With the M-19-21 memorandum issued in June 2019, the U.S. National Archives and Records Administration (NARA) put federal agencies on notice: by 2022, they must be managing all permanent records in electronic format, with metadata, and they must be managing all temporary records in electronic format or storing them in approved commercial records storage facilities.
Given the size of this task – and the fact that the effort is largely unfunded at this point – 2022 does not offer a lot of time to make this transition. Further, the scope of the requirements compared to the time available creates risks that federal agencies need to understand if they are to meet this mandate.
Dealing with the proliferation of document formats introduces complexity.
The proliferation of electronic formats adds significant complexity to the task. While NARA has identified different types of records that must be managed – including text and SMS message, social media records, voicemails, etc. – this list does not account for the huge range of formats in which electronic records can appear.
For example, a document might appear as a PDF document, a text file, or a proprietary file format specific to a now obsolete program. Some records may be accessible only through a single or very small number of programs (like an engineering AutoCAD drawing). How can records managers properly address not merely the categories of records that must be managed but also the staggering array of formats that can populate those categories?
Elevation of facsimiles at the expense of originals could erode quality.
One solution to the previous issue is to somehow convert the original record, or create a facsimile of it,in a standardized format that’s universally accessible and is expected to have a long lifespan, like a PDF document. However, this could risk that agencies will begin managing “inferior digitized copies of valuable originals,” according to the Federation of American Scientists (FAS). In response, NARA told FAS the onus is on agencies to change their practices to ensure all digitized records meet “archival standards.” That alone can be a big ask. Any solution will have to be able to accommodate an array of both record types and file formats.
The need to do it all, quickly, makes the whole effort harder.
The ambitious timing adds pressure to potentially bite off more than an agency can chew. This is particularly true during the transition when agencies are still handling both electronic and paper records.
Even NARA acknowledges this. “You can’t really, with the limited resources that we all have, focus on electronic records and do it well, while also at the same time trying to manage legacy paper systems and processes,” said Laurence Brewer, NARA’s chief records officer, last year at the 930Gov records management conference in Washington. The answer, he suggested, was to ensure staff already comfortable working with paper-based records management would feel equally at ease with electronic solutions.
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