You wrote:
"I have been asked to justify to management why we should spend money to
restore these records, rather than leave them frozen for the duration of the
retention period (10 years).  I really see two primary problems with leaving
the records frozen.  The first problem is access to the records for audits,
reviews, etc.  The second problem is security of the records since they
would be in a vendor facility."

Lee you will have to provide them with a cost justification comparing the two
costs.
What will be the cost to freeze dry the records and provide some
restoration/preservation?
How much will it cost on a per cubic foot per month basis to store the
records in a freezer?
Does any commercial records storage facility provide such a service?
What would the costs be at a commercial freezer/cold storage facility?
How often are the records access during the ten year period (rough estimate
-- once a month, 2-3 times per 6 months)?
Are the records subject to FOIA requests?

"The first problem is access to the records for audits, reviews, etc."
Who will be accessing these records for audit purposes? State, Federal,
private citizens.  Are there any outstanding audits that include these
records? Are there any litigation matters that involve these records.

"I believe these records are some of the most important in our company..."
Provide hard objective reasons as to why they are in your professional
opinion the most important records in the company. What do they document, who
do they document, etc. Are equipment guarantees part of these records?

However you will be fighting a tough battle here in that the retention period
is only ten years. If I were a decision maker I would ask "Iffen these are so
dern important why are we gettin rid of 'em in ten yars?"

"The second problem is security of the records since they would be in a
vendor facility."

What security clearance level is required to view these records.
Does the Dept of Energy have them classified, if so at what level?
I believe that many off-site commercial storage vendors require that their
customer to determine provide them with a list of who has access to the
records or can request access to the records. If security is that big of a
concern than the current inactive storage may not meet security requirements.

So to reiterate, you should
1) provide a cost comparison for restoration versus cold storage

that will include information about;
the historical importance of the records,
their security requirements,
access requirements,
commercial storage facilities either records centers or cold storage
and any other alternatives.
Remember be objective not subjective

Put yourself in their mindset and think of the questions that they may ask.

Hope this helps


Peter A. Kurilecz CRM, CA
Richmond, Va
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