Glen Sanderson asked "So does this mean anything below grade? What about companies that have below grade storage?"

To quote Larry Medina's favourite saying:  "it depends".

Merely storing records "above grade" does not, in and of itself, guarantee anything:  you have to have proper storage conditions (construction, management practices, environment, fire protection, etc., etc.).

NFPA 232-2012 states in § 7.2.3 "Underground and basement storage shall be permitted in areas specifically designed by licensed or registered fire protection engineers to mitigate the inherent problems of subterranean storage." 

This is not a blanket prohibition (unlike that for file rooms--NFPA 232 §8.3.1* "File rooms shall not be located in basements"--the term "shall" being prescriptive), so it's really a matter of ensuring the proper storage conditions (see 2nd paragraph above).

There ARE some special issues for storage situations where the facilities are not merely below grade but are actually underground. For starters, dealing with fire suppression:  fire departments typically refuse to go into these underground facilities. I have heard that at least one has its own "fire department" (not sure how that works in practice).

Best regards,

Fred
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Frederic J. Grevin
Vice-President, Records Management
New York City Economic Development Corporation
www.nycedc.com 
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212-312-3903 (w)

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