Are the Secretary of the Interior’s Archaeology Standards good enough?

Coming off of two weeks of intense debate about archaeological standards and accountability on the Archaeology Careerist’s Network, I felt like addressing the Secretary of the Interior’s Professional Qualifications Standards. I have talked to many folks that feel like these standards are not enough. Most graduate students and recent grads feel like they are more than enough. If we want to be honest with ourselves, the standards play an extremely small role in predicting a successful cultural resource management archaeologist (or historian, ethonographer, or architectural historian for that matter).

Success in cultural resource management and heritage conservation takes much more than education or experience. There are unmeasurable qualities (leadership, intuition, business-savvy, attention to detail, and a drive for success among other attributes) that simply cannot be outlined in any standard.

With that being said, many of us, including myself, feel like we need to make some adjustments to the required standards in order to help cultural resource management become a more formal and professional field. I think this is the foundation we can use to push for better wages and eliminate #freearchaeology from CRM consulting (I don’t want to be misunderstood. There is plenty of room for volunteering and free archaeology on private property or through programs at the university, state, and local level. I personally feel like free archaeology has no place in cultural resource management consulting).

I also feel like the existing standards apply only to the management caste even though field techs do most of the actual fieldwork, which is turned into documentation and a CRM company’s products. Also, because the majority of archaeologists are field techs they have little coverage under existing regulations and tend to be treated as expendables. This is not good because most archaeologists start off as techs or field school students and work their way up the ladder– assuming an increasing amount of responsibility.

The lack of compassion and concern for the plights of field techs is one of the most often cited reasons for leaving archaeology. As was explained on the CRM Archaeology Podcast, most techs leave archaeology because they feel undervalued and are treated poorly by supervisors and CRM companies. I think making changes to the existing qualifications by creating some criteria for field techs will do much to promote professionalism within the field. As professionals, techs are in a better position to push for better working conditions and wages because they won’t be as replaceable as before. Companies won’t easily be able to replace techs because there won’t be as many of them that fit the qualifications. (There are also several other elements to this situation that I will address at a later date, such as enforcing GSA wages, creating a FUNCTIONAL grievance system, making the RPA matter, ect.)

I also think there should be more stringent qualifications for project managers and, especially, for principal investigators. The standards I envision also need to have regular trainings and upgrades in order to keep CRMers at the top of their game.

Our Current Standards

In case you’d never read them, here are the Secretary of the Interior’s qualification standards for archaeologists doing work under the National Historic Preservation Act (NHPA), National Environmental Policy Act (NEPA) and on federally administered lands:

The minimum professional qualifications in archeology are a graduate degree in archeology, anthropology, or closely related field plus:
 1.    At least one year of full-time professional experience or equivalent specialized training in archeological research, administration or management;
 2.    At least four months of supervised field and analytic experience in general North American archeology, and
 3.    Demonstrated ability to carry research to completion.
In addition to these minimum qualifications, a professional in prehistoric archeology shall have at least one year of full-time professional experience at a supervisory level in the study of archeological resources of the prehistoric period. A professional in historic archeology shall have at least one year of full-time professional experience at a supervisory level in the study of archeological resources of the historic period.

(You can read more here

As you can tell, those qualifications mostly revolve around college education and a short stint of “professional experience”. You can easily become a qualified archaeologist according to those qualifications by simply teaching a field school, being a teaching assistant, writing a dissertation or thesis, and following your major professor around for a year (I know several folks that have done just that and are now considered CRM archaeologists). You don’t even need CRM experience to be an archaeologist qualified to do CRM.

Some states have recognized the shortcomings of these qualifications and have raised the bar. Arizona is one of those states. In order to be a principal investigator for a CRM archaeology project on state or federal lands in Arizona, an archaeologist must fulfill the following criteria:

To qualify for listing as a principal investigator (PI) on an Arizona Antiquities Act permit, the permit applicant is in part reviewed according to a demonstrated competence in managing and administering research projects. Demonstration of this qualification must be met by providing the following information and documentation for review.
1. Two historic properties treatment plans (HPTPs) (i.e., two research designs with work plans) written by the applicant.

2. The reports resulting from the archaeological research described in the two HPTPs (i.e., the two research designs with work plans).

3. The two types of archaeological research projects are 1) excavations and 2) nonclearance (pure research) surveys greater than 10 linear miles or 640 acres. At least one of the required projects must be an excavation.

4. The PI will have administered and supervised both projects from start to finish, including supervision of all the project director(s) in the laboratory or in the field, consultations with state and federal agencies and tribes, and supervision of all the projects’ phases until final delivery of all project materials and reports, so that the research and work is conducted and concludes according the two HPTPs or two research designs with work plans, as appropriate.

5. Copies of any consultation letters, including comments and acceptance letters by the state or federal agencies involved in the review process. These agencies would include the respective state historic preservation officers and federal and state leads with jurisdiction over the project.

(you can see the regulation at

Those regulations are pretty stringent and are higher than any other state I’ve worked in. You may think that would discourage CRM business in Arizona, right? On the contrary. Arizona has more archaeologists and anthropologists than any other state in the U.S. There are more archaeologists per capita in Tucson than anywhere else in the U.S. (arguably, the world).

Those laws were created so strictly because Arizona was the first state to seek and receive protection from being plundered for its archaeological remains. The Antiquities Act of 1906 was partially motivated by the fact that folks were ravaging Casa Grande National Park for Hohokam artifacts. The Antiquities Act put an end to this by making the site a federally protected place– the first of its kind in the U.S.

The laws are also strict because busloads of aspiring archaeologists flow into AZ each year in hopes of digging on one of the sites like they’ve read about in college textbooks. The flow of aspiring archaeos into Arizona never seems to cease and the only thing that keeps wages within the boundary of livability is the fact that most companies tend to hire people they know and rarely advertise permanent jobs. This makes it hard to break into the industry in AZ and causes some archaeos leave the state.

What about archaeological technicians, crew chiefs, and project directors?

As you can see, these qualifications are focused on the highest level of the management pyramid. To my knowledge, there are no corresponding formal standards for the lower level folks (although I’ve heard California has some standards for techs). This is probably where most of the problems regarding the quality of CRM products originate. If poorly trained folks do a crappy job obtaining the archaeological data and lazy, unqualified, or disheartened project directors write up the reports, the resulting document and dataset will be subpar at best. This is amplified when projects are lowballed or have tight schedules.

I feel like the best way to improve our products and services is to improve the quality of the folks that produce them. One way to improve quality is to create minimum qualification standards more similar to the job descriptions companies use to hire employes. Another way is to invest in proper trainings, such as the Section 106 seminars put on by the Advisory Council for Historic Preservation (ACHP).

Most companies already realize the value of quality field folks. If you look at job descriptions and then scan the Secretary of the Interior’s qualification standards, you can easily see there is a huge disconnect between what companies are asking for in project managers and field directors and what the minimum federal requirements. I think we can improve the quality of our research and reporting by making the minimum standards for archaeology work correspond with the qualifications companies are already asking for. There could also be a grace period (5 years?) for new graduates to obtain the proper experience and training, which would allow them to qualify for positions as a professional.

Of course, this is just a concept. But there is no reason why it cannot become a reality. In the early 20th century, medical doctors pushed for official qualifications. Much of this impetus came from members of the American Medical Association (AMA) who urged states to create mandatory education and experience qualifications in order to practice medicine. The result: all beginning doctors today have extensive university education and a multi-year long residency.

Ultimately, the choice is up to us. We can continue on this path until only the wealthy and folks with PhD’s can afford to do archaeology (just like in the old days). Or, companies can pull a couple minivans up to the local Home Depot and hire a bunch of “archaeologists” to do to do the surveys and excavations they’ve been contracted to do. OR, we can get behind the idea of improving our trade and create some functional qualifications and certifications that meet the needs of our industry. We also need to enforce the regulations we already have so companies that try to undercut the market can no longer compete.

I believe Captain Planet said it the best, “The choice is yours!”
If you have any questions or comments, write below or send me an email.


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