COMMENTS DUE BY END OF DAY TODAY!!!!

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Subject line: RIN 3095-AB31

The Proposed changes to the this Code of Federal Regulations facility standards will have a major impact on the level of protection provided to records stored by by the private sector, not only to Federal Agencies who are using NARA's Facilities.

These changes are under the guise of being necessary to provide an opportunity for "small and disadvantaged businesses" to compete with the Federal Records Centers to offer storage to the Federal Agencies and not to have to comply with the existing facility construction, operations and fire protection standards.

Keep in mind that the Office of Management and Budget has requested NARA make these changes based on the assertion by a professional association representing the commercial storage industry that these changes would help small businesses more fairly compete for business to store records for Federal Agencies... how many small businesses do you know that would be impacted by the se changes and would benefit from them?   Now, how many LARGE RECORDS STORAGE COMPANIES do you know that might benefit from them?

The primary concern for the Record and Information Management Professionals to consider is the backlash these changes will have on the NFPA 232 Standard if NARA is required to weaken these facility construction, fire protection, heating and handling equipment requirements, and the NFPA standard is what WE ARE ALL using to ensure adequate protection is provided to records we are required to manage.

I STRONGLY URGE YOU to make comment to NARA at the e-mail address provide above by the end of the day to ensure your voice is heard.

The chief areas of compromise sought are:

1) Lowering the requirement from the existing 4-hour FIRE WALL to a 3-hour "fire barrier wall", which is a simple free standing sheetrock wall, not required to penetrate existing walls, ceilings, roofs, or floors

2) Allowing for the use of mechanical handling equipment in the records storage areas, which could include the use of gas and propane  powered forklifts and other equipment where records are stored.

3) Allowing for the use of open flame heating equipment in records storage areas.

4) Maintaining the requirement for a maximum volume of no more than 250,000 cu ft of FEDERAL RECORDS to be stored in any one compartment, but allowing an unlimited volume of non-Federal records to be stored in the same compartment.

5) Dropping the requirement for a CERTIFIED fire protection engineer (FPE) and a civil/structural engineer to evaluate a facility, and relying on local building codes and acceptance that a seal on the drawings is sufficient proof of structural integrity.

6) Similarly, to drop the requirement for a certified FPE to certify the fire detection and suppression system, and to accept the design and installation of a NICET technician or installation contractor as being adequate.  (Seen any of the reports on the Diversified, Recall or Iron Mountain fires?)

7) Inclusion of the terminology "racking" in what is currently defined as "shelving systems" and to rely solely on the use of state and local codes to provide adequate standards for seismic bracing.

8) Removal of the existing requirement for computer modeling provided by an FPE as part of fire testing.

Larry Medina

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