Fred-

As with many issues raised here, I must give a hearty "It depends...".

The actual text in the cited portion of 36CFR says :

"All interior walls separating records storage areas from each other and
from other storage areas in the building must be at least three-hour fire
barrier walls. A records storage facility may not store more than 250,000
cubic feet total of Federal records in a single records storage area. When
Federal records are combined with other records in a single records storage
area, only the Federal records will apply toward this limitation."

So, depending on how construction is done and "areas" are isolated within a
"facility", it could be one or any of your described options.  The intent
of the regulation is to ensure than in a fire, flood or other disaster, no
more than 250,000CF of Federal Records would be put at risk in a single
incident.

That said, if you look at the two total burnouts in NJ in the past, or the
two other well documented total losses in PA or IL, all in commercial
records storage facilities, no matter HOW THEY WERE CONSTRUCTED, if the
records were isolated in different "areas", parts of a "facility" or in a
"multi-building complex" they would have all been lost.  Same is true of
the two other incidents discussed here in FL and NM in more recent years.
Catastrophic fires in these types of facilities will frequently result in
these types of losses, simply because fire fighters are unwilling to risk
life and limb to save paper in a cavernous warehouse.

This borders on another discussion that needs to take place between records
management professionals regarding the weakening of NFPA 232, the "Standard
for the Protection of Records" which has happened over the past 12 years.
This is exacerbated now that NARA, the Library of Congress, Department of
the Army, and other Federal entities have left the NFPA 232 Technical
Committee and will not be returning, since NARA has dropped NFPA 232 as a
reference and compliance requirement from 36CFR when the former Part 1228,
Subpart K was replaced by the current Part 1234.

This is rather unfortunate (for Federal Agencies, especially) because now
there is NO GUIDANCE in Federal Regulations for the construction
requirements, environmental issues, storage volumes, or working conditions
in vaults, file rooms, or records centers any longer.

Federal Agencies have 36CFR Part 1234, but privately held organizations
ONLY HAVE NFPA 232... and if records management professionals are unwilling
to step up and do their part to strengthen the language in this document
once again to the position it held in the past for protection of
information assets, more commonly known as 'records'  while in storage, its
their own fault if records are lost in fires.  A greater number of
participants covering a wider range of industry segments is needed to
adequately represent the records being stored that seek protection under
the guidance in NFPA 232.  Members from industry segments such as higher
education, insurance, financial services, pharmaceutical, research and
development, legal, healthcare, manufacturing, transportation, utilities,
petroleum, and others all need to step up and be represented.  By building
a broader base of representation, a louder voice will exist that results in
more votes to ensure changes necessary to strengthen the language
supporting PROTECTION returns to the Standard.

Larry
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On Wed, Nov 28, 2012 at 8:30 AM, Frederic Grevin <[log in to unmask]> wrote:

> Larry, you said "... 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 ..."
>
> In this context, does the term "facility" designate a multi-building
> complex, a single building, or one storage area within a building or
> multi-building complex?
>
> I have always thought it designated a storage area within a building or
> multi-building complex.
>

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

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