I am a new subscriber to the listserv and joined the records management
industry two years ago as a co-owner in Advantage Records Management &
Storage.  I spent a number of years in the banking industry prior to this
and started this company in response to the increasing government
regulation, privacy demands and need for secure offsite storage of records
by businesses.  As a commercial lender I know many companies do not
realize the value of their records until they have suffered a catastrapic
event, and they are no longer availabe to them.

I am very interested in the proposed NFPA 232 policy changes and have
decided to send in my own response to the NFPA.  I would recommend anyone
that is seeking background on NFPA 232 to find the Information Management
Journal, Nov.Dec 2002, Vol 36, No. 6, "Records Under Fire" by Shanna
Groves, Published by Arma International.  You can download this as a .pdf
file for free through ARMA, and it is a very good place to start.

Below is a copy of my "submittal" to the NFPA.  I would encourage any and
all records managers to respond to the NFPA with their own reasons but DO
respond.  I believe this may be one of those issues that appear harmless
and insignificant in the beginning, but can have a huge future impact to
all records centers and record managers once you do your due diligence.

"I am very concerned about the proposed weakening of NFPA 232.  In the
2000 Edition of `NFPA 232, the standard was merged with what was then a
recommended practice, known as NFPA 232A Guide for Fire Protection for
Archives and Records Centers 1995 Edition.  This guideline contained the
250,000 cubic feet maximum, which of course was established to minimize
loss of records due to a fire, and referred to firewalls as a method of
limiting the spread of the fire.

The issue at hand seems to be two fold;
1. whether the compartmentalized records center is safer than those
facilities that are not compartmentalized
2. and whether the records industry needs to differentiate itself to
their clients by designating their facility as compartmentalized, and
therefore safer, and a better storage facility for records deemed critical
by the client.

It would seem that larger, open facilities would be against this type of
critical differentiation saying simply: “storage space is storage space
and a sprinkler system is sufficient.”  Although the NFPA 232 standard may
have been established without a scientific basis, it was implemented and
accepted with a common sense foundation and historical evidence.

I am urging against any change in the current policy.  Compartmentalized
records centers are safer than non-compartmentalized records centers.  A
sprinkler system, firewall(s), smoke detectors, an internal response plan
and the response time of the local fire department make up your total
protection.  To eliminate any part of your safety net, and then state that
you are as safe and secure as those facilities with that feature is
illogical.  Fire, and minimizing the effects and damage of a fire is one
of the top disaster scenarios for a records center.  The most likely
scenario for a terrorist act on a record center would be arson, and
multiple fires started within the facility.  There are historical
statistics from the NFPA that show arson to be the leading cause of fire
since 1997.  These arson and multi-point fires exceeded the ability of the
sprinkler system to extinguish the fire.  This would lend credence to the
original concept of compartmentalization of records centers and sprinkler
systems.  Shouldn’t the NFPA maintain and create policy that is in line
with this differentiation?  Isn’t NFPA 232 in line with the current
environment of legislating responsibility of records to companies?

Legislation in the form of Graham/Leach/Bliley, SOx and even HIPAA
displays the concern and intent of the Federal Government to increasingly
put the responsibility of the records safety, retention and accessibility
directly on the company’s shoulders.  To change NFPA 232 to say that your
records are now as safe in an environment without firewalls as they are in
a facility with firewalls and compartmentalization would run counter to
the concept and policy of accountability.  It would seem precarious for a
company to rely on only one system and say well enough!  Redundancies in
the protection of the records create a confidence in the company storing
the records and in the bodies creating the policy.  If it is agreed that
there are differences in records that are being stored, i.e. vital,
archival, active, inactive, temporary, etc. isn’t the NFPA impacting the
challenge of managing records by simply saying that all records are the
same and all records center are good enough if they conform to a local
fire code?  I personally am not so confident in the ability of the local
bureaucrats to create, maintain or implement policy relating to the safety
and continuity of records centers.  Nor do I welcome the concept of a
thousand local jurisdictions having this same debate; absent the expertise
and experience the NFPA can enlist from its organization and colleagues.

Cost also seems to crop up as a reason for changing the current policy.
Newer warehouses and records centers have not been constructed with the
appropriate firewalls.  The cost to retrofit their facility is enormous,
and may put them at an economic and a market disadvantage.  Therefore, the
elimination of the differentiation creates a “flat zone” in which the
larger newer facilities are viewed as being equal to smaller facilities
with compartmentalization.  I don’t believe that this argument is the
concern of the NFPA.  A policy making body should not be influenced by the
cost of an industry to meet the policies and standards it has
implemented.  Any argument by an industry that relates to the cost of that
industry to implement a standard can by its very nature give the
appearance of a conflict of interest.  Policy, once implemented, should
stand on its own merit and changes should be detailed with scientific
evidence and debated in an open forum.  I would ask that you seek that
scientific evidence before accepting any changes in the current policy.

Changes in our political climate due to 911 would also encourage records
to be differentiated and protected in facilities that can be designated as
compartmentalized.  Terrorism or sabotage is a much higher concern that it
was just a few short years ago, and the safety of vital records would
again require redundancies in the protection system.

The NFPA can have a dramatic and positive impact simply by maintaining
NFPA 232 without any changes."

Respectfully submitted, Dean Sturtz

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