On Tue, Nov 5, 2013 at 5:11 AM, Corbin, Jan F. (KSC-GPC10) <
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> As the bearer of bad news from another gov't agency we have found that
> there are VERY FEW facilities in gulf coast region or Florida that meet the
> 36CFR requirement. Before you throw stones at NARA what about the records
> manager for the agency or even for the area, why didn't they know the
> regulation and make sure the records were protected?  Katrina is a perfect
> example of the lack of proper storage and protection of vital records. In
> the aftermath of Katrina it was amazing the amount of paper records, tapes,
> and other storage device methods that were damaged in the flood
> waters...and we all know that Louisiana is below sea level in some areas!!
>

Jan-

There may not be many facilities that meet the 36CFR requirement in the
Gulf Coast area, but there are some...and if that's true... then the
records shouldn't be stored locally. There are NO exceptions given in 36CFR
for geographic locations.  And yes, this may not be convenient, but for
issues of convenience, copies or scanned images should suffice for
reference purposes locally and the "official records" should be stored
elsewhere.  As in all cases, the FRCs offer storage for Federal Records.

And YES... it *IS* the Agency's responsibility to ensure records are
properly stored and protected, and every 2 (or 3) years, every Agency is
required to perform a self assessment and provide feedback to NARA of their
ability to comply with requirements for the storage or records and other
aspects of their programs... and NARA and the IG are responsible for
grading these and performing at least "cursory" inspections to ensure they
are accurate.  And where shortfalls are identified, request remediation
plans.

However, IF the Agency is unable to meet the requirements, then it is
NARA's responsibility to seek a resolution through enforcement of the USC
and the CFR. And you're right Katrina WAS a perfect example of how wrong
things can go, and the question is, what has been done to ensure when the
next Category 5 hits the Gulf, the same thing doesn't happen?

Disaster preparedness (An ounce of prevention) is much easier to do than
Disaster recovery (A pound of cure).

I didn't even visit the concerns for storage of what are actual "Vital"
records as defined in the Federal realm- the protection requirements for
those far exceeds standard record protection.

Larry
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-- 


*Lawrence J. MedinaDanville, CA RIM Professional since 1972*

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