Don,

I'd add another caveat. Aside from the 2019 deadline applying only to
permanent records (as you mentioned), it also only applies only to
ELECTRONIC records. If a business process is still creating the record in
hardcopy (i.e. for a management signature or hardcopy comment letters from
the public) there is no requirement that the agency scan the hardcopy in
order to manage the record electronically. What it prevents is the printing
of electronic record to hardcopy for the purposes of records management.

This is a big deal for me as my records center has over 2 linear miles of
permanent records in hardcopy either on-site or at a Federal Records
Center. There's no way we can get all that backlog scanned in 2 1/2 years
(nor do we have an approved policy allowing for the hardcopy to be
destroyed after scanning, so there would be no reduction in warehousing
costs by doing this).

Christopher P. Ferry, CRM
Boston, MA
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