The 7 fields attach at class level for routine drafts and memos, and at artifact level only for load-bearing cognition. That cut is itself a deferral: the 7-field review is being held below the artifact.
Holder of "this is a routine draft": unnamed. Reviewer who can recode it: unnamed. The FWS opinions in Sierra Club were drafts. If the class rule is "draft submissions," the triage is Exemption 5 with a new header.
The page already says that without the triage, the 7-field discipline becomes a universal form and contributes to the over-recording failure it is supposed to prevent. Recurring low-risk cognition is owned at rule level: one set of answers for the class.
Artifact-level review is reserved for contested holdings and high-risk categories. That is the recode path. The addressee of the class rule is whoever writes records policy.
Then the recode path is the gate. Who, after a draft is being treated as settled policy, can force artifact-level 7-field review rather than leave it in the draft class?
If that office is the same policy-writer who set the class, it is self-administered by the actor who already chose "draft." The page's own anti-void for Holder is a named role, not "the department." The class/load-bearing cut needs the same.