First and foremost, they can contact NARA and ask for a facility
inspection, which will tell them where they are deficient.... and if there
is a Federal Agency they are in contact with who is considering using them,
said Agency can broker a meeting on their behalf.  All the Agency has to do
is let NARA know they intend to store records with a commercial services
provider (1234.30 (a)(2) )and prior to using the facility, follow the
instructions in (1234.30 (e) ).

If thre commercial provider wants to have their facility independently
certified without working through an Agency, then they must evaluate all of
the requirements in 1234, including Appendix A "DOJ Minimum Standards for
Security Threats, Level III Facilities" to determine if they think they can
pass.  The fire detection/suppression system is critical and Appendix B
tells them the requirements they must meet there.

And the maximum volume of Federal Records that can be stored in any one
facility is 250,000CF (1234.12 (b) ) and they must be protected by 3hr fire
barrier walls (but they are NOT required to be isolated form other records).

This last requirement is why many commercial providers are unwilling to
meet the other stringent requirements- it's a cost benefit scenario.  And
any/all commercial providers navigating 1234 are subject to the "new
records storage facilities" guidelines, because they have NOT stored
Federal Records before.

Larry
[log in to unmask]


On Tue, Nov 27, 2012 at 1:28 PM, Tod Chernikoff <[log in to unmask]>wrote:

> Good late afternoon - here on the east coast at least:
>
> On behalf of an organization who does not take part in this forum I have a
> request.
>
> This organization, a commercial records center, is interested in
> retrofitting one or more facilities to comply with the applicable
> provisions
> of 36 CFR 1234 in order to be able to provide storage of hardcopy Federal
> Agency records.  They are looking for an appropriate party who can guide
> them through understanding the requirements, and how to approach bringing
> the facility(ies) to a level of meeting the requirements, so that the
> Agency
> in question can certify to NARA appropriate compliance.
>
> Anyone with knowledge of such a consultant/lawyer/engineer/what-have-you
> can
> respond on or off-list.
>

-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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