NOTE:   I bet the entire Listserv that no more than 10 of you will 
even render an opinion on this key issue.  But if more than 30 Records 
Managers send a comment to NARA on the Records Center Design Issues 
then I will personally pay for dinner and wine for the entire Listserv 
party in Chicago.  I think Chicago is supposed to have good ribs right? 
  So Ribs and Wine and Hot Wings for the Listserv party if more than 30 
of the 1600 here speak up and fight for the protection of records.

Also could Nancy Allard of NARA provide the proper links to the Web 
Site so I don't give the wrong information?

_____________
Comments to Proposed Rules Changes to 36CFR, Part 1228

ARMA has had to ask for an extension to allow time for more comment. Or 
should I say "any" comment by records managers. So far two records 
managers have responded from a body of 5000 or so.

After years or working with records managers, I have great respect for 
you.  But you are letting the industry down by your lack of interest in 
the comment periods for NARA on changes to the fire code and design 
issues for records centers.  Even if ARMA presents an eloquent opinion, 
where is the support for that opinion that records are important and 
must be protected to the highest standards as they protect the rights 
of the citizen, the voters and commerce.

Several independent records storage companies have spoken out against 
gutting out the fire standards for warehouses so a few giant records 
storage companies can make a few more cents per box.  I commend them 
for their input. But where is the records management community's 
opinion on this?

As one individual described records managers  "You don't know about any 
of these issues but more importantly you don't care!"  One poster on 
this List said "Nobody cares what records managers think!"  Well NARA 
cares what you think!  And the Office of Management and Budget of the 
Federal Government cares what you think!  It is your opinion more than 
anybody else in the world that matters here.  This is your fight and 
you have a Dog in this fight and he/her is losing because you won't 
stick up for it.

I hope you will take the time and spend five minutes on writing an 
email to NARA to provide support for their Standards against those who 
seek to diminish them.  If you do not, then those with the paid 
lobbyists will be the only voice the OMB will hear.

If every member of the ARMA Listserv would send one comment to NARA 
these standards would not be weakened. Send your email to 
"[log in to unmask]"
with NARA Comments  RIN 3095-AB31 in the subject line.

You need to put this at the top so they can see the comments are coming 
from individual records managers.

Submitted by:
Name
Address
email
Phone

Provide a short Bio of who you are and your interest in the protection 
of National Archive Records and Records Management in general.

You can speak in general about why records needs the highest level of 
protection, or you can be specific.  Go to the NARA Web Site and you 
can see all the changes. Here are just a few of the most ridiculous 
changes to the NARA Standard which, if allowed to be modified, will 
then become the same argument for changing the NFPA 232 document that 
governs your records storage vendors centers.

Section 1228.230(l), Use of Open Flame Equipment

 Australia, Britain, Canada and the United States have all written 
various codes forbidding or discouraging the use of open flame heaters 
in warehouses storing records.  Those who argue there is no history of 
fire in records warehouses due to this, say it with tongue in cheek, as 
they know that they have been forbidden from use for so long that there 
are no fires to point to with this as a cause. If a forklift or other 
equipment for moving records was to hit a heater with a gas line or the 
gas line itself, the potential for an explosive gas fire would be very 
high.

The large records storage companies who wish to build warehouse 50 to 
100 feet high say that other types of heating systems add to the cost 
of their facilities.  They do not mention that income from storing 
records is far in excess of that of storing tires or furniture or other 
commodities.  Records require better fire protection. Records are not 
some base commodity. They represent archival information, the interests 
of plaintiffs and shareholders, they protect us when whistle-blowers 
point out fraud and corruption.  Therefore these Astrodome size 
warehouses must be discouraged.  A single fire destroys 10,000 
businesses records or the archives of an entire nation.  That is why 
compartmentation is necessary, to limit individual loss.


Section 1228.226, Definitions: The issues range from defining walls to 
be real Rated Fire Walls to just being fire barrier walls which due to 
vague descriptions could be any type of construction and make the claim 
that it is a barrier to fire. (How good is anybodies guess???)

Section 1228.230(e), Fire Resistive Rating of Roof:

The intent here is to lower the fire resistance of the roof structure 
to 1/2 hour and the column ratings to 1 hour.  Given that so many 
records centers are in multi-tenant facilities or mixed use facilities, 
this is a recipe for Disaster.  Fires will race across a roof structure 
igniting facility after facility. The fire rating of a roof is 
important for this reason but also for protection against arson.  Why 
have concrete walls or other fire resistive materials and the roof can 
be made of wood with a tar coating.  Starting a fire on a roof 
structure where an accelerant can be poured across the roof, ignited 
and then burn through to all portions of the warehouse is a weakness 
that must not be rewritten into codes because those bidding on storage 
contracts want to build cheaper warehouses.

Also building structural columns need to be rated for the same level as 
the walls or the roof structure can collapse and expose other parts of 
the building to fire.

But these are just a few areas that can be discussed.  You know this 
issue better than me.  Your opinion matters more than mine.  But how 
can you ask people to respect your opinion if you never give it when it 
matters.

If nothing else think of the affect you can have on the Chicago 
Listserv Party.

   


Hugh Smith
FIRELOCK Fireproof Modular Vaults
[log in to unmask]
(610)  756-4440    Fax (610)  756-4134
WWW.FIRELOCK.COM

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