Thanks Larry.  Great point. I've looked at that one too. I still like a lot of the layout of the old standard. It seems to have better readability.

Rob Seibolt, CRM
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Manager-Records and Library Services
http://www.mriglobal.org


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Larry Medina
Sent: Friday, February 05, 2016 11:56 AM
To: [log in to unmask]
Subject: Re: Audit of Off-site Facility

On Thu, Feb 4, 2016 at 9:57 AM, Seibolt, Robert <[log in to unmask]>
wrote:

> We do onsite audits every two years. I use the NARA CFR standard as a
> guide (36 CFR Part 1228 Subpart K). You can have performance levels
> for deliveries and notifications regarding things such as sales and
> acquisitions of providers in your agreements. I use the "spirit of the CFR"
> to cover basics such as security, organization(people and the facility
> itself- are there too many shelving units, is the processing area a
> mess etc.), access, pest control, fire control, disaster planning,
> training of employees, procedures and SOPs, and environmental controls.
>
>
Robert-

Just an FYI, the CFR has been revised a few times since that was the correct reference.  There was a major re-write in 2009 that moved "the artist formerly known as" Part 1228 Subpart K, to Part 1234.  And bits and pieces of the new Part were changed and rather than say it was weakened, let's just say it was "softened".  You can find Part 1234 here:
https://www.gpo.gov/fdsys/pkg/CFR-2011-title36-vol3/pdf/CFR-2011-title36-vol3-part1234.pdf

It's still designed to address "establishment, maintenance and operation of record centers" either Federally owned and operated, by NARA, another Agency, or Contractor operated.... and it also covers use of commercial facilities when they are storing Federal records.

Hugh's suggestion of also reviewing NFPA232 is spot on.  The caveat of "Federal" doesn't apply there... so it's a broader scope of coverage.  But sadly, the Standard has weakened from the 2007 version, which had really clear guidance that was easy to "audit" against.

Larry

--
Larry
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*----Lawrence J. MedinaDanville, CARIM Professional since 1972*

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