M-19-21 Digital Records Requirements Not so Simple

Just because M-19-21 digitization sounds easy doesn’t mean that it is. Like separating two flat pieces of Lego. Or matching socks out of the dryer. Or folding a fitted sheet.

Or consider this straight-forward sounding M-19-21 digital records requirements (item 2.4) relative to the transfer of records to NARA:

By 2022, NARA will no longer accept transfers of permanent or temporary records in analog formats and will accept records only in electronic format and with appropriate metadata.

After December 31, 2022, NARA will no longer accept new transfers of permanent or temporary analog records to the fullest extent possible. NARA will continue to store and service all analog records transferred to a Federal Records Center by that date until their scheduled disposition date. Once those records reach their disposition date, NARA will accept the permanent records into the National Archives in their original (analog) format and will appropriately dispose of the temporary records.

Beginning January 1, 2023, all other legal transfers of permanent records must be in electronic/digital format, to the fullest extent possible, regardless of whether the records were originally created in electronic formats. After that date, agencies will be required to digitize permanent records in analog formats before transfer to NARA. Digitization and transfer must be made in accordance with NARA regulations and transfer guidance, including metadata requirements.

On the surface, this sounds pretty straightforward. Some bosses I worked for over the years might respond to this mandate in this kind of fashion: “Sure, paper is a pain. But for heaven’s sake, just scan it and send it along; I think I saw some scanners at Best Buy the other day.”

But meeting the M-19-21 digital records requirement isn’t just a question of scanning a few file boxes of paper. M-19-21 digitization means making sure each image is in the right format and that no information has been lost along the way. It also means that appropriate metadata has been assigned. And most importantly, it means being able to do all this at scale and that the digitization process itself can be audited and verified.

Not so simple.

Per NARA M-19-21 digital records requirements, general requirements for scanned text include the following:

  • Agencies must digitize to standards appropriate for the accurate preservation of the information on the printed page. When converting analog or film based material (microfilm, microfiche, slides, etc.), agencies must digitize to standards appropriate for the accurate preservation of the original image;
  • Bitonal (1-bit black and white) images must be scanned at 300-600 ppi. Scanning at 600 ppi is recommended. This is appropriate for documents that consist exclusively of clean printed type possessing high inherent contrast (e.g., laser printed or typeset on a white background);
  • Gray scale (8-bit) must be scanned at 300-400 ppi. Scanning at 400 ppi is recommended. This is appropriate for textual documents of poor legibility because of low inherent contrast, staining or fading (e.g., carbon copies, thermofax, documents with handwritten annotations or other markings), or that contain halftone illustrations or photographs; and
  • Color (24-bit RGB [Red, Green, Blue]) must be scanned at 300-400 ppi. Scanning at 400 ppi is recommended. Color mode (if technically available) is appropriate for text containing color information important to interpretation or content.

Anyone in the scanning business for any time will recognize a recipe for some pretty big file sizes in these requirements. But even this is just one part of the M-19-21 digitization puzzle.

Think for a minute about the huge variety of potential records types and formats that don’t fit neatly into the above “scan some paper documents” metaphor. Take a look at the NARA guidance for each of these — HERE — and you can get some idea of the complexity of creating a true digital government strategy.

Computer Aided Design
Digital Audio
Digital Cinema
Digital Video
Digital Still Images and Photographs
Digital Posters
Geospatial Formats
Presentation Formats
Textual Data
Structured Data Formats
*Web Records

*In the next few posts, I’ll talk a bit about these last three — because hey, how complicated can they be? Spoiler alert — very.

#NARACompliance #M-19-21