A Safer Space: Assessing Your NARA Compliance Status

If you work with or within the federal government, you’re subject to the National Archives and Records Administration’s “36 Code of Federal Regulations Part 1234,” a stringent set of specifications for protecting government records storage facilities. Here’s what to consider as you address these requirements.

As the world copes with earthquakes, floods and other large-scale events, it’s easy to understand why the federal government has created rigorous records storage and protection standards such as 36 CFR. While such rules may pose temporal challenges to government agencies and their vendors, they’re ultimately designed to maintain government operations in the aftermath of calamity.

Though agencies were instructed to comply with 36 CFR by October 1, 2009, many have not yet met those specifications; but the government has made it clear that time is running out. Essentially, there are three ways to go about reaching 36 CFR compliance: do it yourself, use NARA facilities, or turn to a trusted vendor partner with the technology, certification and expertise to meet or exceed the code’s specifications. Noridian Administrative Services, a Medicare and Medicaid records processing firm, chose the latter and got a jump on satisfying 36 CFR Part 1234 requirements.

The company’s executives set out to provide compliant storage for 300,000 cubic feet of records spread across 14 states. It didn’t take long for management to realize that its facilities couldn't meet 36 CFR’s more stringent compliance requirements without considerable reconstruction. “We had to find a partner who could make compliance easier and more cost effective,” says Ken Roseth, Noridian’s assistant vice-president of facilities.

To meet the compliance deadline, the firm partnered with Iron Mountain to develop a document storage plan based on a nationwide network of Federal Record Storage Centers. Each of these facilities was designed for storing and imaging government documents, with standards that meet or exceed specific 36 CFR Part 1234, as follows:

Advanced Fire Suppression
Facilities housing government records storage must meet numerous fire safety criteria, including:

• Construction materials must be completely non-combustible. Only a NARA waiver or proof of the facility’s accordance with local building codes can override this mandate.
• Roof structure and walls. Facilities must feature three-hour fire resistant firewalls between each storage chamber.
• NFPA compliance. Sprinklers and fire detection and suppression systems must conform to National Fire Protection Association specifications.
• A building with two or more floors must either be designed or approved by a licensed fire-protection or civil engineer to ensure its fire resistance.

Environmental Controls: Water
In its many forms, water is a particular concern:

• Flood plan considerations: A facility in compliance with the NARA code must sit at least five feet above and 100 feet away from 100-year flood plain areas—or have flood-wall protection as per local building codes.
• Proper piping: Pipes running through a storage area must be inspected regularly; gutters and shields can quell potential leak damage.
• Above and beyond: The facility’s roof must be leak-proof and free of potentially damaging heavy equipment.
• Toxic/non-toxic mold: Properly regulated air-conditioning or cold storage guards against mold. Audiovisual records, such as photographic film and digital images on magnetic tape, are particularly vulnerable.

Infrastructure Protections
As some unfortunate world calamities attest, a facility must withstand considerable challenges to its structural stability:

• Storage shelving and racking systems must support at least 50 pounds per cubic foot.
• Shelving units must incorporate earthquake-resistant seismic bracing, in accordance with local code standards.

Policing Valuable Assets
The very nature of government records calls for stringent security:

• Site Constraints. Closed-perimeter fencing, high-security locks on all entrances and exits and a system of man-and vehicle-traps serve to protect data from unauthorized access.

Surveillance
Security card-accessible parking lots, gated entrances, exit and parking areas, in addition to 24-hour closed-circuit surveillance cameras provide constant monitoring.

Iron Mountain not only met but exceeded these facilities requirements when it built four Federal Records Centers—in Redlands, CA; Kansas City, MO; Elgin, IL; and Fredericksburg, VA

In the case of Noridian, the lessons learned during this exercise extend far beyond that first deadline: “During the transition, we worked closely with Iron Mountain to establish information management best practices and operational workflow processes to ensure that we could maintain long-term compliance,” says Roseth.

All in all, Noridian’s collaboration with Iron Mountain saved the company $1.43 million in compliance costs over building and maintaining its own facilities. What’s more, it did it all comfortably before that October 1 deadline. A savings of both time and money—no small feat.

More questions about NARA and other pertinent compliance topics? Read additional Knowledge Center stories on these subjects, or Contact Iron Mountain Government Services to be connected with a knowledgeable product and services specialist who can address your information management challenges.