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Also note the following:

Code of Federal Records (CFR) 36 1228.150, Subpart I –Transfer of Records to Records Storage Facilities

(f) Move temporary records that are subsequently reappraised as permanent to a facility that meets the environmental control requirements for permanent records in §1228.232 within one year of their re-appraisal, if not already in such a facility.(Paper-based permanent records in an existing records storage facility that does not meet the environmental control requirements in §1228.232(b) on October 1, 2009, must be moved from that facility no later than February 28, 2010.)

Liz Allan, RHIA
Director of Client Programs
SOURCECORP Deliverex



-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Larry Medina
Sent: Tuesday, June 08, 2010 10:15 AM
To: [log in to unmask]
Subject: Re: [RM] RAINDrop - Literally - Federal and state documents damaged by heavy rains in Illinois

Some food for thought- doesn't matter if heavy rains were predicted or not,
any facilities used to store Federal Records are subject to the requirements
of 36CFR Part 1234- whether they are managed and operated by a Government
entity or a privately owned commercial provider. http://bit.ly/ctJQ0k 

Some excerpts that discuss a few of the issues raised in this thread:

(c) The building must be sited a minimum of five feet above and 100 feet
from any 100 year flood plain areas, or be protected by an appropriate flood
wall that conforms to local or regional building codes.

(d) The facility must be designed in accordance with the applicable
national, regional, state, or local building codes (whichever is most
stringent) to provide protection from building collapse or failure of
essential equipment from earthquake hazards, tornadoes, hurricanes and other
potential natural disasters.

(f) A floor load limit must be established for the records storage area by a
licensed structural engineer. The limit must take into consideration the
height and type of the shelving or storage equipment, the width of the
aisles, the configuration of the space, etc. The allowable load limit must
be posted in a conspicuous place and must not be exceeded.

§ 1234.14 What are the requirements for environmental controls for records
storage facilities?

(a) Paper-based temporary records. Paper-based temporary records must be
stored under environmental conditions that prevent the active growth of
mold. Exposure to moisture through leaks or condensation, relative
humidities in excess of 70%, extremes of heat combined with relative
humidity in excess of 55%, and poor air circulation during periods of
elevated heat and relative humidity are all factors that contribute to mold
growth.

(b) Nontextual temporary records. Nontextual temporary records, including
microforms and audiovisual and electronic records, must be stored in records
storage space that is designed to preserve them for their full retention
period. At a minimum, nontextual temporary records must be stored in records
storage space that meets the requirements for medium term storage set by the
appropriate standard in this paragraph (b). In general, medium term
conditions as defined by these standards are those that will ensure the
preservation of the materials for at least 10 years with little information
degradation or loss. Records may continue to be usable for longer than 10
years when stored under these conditions, but with an increasing risk of
information loss or degradation with longer times. If temporary records
require retention longer than 10 years, better storage conditions (cooler
and drier) than those specified for medium term storage will be needed to
maintain the usability of these records. 

Paper-based permanent, unscheduled and sample/select records.

(c)Paper-based permanent, unscheduled, and sample/select records must be
stored in records storage space that provides 24 hour/365 days per year air
conditioning (temperature, humidity, and air exchange) equivalent to that
required for office space. See ANSI/ASHRAE Standard 55 (incorporated by
reference, see §. 1234.3), and ASHRAE Standard 62 (incorporated by
reference, see § 1234.3), for specific requirements. 

(d) Nontextual permanent, unscheduled, and/or sample/select records. All
records storage facilities that store microfilm, audiovisual, and/or
electronic permanent, unscheduled, and/or sample/ select records must comply
with the storage standards for permanent and unscheduled records in parts
1238, 1237, and/or 1236 of this subchapter, respectively.

Subpart D--Facility Approval and Inspection Requirements

(a) General policy. Agencies are responsible for ensuring that records in
their legal custody are stored in appropriate space as outlined in this
part. Under § 1232.18(a), agencies are responsible for initiating action to
remove records from space that does not meet these standards if deficiencies
are not corrected within 6 months after initial discovery of the
deficiencies by NARA or the agency and to complete removal of the records
within 18 months after initial discovery of the deficiencies.

SO based on the above, there were a lot of bad decisions made by those
charged with the responsibility for the protection and management of these
records... and this isn't a case of poking a sandy, splintered stick in the
eye of the organization/Agency and then rubbing it around to achieve maximum
discomfort... it's a case of pointing out that clear guidance existed and
they elected NOT TO follow it. 

But as mentioned earlier, I'm still wrestling with the whole 99 year deal,
and **IF** for some reason this retention WAS legitimate, why didn't they
elect to send these records to the Federal Record Center for storage if
proper space was a problem?  Any Agency can store records properly
identified and placed in appropriate boxes at an FRC for a monthly storage
fee and processing costs for retrieval, etc.  There's no reason I can see
that these wouldn't have been candidates for such handling, unless they were
regularly used and referenced.

Larry
[log in to unmask]
[Yes, it's really me =) ]

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SOURCECORP, Incorporated 
www.srcp.com

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