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.

  • ONE STAR – Should only be considered informational, in that images are not of a sufficient quality to be useful for optical character recognition or other information processing techniques. One star imaging is appropriate for applications where the intent is to provide a reference to locate the original, or the intent is textual only with no repurposing of the content.
  • TWO STAR – Appropriate where there is no reasonable need or expectation of achieving 3 or 4 Star performance. These images will have informational value and may, or may not, be suitable for Optical Character Recognition (OCR).
  • THREE STAR – An exceptionally good image capable of serving most use cases, which includes being suitable for OCR as well as for reprint on the best commercially available printers.
  • FOUR STAR – Images created to a 4 Star level represent the state-of-the-art in image capture and are suitable for almost any use.

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.

  • This rulemaking covers only permanent paper and photographic records, including paper and photographs contained in mixed-media records.
  • NARA previously amended 36 CFR part 1236 to add standards for digitizing temporary records, which constitute most Federal records (RIN 3095-AB98, 84 FR 14265 (April 10, 2019), effective May 10, 2019).
  • The standards in the proposed rulemaking apply retroactively to digitized permanent records that agencies have not yet transferred to the National Archives.

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:

  • First, for acceptance testing of scanners and cameras. Before signing off on an expensive and complex scanning device, customers should make sure that it is performing as expected. In this way, scanner vendors can demonstrate that their equipment meets FADGI 3 Star image quality standards, and agencies can make sure that their operating environments meet the FADGI 3 Star standards.
  • Second, for periodic image quality monitoring and audits. Any number of imaging inconsistencies can appear—and go unnoticed—into digitizing workflows of an agency or service provider. These inconsistencies can range from incorrect exposure selections to inappropriate image processing choices. Meeting FADGI 3 Star quality standards is not just required during a system’s initial installation but also must be measured over time.

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:

  • Do not apply pressure with a glass platen or otherwise unless approved by a paper conservator.
  • Do not use vacuum boards or high UV light sources unless approved by a paper conservator.
  • Do not use auto page turning devices unless approved by a paper conservator.
  • For master files, pages, documents and photographs should be imaged to include the entire area of the page, document or photograph.
  • For bound items, the digital image should capture as far into the gutter as practical but must include all content that is visible by the eye.
  • If a backing sheet is used on a translucent piece of paper to increase contrast and readability, it must extend beyond the edge of the page to the end of the image on all open sides of the page.
  • For master files, documents should be imaged to include the entire area and a small amount beyond to define the area.
  • Do not use lighting systems that raise the surface temperature of the original more than 6 degrees F (3 degrees C) in the total imaging process.
  • When capturing oversized material, if the sections of a multiple scan item are compiled into a single image, the separate images should be retained for archival and printing purposes.
  • The use of glass or other materials to hold photographic images flat during capture is allowed, but only when the original will not be harmed by doing so. Care must be taken to assure that flattening a photograph will not result in emulsion cracking, or the base material being damaged. Tightly curled materials must not be forced to lay flat.
  • For original color transparencies, the tonal scale and color balance of the digital image should match the original transparency being scanned to provide accurate representation of the image.
  • When scanning negatives for master files, the tonal orientation may be inverted to produce a positive. The resulting image will need to be adjusted to produce a visually pleasing representation. Digitizing negatives is very analogous to printing negatives in a darkroom, and it is very dependent on the photographer’s/technician’s skill and visual literacy to produce a good image. There are few objective metrics for evaluating the overall representation of digital images produced from negatives.
  • The lack of dynamic range in a film scanning system will result in poor highlight and shadow detail and poor color reproduction.
  • No image retouching is permitted to master files. These details were pulled directly from the standard. They cover a lot of ground, but there are always decisions to be made that are uniquely related to the material to be digitized. There are 50 or so more pages of this standard related to workflow, color management, data storage file naming and technical metadata.

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:

  • ibml with release of the FUSiON™ FADGI-capable scanner series
  • Kodak-Alaris with release of the 5850 FADGI-capable scanner series

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.

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