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South Africa: The Making of U.S. Policy, 1962-1989

Acknowledgments|Essay

Introduction

The Scope and Sources of the Document Set

The South African document collection provides a contemporary record of changing U.S. responses to historical events in South Africa from 1962 to 1989. Coveted for its resources, supported as an ally, empowered by its nuclear capability and hated for its policy of apartheid, South Africa remains a country of extremes. Reactive in nature, U.S. policies toward South Africa reflect a desire to reconcile conflicting interests in South Africa and the region.

The collection provides primary source documents dealing with most aspects of U.S. policy toward South Africa from 1962 to 1989.

The document collection highlights the fact that U.S. policy toward South Africa has sailed an improvised, often erratic course between U.S. economic, scientific and strategic interests and South Africa's repressive racial policies, with occassional concessions to black African leaders as the pressure mounted, while avoiding an irreparable break with the white regime.

Most frequently, U.S. policies toward South Africa have been reactive, not proactive. Following the Sharpeville Massacre of March 21, 1960, the United States asserted, for the first time to the U.N. General Assembly, its "abhorrence" of South Africa's apartheid policies. Soon thereafter, President Kennedy instructed U.S. Ambassador to the United Nations Adlai Stevenson to vote in favor of an arms embargo against Pretoria. The United States subsequently authorized the sale of helicopters, air-to-air missiles, torpedoes, sidewinder missile and other military equipment to South Africa, however, justifying the sales as necessary for the "maintenance of peace and international security and the common defense effort in the interest of the world community."

South Africa: The Making of U.S. Policy, 1962-1989 addresses the following central aspects of U.S. policy toward South Africa: Arms Embargoes, Nuclear Collaboration, Economic Sanctions and Regional Conflict. The making of U.S. South African policy appears as a series of responses to South Africa's changing domestic situation and to its relations within the region. The following pages address four broad policy areas, identifying issues central to U.S.-South African relations and charting their coverage in the document collection.

Arms Embargoes

In the 1960s, U.S. criticism of South Africa's policies of apartheid was coupled with full or partial restrictions on arms sales to Pretoria. Prior to the imposition of economic sanctions in the mid-1980s, the United States relied mainly on arms embargoes to pressure the South African government to change its domestic policies, although the potential impact was sometimes undercut.On August 2, 1963, for example, the United States voted in favor of U.N Resolution 181, imposing an arms embargo against South Africa. However, in a statement announcing the U.S. vote, Ambassador Adlai Stevenson insisted on making two exceptions to a total embargo. Sales of arms to South Africa could be restricted, he argued, except: a) those sold under "existing contracts which provide for limited quantities of strategic equipment for defense against external threats, such as air-to-air missiles and torpedoes for submarines"; and b) "if the interest of the world community required the provision of equipment for use in the common defense effort."

A gradual relaxation of restrictions on arms sales to South Africa was, in large part, reversed in the early 1970s, under President Nixon. In 1977, the United States again joined the international community in condemning apartheid following the June 16, 1976, student unrest and supported U.N. Resolution 418 adopting mandatory arms embargo against South Africa. In the wake of international censure of South Africa following the 1977 death in prison of Black Consciousness leader Steve Biko, the United States introduced regulations barring the export of all commodities or technology to the South African military and police.

However, the full force of the arms embargo was blunted by the fact that, the United States had failed to adopt procedures to effectively implement the restrictions. Documents included in this collection indicate that, since the first imposition of an arms embargo in 1963, the United States continued to authorize the sale of aircraft, including Lockheed L-100s, Cessna 185s and "gray area" goods--such as computers and aircraft engines--to South Africa. In addition, U.S. firms exploited loopholes in the embargo and continued to sell arms and military equipment to South Africa through wholly- or partially-owned subsidiaries of U.S. firms in third countries, illegal direct corporate sales of "military hardware and technology by U.S. arms firms, the sale of "dual use" equipment--transport planes, helicopters, communications systems and computers. Similarly, sales of embargoed items were made through South Africa licensees. In addition, firms in France, West Germany, Belgium, United Kingdom, Switzerland and Italy have on occasion been more than willing to fill the gap created by the embargo.

Nuclear Collaboration

The U.S.-South African Agreement of Cooperation concerning the Civil Uses of Atomic Energy of 1957 defines nuclear collaboration between the two countries. According to the Atomic Energy Act of 1954, which authorized a broad program of international cooperation in peaceful nuclear application, special nuclear materials and reactors could be exported by the United States to South Africa. The 1957 agreement allowed South Africa to purchase a U.S.-designed research reactor--SAFARI-I--and the highly-enriched uranium needed to run it. The SAFARI-I reactor became the principal training instrument for South African nuclear scientists and technicians.

Suspicions that South Africa possessed a nuclear bomb were raised in the summer of 1977, following the alleged detection by Soviet satellites of a nuclear test facility in the Kalahari Desert. After information about the detection was relayed to the U.S. government on August 6, 1977, President Carter ordered an independent investigation of the incident. The U.S. review subsequently confirmed the Soviet findings. As documents in this collection demonstrate, the Carter Administration unequivocally warned South Africa against using the facility, and the South African government apparently agreed, Although the Vorster Administration did not offer an explanation on the nature of facility.

Questions about South Africa's nuclear capability were again raised when, on September 22, 1979, the U.S. Vela satellite detected a double flash in the South Atlantic, indicating the possibility of a nuclear blast. Again, President Carter convened a panel of scientific experts to conduct a thorough technical review of all available data. The panel concluded that, although it cannot rule out the possibility that the signal was of nuclear origin, the panel considered the it more likely to be a consequence of the impact of a small meteroid on the satellite. Other U.S. government agencies investigating the event--including the Defense Intelligence Agency (DIA), the Central Intelligence Agency (CIA) and the Naval Research Laboratory--concluded that a nuclear blast had occurred.

The United States represents South Africa's most important foreign source of nuclear expertise. Documented in this collection is the extensive transfer of technical personnel initiated by the 1957 cooperation agreement between the United States and South Africa.U.S. technicians and scientists have visited South African nuclear facilities to provide technical assistance and training and South Africans have, in turn, come to the United States to receive training and practical experience. In addition, U.S. companies have, with the approval of the U.S. government in the form of export licenses, sold special nuclear materials and technology to South Africa.

Despite South Africa's reliance on nuclear collaboration with the United States, Pretoria has steadfastly refused to sign the Nuclear Non-Proliferation Treaty. It has, as well, suggested indirectly that it could easily acquire nuclear capability and that it might use it. In 1977, the U.N. Security Council adopted Resolution 418, calling for a mandatory arms embargo against South Africa. Cable traffic between the U.S. Mission to the United Nations and the State Department, included in this collection, suggests that this Resolution, had it been approved, would have prohibited all nuclear cooperation with South Africa.The United States vetoed the Resolution, arguing that "the international action at this stage should concentrate on efforts to win South African adherence to the Non-Proliferation Treaty and immediate agreement to place its facilities under international safeguards."

That nuclear cooperation was a focal point of U.S.-South African relations during the Reagan Administration is reflected in briefing papers prepared for a May 1981 meeting between Secretary of State Alexander Haig and South African Foreign Minister Pik Botha and included in this collection. Perhaps as a result of that meeting, the Reagan Administration increased nuclear-related assistance to Pretoria by approving exports of nuclear material, computers and high technology items to South Africa. The Administration also re-negotiated with Pretoria for the resumption of uranium imports, prohibited when Congress passed the Nuclear Non-Proliferation Act in 1978.

Economic Sanctions

U.S. policy toward South Africa since 1962 has been shaped largely by strategic and economic concerns, including the preservation of access to South Africa's immense mineral resources and the protection of markets and investments. For three decades, U.S. administrations have consistently resisted calls from within and outside South Africa for economic sanctions and have argued for the importance of trade and investments as a means of encouraging change in South Africa's policy of apartheid. In the mid 1970s, mounting international pressure for U.S. to consider economic sanctions against South Africa was rejected. The Carter administration vetoed U.N. resolutions urging reduction of economic ties with South Africa. Responding to critics of U.S. policy in South Africa, President Carter emphasized the positive side of economic relations and enlightened free enterprise as a positive force for change in South Africa.

Throughout his tenure, President Reagan studiously avoided criticizing the South African government, repeatedly praising the Botha Administration for making substantial reforms despite the overwhelming evidence of the continued and extensive exploitation and oppression of the black majority in South Africa. He has directly and openly embraced the Botha Administration as "an ally and friend," demonstrating what critics saw as a callous indifference to world-wide demands for human rights and basic freedoms for the blacks.

In the mid-1980s, public concern about the Reagan Administration's policy toward South Africa was rapidly translated into political action by a broad-based anti-apartheid movement across the United States.The movement was marked by protest demonstrations in major cities and on college campuses and by a call for tougher U.S. policies toward Pretoria. This campaign included boycotts of banks that made loans to South Africa, the sale of stock in U.S. firms operating in South Africa and the withdrawal of U.S. firms with subsidiaries there. In response to both these pressures and to a declaration by the Botha Administration of a country-wide state of emergency in July 1985, Congress, led by the Congresional Black Caucus, introduced legislation calling for economic sanctions. The House passed a sanctions bill in May 1985, followed soon after by the Senate. The sanctions bills provided for broad restrictions on trade with South Africa and the complete disinvestment of U.S. companies. However, both bills were pre-empted by the introduction of a series of limited economic sanctions in a Presidential Executive Order issued on September 9, 1985. In a statement accompanying the order, President Reagan explained that he opposed economic sanctions and was issuing the order only to forestall Congress from adopting even harsher measures.

The Reagan Administration began a concerted effort to ensure that any sanctions that were implemented would be coupled with new and more aggressive efforts to maintain close relations with the South African government. Fundamental to these efforts was the coordination of a public diplomacy campaign, initiated by National Security Decision Directive 187 (NSDD 187), which outlined the Administration's new course of action to maintain a positive image for its policy of "constructive engagement" and for the South African government itself. Approved by the National Security Council in 1985, the public diplomacy strategy calls for the undertaking of a program to gain better public understanding and support of U.S. policy toward South Africa (NSDD 187 and related documents are contained in this collection.

Exactly one year later, Congress passed the Comprehensive Anti-Apartheid Act of 1986 over President Reagan's veto. The Act prohibited U.S. trade and other economic relations with South Africa. It anticipated the need for sanctions by other countries and specifically directed the president to seek the cooperation of industrialized democracies as well as South Africa's other trading partners. But because of its opposition to sanctions, the Reagan Administration did little to gain cooperation from other countries and refused to support mandatory international sanctions against South Africa in the United Nations.

Regional Conflict

In addition to vested economic interests, U.S. policies toward southern Africa contained a major East-West component. South Africa has consistently been viewed by U.S. administrations as a lone ally in a region vulnerable to Soviet influence. As a result, U.S. support for the status quo in southern Africa did not change significantly in the 1960s and continued unabated until after the Coup in Portugal in April 1974.

Guided by Secretary of State Henry Kissinger, the Nixon Administration adopted a moderate policy of establishing broader ties with both the white and black-ruled states and replacing political and economic restrictions on the white states. In 1969, Kissinger ordered a study, National Security Study Memorandum (NSSM) 39, of southern Africa to identify the range of policy options available to the Nixon Administration. NSSM 39 proposed five options for future U.S. policy in the region, ranging from closer association with the white regimes to lessening ties with the white states and strengthening those with black states to a complete withdrawal from southern Africa. The United Nations provided a forum for the Nixon Administration's non-confrontational, "quiet" policy toward South Africa. In 1972, the U.N. General Assembly voted on eight resolutions on southern Africa; the United States voted against seven and abstained from voting on one of the resolutions.

The 1974 coup in Portugal dismantled colonial rule in Angola and Mozambique, facilitating the rise of nationalist movements to power in both countries. Rather than accommodate these movements, Secretary of State Kissinger, fearful of the Soviet threat in the region, initiated a policy of covert intervention in Angola's civil war of 1975-1976. "John Stockwell, who headed the CIA intervention from the end of July 1975, later noted that each major escalation was initiated by the United States and its allies." In 1976, Congress expressed its opposition to the covert activities by passing the Clark Amendment, which prohibited all covert aid to any of the factions in Angola. The intervention was not successful in stemming Soviet involvement; it led instead, to increased Soviet aid to the MPLA government in Angola and, in response to MPLA's plea for help in countering external intervention, to the arrival of thousands of Cuban troops.

In 1976, Kissinger embarked on a new initiative for southern Africa. This collection provides a detailed account of Kissinger's project, including meetings with South Africa Prime Minister Vorster, Rhodesian Prime Minister Ian Smith, Zambian President Kaunda, Tanzanian President Nyerere and Botswana President Seretse Khama.

The Carter Administration's policies toward southern Africa and the language in which they were framed were more confrontational than his predecessor's. Vice President Mondale's May 1977 meeting with Prime Minister Vorster signalled the shift.In contrast to Kissinger's approach, which emphasized majority rule in Rhodesia, the Carter Administration sought to focus directly on South Africa, Namibia and Rhodesia. Following his meetings with Vorster, the vice president told a press conference that "the policy which the President wished me to convey was that there was need for progress on all three issues: majority rule for Rhodesia and Namibia and progressive transformation of South African society to the same end. However, as this collection demonstrates, despite its strong criticisms of the South African government, the Carter Administration broke none of the traditions of U.S. policy in southern Africa. Like its predecessor, the Carter Administration refused to recognize the government of Angola and sought congressional support for UNITA with the aim of complicating the Cuban position in Angola. In addition, it actively discouraged revolutionary change in South Africa and advocated moderate reforms.

Early in 1981, the newly-elected Reagan Administration introduced its policy of "constructive engagement." As outlined by its chief architect, Assistant Secretary of State for African Affairs Chester Crocker, this policy comprised two ideas: first, that change in South Africa had to be controlled and second, that the region had to be made "stable" before initiating controlled change. Documents in this collection point to the ways in which "constructive engagement" formed part of a larger strategy designed to weaken the links between revolutionary regimes and the Soviet Union. In southern Africa, the Reagan Administration immediately embraced Angolan rebel leader Jonas Savimbi and his organization, UNITA, as "freedom fighters," and urged Congress to repeal the Clark Amendment. By mid-1986, the United States had provided UNITA with $15 million in aid, including Stinger anti-aircraft missiles, and by the following year, had promised the rebel group a second $15 million.

The Reagan Administration emphasized South Africa's geopolitical role as an ally against Soviet infiltration into southern Africa and against the spread of communism in Africa. In response to new opportunities afforded by the U.S. policy of "constructive engagement," South Africa "hardened its bargaining position in Namibian negotiations; embarked on concerted military and economic campaign to establish regional dominance by intimidating and destabilizing neighboring states, particularly Angola, Mozambique, Zimbabwe, and Lesotho; and failed to make a clear and persuasive commitment to move toward extending meaningful individual political rights to black South Africans."

The Reagan Administration's policy of "constructive engagement" met with intensified critique in the mid-1980s. In response to congressional criticism, the White House adopted the role of mediator between South Africa and its neighbors, with the following results: in February 1984, Angola and South Africa reached an agreement, called the Lusaka Accord, to disengage their forces in southern Angola; in March 1984, South Africa and Mozambique agreed to a non-aggression pact, the Nkomati Accord; in 1988, a tripartite settlement was signed between Angola, Cuba and South Africa, providing for the withdrawal of Cuban troops in Angola and the implementation of UN Resolution 435 for the independence of Namibia.

Like President Reagan, Bush embraced "constructive engagement" as a sound U.S. policy toward southern and South Africa. The Bush's administration policies attempt to accomodate the new realities in South Africa. As much as Bush is opposed economic sanctions, he is unable to effectively temper with existing sanctions imposed by the Comprehensive Anti-Apartheid Act of 1986, which require that South Africa take certain specific measures before he can terminate them. However, the Bush administration is engaged in programs designed to broaden participation in and acceptance by all South Africans of a market based economic system in South Africa. President Bush has encouraged President De Klerk to accelerate the repeal of apartheid laws, to engage in negotiations with representatives of the black majority, release political prisoners, and to end the state of emergency. In the region President Bush is committed to the reduction and elimination of Soviet and Cuban military presents, access, and influence in Angola and elsewhere in southern Africa, promotion of political reconciliation in Angola between the MPLA and UNITA reduction of prospects for revolutionary change in southern Africa.

The South Africa project was initiated in late 1976. Over a period of the next four years, the South African project team set out to build a substantial collection that would document all major aspects of U.S.-South Africa relations, including arms embargo issues, nuclear collaboration, economoic sanctions, regional issues, commerce and trade, emergence of trade unions and the USAID program. Although much has been written about U.S.-South African relations over the years, very few primary documents acquired through the FOIA existed in the public domain when this project was initiated. Therefore, the project team was compelled to obtain almost all its documents through the FOIA. For most government agencies this process is not only lengthy, but also with subjects as sensitive as U.S. covert actions in the region, SADF cross border raids, nuclear issues, not always fruitful. Without a keen sense of how the national bureacracy operates and knowledge of which personnel are working on the subject, a researcher using the FOIA to obtain material on U.S. activities in South and southern Africa would not get far.

Thus, between 1986 and 1990, the Archives's South Africa Project Team surveyed a vast assortment of secondary source material; spoke with congressional staff members, government officials, academics, journalists, lobbyists, representatives of the various liberation movements in the region, and private experts working on various aspects of U.S. policy toward South Africa; and attended numerous conferences on South and southern African issues.

Using the FOIA, the South Africa project obtained previously unavailable documents from government national security bureaucracy and other agencies. The collection contains declassified reports, memoranda, minutes, notes and other forms of documentation from the Central Intelligence Agency, the Defense Intelligence Agency, the State Department's Bureau of Intelligence and Research, the Nuclear Regulatory Commission, the National Security Council and the Agency for International Development. In addition, the project acquired key documentation from the legislative branch, which played a major role in U.S. policy toward South Africa. The collection includes previously unpublished correspondence between legislators and U.S. officials, unclassified and declassified General Accounting Office investigations, and difficult-to-access research publications of congressional organizations such as Congressional Research Service reports and analyses of various hotly debated topics, including sanctions, implementation of the arms embargo, nuclear sales, technology tranfers, SADF cross border raids, covert actions and peace initiatives, are also provided in this set.

Pending Freedom of Information Act Requests

The South African project team has filed FOIA requests for many of the documents in the collection. The team has also requested agencies review once again review denied and heavily excised documents to determine if further information can be released. In addition, requests for documentation pertaining to specific persons, events and interactions have been made whenever the project staff and review panelists felt that such documentation was necessary in order to understand better the course of U.S. foreign policy.

Unfortunately, U.S. agencies have often been slow in processing Archive requests and appeals. Some requests, seeking many hundreds of documents, have remained pending without a substantive response from these agencies for periods of up to several years. Outstanding FOIA requests and documents released after publication of this collection may be consulted in the National Security Archive's library facility in Washington, D.C.

Excluded Materials

In addition to documents that are exact duplicates or contain no substantive information, such as blank or fully excised pages, were excluded. To ensure the unique nature of this collection, the set also omits certain government materials which are readily available elsewhere. Congressional hearings and reports, certain Congressional Record debates and Foreign Broadcast Information Service daily reports are among the types of documents omitted. A selected list of relevant items appears in the bibliography.

All documents received through the FOIA, whether or not they are reproduced here, have been carefully studied and the information contained in them has directly contributed to the set's comprehensive picture of the development of U.S. policy toward South Africa. Researchers are invited to examine all documents collected in connection with this set at the Archive's public reading room in Washington, D.C.

Research Value of the Document Set

The South African collection provides both a comprehensive index and catalog--accompanied by an extensive chronology and set of glossaries--to a centralized record of one of the most controversial foreign policy issues since World War II. Spanning the years 1962-1989, the collection provides one of the most complete sets of documents available to the Public on U.S. management of a conflicting set of interests . The documents collected here are up-to-date (some were created as recently as 1989), broad-ranging and, until now, virtually unavailable to scholars, researchers and the general public. Indeed, one indication of the exceptional value of this collection is the fact that former Carter and Reagan Administration officials who made and implemented U.S. policy toward South and southern Africa have already approached the National Security Archive to gain access to papers--including documents they authored--that they otherwise have been unable to obtain from the U.S. government.

Diplomatic historians will also find the early cable traffic, as well as later reporting during the Reagan Administration, of particular value for documenting the various activities and functions of a U.S. Embassy in a controversial environment. Regional studies scholars will also find value in the U.S. Embassy reporting on the military and political tensions in the region. Although biased in part by a hostile U.S. policy toward the governments of Angola and Mozambique in particular, and to the liberation movements in the region.

Documenting U.S.-South African relations from the Kennedy Administration through the Reagan years, this collection allows researchers to evaluate changes over time and to chart the evolution of U.S. policy toward South Africa under six U.S. presidents.

Limitations of the Document Set

Although the South Africa project team made an exhaustive effort to construct a comprehensive set of documents that record the history of U.S. relations with South Africa, impediments stood in the way. First and foremost, the executive branch continues to withhold relevant documentation. While the State Department, for example, declassified numerous secret documents from the Carter era, only a handful of highly classified cables from the Reagan period were declassified and released in response to Archive FOIA requests. Moreover, important interagency deliberations that took place under the auspices of both Carter and Reagan's National Security Councils continue to be inaccessible to the public because of the NSC's resistance to expediting the release of these important records. And the Central Intelligence Agency has been no more forthcoming on documents generated CIA stations in southern Africa.

Characteristics of the Document Set

The following charts provide information on the contents of the document set, listing the number of documents by period and origin:

Year  Number of Documents
1960s 2
1972-1977 23
1978 590
1979 499
1980 137
1981 174
1982 200
1983 278
1984 395
1985 306
1986 300
1987 77
1988 79
1989 60
1990 11


Major Origin  Number of Documents
United States Embassy. Nicaragua 566
United States Embassy. Costa Rica 43
United States Embassy. Honduras 39
Department of State 451
Congress 65
National Security Council 52
Central Intelligence Agency 31
Executive Office of the President 12

Project Methodology

Like all Archive document collections, the South Africa document collection represents work on a number of levels. When staff analysts begin a two- or three-year project at the Archive, they are guided by a scope paper which lays out the basic subject matter of the set, the time period it will cover and other parameters. Based on this preliminary guideline, the analyst begins to build a detailed chronology of relevant events based first on secondary sources and later on the primary documents which ultimately make up the collection.The chronology is itself a tool to help the analyst identify issues and subjects worth documenting. As the chronology and collection grow, the analyst begins to create a databank of glossaries on key individuals, subjects and concepts based, again, on the chronology and the documents. Over the course of the project, each area of activity contributes to the others. The growing body of information that results enriches the project by providing in-depth reference material as well as the most comprehensive collection of documents possible. Key to this entire process are the advice and guidance of present and former executive and legislative branch officials, scholars, journalists, representatives of public interest organizations and other experts who are consulted regularly by Archive staff not only about the range of issues covered by the set but about the all-important task of targeting and acquiring the documents themselves.

During the acquisition process, staff analysts solicit major collections of documents from other researchers, then file Freedom of Information Act (FOIA) and Mandatory Declassification Review (MDR) requests to fill gaps in the collection. While the Archive recognizes the legitimate need for certain national security information to be protected and controlled by the government, experience has shown that much of the information that is classified can shortly thereafter be safely declassified and released to the public. In order to prevent the improper destruction and removal of documents, the Archive attempts to file FOIA requests for relevant materials as soon after the events as possible to allow processing and declassification without interfering with agency operations. Under current governmental record maintenance practices, much relevant information might no longer exist 30 or more years later, when it would otherwise first be scheduled for declassification review. In addition, these practices make it unlikely that many materials crucial to knitting the documentary record back into a meaningful whole will be publicly available until half a century or more after the actual event.

When the chronology or cross-references in cataloged documents reveal events or processes for which there is incomplete documentation, additional FOIA and MDR requests are filed for missing materials. If all or part of a document is denied and the denial appears improper, an administrative appeal is filed to the agency.If the appeal still results in what Archive staff and the outside experts they consult deem to be an improper response, a lawsuit may be brought to compel release of these missing materials.

Analysts also visit governmental libraries, review court records and congressional hearings, and seek copies of documents from other sources for background information as well as to identify documentation that is relevant to the set.

As materials are collected, they are cataloged by Archive staff. Document descriptions, when reviewed in the aggregate, often reveal leads to other information that can be sought under the Freedom of Information Act. Periodically, the staff reviews the Archive's on-line database of cataloging information to identify patterns of documentation. Scholars and journalists conducting research at the Archive reading room are asked for leads to additional materials. Outside experts, including present and former officials, are asked to suggest documentation known to them, with a view to ensuring comprehensiveness and balance in the resulting collection.

At the conclusion of this process, when the bulk of FOIA and MDR requests have received responses, Archive staff finalize the scope of the set, decide on its relative completeness and close it for the purpose of publication. Once closed, the collection of documents is indexed. Archive staff assign indexing phrases describing the content of the document and providing the context of key terms to substantive sections of the document. This sometimes results in the assignment of a number of index phrases for a specific page, or for a table or exhibit in the document itself.


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