> From:    "Jones, Virginia" <[log in to unmask]>
> Subject: Re: NFPA 232 The Gift that keeps on Giving
>
> <the proposals you submit are to be based on the CURRENT EDITION of the
> Standard, as that is what is subject to change. ... the ENTIRE STANDARD
> is still open to comment...>
>
> This is what I find confusing.  I have a copy of the current standard,
> but would like to comment on the proposed changes, in order to support
> continuation of safe and protective storage of records.

What is unique about NFPA 232 is that one small element of records
storage has attempted to subvert the Standard by trying to eliminate
the protection aspect in favor of the cost aspects. In order to avoid
costs in new records centers they would propose to allow "Open Flame
Gas heaters" and "Gas Powered Forklifts" and the total elimination of
fire walls in records centers.

The goal of this Standard is to protect records stored either in a
Vault, File Room or a Records Center. Over the years, this Standard has
attempted to remove risk from the storage area at reasonable cost and
with reasonable implementation requirements.

In almost every NFPA Standard we have seen improvements in fire
security over time. Sprinkler Systems have become better.  Fire
Suppression has been improved and elements such as very early smoke
detection added as a feature.  Fire barrier walls have become more
effective and less costly to build with improved engineering and
testing.

Certain members of the records storage community on the Committee have
stated before the Committee that the records stored offsite have little
value,  "that many of the companies that lost records in their fires
were happy to have their records destroyed" and that no value is gained
for the industry by increasing protection. They define what they do as
records storage and that protection is not a part of their function.

IS THIS TRUE??

Before the merger of Iron Mountain and Pierce Leahy the industry was
dominated by small records centers. A fire in 1990 had little chance of
destroying over 250,000 boxes.  There are over a 1,000 vendors even
today and of these records centers out there the norm is seldom over
250,000 boxes in a center.  Based on 20 years of working with records
vendors, less than 5% of all records center facilities are capable of
storing over 250,000 boxes at a location. Due to the fires in 1997 and
1998 and due in part to the merger of the two largest companies, my
concern as well as others in the industry, is that catastrophic losses
in records centers could have an economic impact on the economy of the
nation.  The insurance underwriters warn that insurance costs will
climb for individual companies if these large records center losses
increase in volume of records lost per occurrence. Your company and the
nation will bear these costs.

Losses in New Jersey and Pennsylvania resulted in 2,000,000 boxes being
destroyed. Yet a fire in a compartmentized records center in Chicago
which could have resulted in very large losses was held to 250,000 due
to fire walls dividing the warehouse.  Fire walls have proven
throughout history to be effective in allowing fire departments to
establish a defense against fire and stop the spread from one
compartment to the next.

The technical committee has tried to negotiate a proactive solution by
offering to:
1)  Reduce the fire wall requirement from "Four Hour Fire Walls" to
"Two Hour Fire Barrier Walls"
2) Negotiate the size of the compartment size to a different size since
they argue 250,000 is arbitrary.
       (Many of us believe that some reasoning could occur here.  (
300,000?   400,000? )

But the large records centers have taken the approach that 'No Fire
Walls can be part of the Standard.'  They want unlimited compartment
sizes.  A task force was organized to negotiate the size, with ARMA on
one side and the large records centers on the other, but no counter
offer was ever tendered.

The large records centers have argued since 2000 that we need to be
afraid of "Rogue Fire Marshals" who would enforce the Standard
retroactively on existing warehouses, even though the Standard clearly
states that the Standard applies to new construction and not existing
construction.  In the four years the Standard has been in force  NO
Rogue Fire marshals have materialized!

The large records centers hide behind PRISM, as if all independent
records centers are against protecting records, as described in the
Standard. Yet several independent records centers are responding to
this NFPA 232 Technical committee to alert the NFPA that PRISM does not
speak for the industry but for a few large storage companies.

But the NFPA has made it known that it wished to hear from Records
Managers from our nation's corporations and organizations as this
Standard is about protecting records; and therefore the user is the
records manager.  Your opinion matters.  You are the Responsible Party.

I am told that I am only a few more responses away from losing my bet
with the Listserv.  Can that be?  So close to Ribs and Wings and Beer
and Wine!  But will those few more RM's come forth with a comment to
the NFPA??

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

List archives at http://lists.ufl.edu/archives/recmgmt-l.html
Contact [log in to unmask] for assistance