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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Mon, 6 Feb 2012 11:35:21 -0800
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On Mon, Feb 6, 2012 at 8:15 AM, Steward, David <
[log in to unmask]> wrote:

> I was on the committee that wrote the guidelines.  Interestingly, I have
> been trying to find any kind of standard regarding wind ratings for offsite
> records storage facilities.  These are not in the guidelines.  Put simply,
> could the facility survive tornadic winds?  (Or hurricane if you operate in
> areas prone to those storms.)  We did not consider this question in our
> committee.  A definite oversight!
>
> It is difficult to expect any storage facility, other than a cave, to
> withstand a direct hit from a tornado of F3 or higher without some level of
> damage.  But the roof should not lack integrity for winds outside of a
> direct hit.  Not sure what the equivalent would be for a hurricane.  Does
> anyone know where I can find information on minimum requirements for a roof
> to withstand pressures such as I described?  I have located the standard
> requirements, but nothing more descriptive of what should be in place for a
> records facility.
>
>
> David B. Steward
> Director of Records
>
> HUSCH BLACKWELL LLP
> 4801 Main Street, Suite 1000
> Kansas City, MO 64112
> Direct:  816.983.8860
> Fax:  816.983.8080
> [log in to unmask]
> huschblackwell.com
>

Actually, it wasn't overlooked.

The decision was made to limit the language regarding specific hazard
requirements and concerns such as earthquake (seismic zones),
tornadoes/hurricanes (wind velocity or class ratings) and other factors
beyond the mention of the "500 year flood plain" issues.

There is reference to 36CFR as an additional standard for US consideration,
and at the time it was to Part 1228, Subpart K which was changed in the
2009 re-write to Part 1234.  in 36CFR Part 1234, Section 1234.10 (d), it
states: (capitalization added for emphasis)

"The facility must be designed in accordance with the applicable national
regional, state, or local building codes (whichever is most stringent) to
provide protection form building collapse or failure of essential equipment
from EARTHQUAKE HAZARDS, TORNADOES, HURRICANES and OTHER POTENTIAL NATURAL
DISASTERS."

And yes, its true that the application of 36CFR is only directly required
for entities managing Federal Records (agencies or contractors), but for
privately held businesses, its completely up tot them to determine the
level of risk they are willing to accept and what they may be based on
their location and the location of their commercial service provider.

Keep in mind the mix of the participants on this task force and the fact
that a a guideline that was fully written in 6 months required over 2 years
to get off the ground based on determining what was palatable and
acceptable to the members of the Commercial Service Industry, and I'm sure
you can better understand why EVERYTHING wasn't included and SOME things
that were are of minor value to those whose records are being placed into
storage.

If any of you have any knowledge./experience of the NFPA 232 situation, I'm
sure you'll have a greater appreciation of what it took to get this
"Guideline" produced and WHY it ISN'T a Standard.  (and yes, Hugh... I know
YOU know about this =) !!  )

Larry

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

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