Presidential Records Management Directive: It Takes A Village
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User Rank: Apprentice
8/15/2014 | 11:32:20 AM
Takes MUCH MORE than a village
For this effort to succeed, it will take funding and staffing... lots of both.  And given the manner in which funds are allocated to Federal Agencies (and their Contractors, who manage the Lion's Share of Federal records), we've already missed the boat for FY 2015.  The budgeting process for FY15 failed to include ANY estimates of cost/effort for this work, because few Agencies have even scoped it yet.

The other key component missing is written guidance from NARA providing specifications, processes and practices needed for proper capture and conversion of these records into digital formats.  Many "Permanent" records are still in regular active use by Agencies and Contractors, so when this effort takes place, "reference copies" will need to be retained locally to support ongoing work, in some cases for DECADES into the future. 

Guidance regarding preparation, sampling procedures, QC for scanners, selection of proper equipment, minimum required metadata elements, common file naming conventions, and capture in a quality for legal acceptance should ALL be produced by NARA in a "manual".  This guidance should CLEARLY DETAIL the requirements to allow Agencies, Contractors and others (if the work is vended to a third party) to perform the work properly.  36CFR lists Standards for micrographic work, but fails to give guidance for conversion of paper source materials to digital images. As a final step, captured images and metadata applied need to be QC checked to ensure there are no skewed images, dyslexic entries, or glaring errors.  Where this becomes even more critical is images will be transferred to NARA from many different Agencies and then managed in a single repository. The potential for commingling of content and items with identical identifiers overwriting each other is HUGE.

Standards for consideration should include:

ANSI/AIIM TR31, TR34, MS 44, MS52, MS54 and ISO TR 15801 and 19005-1 AT MINIMUM.

But rather than simply citing the specs, NARA should dig out the SPECIFIC necessary requirements and put them into language and methods for Agencies to follow in a "cookbook fashion".  The reason this is CRITICAL, is if a wide range of Agencies are left on their own to determine how to go about doing this, then the original source materials are destroyed. Once the resultant images are captured, if insufficient, the source information WILL BE GONE.  Key to consider is there is a REASON these records have a Permanent retention.  If the information included in them is no longer accessible, then all is lost. 

The long accepted estimate of the volume of Federal records that reach the level of Permanent is anywhere between 3-5%, however, with some Agencies the number is substantially higher.  And some of those records are critical to Agency process and practices.  Among the more obvious examples are records from DOE, DOD, DOJ, HHS, and DHS.



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