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Records Management Program <[log in to unmask]>
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"Ramirez, Cindi - L&M" <[log in to unmask]>
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Mon, 22 Nov 2004 12:50:07 -0700
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Records Management Program <[log in to unmask]>
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http://www.aafp.org/fpm/990900fm/33.html
They say a picture is worth a thousand words. Isn't it amazing how we know
what we SHOULD have done BEFORE the disaster instead of after?!

-----Original Message-----
From: Hugh Smith [mailto:[log in to unmask]]
Sent: Monday, November 22, 2004 11:45 AM
To: [log in to unmask]
Subject: Re: NFPA 232 Protection of Records Standards - Last Chance!

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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