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Date:
Thu, 27 Jul 2006 11:04:17 -0400
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Records Management Program <[log in to unmask]>
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Hugh Smith <[log in to unmask]>
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 From time to time as events impact our industry, I propose after the 
news articles stop on a given records management and protection event 
that we see if we can summarize what we have learned from the event.  
We could title this "Recent Event Knowledge"  or REK for short.

I am prompted to this by a recent correspondence from someone I respect 
in the field of Fire Protection Engineering who serves on the NFPA 232 
Committee with Larry Medina and me. We are discussing the recent 
changes within the NFPA 232 document that allows records storage 
centers to climb from 250,000 cu. ft. per compartment to much higher 
levels.

While we fought for the 250,000 limit for six years, the consensus of 
the NFPA committee was that this number could be raised to a higher 
level to grant greater records storage efficiency to those who store 
records.  That certain increases in potential "loss of records" was 
justified by gaining "reduced storage costs."

At the time of the changes to the Standard, we worried about 
theoretical losses in the future, but theoretical losses never seem to 
make people emotional.  Now we sit down with our conscience in private 
thought and wonder what the loss of 1,800,000 boxes in London and some 
far lesser number in Ottawa mean to the industry.

For clarity, the "industry preferred approach" is the desire by the 
offsite records storage industry to have extremely large (4,000,000 
boxes/compartment) or unlimited compartment size.

Excerpts from his comments were as follows:

> As I re-read my own comments I am realizing that it is
> not only the commercially-minded insurers who are turning a blind eye 
> to the
> weakness in the industry-preferred approach to design of records 
> centers.
> NFPA 232-2006 has now fully condoned the approach:  storage heights to 
> 60-ft
> with intermediate catwalks;  records volumes to 1.2 million cu.-ft..; 
> 2 hour
> rated gypsum board fire separations = no separation at all by the NFPRF
> study;  no concessions to provide fire fighter access to the interior 
> of
> buildings filled with 60-ft high racking and 30-inch aisles.
>
> ............................................. The problem is that
> I/we let ourselves be bullied into accepting the flawed concepts and we
> voted affirmatively on many issues that were concessions to appease an
> organized faction on the committee. The over-all design approach 
> preferred
> by the industry is so flawed that fire protection engineers everywhere
> should be cringing, or speaking out in outrage.

[The design approach of using mezzanines with 30" aisles with catwalks 
and the elimination of in-rack sprinkler heads for records storage is 
almost a prescription for a total loss facility. The design flaw is 
that  fire fighters cannot place water on the fire location unless it 
is within the outer edge of the storage rack and the narrow aisles 
allow fire to spread far too easily.]

So what do we concur as a group is the "REK" from these events:
(Comment on what I provide or provide your own list.)
1) That paper documents really have little value based on what we read 
in the articles and the impact of these fires will be non-events?
2) That RM is now totally dependent on IT to provide the records that 
are required in a disaster like this? ( or flooding, or tornado?)
3) Selecting a vendor who compartments into rational bays and vaults is 
an added benefit to be sought out and therefore must be written into 
future RFP's?
4) Total loss is a given, based on the recent changes to the Standards, 
so the RM must select multiple vendors to divide their records 
collection to minimize loss?
5) Storing your media and paper documents with the same vendor, when 
that vendor is using an uncompartmented approach is foolhardy?

I learned that believing a sprinkler system, (no matter whether it is 
"state of the art" or an older system)  can actually stop a fire is a 
fantasy.

Add to this Recent Event Knowledge (REK)  that the Diversified Fire 
Court  Rulings have been upheld, so it is possible to recover the value 
of your records in court.  But what is the value of the records?  But 
if you are storing them as media, as well then the paper, does this 
make them less of a loss?  Or less valuable?  I think it does, 
therefore it is a responsibility of the RM to assure that two different 
mediums are employed.  Media and paper and maybe microfilm for 
permanent records.

But many of the world's largest corporations choose to store all their 
documents with one company and no requirement to store in multiple 
facilities to spread the risk? So for those who choose to store in that 
manner, should there be any liability?  Let the buyer beware.

I believe they are negligent as they could have chosen any vendor but 
selected one that lowered their cost but with the full awareness that 
they were increasing their risk exposure.  After all, in the end, we 
cannot outsource the prudent management of the corporation.  SOX 
clearly put the burden on the CEO and the CFO as they must weight cost 
savings here versus risk there?

The argument of the offsite storage industry is that, "This is what we 
offer! If you want more it has to come from your management style!"  So 
this now makes it your opportunity to choose a matrix of vendors and 
security measures based on this knowledge.

So is the REK on this that you just gained a powerful argument for your 
insertion into all the phases of records management, including 
oversight of  IT. After all, they are a back up to your system.  A 
combined matrix of protection must now exist.

So the rules have changed based on REK.  How do you see it affecting 
your organization?

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

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