Lori:

I wrote my master's thesis on:  Developing Written Policy for the Curation, Conservation and Exhibition of Native American Artifacts Using Model Guidelines.  Here are chapters 4 & 5.  Hope this helps.

Becky Fitzgerald
Executive Director
Erlander Home Museum
404 S. 3rd St.
Rockford, IL 61104
(815) 963-5559
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IV. THE CREATION OF MODEL GUIDELINES
As the registrar at the Mabee-Gerrer Museum of Art, I struggled to find a way to logically organize the bits and pieces of information I obtained from a variety of sources about managing Native American artifacts.  I searched in vain for existing written guidelines before developing the Model Guidelines proposed in this paper.  A few temporary guidelines developed by tribes are available, but none of the guidelines addressed all of the issues I wanted to include in the museum policies I needed to develop.
The Southern Cheyenne and Arapaho temporary guidelines are the most detailed of the guidelines I found.  The introduction to the Southern Cheyenne and Arapaho guidelines explains why only temporary guidelines are being developed by the tribe:
These objects are treated in Southern Cheyenne and Arapaho culture in a certain
specific ways.  The Southern Cheyenne and Arapaho traditional leader/religious leaders possess knowledge of these values of care, and treatment.  Such values, should not and can not be revealed to uninitiated people.  Therefore, the Southern Cheyenne and Arapaho have developed the following temporary policy for Museums, Institutions, and Federal Agencies, only as a guide/reference, in accordance with the Native American Graves Protection and Repatriation Act.
The Cheyenne and Arapaho Tribes of Oklahoma anticipate that their temporary guidelines will serve as a prototype for other tribes developing similar guidelines.  The tribe recently submitted the guidelines to the NPS for final approval.
 The proposed Model Guidelines use the four categories of cultural property defined by NAGPRA as the basic framework.  I used the language of NAGPRA to provide consistency in terminology.  Many tribes producing temporary guidelines also use the NAGPRA categories.  Several issues that may be foreign to non-Native American museum personnel need to be  addressed.  A section for special considerations about tribal uses and attitudes toward objects should be incorporated into written collections policy for each of the four categories.  Special considerations include tribal philosophies about appropriate attitudes or physical conditions when handling collections, gender restrictions, and permission or prohibition of photographing collections items.  Museum practices, like the "Object ID" program produced by the Getty Information Institute, mandate the inclusion of photographs with other documentation of artifacts.  Religious beliefs of some tribes, however, deem the practice of photographing certain culturally sensitive items as a sacrilegious act, and therefore an affront to the religious freedoms of the tribe.   Tribal procedures for handling and caring for artifacts may differ from common museum practices, but conflicts over conservation practices can be resolved in most cases.  Many tribes, for example, request that organic offerings like sage or tobacco be placed with stored objects.  These offerings are potential food sources for insects and rodents that destroy museum collections.  Curators and registrars can adjust their policies to prevent pest infestations while adhering to tribal wishes.   Several museums handle this situation by accessioning the offering, and storing it in an acid-free zip-lock style polyethylene bag.  The offering is then placed near the artifact.  "Accessioning lets you keep track of what it is and why you kept it in your collections, and the bag prevents it from damaging your artifacts."   A notation can be placed in the collections records that associate the two items in case of accidental separation in the future.
Museum personnel should show an appropriate attitude of respect. They must handle artifacts with solemnity, sobriety and care. The Cheyenne and Arapaho Tribes of Oklahoma require tribal members and museum personnel to use white gloves to handle objects and human remains as a matter of respect.  They believe that the gloves protect the objects physically and spiritually.  Many tribes appreciate the use of gloves by museum personnel when handling artifacts as a gesture of respect for their ancestors.  A worker at a university museum recently said that a positive comment made by a tribal elder involved the use of gloves.  He told the museum staff member that he "appreciated us using gloves to handle objects" during preliminary consultation.  The elder viewed the use of gloves as a sign of respect for both the artifacts and their makers.
A concept of spiritual purity held by most tribes requires proper respect for objects and the deceased.  For the Cheyenne and Arapaho Tribes of Oklahoma, for example, spiritual purity is more than an attitude of respect--the physical body is involved as well.  The Cheyenne and Arapaho guidelines explain that the use of alcohol or drugs defiles the body and impairs spiritual purity.  Their guidelines call for spiritual purity for both tribal members and museum personnel handling objects and remains as a show of respect for their ancestors.
Some tribes place gender restrictions on objects used only by one gender such as tools, weapons, burial goods, or even human remains.   The Southern Cheyenne and Arapaho policy guidelines advise museum personnel to adhere to strict gender divisions when handling associated funerary objects.  Only males are to handle male associated funerary objects, and only females are to handle female associated funerary objects.  For the treatment of unassociated funerary objects, however, guidelines are subject to determination "on a case-by-case basis, and based on accession and catalog information."   The Tribal Collections Management Policy at the Makah Cultural and Research Center places gender restrictions on "the handling of some tools; whaling gear, for example, cannot be touched or handled by women."   Similar restrictions exist for Makah tools used by women.  Makah custom also restricts men from handling women's tools.  The museum at the Makah Cultural Center handles the gender restriction problem by flagging gender restricted objects and by hiring both male and female employees.
Some tribes insist on a hierarchy of storage arrangements when dealing with gender-related objects.  The Southern Cheyenne and Arapaho, for example, request that clothing be stored in a way that reflects the hierarchy of their traditional culture: men's clothing should be stored above those of women, and women's clothing should be stored above those of children.  Tools and other items separated by spheres of gender influence may require similar treatments.  Cleaning restrictions may also apply to Native American artifacts, requiring museums to place an emphasis on preventive conservation rather than restorative measures.  Permission should be obtained from tribal authorities before subjecting culturally sensitive items to cleaning or restorative processes.
Many traditional tribal leaders prohibit or place restrictions on the use of photographs.  Such restrictions may affect collections management policies in the future because current museum registration methods recommend photographic documentation of collections.   Registrars should develop collections policies that include the documentation of permission to photograph, the date permission was granted, and the name the person(s) granting permission.  Photographic restrictions or limitations often stem from a belief that objects made from living things retain the essence of the life from their raw materials, even after the plant or animal is transformed into a manufactured item.  The belief that photographing these objects extract spiritual essences from them places the standard museum practice of photographing objects for documentation at odds with the religious beliefs of many tribes.  Registrars should  avoid an affront caused by photographing culturally sensitive materials without permission. Pencil sketches may serve as a feasible alternative to photographs.   Transference of sketches to computer programs through scanners or digital cameras allows the incorporation of sketches into computerized collections management files without violating tribal beliefs.
Many tribes prefer the use of natural or organic materials in the storage and exhibition of Native American funerary items.  Funerary objects are spiritual objects--intended to deteriorate with the deceased.  These objects contain the essences of living things according to some tribal religions.  Some tribes consider inorganic materials like plastic inappropriate for collections care because plastic does not allow the object to breathe properly.  This restriction on conservation materials poses less of a problem to museum professionals than other tribal restrictions.  Many museums also prefer the use of natural materials for preventive conservation.  Non-acidic natural materials often withstand the test of time better than synthetics.
Many museums organize their collections by groups of similar items like moccasins or war clubs. Organizing collections storage by tribe, however, may prove more efficient when collections contain artifacts from more than one tribe .  At DAM, for example, personnel recently reorganized their storage area by tribe.  The DAM collection represents over 200 tribes.  DAM personnel undertook the massive effort of reorganization to better accommodate tribal wishes and to simplify the task finding objects during consultations.
The Model Guidelines I have proposed can be converted to computer use and formatted to accommodate each tribe or band as consultations take place.  Few guidelines written by tribes do exist.  Most of the existing tribal guidelines do not deal with the care of specific objects or types of objects, since many tribes prefer to discuss each object separately.   The proposed Model Guidelines can serve as a catalyst for obtaining information from both tribes and museums to produce genuine dialogue leading to written policy.

MODEL GUIDELINES
Name of Tribe:____________________________________________________
Address:_________________________________________________________
 __________________________________________________________
Phone: (     )         -                  x                              Fax: (     )            -
NAGPRA Contact:_________________________________________________
Date:____________________
Number of objects in the collection associated with this tribe:__________
Letter requesting consultation sent ____     Date _______________
Phone call to set up pre-consultation negotiations ____   Date ______________
Consultation:
Place:____________________________________________________
Date(s):__________________________
Time(s):_____________

Accession number and location of objects considered associated funerary objects:
Example: 1919.3.56.a  beaded cradleboard cover, belongs with Comanche child remains number 1919.3.56.b  location: storage shelf 5-G.
Accession number and location of objects considered unassociated funerary objects:
Example: 1919.3.57, quill work necklace
Accession number and location of objects considered sacred:
Example: 1919.3.58  medicine bundle
Accession number and location of objects considered cultural patrimony:
Example: 1919.3.58 Iroquois confederation wampum belt
  1927.0.43 Catlinite pipe with wooden stem

Associated Funerary Objects:
Definition:  items buried with and still associated with an individual remain
Example:  Comanche cradle board excavated with child-size human skull*
1  Proper respect/spiritual purity issues:
1.1  Use of white gloves _____by museum staff  _____by traditional leaders for
                spiritual and physical protection of handlers as well as respect for the dead.
 1.2  Prohibition of alcohol/drugs use during handling _____by staff  _____  by traditional
               leaders for spiritual and physical protection of handlers as well as respect for the
           dead.
1.3  Appropriate attitude of respect
1.4  Limited access to public  _____ yes    _____no
1.5  Photographic prohibitions  _____ yes    _____no
2.  Collections care
2.1  Gender restrictions  _____ yes    _____no
Male   _____ yes    _____no
Handling only ____  Handling and sight _____
        Female    _____ yes    _____no
Handling only ____  Handling and sight _____
Same for children   _____ yes    _____no
2.2  Conservation products
breatheability important   _____ yes    _____no
natural products only   _____ yes    _____no
2.3  Cleaning
restrictions   _____ yes    _____no
suggestions made during consultation   _____ yes    _____no
permission required   _____ yes    _____no
2.4  Storage organization
Hierarchy   _____ yes    _____no
Flagging for gender restrictions   _____ yes    _____no
2.5  Policy provisions for items that need to be used
_____ Facility provision
_____ Preventative treatment allowed before return to storage
_____ Acceptable conservation alternatives
2.6  Inclusion of offerings  _____yes  _____no
Approval for encasing offering in acid free-plastic? _____yes  _____no
2.7  Public access restricted?  _____yes   _____no
Exceptions?  ____yes  _____no  If yes, what are the exceptions?
_________________________________________________________________
_________________________________________________________________
2.8 Tribal access agreement made  _____yes  _____no.
If yes, agreement terms:
3. Exhibition restrictions
 _____yes  _____no  If yes describe:
4. Other comments:

Unassociated Funerary Objects:
Definition: objects buried with individuals, but no longer associated with individual remains.
Examples: clothing, tools, pottery, etc.
1  Proper respect/spiritual purity issues:
1.1  Use of white gloves _____by museum staff  _____by traditional leaders for
       spiritual and physical protection of handlers as well as respect for the dead.
1.2  Prohibition of alcohol/drugs use during handling   _____by staff  _____  by
       traditional leaders for spiritual and physical protection of handlers as well
       as respect for the dead.
1.3  Appropriate attitude of respect
1.4  Limited access to public  _____ yes    _____no
1.5  Photographic prohibitions  _____ yes    _____no
2.  Collections care
2.1  Gender restrictions  _____ yes    _____no
Male   _____ yes    _____no
Handling only ____  Handling and sight _____
        Female    _____ yes    _____no
Handling only ____  Handling and sight _____
Same for children   _____ yes    _____no
2.2  Conservation products
breatheability important   _____ yes    _____no
natural products only   _____ yes    _____no
2.3  Cleaning
restrictions   _____ yes    _____no
suggestions made during consultation   _____ yes    _____no
permission required   _____ yes    _____no
2.4  Storage organization
Hierarchy   _____ yes    _____no
Flagging for gender restrictions   _____ yes    _____no
2.5  Policy provisions for items that need to be used
Facility provision
Preventative treatment allowed before return to storage
Acceptable conservation alternatives
2.6  Inclusion of offerings  _____yes  _____no
Approval for encasing offering in acid free-plastic?_____yes  _____no
2.7  Public access restricted _____yes  _____no
Exceptions?  ____yes  _____no  If yes, what are the exceptions?
2.8 Tribal access agreement made  _____yes  _____no.
If yes, agreement terms:
3. Exhibition restrictions
 _____yes  _____no  If yes describe:
4. Other comments:



Sacred Objects:
Definition:  objects used for ceremonies, or worship in traditional Native American  religion
Examples:  tobacco pipes, dance fans, kachina masks
1  Proper respect/spiritual purity issues:
1.1  Use of white gloves _____by museum staff  _____by traditional leaders for
      spiritual and physical protection of handlers as well as respect for the dead.

 1.2  Prohibition of alcohol/drugs use during handling   _____by staff  _____  by traditional
        leaders for spiritual and physical protection of handlers as well as respect for the
       dead.
1.3  Appropriate attitude of respect
1.4  Limited access to public  _____ yes    _____no
1.5  Photographic prohibitions  _____ yes    _____no
2.  Collections care
2.1  Gender restrictions  _____ yes    _____no
Male   _____ yes    _____no
Handling only ____  Handling and sight _____
        Female    _____ yes    _____no
Handling only ____  Handling and sight _____
Same for children   _____ yes    _____no
2.2  Conservation products
breatheability important   _____ yes    _____no
natural products only   _____ yes    _____no
2.3  Cleaning
restrictions   _____ yes    _____no
suggestions made during consultation   _____ yes    _____no
permission required   _____ yes    _____no
2.4  Storage organization
Hierarchy   _____ yes    _____no
Flagging for gender restrictions   _____ yes    _____no
2.5  Policy provisions for items that need to be used
Facility provision
Preventative treatment allowed before return to storage
Acceptable conservation alternatives
2.6  Inclusion of offerings  _____yes  _____no
Approval for encasing offering in acid free-plastic?_____yes  _____no
2.7  Public access restricted _____yes  _____no
Exceptions?  ____yes  _____no  If yes, what are the exceptions?
2.8 Tribal access agreement made  _____yes  _____no.
If yes, agreement terms:
3. Exhibition restrictions
 _____yes  _____no  If yes describe:
4. Other comments:

Cultural patrimony:
Definition:  objects with ongoing historical, traditional, or cultural importance to the tribe  and are considered inalienable by the tribe at the time of its separation from the group.
Examples: Confederacy Wampum belts of the Iroquois, Zuni war gods, etc.
1  Respect/spiritual purity issues:
1.1  Use of white gloves _____by museum staff  _____by traditional leaders for
       spiritual and physical protection of handlers as well as respect for the dead.
 1.2  Prohibition of alcohol/drugs use during handling   _____by staff  _____  by traditional
        leaders for spiritual and physical protection of handlers as well as respect for the
        dead.
1.3  Appropriate attitude of respect
1.4  Limited access to public  _____ yes    _____no
1.5  Photographic prohibitions  _____ yes    _____no
2.  Collections care
2.1  Gender restrictions  _____ yes    _____no
Male   _____ yes    _____no
Handling only ____  Handling and sight _____
        Female    _____ yes    _____no
Handling only ____  Handling and sight _____
Same for children   _____ yes    _____no
2.2  Conservation products
breatheability important   _____ yes    _____no
natural products only   _____ yes    _____no
2.3  Cleaning
restrictions   _____ yes    _____no
suggestions made during consultation   _____ yes    _____no
permission required   _____ yes    _____no
2.4  Storage organization
Hierarchy   _____ yes    _____no
Flagging for gender restrictions   _____ yes    _____no
2.5  Policy provisions for items that need to be used
Facility provision
Preventative treatment allowed before return to storage
Acceptable conservation alternatives
2.6  Inclusion of offerings  _____yes  _____no
Approval for encasing offering in acid free-plastic?_____yes  _____no
2.7  Public access restricted _____yes  _____no
Exceptions?  ____yes  _____no  If yes, what are the exceptions?
2.8 Tribal access agreement made  _____yes  _____no.
If yes, agreement terms:
3. Exhibition restrictions
 _____yes  _____no  If yes describe:
4. Other comments:


V.  CONSULTATIONS, CONTINUING DIALOGUE, AND COMPLIANCE
Tribal consultations are an essential source of information for the development of museum policy governing the management of Native American collections.  I combined information obtained through interviews, primary documents, and personal experience to devise recommended consultation procedures. The NPS document Suggested Consultation Plan Format served as a starting point for producing the consultation plan.  The NPS format is useful as an example for initiating consultations, although the document's intended purpose does not include consultations to create policies for museum collections.  The NPS suggests a four-step process for consultations: a letter of notification to tribal leaders, a telephone call, an initial meeting, and a second meeting.
Each step in the consultation process requires forethought, preparation, and good communication skills.   Contact for consultations by the NPS begins with a formal letter to the designated tribal NAGPRA representative.  Tribes choose their NAGPRA representative and then notify the NAGPRA representative at NPS. The tribal NAGPRA representative is then placed on the NPS list of federally recognized representatives.  However, the Federal Register does not list all tribes.  A tribe may not have a representative listed if it has never signed a treaty with the United States, or the tribe may still be developing a repatriation program.   The NPS list changes frequently as tribes change representatives or begin repatriation programs for the first time.  (The NPS keeps an updated list of federally recognized NAGPRA Representatives.)  It is important to deal only with contacts approved through the NPS in repatriation cases, since failure to do so can result in penalties imposed by the Secretary of the Interior for non-compliance. (NAGPRA does contain a clause stating that museums are not liable for repatriations conducted in good faith.)
After the initial letter, the Suggested Consultation Plan Format recommends a follow-up phone call.  A delayed response following the initial contact by letter does not indicate a tribe's disinterest, but may suggest bureaucratic red tape, under-staffing, or a lack of funding.  The phone call is placed two weeks after mailing the letter to schedule a face-to-face meeting, beginning the negotiations for a consultation.   Successful consultations require more than a time and place to meet.  Before a consultation takes place, several issues should be discussed.    A museum, as the host institution of a consultation, may need to provide a place to hold religious ceremonies.  Many tribes both begin and end consultations with religious ceremonies that include the burning of small amounts of cedar, sweet grass, sage, or tobacco.   A private area in a well-ventilated room without a smoke detector or an outside area screened from public view should be provided for these ceremonies.  The area should be as close as possible to the consultation area.
Some NAGPRA representatives, like Gordon Yellowman, Sr. of the Southern Cheyenne and Arapaho Tribes of Oklahoma, suggest video or audio-taping of the consultation.  He explains to the traditional leaders that the video is a form of artificial memory that will provide future generations with the expertise of today's elders.   Other tribes may prohibit video or audio-taping of consultation sessions. Some traditional leaders feel uneasy about being recorded.   Obtaining permission to video or audiotape consultations in advance of a consultation allows preparation by both the museum and traditional leaders.   A copy of the video or audio-tape should be provided to the tribe as a courtesy of their visit.
Consultations require a quiet place to discuss sensitive issues.  The provision of a consultation table, chairs, and several pairs of white gloves by the host museum helps provide a relaxed and respectful  atmosphere.   Jotting down notes during a consultation often enhances communication.  The provision of pencils and paper to consultation participants increases effective communication during the consultation.
Arranging objects for viewing by the consultation group requires preparation by  curator or registrar.  Many tribes prefer to view similar items as a group to allow comparisons. Adequate space is necessary to avoid crowding objects together during the consultation.   All participants should be provided with copies of museum records, including the provenance for each object. Information contained in museum records encourages open dialogue about specific objects.
The art of effective communication with traditional leaders involves relaxation and a willingness to listen more than one speaks.  Long pauses may signal a gathering of thoughts rather than the end of a conversation, and repetition is an important element of most oral traditions. Like a memorable speech or a popular song, the repetition of important statements ensures that the audience remembers the story.  A successful consultation involves excellent communication skills and thorough planning.
Sending prepared questions to consultation participants before the meeting allows everyone involved time to think about his responses and increases the possibility of meaningful communication.   Using a document like the Model Guidelines proposed in this paper to collect information about collections management practices preferred by traditional leaders will speed the process and assure that important questions do not remain unnoticed during consultations.
Tribal NAGPRA Representatives serve as liaisons between traditional tribal leaders and the museum community.  Keeping the tribal NAGPRA representative well informed about consultation preparations promotes successful dialogue. Communication is the key to achieving consultation goals in the sometimes expensive process of tribal consultations.  Dialogues leading to tribal consultations need to address several questions not mentioned in the NPS plan.  Addressing these issues before a consultation takes place prevents potential misunderstandings between museums and tribal authorities.  For example, NAGPRA representatives, traditional religious leaders, and tribal elders usually receive daily stipends ranging from $150 to $200 for their expertise.   Each tribe decides how many tribal representatives need to attend a consultation and the acceptable rate of compensation for a day's work.   If participants other than museum staff plan to attend the consultation, they should seek the approval of the tribe before finalizing arrangements.  Also, the payment of stipends and reimbursement for travel expenses incurred by the tribal delegation should be prearranged.
Once financial arrangements are settled and the date is set, the process of preparation for a tribal consultation can begin.  Many tribes receive funding from NAGPRA grants to cover the costs of conducting consultations with museums, but often museums need to absorb the cost of consultation.  Competitive NAGPRA grants in amounts up to $75,000 are available to museums to cover the costs of consultations.   The grants, awarded through the NPS, fund projects for both large and small museums. Grant applications showing collaborative efforts receive preference.  Museums not compliant with NAGPRA are ineligible for NAGPRA grant funds.
Museums should comply with NAGPRA before attempting to create tribe-specific policies for managing culturally sensitive artifacts.  Although Oklahoma has more than 300 museums, many housing Native American collections, only six Oklahoma museums have currently complied with NAGPRA: the Oklahoma Historical Society (OHS), Oklahoma Museum of Natural History, Tulsa University's McFarlin Library, Mabee-Gerrer Museum of Art, Philbrook Museum of Art, and the Gilcrease Museum.  Many small museums and library archives that receive federal funding seem oblivious to NAGPRA and the possibility of severe civil penalties imposed by the Secretary of the Interior.
Some museums that house Native American artifacts are exempt from NAGPRA since they have not received federal funding of any sort after the passage of NAGPRA.  These  museums, by failing to meet the compliance deadline, are no longer eligible to receive federal funding.  No further penalties apply to these museums.  Some institutions that failed to comply with NAGPRA did not view themselves as museums, although NAGPRA clearly states that
    museum means any institution or state or local government agency (including any institution of higher learning) that has possession of, or control over, human remains, funerary objects, sacred objects, or objects of cultural patrimony and receives federal funds.
The penalties for non-compliance are severe.  To avoid being categorized as non-compliant by the Department of the Interior, museums covered by NAGPRA must have completed  a summary of the inventory and provided copies of the summary to each tribe represented in their collections by November 16, 1993.  These same museums were to provide an inventory for the Federal Register by November 16, 1995.
Museum personnel need to establish repatriation policies and procedures to avoid unintentional non-compliance penalties.  Following a written request to a museum by a tribe to repatriate an object, the Federal Registry posts a Notice of Intention to Repatriate for a minimum of 30 days to allow other tribes a chance to claim that object.  If no tribes file additional claims on the object within 30 days, the object is transferred to the tribe through the federally recognized NAGPRA Representative of the tribe.  Museum policies  for the twenty-first century need to include deaccessioning procedures for repatriated objects.

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