Observations on the Process

E-signature and Records Management - while NARA has published the helpful Records Management Guidance for Agencies Implementing Electronic Signature Technologies it is not clear that the NOAA General Records Schedules or, where they exists, Regional File Plans, have been adapted for situations where electronic records may actually be the "original", and not just an utilitarian copy of a paper document. For example, in the NOAA General Records Schedules, File Series 1504-20, Dedicated Access Permits, was revised relatively recently (9/06), but it still states:

Disposition: a. Eligible application files: Cut off 5 years after permit granted. Retire to the FRC one year after cut off. Destroy 25 years after cut off.
b. Ineligible Applicant Files: Cut off at end of calendar year in which the file is closed. Destroy 6 years later. c. Electronic copies created with electronic mail, oracle or other database systems, and
word processing applications: Same as hard copy files. Delete if/when recordkeeping copy has been created.
This appears to still assume that the "recordkeeping" copy is based on paper, and that electronic records are copies of paper documents. Perhaps that assumption is always still valid for File Series 1504-20, but, it has been difficult to find any examples of records schedules or file plans that recognize an electronic document as the "original" record.

There is clearly a lot of activity around electronic records; this particular observation is about the difficulty of finding a specific example in the General Records Schedules or a Regional File Plan. A search for general information about electronic records might start at NARA Electronic Records Management (ERM) Guidance on the Web or Electronic Records Archives (ERA).