So you end up with 38 things to memorize, but you have no way of memorizing the order? So in 5 years' time even if you somehow manage to recall all 38 things without forgetting a single one (which is incredibly unlikely), you now end up having to brute force 38! possible combinations, which is impossible. Even if you could brute force a trillion combinations a second, it would take you over a trillion times longer than the age of the universe to even calculate 0.1% of all possible combinations.

Your system also has no way of covering duplicates?

All in all, as with any system which relies on memory alone, this sounds like a great way to lose your coins. Just write your seed phrase on paper like you are supposed to.