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Date:
Mon, 13 Dec 2004 12:08:06 -0500
Reply-To:
Records Management Program <[log in to unmask]>
Subject:
From:
Hugh Smith <[log in to unmask]>
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On Dec 8, 2004, at 12:02 AM, Automatic digest processor wrote:

> This all brings to mind something that bears mentioning... it seems
> that
> there was an error in the date originally provided related to the
> submission of comments in the form of formal proposals to the NFPA
> regarding Standard NFPA232, "the Standard for the Protection of
> Records",
> and that the actual deadline for submission of comments isn't until
> mid-January 2005.
>
> SO.... on that basis, I would urge those of you who submitted comments
> here
> to contact one of the three of us you sent comments to for some
> guidance on
> how to formally submit proposals to the NFPA, and YES... you are ALL
> ABLE
> to submit proposals, you don't need to be a member of NFPA or of ARMA
> or
> any other organization. You simply need to be an involved or interested
> party who is impacted by the conditions of facilities used to store
> records
> and the Standards used to establish the minimums for protection of
> records
> stored in these facilities.
>
> Larry
>
>
>> From:    Chris Flynn <[log in to unmask]>
>> Subject: Re: NFPA 232 Protection of Records Standards - Last Chance!
>>
>> Larry,
>>
>> Does Hugh's offer still stand with the change in deadlines?
>>
>> Chris Flynn

I have been in New Orleans at the PRISM/Association of Contingency
Planners Conference so I have not been able to chime in here until now.

My offer stands, I even have a place picked out to hold the party
because I am positive that those who know me and respect my passion for
protecting records by means of this Standard, will send in enough
replies to make this catered party a reality.  You can send them in
support of the Standard, or you can send them to state that protecting
records does not need to be defined in a Standard.  Either way you have
Wings, Beer and Wine waiting for you in Chicago if you send a reply to
the NFPA.

So you have plenty of time to formulate a reply.  You should respond
directly to the NFPA. This will have 10 times the effect of just
sending them to Larry or Diane or me.  You cannot imagine the respect
the NFPA has for true submissions from Records Managers from our
nations largest and most respected corporations and organizations.

THIS IS IMPORTANT:  I have talked with a great number of records
storage companies over the last few days at PRISM's meeting as well as
a few ACP members.  Everyone I talked to said the same thing:

  "If we knew that records managers would support those who truly
protect the records, then we would be behind the changes to the NFPA
232 Standard.  But if records managers are really in support of the
increased protection for their records collections, then more records
managers should speak out."

Your silence on the issue condemns the Standard and if there is not
more support within the records management community; then NFPA 232
Protection of Records will be deleted from the National Fire Protection
Associations' list of Standards. Your records will then be protected in
the same manner as Campbells Soup, Goodyear Tires and General Mills
Cereal.

This deletion of the Standard is a real concern as the NFPA is trying
to eliminate Standards that are not relevant. Is NFPA 232 relevant to
you??  It defines you in a unique and powerful way for your
organization but you are in danger of losing this authority as the
"ResponsibleParty" if they delete this Standard.

But you know what separates those of you who will go on the record
about this issue, from the few big records centers that attack the
Standard??????  There are only twelve records centers within PRISM that
even signed their name to the Appeal to the NFPA.  While there are over
a 1,000 records storage companies in the country. Many offsite records
storage vendors are in support of the Standard.  In fact, several PRISM
Members even paid their own way to the NFPA Meeting to state they were
not in support of PRISM's position.

But most telling, is the fact that no large records center has spoken
on the record defending the merits of removing fire walls from records
centers. Even the few who would benefit from removing the requirement
for providing fire walls in newly constructed records centers will not
go on the public record in support of their opinion.

But they can get away with this by having paid consultants go before
the Committee and argue that:
1) The value of the records does not warrant protection other than
sprinklers.
2) That sprinklers always work.  (Even though the truth is that
sprinklers failed in every recent records center fire where sprinklers
were employed.)
3) Sprinklers are ineffective in arson and multi-point fires but that
arson should not be considered when writing the Standard for
protection.  (Is this wise given that arson is the leading cause of
fire?)

But, they cannot get away with this if 30 or 50 or 100 records managers
go on the record stating that protecting records is important and that
the Standard should not be weakened.

If you believe that 250,000 boxes is more than enough records to be
destroyed in any fire, then speak out.  If you feel that they should be
allowed to weaken the Standard and allow 1,200,000 boxes of records to
be destroyed in any catastrophic fire or as some wish to do, an
unlimited amount of records, then let them know you are for this.

We are not being harsh on this as we gave the opposition two other
options:
1) Define yourself as "Compartmented" or "Non-compartmented". If you
state that you are uncompartmented then the 250,000 compartment does
not apply.

(They refused to allow this and voted it out as it gave those who
protect records a defined advantage over those who chose not to protect
records in this way. )

2) Define yourself as storing only "Useful Records" in a warehouse and
then the Standard does not impact you.  But if you are storing Vital,
Important or valuable records then you need to supply a compartmented
facility.

(They refused this as it created a higher value records center and they
did not want this. )

In February, the Committee will meet in Florida for the next meeting.
Without sufficient comments, this Standard will be diminished in value
or maybe even eliminated as a Standard.  This affects you.

You and your records are either important enough to warrant a Standard
and protection or you are not.  You will decide this issue.

1,600 people are on this Listserv.  I have already made the bet that
not even 30 of you will take the five minutes it requires to send a
reply to the NFPA in a Comment Form. I will be happy to send you a
"Comment Form"  to print and mail in or ask Larry or Diane.

But whether you like it or not, In 2005 you will either be in the group
that saved it or the group that dumped it in the trash.  There is no
middle ground here.

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

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