Records under fire: a look at the pros and cons of compartmentalizing records centers and why this issue is so hotly debated.

At the Core

This article:

* Defines the concept of records center compartmentalization

* Examines the supporting and opposing views about compartmentalization

* Explains what to expect in the soon-to-be-revised NFPA 232 standard

Over the past few years, the discussion about how to best protect records from fire has fueled a heated debate that shows no sign of burning out anytime soon. In fact, the battle over compartmentalization was born in flames and looks as though it will go out the same way when the National Fire Protection Association (NFPA) votes in November on the revision of NFPA 232 Standard for the Protection of Records.

The concept of compartmentalization garnered serious attention after a massive fire in St. Louis's National Personnel Records Center (NPRC) in 1973. With no automatic sprinkler system or partitions to keep the fire from spreading, the building's entire sixth floor--and 18.5 million files--were destroyed.

"The St. Louis fire was probably one of the most investigated, lessons-learned, research fires that has occurred in federal government for many years," says Stephen E. Hannestad, director of the Safe Security Management Division of the U.S. National Archives and Records Administration (NARA) and chairman of the NFPA 232 Technical Committee. "If the fire had happened on the top floor, it would have brought down the entire building. When you lack compartmentalization and a fire gets out of control, it consumes everything until it hits a barrier. In this case the barrier was the floor."

The St. Louis NPRC experience prompted NARA to more closely examine single-incident and catastrophic fires. "In all of the incidences where there have been engineered and maintained sprinkler systems and compartmentalization, fire losses have been cut back. In instances where fires did not have the best designed sprinkler systems and compartmentalization, you had more significant loss," Hannestad explains.

However, some professionals who serve with Hannestad on the NFPA 232 Technical Committee strongly disagree with the position that records center fires can be best contained by installing compartments.

Compartmentalization, also known as compartmentation, is defined by NFPA 232 as "the subdivision of a building into relatively small areas so that fire or smoke can be confined to the room or section originates." The 2000 edition goes further by requiring that fire walls separate storage compartments and that in records centers, the maximum storage volume of records should not exceed 250,000 cubic feet in a single compartment.

Opponents of compartmentalization attest that records center fires can be adequately contained by a large, well-maintained sprinkler system alone, and they are skeptical about why compartmentalization was included in the NFPA 232 2000 Edition.

"The requirement for four-hour rated fire wall compartmentation of records centers storing ordinary business records that are not of vital or archival character that appeared in the 2000 edition of the standard was ill-conceived," says Jim Booth, NFPA 232 Technical Committee member and executive director of Garner, N.C.-based PRISM International, a not-for-profit trade association representing the commercial information management industry. "There are numerous examples in which modern sprinkler technology, in the records environment and elsewhere, has worked to protect both life and property from fire."

How Compartmentalization Evolved

The NFPA 232 standard can be traced back to 1947 when it was introduced as a result of the 1922 Chicago, Burlington, and Quincy Railway office building fire in Chicago. The fire destroyed "every record of the physical valuation of the railroad's properties, a loss reported to have cost the company $7.5 million in 1922 dollars," notes David R. Hague, NFPA senior fire protection engineer and staff liaison to the NFPA 232 Technical Committee, in his article "How NFPA 232 Can Help You Protect Your Records" in the March/April 2002 issue of NFPA Journal. "This fire showed that valuable and irreplaceable records, even when stored in a so-called fire-resistant building, could be lost forever unless properly protected."

NFPA 232 outlines fire safety requirements for records centers, file rooms, vaults, and archival records storage. Some of the issues addressed in the standard are protecting paper records and magnetic media, planning for a records-related emergency, and evaluating fire risks in records storage facilities.

"The standard also has requirements for construction of vaults and file rooms that are used for archival, vital, and active records," says NFPA 232 Technical Committee member Warde P. Comeaux Jr. of Global Fire Protection Consulting in Concord, California. "As archival and vital records are very important documents, it is necessary to control the size [volume] and [level of] protection of the records."

Now in its 11th edition, NFPA 232 is administered by a technical committee, comprised of professionals from the federal government, commercial storage industries, engineering companies, professional associations, insurance companies, fire protection systems, and consultants in the sprinkler and electrical industries.

The 2000 edition of NFPA 232 saw the standard merge with a recommended practice called the NFPA 232A Guide for Fire Protection for Archives and Records Centers 1995 Edition, which contains guidelines on fire protection for file rooms exceeding 50,000 cubic feet in volume, as well as records centers and archives.

The concept of compartmentalization, specifying a maximum record storage volume of 250,000 cubic feet, stems from NFPA 232A, where it was included as a recommended measure to minimize the potential loss of records to fire and referred to fire walls as a means to prevent fire from spreading to other compartments.

Chapter 3 of the 2000 edition outlines compartmentalization as follows: "For records centers the maximum storage volume of records shall not exceed 250,000 [ft.sup.3] (7079 [m.sup.3]) in a single compartment. For an archive, the maximum storage volume of records shall not exceed 125,000 [ft.sup.3] (3540 [m.sup.3]) in a single compartment."

Last April, the NFPA 232 Technical Committee met to review comments on the 2000 edition and to work on its 2002 revision. At that time, the committee reaffirmed a desire to recognize compartmentalized records centers and uncompartmentalized facilities, which would be required to meet local building codes but not have compartments to limit records storage volume.

The Issues

Some committee members view efforts to recognize both compartmentalized and uncompartmentalized records storage facilities as a necessary step toward embracing different levels of records protection.

"The compromise involved the definition of compartmented records centers, which provide greater records protection for those who want it," says NFPA 232 Technical Committee member Steven Germano, a senior consultant with Royal & SunAlliance Global Consulting in Syracuse, New York, which represents the insurance industry. "When no specific level of records protection is asked for or required, they can be stored in records centers that simply meet the local building code."

"The standard is very essential for practitioners as well as those concerned with maintenance and storage of records," adds committee member Bill Benedon, CRM, FAI, president and owner of Benedon and Associates in Encino, California. "I worked with a major U.S. corporation over a 30-year period and dealt with 250,000 records in storage ... We had to build in fire walls and minimized (records storage volume) to 100,000 cubic feet. We closely followed NFPA requirements, and compartmentalization helped us to protect the documentation."

The Merging Dilemma

However, the initiative to merge NFPA 232A with 232, thus including compartmentalization in the standard, has been met with some concern.

"232A is where the compartmentalization recommendations were, so when it was merged into 232, they became a standard. And that was the genesis of the concern from parts of the commercial storage industry that did not meet that code and felt it would be extremely expensive for them to upgrade their facilities," explains Diane Carlisle, CRM, director of ARMA International's Professional Resources Department.

Booth explains why adding compartmentalization to the 2000 edition of the standard was problematic: "It was 1) based upon suppositions that are technologically archaic and arbitrary, 2) contrary to technological advances in fire protection, particularly automatic sprinkler technology, 3) unreasonably expensive ... and did not provide any significant additional protection, 4) based upon economic value judgments that are properly left to the owner of the records and the records manager, and 5) adopted by a prior committee that reflected the interests of only a small subset of users."

Storage Volume Limits

Other concerns surround the basis of the 250,000-cubic-feet storage volume limit for compartmentalization in records centers, such as how the storage limit was determined.

The origin of the 250,000 cubic feet limit can be traced to sprinkler design standards adhered to by the federal government, particularly NARA. In his article "Trial by Fire: Protecting Federal Records," printed in the March/April 2002 issue of NFPA Journal, Hannestad wrote that NARA limits the number of federal records stored in a single fire compartment to 250,000 cubic feet because "even the best designed (sprinkler) systems can fail or be prevented from operating."

"The 250,000 cubic feet figure was an extrapolation from the sprinkler design standards that limited the area protected by a single sprinkler system to 40,000 square feet and a ratio of 5.5 to 6 cubic feet of records per square foot of floor space, rounded off. Like most NFPA measurements ... the number is somewhat arbitrary," Hannestad wrote. "Is there scientific evidence that `proves' how much better 25 feet is than eight meters? The 250,000 cubic foot figure was a risk-management judgment by professionals on the technical committee."

The "arbitrariness" of the storage limits concerns some technical committee members, who want scientific proof that the 250,000 cubic feet volume limit for records center compartments, as well as the 125,000 cubic feet limit imposed on archives storage compartments, are the most protective storage options for records. "This volume, as well as the volumes for vaults and file rooms, was an arbitrary number that was not selected from any testing. No reports, test, or other documentation specifically recommends 250,000 cubic feet or any other figure as the correct volume," Comeaux notes.

Use of Fire Walls

Chapter 3 of the 2000 edition also requires that "each storage compartment shall be designed to contain fire from spreading to any adjacent records storage compartment. Fire walls separating records storage compartments shall be a minimum of 4-hour fire-resistive construction. Fire-resistive construction shall be in accordance with NFPA 220, Standard on Types of Building Construction."

Four-hour fire walls are intended to prevent flames from spreading to other storage compartments outside of the module for four hours. According to comments featured in the NFPA 232--November 2002 Report on Comments (ROC), fire wall proponents indicate that these walls will give firefighters and fire suppression systems ample time to combat fires, decreasing the likelihood of countless records being destroyed by fire.

The main argument against compartment fire walls is that they are expensive to build and install. As Comeaux explains, four-hour fire walls can be "costly and cumbersome."

Booth questions the effectiveness of fire walls. "There are numerous examples where fire separation devices have been compromised by human intervention and thus rendered ineffective," he says.

One example noted by Booth is a small fire that brought extensive damage to a paper products manufacturing plant in Ohio in 1997. Fire officials attributed the damage to a number of factors, including breached fire walls.

A compromise to the fire wall debate could be using less expensive alternatives to contain fires, such as fire barrier walls, Germano says. The NFPA 232 2000 edition "currently requires that compartmentalization be accomplished using self-supporting fire walls, which are difficult and expensive to install in existing facilities. A fire barrier wall, while not self-supporting, provides a high level of protection against fires spreading and is more easily retro-fitted into existing facilities," he explains. "The (technical) committee would have to determine if the present criteria should be relaxed slightly to make it more cost effective for records storage facilities to provide compartmented records centers for their clients who require that level of protection."

The Role of Sprinkler Systems

Whether or not sprinkler systems alone can adequately protect records in a fire is a chief discussion topic in the compartmentalization debate.

Using sprinkler systems exclusively is risky, Germano asserts, because improper sprinkler design, inadequate maintenance, and storage arrangement changes could jeopardize the effectiveness of this technology.

One perspective is that automatic sprinkler technology and compartments can best contain a fire. "While a properly designed, installed, and maintained automatic sprinkler system is an effective means of fire control, compartmentalization reduces the amount of records exposed to a single fire," Germano says. "Compartmentalization increases the chance that a fire will be contained within a given area, even with an ineffective sprinkler system."

In 1996, a records storage facility fire in Chicago resulted in the loss of thousands of records storage boxes and their contents, smoke and water damage to thousands of additional boxes, the loss of steel storage racks, and structural damage to the fire area and adjacent fire locations. The total property loss was reportedly more than $50 million.

One of the lessons learned from the Chicago fire was the role that compartmentalization and sprinkler technology played in containing the flames. "Aggressive fire department interior and exterior operations contained the fire to the 35,000-square-foot compartment of origin," wrote fire protection consultant Tom Goonan in his 1999 presentation for NARA, "Special Challenges --Fire and Fire Suppression." "The successful control of this fire can be attributed to the performance of the fire separation walls supported by a large fire suppression force. Effective pre-incident planning and standard operating procedures also contributed."

Having a well-designed sprinkler system plus separate records storage compartments in place is like a double insurance that records will be adequately protected in a fire, compartmentalization proponents say. Ensuring that the storage volume of file rooms is limited and protecting these rooms with automatic sprinkler systems offers "a high level of protection for records," wrote Hague in his NFPA Journal article.

Sprinkler technology advocates, however, attest that large, well-maintained systems are the best way to control a fire. "As far as protection of records, we believe the records are being well protected in a facility with full compliance to local building and fire codes, which requires in almost all cases a properly designed and maintained sprinkler system," says Booth.

The NFPA 13: Installation of Sprinkler Systems outlines the design requirements of automatic sprinkler systems in modern records storage facilities. "Test data indicates that (automatic sprinkler) systems do work in storage facilities," Comeaux says. "Sprinkler protection is the best method of protection of records, and with sprinklers the potential of saving the stored records is very high."

In his NARA presentation, Goonan also asserted, "As long as the primary protection (sprinklers) does its job, fire walls are redundant."

Assessing the Value of Records

In its review of the standard's 2000 edition, the NFPA 232 Technical Committee has discussed the value of records, how to uniquely store each type of record, and how these aspects relate to the compartmentalization issue.

One perspective shared in the NFPA 232--November 2002 ROC is that because archival, active, inactive, and temporary records have varying degrees of vitality, each should have its own level of storage and fire protection. Thus, compartmentalized records storage facilities would be best suited for records of vital use, while uncompartmentalized facilities could store less vital records.

The question is: Which records are vital and which are not? "As defined by NFPA 232, a record is considered `vital' if it's irreplaceable and contains information that would cause a serious legal problem or business interruption if it were unavailable, even temporarily," Hague wrote in his NFPA Journal article. "Financial records or artifacts are usually considered vital records. An `important' record is one for which a reproduction can substitute for the original but only at Considerable expense or delay. And the loss of a `useful' record might cause temporary inconvenience, but it may not result in a serious disadvantage."

Determining how records are to be stored--and who should make this decision--is another matter.

"That's one of our biggest bones of contention," says Booth. "A statement was made by the (technical) committee which PRISM agrees with: that the records owner ultimately determines where records are stored and received, the value of the record, the potential harm that could occur to the record, and the economic impact to the company."

The reality, however, could be a little more daunting. "In a perfect world, the responsible (records owner) would clearly identify the records, explain to the records storage facility how they should be stored, and the facility would comply," Germano says."I am told that the reality is that records of all types are sent to the records storage facility with little or no instruction. The facility itself has to determine how they are stored."

The Future of Compartmentalization

Despite the efforts to find a compromise, the technical committee's recommendations will go forth without any references to compartmentalization as a result of the committee's last ballot in October. The only construction requirement, therefore, would be for records storage facilities to meet local building costs. The next stop is the full NFPA voting body. It seems unlikely, however, that compartmentalization proponents will let the issue die here. Regardless of what happens in the NFPA meeting, the ultimate decision rests with the customer.

References

"Debate Continues on NFPA Record Protection." InfoPro Online. December 2001. Available at www.arma.org/publications/archive/online12_01.cfm#two (accessed 2 October 2002).

Goonan, Tom. "Special Challenges--Fire and Fire Suppression." National Archives and Records Administration. March 1999. Available at www.archives.gov/preservation/conferences/special_challenges.html accessed 2 October 2002).

Hague, David R. "How NFPA 232 Can Help You Protect Your Records." NFPA Journal. March/April 2002.

Hannestad, Stephen E. "Trial by Fire: Protecting Federal Records." NFPA Journal March/April 2002.

NFPA 232--November 2002 Report on Comments (ROC). Available at www.nfpa.org/codesonline/nfc.asp?path=NFPA/ ROPROC/nfpa0200-0299/0232/232-03-roc.pdf (accessed 2 October 2002).

NFPA 232 ROC Preprint. Available at www.nfpa.org/PDF/ 232-roc-preprint.pdf (accessed 2 October 2002).

NFPA 232 Standard for the Protection of Records 2000 Edition. NFPA International: Quincy, MA, 2000.

"NFPA Standard Revision Moves Forward." InfoPro Online. May 2002. Available at www.arma.org/publications/archive/ online5_02.cfm#eight (accessed 2 October 2002).

Shanna Groves is a freelance writer and former associate editor of The Information Management Journal. She may be contacted at [e-mail].