply with the request of the appropriate Native American tribes as to the disposition of the material, providing the request is in accordance to Public Law 101-601. Please contact the Director of CAS Dr. Todd Ahlman with questions regarding NAGPRA materials housed at CAS. The Notices of Inventory Completion for CAS can be found on the National Park Service website.

CAS’s Access policy for all skeletal material determined to have a likely cultural, geographic, or biological affiliation to Native Americans requires that any researchers interested in examining such material consult with the appropriate tribes before accessing the material. Any necessary consultations about sensitive materials (human remains, associated funerary objects, sacred objects, or objects of cultural patrimony) must be conducted before examination of material. Written evidence of this consultation, including copies of all correspondence, along with the names of the cultural consultants, tribal leaders, and observers involved, must be submitted with the request for access form.

Procedures Concerning Security, and the Handling of Collections

• If approved by the curator or director, access is monitored by the collections management staff. 
• The material requested is removed from the collections storage location and brought to the work area by collections management staff. 
• Research is carried out in an area separate from the collections storage area.  If research is carried out in collections storage areas, researchers are supervised at all times. 
• The collections may not be removed from the CAS facilities, unless authorized by an outgoing loan agreement (more info here).
• When research is completed for the day, the collections management staff checks that all material is present, packaged correctly, and returns it to the housing location. 
• Visiting scholars/researchers handling materials must sign in and out and document which materials they were working with.

CAS will serve as a repository for archaeological records and collections generated from in-house projects as well as non-CAS collections, including state associated Held-in-Trust collections as well as federal collections requiring a repository that meets the standards set forth in title 36, chapter I, part 79 of the Code of Federal Regulations (36CFR79). CAS is especially interested in collections from projects in and around the State of Texas that are consistent with the regional and thematic areas already exemplified by our collections, such as the history and prehistory of Central Texas.

• CAS primarily accepts state associated Held-in-Trust (HIT) materials and records. For the purposes of CAS’s acquisition policy, a collection is considered HIT if all of the following are true:
  • It is generated under a Texas Antiquities Permit issued by the Texas Historical Commission (THC).
  • It is from land belonging to the State, a county, a city, or a political subdivision of the State at the time of collection.
  • The collection contains objects and/or records.
  • An “Agreement for State of Texas HIT Objects/Collections” has been signed and fully executed. With this document, the stewardship of a collection, but not the ownership, is officially transferred to a certified curatorial facility (CAS), to be HIT for the State and People of Texas.
  • CAS will also accept federal collections and non-HIT collections on a restricted individual basis, based on the project’s regional and thematic relevance and the ability of CAS to care for the collection.
• Only collections that possess clear title or HIT status will be accepted.  CAS acquisition of state associated HIT collections is granted by the THC, who transfers stewardship but not title of the collection to CAS. 
• Restrictive or conditional acquisitions are discouraged. 
• Acquisitions must be approved by CAS’s acquisitions committee.
• Acquisition is a necessary prerequisite for accessioning.
• Acquisitions are documented with a Deed of Gift or Letter of Transfer/Ownership.
• An annual report of acquisitions activities is made to the THC regarding all state HIT collections.

• The transfer of non-state HIT collections by gift/donation from a donor to CAS is documented with a Letter of Transfer/Ownership, Deed of Gift, or Governmental Agency Curation Agreement, which is signed by the donor and a CAS official and documents the objects/collections/documents and copyright restrictions or conveyance for which the title is being transferred.  A Deed of Gift is executed between CAS and an individual, while a Letter of Transfer/Ownership documents the exchange between CAS and an agency/institution.  The Government Agency Curation Agreement more specifically documents the exchange between CAS and a governmental agency.
• HIT Agreements and Artifact Curation Forms are written, signed and executed between CAS and the THC to document the transfer of stewardship of state HIT objects/collections/documents.
• The transfer of stewardship of state HIT collections from CAS to another curatorial facility is documented with a Letter of Transfer/Deaccession, which states the agency/institution and objects/collections/documents which are being transferred and is signed by both curatorial facilities and a THC official.

• CAS uses an accessioning system that allows for objects and records to be matched to the Transfer Inventory/Accession Record and number, to be located physically, to be associated with other objects in the accession, and be cross-referenced.
• The accessioning of non-HIT collections into the holdings of CAS is accompanied by a Deed of Gift, Letter of Transfer/Ownership, or Governmental Agency Curation Agreement.
• The accessioning of HIT collections into the holdings of CAS is accompanied by:

1. A deed of Gift, Letter of Transfer/Ownership, or Governmental Agency Curation Agreement and
2. A signed HIT Agreement and Artifact Curation Form.

• An accessions inventory is made at the time of accessioning through the completion of the Transfer Inventory/Accession Record form.
• An annual report of accessioning activities is provided to the THC regarding all state HIT collections.

• Deaccessions are evaluated in terms of redundancy and lack of additional merit.  CAS will consider deaccessioning items or collections for the following reasons:
  1. They do not fall within CAS’s regional or thematic interests.
  2. They do not contribute additional historical or scientific value.
  3. Another repository requests the collection because it better fits with their research interests or is associated with or related to another collection which they hold.
  4. Legal title is questionable, or there are ethical concerns.
  5. They are subject to deaccessioning as required by federal law.
  6. They are lost, stolen or damaged beyond reasonable use/repair.
  7. Federal regulations, such as NAGPRA, provide for the transfer of certain materials from CAS’s collections to another entity. Permission from the THC is necessary for HIT collections.
• Disposal methods:
  1. CAS employs landfill disposal of HIT and non-HITobjects/collections.
  2. CAS will seek THC approval before disposing of any HIT objects/collections.
  3. CAS does not employ the method of sale for non-HIT or HIT collections.
• Reporting
  1. The transfer of any CAS collection to another repository is documented with a Letter of Transfer/Deaccession form.
  2. All deaccessioning activities of state HIT items are reported to the THC in an annual report.

• CAS employs a cataloging system to record the physical attributes of the artifacts and make the objects more easily identifiable and accessible. 
• CAS has predominately utilized a provenience-based cataloging system.  This system is designed to identify objects and their provenience.  The catalog number series is applied to the object and is listed on the artifact inventory.
• All artifacts are cataloged before their permanent housing or a loan is allowed.

CAS accepts incoming and outgoing loans in order to further our mission of research, public education and outreach.  The following are requirements for loans of non-state and state HIT collections:

1. Only the director of CAS has the authority to accept or grant a loan.
2. Loans may be granted for the purpose of research, education, exhibition, conservation and/or inspection.
3. Outgoing loan requests will be granted only to institutions affiliated with a research or public education, while incoming loans may be accepted from institution or individuals.
4. Loans are not to be used for commercial purposes.
5. Collections that are not accessioned/cataloged are not loaned
6. The director will make the final decision regarding the loan period.  Loans will be granted temporarily for a negotiated specific amount of time.  Loan renewals are granted at the discretion of the director.  Materials on extended loan may be recalled by the director.
7. Costs associated with the transfer of the loaned material are to be paid by the borrowing institution.
8. Loaned materials must be covered under the borrowing institutions insurance.
9. A loan agreement documents the loan number and inventory, purpose of loan, start and due date, method of shipment, insurance value of loan, any special conditions of the loan, and the approval signatures of the CAS director and borrowing agent.
10. A borrower requesting a destructive loan, which entails destroying all or a portion of an object or sample to gain specialized information, must supply a proposal, which details the researcher’s goals, methodologies and a project budget.
11. Decisions regarding the destructive analysis of state HIT collections are the legal responsibility of the THC.  Authority to approve destructive analysis requests is delegated to CAS through an agreement between CAS and the THC.
12. Two copies of any publication resulting from the research, as well as any information or data gained from destructive analysis, is provided to CAS.
13. Unused portions of objects/samples are returned to CAS.
14. For state associated items, the state does not relinquish title of the object, nor is the item deaccessioned.  Information gained from the destructive analysis substitutes for the altered/destroyed object/sample.
15. An annual report of loan activities of state HIT collections will be made by CAS to the THC.

• CAS maintains project specific and general collection inventories in order to document the contents and locations of non-HIT and HIT collections.
• An accessions inventory is created with the completion of the Transfer Inventory/Accession Record form during the accession process.
• Artifact inventories are compiled for each project and include the catalog number series, artifact class and description, artifact count, depth, collection date, and excavator.
• A general collections inventory is maintained of all CAS collections and their current status (ongoing, complete, etc.).
• Periodic spot-check inventories are conducted as well as relocation inventories during any relocation activity.
• A separate inventory is maintained for state HIT collections, and an annual report of inventory activities is provided to the THC.

As an entity of Texas State University, CAS is self-insured.  Therefore, CAS has applied for a waiver from the CFCP insurance requirement.

• CAS does not provide appraisals to the general public or prospective donors.
• Prospective donors requiring an appraisal must do so independently and at their own expense.

• CAS maintains the following records for state HIT collections:

1. 1. HIT Agreement & Artifact Curation Form
2. 2. A curation agreement - Deed of Gift, Letter of Transfer/Ownership, or Governmental Agency Curation Agreement
3. 3. Accession record - Transfer Inventory/Accession Record
4. 4. Deaccession record (as necessary) – Letter of Transfer/Deacession
5. 5. Condition report (as necessary)
6. 6. Catalog record – Artifact Catalog
7. 7. Loan agreement (as necessary)
8. 8. Relocation inventory (as necessary)
9. 9. Spot-check inventory
10. 10. Conservation report
11. 11. Infestation report
12. 12. A list of state HIT collections housed at CAS

• CAS provides the THC with an annual report regarding accessioning, deaccessioning and disposals, site inventories, inventory and security issues, incoming and outgoing loans and destructive loans, and conservation actions.
• All CAS paper records are printed on acid-free archival paper, and electronic versions are maintained when possible.
• Records are placed in acid-free archival file folders and stored in metal file cabinets.
• Records are organized as to be easily managed and retrievable.
• Records are stored in a secure location (the curator’s office area) and are maintained and monitored by the curator.
• Duplicates of all the records associated with HIT collections, as well as the CAS Collections Master Inventory and the HIT Collections Inventory, are maintained at a secure off-site location.

• A.  A primary goal of CAS is to promote the long-term curation and preservation of its collections.
• B.  State HIT collections require regulated and monitored temperature, relative humidity, and atmospheric pollutants, as well as low and/or filtered light levels.
• C.  The stability of CAS non-state and state HIT collections is maintained through the following measures:

1. The utilization of archival quality material for all laboratory procedures, including the cleaning, stabilizing, restoring, and labeling of artifacts
2. Artifact storage in acid-free archival bags or other packaging material, which provide a buffer between the artifacts and the environment
3. Housing on archival shelving units, which provide a buffer between the artifacts and the environment
4. Safety measures which insure the safe handling and transport of objects/collections
5. Preventive conservation strategies and routine maintenance
6. Regulated environmental controls accompanied by staff monitoring.

If a state HIT object/document/collection requires further conservation treatment to insure its preservation, CAS requires the following:

1. THC approval of the conservation treatments must be obtained prior to their commencement.
2. Conservation techniques are carried out by trained conservators.
3. Conservation materials and treatments are reversible in nature.
4. Conservation treatments are documented before, during, and after their execution.
5. An annual report is supplied to the THC regarding any conservation treatments applied to state HIT collections.

The following measures are taken to insure the best possible care of non-state and state HIT collections in disaster situations:

1. The prevention of disasters is strived for through preventive maintenance and routine building and system inspections.
2. A written plan of emergency preparedness, based on knowledge of local risks and hazards, is tested and evaluated annually.
3. The emergency preparedness plan includes measures to be taken before, during, and after a disaster.

CAS strives to maintain the exclusion of pests from the facility through the following measures:

1. Monitoring and detection
2. Identification and isolation
3. Habitat modification
4. Appropriate pest eradication/suppression treatment using non-or least-toxic solutions
5. Evaluation of success of pest management treatment
6. Continued education of staff on pest control

CAS maintains the security of non-state and state HIT collections through use of alarms, cameras and key-controlled/restricted access to the facility.