Distinguished Colleagues:

In the next few days the comment period for the NFPA 232 Standard for
the Protection of Records will close out.  I need your assistance and I
will try to make this as easy as possible for you to participate and
play a role in something that has a large bearing on your future as a
respected records manager officer.

THIS IS YOUR LAST CHANCE TO INFLUENCE THE COMMITTEE.  NO MATTER WHAT;
THE STANDARD WILL GET BETTER OR WORSE IN THE NEXT COMMENT PERIOD?  THE
NFPA IS AMAZED AT THE LACK OF INTEREST OF THE RECORDS MANAGERS WHO
SHOULD HAVE A SAY IN THIS. THEY ALSO RESPECT THE RIGHTS OF RECORDS
STORAGE COMPANIES TO DO WHAT THEY WANT WITH THE STANDARD IF YOU HAVE NO
INPUT!

I need your comments in the form of an email and you must describe your
function as a records manager in an organization.  These letters will
be for internal NFPA discussion at the Technical Committee and will not
be referenced outside that meeting.

It is as simple as this, include in your letter comments from below,
that you agree with and forward them to the Committee below and you
will have an effect on the future Standard.  Please send these emails
to:
[log in to unmask]       [log in to unmask]    and me so we can have them
as part of our comments.

All you have to do is copy and paste those comments that you feel
represent your opinion on the current state of the industry and with
this direction for the Protection of Records Standard?  Notice I have
equal numbers of Protect Records and Control Costs since this is really
what the balance is about.

Here we go:

(Protect Records:)   The NFPA 232 Protection of Records Standard is
unique in that it protects the vital records of commerce and is a
guiding standard for not only here in the United States but other
countries as well. Efforts to try to transfer protection of records to
other standards such as NFPA 5000 which is a Building Code Standard for
normal structures and contents is totally inappropriate. Failure to
provide the utmost protection for records in storage within records
centers will have catastrophic effects on the operation of our country
and our commerce.

(Control Costs:)  As a records manager, I think it is totally
appropriate to allow records centers to be any size that affords the
records storage operator the ability to cut construction costs. The new
style of records centers which climb to 65 to 100 feet in height and
allow for storage of one to two million boxes of records in one bulk
warehouse are totally acceptable to our organization.  As a records
manager, our goal is to cut records storage costs.

(Protect Records:) Multi-point fires or arson fires have been shown to
exceed the ability of the sprinkler system to extinguish a fire. NFPA's
own statistics reveal that arson is one of the leading causes of fire
since 1997.  Given the threat of terrorism, sabotage and arson, it is
appropriate that the NFPA 232 Committee work to strengthen the
Protection of Record Standard and circumvent the efforts of those who
seek to remove fire compartmentation to limit loss.  Fire Walls have
been the most effective method of protection for preventing the spread
of fire when used along with sprinkler systems. Eliminating the fire
walls to save construction dollars is inappropriate given the strong
coercion to protect record that recent laws such as SOX and Graham,
Leach, Bliley have placed on corporations.

(Control Costs:)  As a records manager, I do not see a fire risk with
open flame heaters and fuel lines running through a records centers. I
also see no threat posed by gas powered forklifts working within
records centers. While other countries and ISO Standards prohibit open
flame heaters and gas powered forklifts in a records centers, we should
allow these open flame heaters to be used because other technologies to
heat warehouses add cost to the construction.

(Control Costs:)Records stored in offsite facilities are cost drains to
the organization with little benefit to the organization.  If allowing
elimination of fire walls can reduce operating costs for a records
center, then this will save the clients money in the long run that is
of greater value than the preservation of the records would have
achieve.

(Protect Records:)   As a records manager, I am concerned with the
exposure of massive amounts of records in one large compartment in a
records center. With the mergers and acquisitions that have occurred in
recent years, these massive concentrations of records within fewer and
fewer structures, pose a tremendous risk in the event of a terrorist
targeting of these facilities.  The economic effects felt by the 911
attacks should guide us to minimize risk by strengthening our records
protection standards not weaken them in our current world condition.
The loss of records in the Northeast in just two records storage
companies created tremendous recovery costs for thousands of companies.
  Insurance premiums have risen due to this. Lowering one vendors
construction cost while driving up the insurance premiums of all of the
clients is foolhardy.  The loss of even one of these new style records
centers has the ability to destabilize an entire region's economy.  The
NFPA must consider the protection of all Americans not just those of
the large storage companies.

(Control Costs:)  The NFPA should not seek to enforce protection
standards on records storage companies. As a client, we can easily move
our records to another vendor providing better protection if we are not
willing to accept the risk of storing all of our records in one massive
un-compartmented facility.  After all we are not held hostage by
removal fees or account closing fees. This is America where such
activity is illegal under our restraint of trade laws.

(Protect Records:)  If the NFPA cannot as a regulatory body, control
the interests of one segment of the records protection industry at the
expense of all corporations, the destabilization of the insurance
industry and a complete mockery of the entire fire protection
engineering field then what is the role of the NFPA?

So all you have to do is copy and paste those you agree with and put
them in an email to us by TOMORROW and we can include them as comments
to back up or refute our positions.

Feel free to write anything you want. Or send a letter to your congress
person telling them that recent legislation to protect records and
computer media by individual corporations is rendered moot by the
influence of the largest records storage companies.  If the very
centers that house thousands of corporations' mission critical
information assets are allowed to build new centers that are not as
safe as that provided by the distributed network of independent storage
companies that existed previously then your companies rights are being
destroyed.

Or on Thanksgiving sit down and look at that Turkey and remember that
you had an opportunity to do something that future generations of
records managers would have to thank you for. Whether it be protecting
records or controlling costs, please speak your mind.



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

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