 Ladies and gentlemen, welcome and thank you for joining today's NARA's Regulations for Digitizing Permit Records webinar. Before we begin, please ensure that you have opened the WebEx Chat panel by using the associated icon on the bottom right corner of your screen. Please note all your connections are currently muted and this conference is being recorded. You may submit written questions throughout the presentation and these questions will be addressed during the Q&A session. To submit a written question, select all panelists from the drop-down menu in the chat panel and see your question in the message box provided and send. If you require technical assistance, please send a chat to the event producer. With that, I will turn the webinar over to Arian Revampash, so please go ahead. Thank you, Michelle, for that introduction. Good afternoon, everyone, and as said, welcome to our webinar on the Regulations for Digitizing Permit Records. My name is Arian Revampash and I will be serving as the moderator for today's webinar. First some housekeeping information. The presentation slides that we are using today are already available on our website. We will place the link to those in the chat as well. When we have the recording available, we will also be posting it to this web page as well as our YouTube channel. A summary of this webinar and all relevant links will also be posted on our blog, Records Express, in the coming days. Records Express is where you can also find a series of posts with additional information about these regulations. For questions during the presentation this afternoon, please use the chat feature as Michelle described. We will be addressing those questions after the presentations. With that out of the way, I'd like to introduce the Chief Records Officer for the US government, Lawrence Brewer. Good afternoon, Lauren. Hi, Arian, and thank you. So as Arian said, I am Lawrence Brewer, the Chief Records Officer, and I am really excited to welcome all of you to this webinar. I cannot believe the numbers are still climbing. We're at, by my account on my screen, 640 attendees. So by the end of this webinar, we may end up setting a record in terms of attendance to one of the webinars that we've hosted. So thank you so much for tuning in, and I promise you we have a lot of really good information to share with you. But before we get to our speakers and introduce them and get to the program, I wanted to tell you all just given how many years and how much time and how much effort has gone into getting to where we are right now, which is having NARS regulations for digitizing permanent records now in effect, how much has gone into this. And it's really been a story of doing a lot of work to get this really watershed critical standards out for all of you to use. So in one sense, it's a story about persistence because it's taken us so long to get here. And I want to thank all of the speakers today and everyone on the team for all their contributions over many years to get us to the point and sticking with it and getting us across the finish line. This is also a story about patience from all of you because we know for years and years you've been waiting and we are finally at the point where we have these standards and can talk about them in final form and really roll up our sleeves now to get to the really critical part, which is implementation and making sure that all of us, our agencies, our vendor community are all fully aware of what we need to do and we're doing it as effectively as we possibly can. So for all of that, my thanks for all of you. We really appreciate you attending and we encourage you to ask questions, drop them in the chat. And we will have time hopefully at the end to answer some questions, but we have some very really important information to share, which is where we're going to begin. So with that, we're going to flip the slide and I'm going to turn things over to Lisa Harrell-Lampus and the team of speakers that we have for you today to start talking about digitizing permanent records. Thank you again for attending. Thank you Lawrence. I appreciate those kind words and I think patience and persistence are two great words to describe the path that we are on today or that got us to where we are today. And path patience and persistence are the hallmarks of where we'll be going next because we know the regulations for many people was really the first step in what is now a process of implementing these regulations. So I'm Lisa Harrell-Lampus. I'm the director of records management policy and outreach and I work for Lawrence in the office of the chief records officer for the US government. And joining me as a speaker today, I'm two of my colleagues, John Martinez and Kevin and I'll let them introduce themselves as well. Hi, I'm John Martinez. I'm supervisor of the policy and standards team. Our team works within Lisa's program and we're obviously that means we're also within the office of the chief records officer. And like I said, I'm supervisor of the team that developed this. One of the experts is here with us today, Kevin, who's going to introduce himself next. And let me pass it to Kevin. I'm an electronic records policy analyst and work for John and Lisa in Lawrence and have been involved in the development of this regulation, as well as other guidance that we put out relating to transfer of permanent electronic records. Thank you. And so the three of us today, we're going to cover our presentation. Our goal for this presentation is to provide a familiarity and awareness. I know there's probably a lot of questions that are going to come like, how do I implement and we'll answer those to the best of our ability at this time. Please know we'll be working on more products that we'll be sharing over the upcoming weeks and months. So I'm saying this now and I'll say it again at the end of the presentation. And so our hope is that the end of our presentation today. We'll have this understanding, this familiarity, we'll know what's in the digitization regulations and we'll take any of your questions towards the end. So let's get started. Next slide. Please slide three. I will say keep sending us questions. One of the questions we've already had is how do I get access to these slides? And they are posted on our website. So we'll drop in the link again as we, I'll thank you, Andy, and you just dropped in the link again. If you wanted to follow along and see those slides or have a copy for you, they're already available. So let's talk about how we got here. I'm going to cover in the beginning, I'll do a little scene setting and provide a little bit of context. We've written these digitization regulations for a specific purpose so that agencies can take analog records, source records, originals, digitize them, and send those digitized versions to NARA to serve in the place of the original records. The originals or the source records will then be disposed of, destroyed. That is the whole guidance approach that we've built the framework on. And that came from quite a few places. Starting in November of 2014, when the Federal Records Act was amended by Congress and signed into law, it told us, that's the first quote you're seeing on the screen, that we should do regulations, so that was clear, wasn't going to be a different type of guidance. NARA, I wanted you to do regulations for reproducing records using digital processes. We'd already had the regulations on photographic and micrographics, so that wasn't new. What was new was to say, do the digital processes with a view to disposal of the originals. So that was our foundation. In 2018, NARA issued one of its first strategic plans that said, we're going to issue regulations and clear policies, and I hope these policies are clear, that permit agencies to digitize records and wear appropriate disposal of the originals. And then we have two hallmark pieces of guidance, OMB and NARA signed joint memos that talk to the entire federal government about the importance of transitioning to electronic records management. And each one of those memos, they said, and NARA will issue regulations that provide standards for digitizing images and disposing or destroying the original analog records. So that is our philosophy. There's many reasons agencies have digitized records over time. They may have digitized for better access. They may have digitized for reference. They may have digitized records to put them into a system, so they can have a complete set of information to take actions on. These records, this guidance is set up again, so that you can digitize records and send those digitized versions to NARA. Next slide, please. So how did we get here? That's what we were told to do. The question is, how did we get here? And I just wanted to share the review process as a way of providing some context into what you've seen in the past and what you're seeing now. So nothing, I know, and it's also a little history lesson and you'll have to forgive me or archivists, we'd like to talk about our history. So starting in 2004, we got those requirements, but at that point we were actually very much focused on email, member email, email management. We were doing a lot of work, so we started our planning and then we started our drafting. And yada, yada, yada, the first piece of digitization guidance we issued was in 2019, and that was the digitization standards for temporary records. So we kind of thought we covered the majority of what agencies produce when they're digitizing records with those temporary record standards. And John's going to talk about them a little bit. So I won't scale his thunder. But once we had the temporary records, we were also starting to work on the more technical digitization standards for permanent records. Back in May of 2020, through the regular regulations process, OMB sent out the draft standards to its regulations liaison officers and federal agencies. And because we're NARA and we have a close relationship with federal records managers, we sent out the draft to our points of contact, hoping that the regulation liaisons and records officers would meet together and respond with our initial comments to our initial draft. And boy, did you ever. I have to say every single round of comments, as Lauren said, we paid the patient in persistence. I love it. We patiently worked through the comments. We created a draft. We got it, went through the process. And in December of 2020, it was posted for public comment. Again, we got so many comments from various members of the public and agencies again. And I say various, we had academics commenting. We had watchdog groups commenting, different people really provided us with a lot of context. So we took those comments. We redid them. We addressed them. We wrote the next version of the rights. That went to review to a certain number of select agencies. We are office of not O and B's office of information regulatory affairs said, you made substantive revisions. So we'll send this back to the agencies that commented, they gave us comments. We get it again. Got more comments. So we had a lot of back and forth. So what you're seeing now is different than what we saw in 2020 on then the miracle happened. We got them published as a final rule. We finished all the processes, got all the signatures on May 4th. They were published and just double checking my calendar. And just two days ago on June 5th, the regulations are now in effect. And they are now, they're done. So done. But are they really done? They're done. So now that is how we got here. I could go to the next slide, please remind myself it's on the next slide. The regulations were have, there was more in those regulations than just digitization standards. So I did want to comment if you read the whole package and said, wow, there's a lot in here. The digitization standards for permanent records are in sub part E, E for excellent, excellent regs sub part F contains metadata that is needed when agencies transfer permanent records to NARA. One of the comments we got back as we were doing our regulations was the importance of having transfer metadata. As people said, they're going to be transferring large sets of digitized records. So we need digit, we need transfer metadata. You need transfer metadata no matter when you send records to NARA or how. So we put that in its own sub part. So out of the digitization regs and some party came some part of metadata. We also had hanging along for the ride for those entire four years, a set of regulation changes that have nothing to do with digitization. It was the 1225.22 a where we have issued a new regulation that says agencies must review all of their schedules at least once every five years. And that should include schedules that are 10 years or older. So the clock on that right started two days ago. And in five years, we will see how that review has gone and what sort of guidance we need to help people with and what that review looks like. So that's in there. That's in the regulations package. If you have questions about that, that's fine. But neither of those two things will be our focus today. Next slide, please. And that's my context and my setting. And now I'm going to turn it over to John and Kevin to talk about the standards themselves. Thanks, Lisa. So we're going to start and as Lisa mentioned, we're going to take sort of a start by taking sort of a step back to talk about the digitization standards or temporary records. And so why are we starting with a discussion on temporary just to emphasize where we started with this and that the regulations just published are for permit, obviously. So and I think, Lisa mentioned that the regulation for digitization of temporary records was the first to be issued in 2019. And you can see here on the slide, the shortlist of the contents of the regulation for temporary. So very brief set of requirements is very brief requirements, brief set of requirements on its own, but especially compared to the standards for permanent records. It's probably much less than a pay printed page in the CFR of the requirements are the requirements for temporary are also at a much higher level, which gives gives agencies the flexibility as well as the accountability to ensure that their permanent records are digitized to an appropriate standard for your business needs. The high level requirements for temporary are really to capture all the information containing the original source records to ensure that you can use the digitized versions for the purposes the original records served. You have the ability to protect them against unauthorized alterations to digitized versions and to ensure that you can locate and retrieve access and use the digitized versions for the records entire retention period. And again, agencies have latitude on how to implement these requirements. You know, they agencies need to meet the thresholds in each area and ensure that those digitized versions can serve the same purpose as the original versions. The temporary regulation introduced the requirement that agencies the term validate that agencies validate the digital records that they create and that they comply with the regulation before destroying the source records, the original records that you digitized. So it validation means that you validate that the digitized versions are suitable quality to replace the original source records, document your validation process and that process again for temporary records, the validation process agencies have latitude agencies can establish their own process to validate that the digitized versions comply with the requirements in this subpart. We've had in 2019, we also issued a a frequently asked question document it's posted on our website. Obviously, an FAQ about NARA's digitization regulation. We'll be doing an update to that actually as part of the part of the part of the series of additional products or producing to support the permanent rack. Next slide please. So the moving to the standards for permanent records. This first slide shows the sections of the regulation for permanent. As we said, obviously this is more requirements and goes into much more detail than the regulation for temporary records. This is a higher threshold because these are to create the requirements in this in this regulation are to create digital versions that are going to serve the same purpose of the original ultimately be transferred to the National Archives and the original paper will be destroyed. So these are not just technical specifications either it's a holistic approach and includes important processes for records management documentation and quality management as well. It goes beyond sort of it goes beyond questions sort of like what resolution do I do or what file format do I use. It's about we try to make a sort of a total quality management approach to ensure completeness usability and again to create digital versions that can serve the same purpose as the original. Next slide please. So the first part I'm going to talk about is the scope section. The scope addresses the types of materials covered by the regulation and you can see on the slide the first part talks about what is it's applicable to records that can be scanned using reflective techniques meaning the digitization process means that light bounces off the surface of the of the document being digitized. So for this we sort of applied it 80-20 rule. We figured this would be the 80% was paper records all sizes and types printed photographs photographic prints and as part of this we also address address mixed media records. What's not in this in the scope is things like photographic negatives motion picture films microphones dynamic media meaning audio visual audio audio or videotapes. Those are not in the scope for this that's going to be the next regulation we work on. So the scope also addresses how the regulation establishes the process and requirements to ensure that agencies can identify the records that you're going to digitize for each project how to account for the records covered by the project implement how to implement quality management techniques for things like verifying your equipment performance and to monitor the processes to detect and correct errors and to produce complete and accurate digitized records again that the agency can use for the same purposes the original source records and the scope also discusses the validation validating that the resulting digitized records meet the standards in this subpart what's again talking about what's not in the scope and this was a question we got a lot at least was talking about the comment periods we had both with the public and agencies but one thing that's we do mention we mentioned that is not in the scope is does not require any that optical character recognition be performed OCR we got a lot of questions about OCR it's not a requirement for this for in the digitization regulation by the same token obviously it doesn't prevent agencies from performing OCR if there's a business need it also doesn't address what we also don't address is other applicable laws and regulations governing documents or digital files in other words if it's addressed elsewhere we didn't repeat it in here this purely deals with the digitization process so we don't get into you know we don't address things like handling of classified CUI questions compliance with section 508 for those areas obviously an agency should work with their legal counsel and other officials to ensure compliance where applicable with these and other requirements and we also don't address other business needs or legal constraints that an agency may have that make it necessary to retain source records for a period of time after digitizing and same thing we advise working with legal counsel and appropriate officials to determine you know if the return longer retention question related to rights and interests litigation holds similar reasons that's an internal discussion and and determination and then again mixed media is included because it's not in common for other media types to be co-located with paper records a CD have them forbid a floppy disk may show up interspersed with your paper records and we'll talk more about mixed media considerations in depth a little bit into the presentation next slide please so the next section is about records management and as we said this regulation includes important processes as part of digitization work as well as the more technical requirements and specifications it's important to establish intellectual control first over the records to be digitized this section talks about how you want to inventory the records to ensure that records are prepared and index and maintained in their original order that you survey the source records for any potential preservation problems make sure you're selecting the equipment that is going to be able to safely digitize those originals and then it discusses identifying the age the media types dimensions the required level of detail and again the condition of the source records prior to digitization again to make determinations about you know it will there be an impact on the image capture techniques you use the equipment you select you know you look at things like the type of paper the type of printing or the size of the records and see if those have an impact on what kind of decisions or equipment you're going to use to digitize and you'll also want to note to identify and note there any missing record or any records that can't be digitized you'll use that informant and part of the reason you're documenting this is you're going to use some of this information at the time of transfer to populate the note section of the ERA TR again when it's when it comes time to transfer them to NARA the digitized origin to NARA this part also talks about capturing relationships any relationships must be captured as part of the digitization process for example are there case files that are associated by case number are there multiple documents staple together what are the relationship of one folder each other folders in the box and you can capture the relationships through metadata and we'll talk more about this in the a little later in the presentation more about metadata or by using file formats that allow for multi-page files such as PDF or TIFF and then during the digitization process you also need to ensure that there are appropriate safeguards for the source records to prevent loss or damage and to minimize the risk of any unauthorized additions or deletions or alterations to the digitized versions next slide please so this next part is about documentation requirements agencies must create digital documentation when digitizing permanent source records the documentation is going to be maintained along with the digitized records until the records have been transferred to NARA and NARA notifies that the agents identify notifies that the the accessioning process is complete disposition of documentation is done in accordance with the appropriate general record schedule GRS or agency record schedule and again this documentation will help the agency some of the information here will help populate parts of the transfer request instrument the TR in ERA we got a lot of questions I'll say we got a lot of questions also during this about will NARA you know what is NARA's role in looking at that you know it does not inspect this documentation and most of the questions were about at the point of transfer is NARA gonna require it review it the answer is no where the one area where NARA may ask to see the documentation is from the office of the chief records officer at the oversight team when they do one of their agency inspections they may review documentation as part of one of their site business so you must create several documents when digitizing permanent records and like I said retain them in association with the digitized versions one is a defined project plan that addresses the record series or file units to be digitized things like the method that we that will be used to name the records the date range if there are missing pages any gaps the estimated volume the media type dimensions the equipment and software you're using the estimated file storage requirements access or use restrictions the method used to capture relationships which we talked about and any metadata if you have we have metadata like I said we'll talk about metadata later and if you have any metadata element labels that differ from those that are specified in the rag will ask you for a crosswalk as well another document will require a piece of documentation is a quality management plan that Kevin's going to talk more more deeply about quality management and quality control coming up but at a high level the quality management plan describes the policies the functions the roles and responsibilities and requirements and objectives the project and the quality control component addresses inspecting image and metadata quality and corrective actions to ensure that the records digitized versions conform to your requirements like I said that's coming up next and then additional documentation as well could be any information needed to associate the digitized records to the source records the agency record schedule and if there are any additional related finding aids or indexes or inventories metadata schemas that are used to manage the records they can serve as sources of the metadata you'd want to capture that and keep it alongside as well next slide and like I said we're moving to quality management and other areas so I'll turn this over to Kevin thank you John as John mentioned for the documentation you'll be capturing information about quality management and here we're using quality management as an umbrella term under which there is quality assurance and quality control and throughout this if you read the reg you'll see reference to something referred to as Faji which is the federal agency's digital guidelines initiative and we were very fortunate that Faji exists it is a group that's managed by the Library of Congress but NARA has participated in for I believe about 15 years and what Faji has done is worked with the vendor community to come up with the image science for how to accurately record information from paper or film so that you have assurance that digitization is being done properly so the quality management in this regulation is very similar to that in Faji and it may be a little bit different from quality management that you've done in the past if you've digitized where you go through your digitization project and then do random sampling at the end here as John mentioned it's a total quality management process it's interwoven into everything and so when we talk about quality assurance that includes working with your vendors to ensure that the equipment that you purchase or rent is appropriate one for the material type if you're using 8.5 x 11 modern office paper then high-speed sheet-fed scanning may be appropriate but if you're dealing with bound volumes or onion skin or something more fragile then you'll want to find equipment that's appropriate for that and then the quality control includes actually the testing and analysis of your equipment and then periodic inspections throughout the process and that helps kind of relieve that burden because you don't want to get to the end where you've digitized large volumes of material and then discover errors and have to pull the paper again and start over or send them back to your contractor so it helps identify malfunctioning equipment if you set up your software incorrectly done metadata and properly or other human errors which I am personally guilty of having committed in the past this quality management approach is quite lengthy and there's a lot there but it you know it's a part of Fadji and has been proven to make digitization more reliable and more efficient so could we go to the next slide please so I've mentioned Fadji and I've mentioned that quality management is interwoven into this process and so on the screen is one of the test targets that were developed as a part of Fadji and it's part of what they refer to as the digital image conformance evaluation or dice process and by scanning this test target and then analyzing the results of that scan with the dice software you can actually determine if your equipment is capable one of achieving the parameters in this regulation and then as you continue to digitize make sure that nothing has gone wrong a lamp hasn't failed or a mechanism isn't working the way it was when it was new because it analyzes the colors for accuracy and then it also measures the resolution because unfortunately just setting your resolution for 300 PPI does not guarantee that your equipment is actually capturing 300 PPI so it's wonderful that we had the Fadji process to rely on so that we didn't have to come up with other quality assurance mechanisms so next slide please so file formats as John mentioned you know throughout this we're balancing the cost to agencies but then the archival needs of the National Archives and researchers in the future and so we're mindful that there are lots of different agencies doing lots of different types of digitization and so we've tried to give options both in terms of file formats as John mentioned if you're scanning a case file and you want to keep material together then packaging it in the PDF may make sense to you if you're doing other types of digitization that may not be a requirement what is novel to this regulation is we have included several types of compression deflate also known as zip but then also JPEG 2000 compression and one thing the agency should be aware of is and this is coming from Fadji's latest guidelines we are allowing up to 21 20 to 1 visually lossless compression and that's with the requirement that if you do that there is no degradation or negative impact on the resulting images but that's you know maybe of interest to agencies if you're doing very high volumes where file size and storage concerns are going to be something that you're looking at and so would encourage you to work with your vendors to test and kind of select from these what's going to best fit your needs so next slide please so 1236 50 is the actual digitization requirements and these again are extracted from Fadji and modified to meet the requirements of federal agency digitization in the Fadji world they line up with what's referred to as Fadji 3 star and there are two major subcomponents in this digitization the actual parameters and one is for permanent paper and then you know as John discussed the scope we were trying to be able to account for as much materials we possibly could and so since the type of equipment that's used is common types of quality control are common we were able to include printed photographs so the actual parameters are a little bit different so that there are these two sec sections detailing what parameters apply to each and as I said earlier the equipment that you select should be appropriate for the material that you have and make sure before you contract or purchase that it's actually capable of meeting the requirements in this regulation and implement the quality analysis that was described earlier in the quality management section and continue to test throughout the process so that you catch any mistakes early and can correct them so the next slide please next media again as John mentioned we recognize that when you pull boxes of what you think are paper records it's not uncommon to find other physical storage device or media inside a box with paper the expression mixed media actually refers to record files that exist on different media so you may have a medical file and then an x-ray and so we've included instructions for that case where you discover related permanent records in your box but they just happen to be on some other media that you're not able to digitize at this time but also instructions in case you find a thumb drive and there's other material on it that's not related to the paper records and that's because you know part of the records management is there is an obligation to treat all records appropriately and so there's instructions to analyze those materials to see are these federal records do they belong in another record series or do they relate to what's the contents of this box and so that's just to assist agencies to avoid either missing failing to digitize or properly account for all of their records so could we go to the next slide please metadata obviously metadata is an important aspect of this process as has been said repeatedly especially with the permanent records the resulting digital files are going to be required to stand in place of the source records and since the documentation that is created by agencies is not going to be transferred to NARA these files need to have all of the information that they're going to need for researchers agencies and the National Archives to be able to manage them appropriately and then discover them and interact with them so as you can see we have administrative metadata to assist in the management and that includes the disposition and item number but then there's also requirements for descriptive metadata which relates to the source record and since the source records are going to be destroyed at the end of the process they're not around for researchers to refer to there is this metadata which describes the source records so that a hundred years from now people have an understanding of what what was originally recorded by an agency and then also any access or usage restrictions that apply to the source records must be captured and retained in the digital versions that are created again so the agencies and the National Archives can manage them appropriately moving forward your equipment is going to generate technical metadata and we have laid out some requirements that will help us preserve these records for as long as they're needed we've also included instructions as part of the records management for maintaining the digital records until you transfer them to NARA and one of those is the generation of checksums so that you can monitor for any unauthorized alteration or corruption that may occur through time and then there's the technical metadata describing the digitization process in the equipment that you've used so could we go to the next slide and validation again this was introduced with our temporary regulation and as John described NARA is not involved in inspecting or approving of your digitization projects our oversight team may conduct an inspection but that's a distinct thing and so this validation at the end of the process is a very critically important step and we recommend that your agency meet with your general counsel and review who is the appropriate person at your agency to conduct this validation it's a high-level process that's distinct from quality control or quality management it's not a review of every image it's more a high-level review where you look at the documentation you look at your processes and you make a determination that you as an agency are satisfied that you followed these regulations and that you feel that what you have produced is of sufficient quality and completeness and accuracy that the digital records can take the place of the source records and once you've done that you have the authority to execute disposition on the source records according to the record schedule or associated GRS so can we go to the next slide and I believe I'm turning this over to Lisa thank you so much Kevin and John so once you hit validation you have come to the end of what is in the regulations on how to digitize permanent records before we get to questions I just had a few more I said in the beginning my goal was to hopefully leave all attendees with an understanding and familiarity of all the parts of the digitization regulations I also said we know that that was the start of our work there's a lot more information we need to provide you on how to implement these digitization standards there's been a lot of questions we've given them we're not appropriate was appropriately not addressed in regulations but there might be some explanations coming so what you're looking at right now is the link that our colleague Andy Leo has been dropping into the chat with crater web page under our hot topics or important topics and this is the the web page where as we develop future products or we have answers they're going to be on this web page and for those of you on the phone it's www.archives.gov backslash records hyphen management MGMT backslash policy backslash digitization and I hope a quick couple of searches will get you to this page you can see here we've got a couple of boxes of information and we plan to add more this is where you can find a link to the standards and if you scroll down on your page you don't see it on my screen capture underneath that there's the box where we're communicating and that's where the web's oh they're forward slashes thank you Patty Stockman I just saw your chat forward slash forward slash forward slash you'll be able to find information on communications so more to come and this is the place to find it and then in closing I think there's one more slide I did want to say how are you going to find these additional products I wanted to let you know what was coming so we have been issuing a series and we're we're working through that there's a few more to come on our records express blog and that was sort of doing in writing what we did here today in our webinar take each one of those sections piece by piece and talk about what's in them we will be issuing a GRS 4.5 for digitizing records believe that's one of the questions we had in chat already is has transmittal 34 with that GRS gone out yet and the answer to that question is no it hasn't gone out yet it's still going through the internal signature processes and we expect that GRS will be issued I would say hopefully the next few weeks those of you know when Nara says soon we know sometimes soon takes longer than any of us would appreciate but it should be up very soon in a few more weeks and that did GRS is key as John said in order to implement the digitization regs give you the standards that you have to validate to the disposition authority comes from your record schedules either a general record schedule or an agency record schedule and we will work to get that general record schedule out as soon as possible and as Kevin and John mentioned we know we have more digitization standards to issue the next set of issues things will be issuing will be those film records we expect that will go much much faster than the package we put out as you saw our history of going through it because we're going to be adding those standards to what already exists so we don't need new documentation new records management new valid and that's all going to stay the same we just need to get your technical standards for digitizing those types of materials and I appreciate all the suggestions you haven't been able to see them but I've been watching them come in through chat we are going to be working on some more guidance products and I appreciate the suggestions I'm sure we'll talk about that soon so believe that takes us to the end of our recorded so I our end of our formal presentation so I'll turn it over to Arian. Thank you Lisa and at this time let's stop recording.