Frequently Asked Questions
The M-19-21 Directive and FADGI Image Quality
What is M-19-21?
The federal government’s executive branch-wide effort to transform records management policies and best practices—known as the M-19-21 directive—calls for a transition to a fully electronic environment. One component of the M-19-21 directive mandates that the National Archives and Records Administration (NARA) will only accept electronic records for all permanent government records after December 31, 2022.
What is FADGI?
In 2007, the federal government began a collaborative effort to articulate “common sustainable set of technical guidelines, methods, and practices for digitized and born digital historical, archival and cultural content.” This effort led to the creation of FADGI (Federal Agencies Digital Guidelines Initiative) standards—a four-star ranking system for digital capture image quality.
FADGI defines four quality levels of imaging, from one star to four stars. Higher star ratings relate to better and more consistent image quality, but require greater technical competence of the operators, more detailed quality processes, and increased capabilities from the imaging systems.
Why am I suddenly seeing “FADGI 3 Star Capable” labeling on scanners?
In December 2020, the National Archives and Records Administration (NARA) issued draft standards “proposing to amend our electronic records management regulations to add a subpart containing standards for digitizing permanent federal records so that agencies may dispose of the original source records, where appropriate and in accordance with the Federal Records Act amendments of 2014.”
The proposed standards for M-19-21 compliance—currently under final review by the Office of Management and Budget (OMB)—require that permanent federal records meet quality requirements that equate to FADGI 3 Star aimpoints and tolerance ranges. These proposed standards help explain why there is so much current conversation about “FADGI 3 Star compatible scanners” as federal agencies switch from paper-based to digital records management.
What kinds of records does the new standard cover?
There is a lot of confusion about the kinds of records impacted by the new digitization standards.
Permanent records are those approved by the Archivist of the United States as having sufficient historical or other value that warrants their preservation beyond the existing retention period needed for administrative, legal or fiscal purposes (At the end of the scheduled retention period, agencies then transfer permanent records to the legal custody of the National Archives).
The proposed new FADGI 3 Star compliance standards apply only to permanent records as approved by NARA – a tiny portion of the overall percentage of federal records. Per 84 FR 14265, “While permanent records require more rigorous quality standards for archival reasons, most temporary records do not need to meet those standards. Because the needs and uses for temporary records differ vastly across the government, it is not reasonable to set a single baseline image quality or other similar standards; different standards will serve to meet the business needs for different records.”
However, given the application of proposed FADGI 3 Star standards to permanent records—and the absence of overall standards for all other records—industry experts believe that over time, the FADGI 3 Star requirement could extend into RFPs regardless of record type, which is a primary driver of meeting FADGI 3 Star standards.
How do you recognize a scanner as being FADGI 3 Star capable?
To achieve FADGI 3 Star capable status for scanners requires the utilization of the Golden Thread™ analysis software. Developed by Image Science Associates, LLC (ISA), the Golden Thread analysis software specifies and assesses the quality of an imaging system—including consistency with FADGI 3 Star quality standards. Organizations typically use the software in two ways:
How difficult is it for a scanner to be recognized as being FADGI 3 Star capable?
Digital records management experts, such as those with QAI and ISA, believe that many large-scale and high-speed scanners can achieve FADGI 3 Star standards if they are configured properly. Vendors will need to demonstrate that the workflows meet the FADGI 3 Star specifications in real-time operational environments for short-term, as well as for long-term use.
Finally, it is important for future planning to keep in mind that the FADGI standards apply to the integrity and quality of the overall scanning and capture process, not just the scanner. It is equally important to understand that the FADGI requirement includes ongoing monitoring of the capture process, not just a one-time hardware installation.
What are some recommended best practices for meeting FADGI 3 Star guidelines?
The FADGI guidelines document provides a host of recommendations for many of the performance level specifications for the imaging environment, equipment testing and calibration routines. Below are some general guidelines recommended for still image capture following FADGI Star guidelines:
What technologies are available to meet FADGI 3 Star standards?
Quality Associates, Inc. (QAI), the industry authority in—and key provider of—compliance, digitization and records management solutions, has partnered with several of the industry leaders that manufacture FADGI 3 Star compatible capture solutions. including:
Additionally, QAI has formed a strategic partnership with Image Science Associates, LLC (ISA). The company*, known for having collaborated closely with federal archivists in several government agencies to help define and fully understand current FADGI standards, is the developer of the Golden Thread™ analysis software—widely recognized as the premier M-19-21 compliance solution for meeting FADGI 3-Star required quality specifications and standards.
*Don Williams, who founded ISA in 2006 when he left Kodak after a 25-year career working as a research imaging scientist interfacing with the digital image archiving industry, is the foremost authority on image quality specification and certification. Early on at ISA, he focused on both digital and traditional imaging practices across disciplines that included reconnaissance, microfilm, consumer photography and professional photography sectors—using the Association of Intelligent Information Management (AIIM) standards program that began with the creation of test targets to measure image quality back during the microfilm days. Mr. Williams has published extensively on both technical and policy matters as they relate to digital image fidelity and metrology. He sits on the Still Image Working Group advisory board and several international standards committees. He also is heavily involved in the digital image archiving community, frequently contributing to FADGI standards projects.
To learn more about FADGI requirements for your organization, visit https://www.qualityassociatesinc.com or contact us.