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Subject:
From:
Hugh Smith <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 2 Mar 2010 15:49:28 -0500
Content-Type:
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On Mar 2, 2010, at 12:00 AM, RECMGMT-L automatic digest system wrote:

> Subject: Re: Vendor Service Issues/Sales Rep Turnover (NFPA)
>
>
> <1) How many on this List even own a copy of NFPA 232 Protection of
> Records?>
>
> I not only have a copy, but I teach the standard in my Vital Records  
> and Disaster Recovery workshops.  It is also referenced in the ARMA  
> publication "Emergency Management for Records and Information  
> Programs" (newly revised edition to come out the end of this year)  
> AND the ARMA Vital Records standard.
>
> Ginny Jones
> (Virginia A. Jones, CRM, FAI)

All right you have the Standard and you know Vital Records, so let's  
play a game of "What if?"  If I am the records manager and I treat  
vital and permanent records the same as useful records, am I negligent  
as the records manager?

Am I negligent if I do not classify the records and I treat all  
records the same as the lowest class of records, is that acceptable?

Can I refuse to accept the concept or classification of Vital or  
Permanent?  If I do, what are the ramifications?

Remember new laws do mandate certain things.  So a RM can refuse to  
acknowledge different classes of records?
SNIP from Doug
>
> I encourage anyone who sees a gap in what we deliver to fully  
> participate -
> to write that compelling article on NFPA standards changes and what  
> it means
> for RIM professionals, to jump in as a volunteer to work on any of  
> the calls
> for volunteers, and to fully participate at each opportunity that  
> exists to
> indicate what you as an individual see as the most critical issues  
> that ARMA
> can address.
I have volunteered for 10 years with meetings lasting three days and  
often twice per year. Grueling sessions where every "shall and should"  
and every point is argued. Larry Medina fought beside me but for most  
of it ARMA dropped the ball.  ARMA took the issue of Standards away  
from records managers and gave it to staff who have no clue. Your GARP  
Program language  would boot you out the door of any standards body  
because "Generally" is an unenforceable term.
>
> What ARMA members can expect is that we will remain responsive to  
> the needs
> of our members - by continuing to pay close attention to the input  
> that we
> receive from those members.

I am giving you input.  The Standard will, "the responsible party  
shall determine which records justify the application of this  
Standard".  It then states that,  "uncompartmented records centers are  
not covered by the standard." If the responsible party determines that  
the existing situation presents an unacceptable degree of risk, they  
have the responsibility to correct the situation to a level of risk  
tolerance acceptable to the responsible party or the owner of the  
records. An active record is a record the responsible party has  
determined is needed to perform current operations. A permanent record  
is a record the responsible party has determined is of sufficient  
value to warrant its permanent retention and preservation. Vital  
records is a records the responsible party has determined to be  
irreplaceable or that contains information  for which the temporary  
unavailability could constitute serious legal or business impairment.

Ahhhh, now we are at the meat of it. Useful records which, no one  
cares about, may be stored in non-compartmented records centers. The  
above listed records cannot.  How many of you know where your records  
are?

You are legally responsible. This Standard is an accepted piece of  
evidence.  It is an enforceable code in US law. The plaintiff's  
attorney will show up with  it and point to you and say "The  
responsible party was willfully negligent."

As Larry Medina said "
>
> This represents the only guidance issued by an official body that  
> addresses
> fire protection and construction standards for facilities designed
> specifically for this purpose.  "

This Standard went from having the Authority Having Jurisdiction (AHJ)  
and the Responsible Party (RP) working as a team.  All the  
responsibility is now on the RP.  I doubt many of you are prepared for  
such a responsibility.

> Certainly not every concern of every member can
> be addressed - the resources to do that do not exist for us or for any
> association.  However, as an organization, ARMA International takes  
> the
> interests of its members and the profession seriously, seeks the input
> needed to ensure that we're "on track" with member concerns, and  
> crafts its
> programs and plans to meet the concerns shared by its members -  
> within the
> limits of our resources.
>
> Douglas P. Allen, CRM, CDIA+
> President, ARMA International

I ask that you take your members interests in this most dangerous  
situation. Be aware you have liability. Appoint someone to speak at  
ARMA or create a Web Cast and place it on the site, explaining what  
the Responsible Party must do. If you wanted Records Management from  
the Basement to the Board Room, you have it.  Your CEO would be a fool  
not to pay attention.  The NFPA just gave you a big increase in  
responsibility and the liability and risk that always comes from  
increased responsibility.  You should be able to win a raise. But you  
have some new jobs to do, audit inspections, check lists and so on.

It is not my intent to make RM's mad.  That doesn't serve my primary  
goal of selling vaults but I see a risk exposure here that is going  
below your radar and I am trying to bring it to your attention.

ARMA should be paying to send at least two members if not four to this  
meeting. You are not just under represented, you are not in the  
picture.  Sooner or later a RAIN article will appear concerning a  
records manager at Giant Dynamics was found to be criminally negligent  
because they failed to perform minimal due diligence. You are the  
person on the hot seat. Someone should point this out to you before  
you say "How did this happen?"

It is a good thing that Records Manager now have all the liability.   
You will have a lot more prestige.  If you are not there, the Owner of  
the Records is directly responsible.  You are now indispensable.

I personally like the way the Standard reads now. The risks associated  
with records loss are either on the records manager or the Owner of  
the records. But you need to know what the standards say about your  
records classes and how those records should be protected or not  
protected if the records are deemed "Not records."

I will not mention this again, as my wise Mother said "A word to the  
Wise is sufficient!"


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


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