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RECMGMT-L  February 2001

RECMGMT-L February 2001

Subject:

Re: More on NFPA 232 -- long

From:

Lawrence Medina <[log in to unmask]>

Reply-To:

Records Management Program <[log in to unmask]>

Date:

Mon, 26 Feb 2001 09:16:57 -0800

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (156 lines)

>Maybe you're all tired of this 'thread", but I thought the following points
>of clarification might be useful.  This is a consolidation of responses to
>some points that have been raised in both listserv and private e-mails......

Oh.... NOT AT ALL, Diane!  In fact, it's the first meaty topic that
involves EVERYONE on the list in a long time.

>TERMINOLOGY -- One posting questioned whether owners of records (even
>records managers) really use ANSI/ARMA glossary standards when putting their
>programs together.  You should understand that the ANSI/ARMA "Glossary of
>Records and Information Management Terms" really formalizes the
>well-established long-term usage of terms such as vital records, inactive
>records, active records, historical records, records centers, archives, etc.
>For example, we use the classic definition of "vital records" which pertains
>to those 3-5% of an organization's records necessary to ensure they can
>continue in business if a disaster strikes.  Putting the definitions in a
>standard didn't *change* the terms, although it did give them more formality
>and "weight".  These are the classic definitions -  since the NFPA standard
>is for protection of records - it is logical to use the terminology that has
>been developed throughout the history of our profession.

Will CRCs be providing an ANSI/ARMA Glossary of Terms to all current
and prospective clients to ensure they know the level of protection
being provided to their records being stored?  If these terms are
classic and have been developed throughout the history of our
profession, why haven't they been used by CRCs when offering to
provide storage prior to this point?  I think this comment makes the
assumption that all customers using CRCs (or other storage facilities
for that matter) are familiar with the ANSI/ARMA terms... many of the
customers don't know the difference.

>COST AS A FACTOR IN CHOOSING SERVICES - We do not support treating records
>as you would commodity storage of blank paper.  We are not saying that "low
>cost" should be *the* determining factor in selecting a records center.  We
>are saying that cost is *one* factor that the owner of the records has to
>consider.  If the standard is written to establish one, very stringent
>specification for protection of *all* categories of records - some records
>that are of lesser value will receive more protection than is really
>necessary.  This assumes that the level of protection would have to be set
>very high to protect archival value, vital records and permanent records.
>It would mean that records of lesser value would be "over-protected" and,
>that the users of the facility would absorb more costs than really
>necessary.  Although cost should never be the only criteria for making a
>vendor selection, it usually weighs pretty heavy in the decision.  Consider
>also that this standard is not restricted to commercial records centers -
>companies who establish their own records centers follow the specifications
>- so there's a construction cost consideration there as well.

I'm assuming the "WE" throughout this response refers to ARMA
Headquarters? It's rather apparent because of the lack of comments
from the general membership during the revision phase of the
standard, it doesn't refer to the ARMA Membership.  Comments were
solicited, but how many responded?

I have problems with the assumptions regarding cost... this supposes
that if additional costs are going to be incurred for a CRC (or
private RC) to comply with the standard they should be able to pass
these costs on to their clients.  These are capital costs for
facility improvements, which are a cost of business, and are written
off their taxes as an operating expense... in the worst case, they
are depreciated over time.  Is ARMA taking the position these costs
should be passed on to the clients?  Records of varying levels of
value are currently stored in these facilities and are all provided
the same level of protection, irrespective of the terms developed
through the history of our profession at the same cost; should the
cost now be higher to protect them in the manner they should have
been afforded all along?

>TIERED LEVELS OF PROTECTION - the above discussion leads to the conclusion
>that establishing 3 tiers of protection is an appropriate strategy (Vault,
>records center, file rooms). Vaults would be primarily used for the
>archival, vital, historical, special media and permanent records.  But, if a
>company decided they wanted to use the vault for other categories of records
>(maybe, records applicable to litigation for example), that is their choice.
>Likewise, if records which were not previously categorized as vital, become
>vital - they can be moved into the higher levels of protection.  Records
>center standards should provide adequate fire protection for records which
>are inactive, but are living out their required retention periods.  File
>rooms would apply to centralized storage areas "on-site", that is, in the
>office building the organization  occupies.  Keep in mind that one facility
>may be able to offer both vault storage and more general records storage.  I
>have used many facilities in the past where this was the case.

If the CRC is unable to offer the level of protection the client
desires for their records, are they going to be allowed to remove
their records (without a penalty) and store them somewhere that DOES
provide that level of protection?

If a firm is in the process of negotiating a sale of their assets to
another firm, wouldn't that potentially make ALL of their records
"vital" to their continuation?

>I was asked whether ARMA would recommend the standard be three parts, or one
>standard with sub-standards for protection of varying types?  My
>understanding of the direction NFPA has been taking in its standards program
>is to consolidate the standards that deal with the same types of issues.  To
>be consistent with that trend, and also to make it easier for people to use,
>we suggest that NFPA 232 remain one publication addressing protection of
>records in the 3 tiers identified above.  It would probably be easiest to
>use if each tier of protection has its own chapter.

I see an inherent problem with this concept though... unless the
customer is familiar enough with the standard, how would they know
which chapter of the standard provided them the level of protection
they desired?  If there were independent standards, one for "
archival, vital, historical, special media and permanent records" and
one for "adequate fire protection for records which are inactive, but
are living out their required retention", then a customer would know
what level of protection they should be expecting based on the NFPA
standard associated with their contract.  What I mean is, the terms
and conditions of the contract would HAVE TO be different, right?
This is where the protection provided is generally spelled out in the
agreement between the provider and customer.

>  ROLE OF RM'S vs. ROLE OF THE STANDARD - The *standard*  should set
>appropriate levels of protection for each of the tiers defined above.  If
>those levels are clearly defined so that everyone has the same
>understanding, the communication between RM's, other records owners who
>don't have RM's,  fire marshals, and commercial records centers will have
>the same foundation and this should improve the relationships among all the
>parties involved.

What the standard should address is fire protection, period.  That's
what the NFP of NFPA is all about, right?  The tiers should define
the level of protection required for a record center and those should
be communicated between the provider and client... I doubt that
during an inspection a fire marshal is going to be wandering around
saying "Now, these records are vital and these are historical and
these are just living out their required retention, Right?" I hope
that unless the fire marshal carries a CRM, his interests are related
to ensuring the facility meets the construction and fire protection
requirements that are CLEARLY communicated in a standard solely
related to fire protection.
>  If we all work from the same definitions of protection levels and
>terms, those people making purchase decisions, can make better risk
>assessments for the records they are placing in storage.  Likewise,
>commercial storage providers can indicate what levels of protection
>their facilities provide.

What would go a long way towards improving the relationship between
all parties involved would be clarity... but it would be clarity in
the "terms and conditions" more than in the terms used for defining
the protection options.  I know this doesn't matter to the fire
marshals, and doesn't have anything to do with NFPA 232.... but it
has a lot to do with the ability of a customer to understand what
they're being provided in terms of protection.  Something other than
$1 per box for their "monopoly money."

Larry Medina

... all comments and views presented are MINE, not those of my
employer nor those of a commercial records center because they
certainly wouldn't agree with them.

List archives at http://lists.ufl.edu/archives/recmgmt-l.html
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