Technical Bulletin 3

Records Security

Version 2 (1999)
 
Purpose
Two of the prime responsibilities of records custodians are ensuring the physical security of the operational records and preserving the corporate memory of the agency/department.
Loss of records can result in:
* Disruption of government business and services.
* Legal risks and excessive legal bills.
* Severe operational and financial setbacks.
* Damage to the interests of the constituency.
* Loss of political and historical context and legitimacy.
There are also legal repercussions if the custodian's responsibilities have been clearly enunciated. Failure to provide for the security of records in the face of clear requirements to do so may well be interpreted as negligence.
 
Threats to Records
Records custodians have a responsibility to protect their records against a variety of threats including fire, flood, theft, vandalism, pests and environmental damage. In the past, this was relatively straightforward: today, advancements in storage technologies and a proliferation of record media have complicated the task.

Environment
Now records custodians must provide protection for a variety of media, including paper, photographic film and magnetic media. Each recording media has its own environmental requirements and limits at which irreversible degradation will occur. These requirements must be taken into consideration when planning for the security of public records.

Paper
Paper is the most durable of recording mediums. While paper can survive temperatures up to 350EF., humidity levels up to100%, or total immersion in water, only a stable environment will assure long-term security and preservation. Temperatures below 70EF. and relative humidity of 40-45% are optimal. Due to the difficulty and expense of meeting these criteria, it is permissible to maintain average vault temperatures of 70EF. or below and an average relative humidity of 30-50%, with daily fluctuations of ±2EF. and ±3%RH. The Supervisor of Public Records publication Performance Standards for Safes and Vaults mandates that in the event of a fire, storage spaces with public records may not exceed the upper limit of 350o for the duration of a fire.

Photographic Film
Silver halide microfilm masters require a constant temperature of 70EF. or below and a relative humidity of 20-30% for long-term preservation. It is preferable that temperatures do not exceed 65EF, and cooler temperatures are preferable. Storage space designed for the protection of paper records is not sufficient for the low humidity storage requirements of film. Storage requirements for film are specified in 950 CMR 39.06 of Regulations on Using Microfilm.

Magnetic media
Magnetic media has a much lower tolerance for high heat and humidity levels than paper. Magnetic media begins to suffer severe degradation at 150EF. and relative humidity of 85% and above. Storage space designed for the protection of paper records cannot protect magnetic media from the heat of a fire or the moisture generated by fire-suppression efforts. Periodic copying and dispersal of media, and specialized Class 150 records storage devices or vaults are necessary for the protection of magnetic media; please see the "Records Storage Equipment" section for more details. Storage devices and vaults must meet the guidelines specified in the Supervisor of Public Records publication Performance Standards for Safes and Vaults.

Please see the Records Management Unitís Web page at www.sec.state.ma.us/arc/arcrmu for a copy of the publications mentioned, or contact the RMU (617-727-2816 or recman@sec.state.ma.us) for a paper copy. For more information, please see the "Environment" section of Northeast Document Conservation Centerís Preservation of Library and Archival Materials at www.nedcc.org/index2.htm

Dirt and Pollutants
Cleanliness of the vault is essential to the protection of the records. Dust and pollutants can damage records and are sources of ignition. Unsanitary conditions are a hazard and are a breeding ground for insects and vermin. Prohibit food, drink and plants from the vault. Remove trash daily, and do not allow collected trash to accumulate in areas directly outside the building.

Protect archival records from dust and pollutants by housing them in archival-quality folders and boxes. The folders and boxes should meet the American National Standards Institute (ANSI) standard for permanence, Z39.48-1992. The alkaline reserve serves as a buffer between the contents and a potentially harsh environment. Boxes and folders meeting the ANSI standard will create a stable micro-environment for permanent records. For more information, please see the "Storage" section of this publication.

Maintain an overall environment that is as dust-free as possible:
* Change furnace and air conditioner filters on a regular schedule, e.g., quarterly.
* Use vacuum cleaners equipped with high-efficiency, particulate air (HEPA) filters if possible, so as not to redistribute dust. Sweeping is discouraged, since it stirs up and scatters dirt.
* Avoid introducing materials that create internal pollutants, such as wooden cabinets and shelves, cleaning compounds, andcarpeting.
* Do not store records near copying machines, which produce ozone and toner dust. Records should be properly boxed and shelved. Boxes should not hang over shelf edges. Records should be promptly returned to their boxes; boxes should be promptly reshelved. Lit tobacco products, matches or lighters should be prohibited from the vault.

Cleaning compounds with ammonia, chlorine, solvents or volatile oils should not be used in the vault. Typically dust cloths and water are sufficient. Use caution with water because of the risk of spills and raising the relative humidity in a confined area. Make sure shelves are completely dry prior to reshelving. For more information, please see Northeast Document Conservation Centerís technical leaflet "Cleaning Books and Shelves" at www.nedcc.org/tleaf43.htm.

Insects and Vermin
Pests indicate an environmental problem such as high humidity or gaps in the building structure, or poor housekeeping. Unless there is a specific problem, avoid regularly scheduled chemical treatments. Chemicals emit strong odors that may create long-term problems for staff, records, and record users.

There is no all-purpose solution for eliminating every pest problem. Practice a preventive approach to pest management. Maintain good housekeeping, prohibit food, beverages and plants, monitor the environment, use the least toxic eradication methods first, and work with your pest control professional. A pest infestation inside records boxes indicates a serious condition. Call the Records Management Unit at 617-727-2816 immediately.

Light
Artificial and natural light causes irreparable and irreversible damage. Vault areas should not have windows: if records are in an environment where they are exposed to light, cover windows with shades or drapes that completely block the light. This will also help maintain a stable temperature. Turn off interior lights when they are not in use and install ultraviolet (UV) filters on florescent lights. Store archival records in archival-quality folders and boxes.

Photocopiers are a powerful source of light. Avoid repeatedly copying the same record. Create "surrogates" or use copies for heavily requested records. Provide users with surrogate copies to reduce wear and tear on originals.

Mold
Excessive heat, poor air circulation, and relative humidity above 65% can provide a suitable climate for mold growth. If relative humidity goes over 65% for more than two days, or the airflow is stagnant, there is a risk of mold growth. High humidity is especially problematic in basements, where ground water and cooler temperatures encourage water vapor to collect. The appearance of mold indicates a serious condition and requires immediate action.

If mold occurs, reduce the temperature and relative humidity. Do not move records or try to remove mold from records without first consulting preservation personnel.

Determining the mold species is an important first step in addressing the mold outbreak. Some molds can present very serious health concerns. Even dormant (dry or powdery) mold spores can be readily redistributed within a storage space, becoming active (velvety) when environmental conditions are favorable for growth.
If you discover records with mold, immediately contact the Records Management Unit at 617-727-2816.

Records Storage Equipment
Records storage equipment and facilities should be designed and constructed to protect paper, photographic film and magnetic media against catastrophic events such as fire or flood, malicious attack or theft, and against long-term threats caused by environmental factors.

Storage units should be fire resistant in the sense of being noncombustible, and must be heat resistant, in order to prevent degradation or auto-ignition of the records. Storage units must protect records against water intrusion and high humidity levels. It is crucial that records storage units (vaults, records safes, or insulated files) prevent the transfer of heat and that the storage units maintain their structural integrity.

Unrated devicesóincluding the so-called Old Line steel and cast iron safes found in many officesócannot be relied upon to provide the required level of protection. Although Old Line safes have been known to survive serious fires, they cannot be counted on to provide the heat-resistance or impact-resistance necessary to safeguard public records. Old-fashioned steel plate vault doors, with or without inner doors, provide only 10 or 15 minutes of fire protection, respectively. Unrated steel or wood filing cabinets, desks, etc., only provide 5 minutes of fire protection.

Storage equipment is tested by various testing laboratories e.g., Underwriters' Laboratories and is classified in terms of interior temperature limits and time in hours. For non-paper records, protective storage devices are classified 150 and rated 1, 2 or 4 hour e.g., the storage unit can maintain an internal temperature of 150EF. or below for 1, 2 or 4 hours. Units that are classified 150 require the maintenance of 80% or below internal relative humidity for the period tested.

For paper records, devices are classified to 350o and rated 1, 2 or 4 hour, with an allowance for 100% internal relative humidity. Devices may be equipped with inserts for greater fire resistance or for the storage of mixed media; for example, a storage device for paper records may be fitted with small, internal units for magnetic media. These devices may carry more than one classification and rating. The first classification applies to the whole unit and the second classification applies to the insert, e.g. 350 4 hour/150 4 hour.
Ratings assigned to various records storage devices are as follows:

Insulated Records Containers Class 150 rated for 4, 2 and 1 hour
Class 350 rated for 4, 2 and 1 hour
Fire-resistant Safes Class 350 rated for 4 and 2 hour
Insulated Filing Devices Class 350 rated for 1 hour
Insulated File Drawers Class 350 rated for 1 hour
Vault Doors Class 350 rated for 6, 4 and 2 hour
Insulated File Room Doors Class 350 rated for 1 and 1/2 hour Since fires often result in the collapse of structures, the fire-rated storage device must be able to withstand high impact e.g., the force of dropping through the building floor. This is tested as part of the classification rating.

Vaults must be constructed to withstand the impact of falling building members, equipment and the stresses and strains of collapsing structural members. Vaults must be constructed so that a fire will not: destroy the vault structural supports; produce stresses that will cause the walls, floors or ceilings to crack; cause the vault to erode due to sudden cooling from fire hose streams; and so that the vault will in no way lose its structural integrity.
It is undesirable to locate vaults and other record storage units in the basement of buildings, since burning debris may accumulate in the basement and create a "cooking effect." This leads to high temperatures for longer periods of time than would otherwise be the case. Basement units are also more susceptible to the impact of falling equipment and structural members. It is also more difficult to evacuate personnel from basement units.
In addition to fire-imposed hazards, basement areas are more prone to flooding and high humidity than areas at or above grade. This increases the risk of environmental and preservation hazards.
 
VAULT OPERATIONS
Because of the expense and inherent size limitations of vault construction, it is crucial that the vault is utilized effectively. The vault is specifically designed to ensure the safe preservation of the government records. Using the vault for the storage of supplies, office machines, seasonal decorations, equipment or other non-record materials is a waste of valuable and secure space, and is an egregious misuse of scarce government resources.
Secure space is a limited resource: care must be taken to determine which records are stored in the vault. In order to make the most efficient use of vault space, public records should be prioritized as outlined in the following section, "Vital Records Management." Records that should be given priority for vault storage are records that are 1) vital to the operation of the organization, or are 2) archival due to their historical value and importance for preserving institutional and community memory. Secondary space allocations should be made for records appraised as important. If the vault cannot accommodate all important or useful records, provisions should be made for their storage in fire-resistant file rooms as specified in NFPA-232, Protection of Records.
When planning the size and location of a new or reconstructed vault, records custodians should consider the current volume of records needing protection and attempt to estimate future space needs; this estimate should take into account projected growth estimates for the community and the annual accumulation of each record series. In the planning stage, it is appropriate to explore various avenues for reducing the growth of records e.g., miniaturization, electronic archiving of electronic records, and implementation of a comprehensive information management program and review.

Since vital records are usually active records, consider the needs of all involved and ensure convenient access to the vault. It may be desirable to construct two or more small vaults that are readily accessible to the operational offices, rather than a single large vault that is distant and inconvenient to access.

Supervision and Control
The vault should be under responsible supervision at all times. If the vault is not under constant surveillance, it should be closed and locked at all times it is not in use. Only authorized personnel should be allowed access to the vault: the authorization procedure should be documented in the record management policies and procedures manual, and it should designate which individuals are authorized to deposit or remove records. The vault should be inspected several times a day and at closing time to ensure that all records are properly shelved, all waste papers are removed, and that the door is closed and locked.

Removal of records should be controlled through the use of a sign-out or charge-out system. An example is the use of an outguide, a stiff cardboard divider with a protruding tab, which is placed in the box in place of the folder. The outguide should be ruled and labeled so that the worker may write in the file name, his name and the date the file was removed. There are many variations of sign-out systems ranging from basic lists to the use of bar codes. Whatever system is decided on, it should be documented in the records management policies and procedures manual.

It is highly recommended that a single officer or employee be placed in charge of the vault. This individual should have the authority to: control access to and change the combination; allocate space; establish requirements for boxing and labeling records; accept or reject records to be stored, based on the vital records program; and require the removal or rescheduling of records that have exceeded the required retention period.

Equipment
All filing equipment should be noncombustive throughout. If mobile shelving is installed, it must be of the mechanical type. Only equipment needed to service the files should be allowed in the vault. Desks, chairs and other furniture should be forbidden. If possible, ladders needed to reach upper shelves should be stored outside the vault; ladders should only be brought into the vault as needed. In the event of a fire or other emergency, the vault lights will probably fail, and it is essential that the vault aisles are kept clear. Aisles cluttered with boxes or equipment present a safety hazard.

Filing cabinets provide extremely inefficient storage and should not be used. Optimize space with shelving: shelving allows five times as much storage per square foot as equivalent office space. High-density shelving allows ten to twelve times as much storage per square as equivalent office space. Shelving should be designed for standard-size record boxes (typically 10" x 12" x 15"), as this will maximize the use of space.

Shelves that are closed on the ends and that have a front closure system, and mobile shelving in the compressed position, provide additional protection against fire and water damage from sprinkler heads or fire suppression. These systems also reduce air circulation, which may lead to mold growth. If closed systems are chosen, the environment should be carefully monitored.

Storage
All files should be properly arranged prior to boxing: only important records should be sent to the vault. Remove duplicate records and other non-essential materials. Record boxes should be of uniform size and clearly labeled with the office of origin, contents and span and disposal dates. For a sample inventory database (including box labels), please see the "Tools and Models" section of the Records Management Unit Web page at www.magnet.state.ma.us/sec/arc/arcrmu/arctoo.htm. In order to prevent mixing records with different offices of origin, each office should be assigned its own storage area in the vault.

Record containers should be at least 6 inches from piping and conduit that penetrates the wall. Record containers should be at least 4 inches from the wall to allow for maximum air circulation. Record containers should be kept a minimum of 18 inches below sprinkler deflectors. All records should be stored on shelves that are a minimum of 3 inches above the floor of the vault.

Storage Boxes and Enclosures for Permanent Paper Records
Paper records should be stored in archival-quality folders and boxes (low lignin or lignin-free, buffered, pH 8.5 or above). The folders should be stored in archival-quality boxes with lids. The calcium carbonate "buffer" of archival-quality materials prevents the formation of acid in paper records.

Select the appropriate-sized boxes and folders for paper records. Do not overstuff folders, and do not bend the materials to fit the folder or box. Folders should stand upright in the box. If necessary, use archival-quality fillers to support the folders and to prevent them from falling over.

Mark folders in pencil: pen and labels are chemically unstable and labels will fall off. Purchase supplies from companies that specialize in archival products. Contact the Northeast Document Conservation Center at 978-470-1010 or see their technical leaflet "Preservation Suppliers and Services" at www.nedcc.org/listsup.htm for a list of suppliers. Also see the Massachusetts Historical Records Advisory Boardís (MHRAB) technical leaflet "Preservation Basics" at www.magnet.state.ma.us/sec/arc/arcaac/aacipre.htm.

See the Records Management Unitís publications page www.magnet.state.ma.us/sec/arc/arcrmu/arcpub.htm for more information on archival storage of non-paper records or contact the Records Management Unit at 617-727-2816. Also see the Northeast Document Conservation Centerís "Storage and Handling" section of Preservation of Library and Archival Materials: A Manual at www.nedcc.org/index4.htm.

VITAL RECORDS MANAGEMENT
There is a small percentage of information within any organization that is crucial to the successful operation of the organization. Without this information, the organization cannot function. These records are the vital records of the organization.

Although vital records typically constitute 3-5% of the organization's total information stock and may have only short-term value, vital records are essential for the:

* Operation of the organization
* Resumption or continuation of operations following a disaster
* Re-establishment of the legal, financial and functional status of the organization
* Determination and protection of the rights and obligations of the employees and citizens. Loss of this information can result in: vulnerability to litigation; exposure to unplanned financial losses due to financial settlements or revenue loss; disruption of the continuity of operations; loss of efficiency; and damage to the interests of the citizens and employees of the organization.

The objective of vital records management is to minimize risks and hazards to vital information, and to do so in the most efficient and economical manner possible. In the public sector, vital records programs protect the public interest, ensure the maintenance of individual rights, and preserve the public trust.

Establishing a Vital Records Program
Before implementing a comprehensive plan to safeguard vital records, the organization must complete a thorough study of its records. This study should include: determination of records classification; physical volume by class; storage space requirements; costs of the loss of each class; protection needed; and handling procedures.

Records Classification
Records are generally classified in one of four groups in a scheme suggested by the National Fire Prevention Association:

CLASS DEFINITION EXAMPLE
RECOMMENDED
PROTECTION

Class I
Vital Records essential to the continued life of the organization. These records are irreplaceable because they give evidence of legal and financial status, and of the rights and obligations of the organization. Vital records are generally housed in active storage. Accounts receivable, contracts, charters, minutes, payroll, ordinances and resolutions, master personnel listings, all documentation needed to run and read electronic records systems. Fire resistant vaults and safes, dispersal.

Class II
Important Records necessary to the continued life of the organization. While the records can be replaced or reproduced, this can only be done at considerable cost in time and money. These records may be housed in either active or inactive storage. Accounts payable, tax lists, directives. Fire resistant safes, vaults or file rooms.

Class III
Useful

Records useful to the continued life of the organization.

These records may be replace although their loss would cause temporary inconvenience. Bank statements, correspondence. Fire resistant safes, file rooms, filing devices.

Class IV
Non-essential Records that have no present value and should be destroyed. Requests answered, advertisements, announcements. Use, then destroy.

Although there is a tendency to equate vital records with records that have historic or archival value, they are not always one and the same. The life span of vital records may be very brief, and may inversely proportional to its importance to the organization. While archival records have enduring interest and historical value, they may not be relevant to the continued functioning of the governmental unit.

Documentation of computer systems, accounts receivable and insurance policy information are essential to restoring operations after a disaster, even though this information may have a brief usable life or retention period. On the other hand, records such as militia lists, Civil War records, and pre-1870 correspondence have historical interest and should be retained permanently, but they are not essential to the resumption or maintenance of government operations. The vital and archival categories are not mutually exclusive: records frequently fall into both categories. Since the protection of vital records should take precedence over other records, vital records classifications should be carefully assigned.
 
Protection Methods
To determine the most appropriate level of vital records protection, estimate the severity of potential disasters. The severity of the disaster, costs of protection, and budgetary levels will dictate the level of protection. There are two means of protection available to local governments in Massachusetts: on-site storage, and duplication and dispersal.

1. On-site storage
Considerations for on-site storage of vital records include the analysis and improvement of buildings or facilities, equipment and supplies, and establishing procedural controls.

1. Building considerations. Establish the adequacy of the floor-load capacity, lighting, ventilation, environmental controls, wall and door fire ratings, smoke and fire alarms and fire suppression systems. Eliminate hazards such as leaks and pest infestation.

2. Equipment considerations. Determine whether the vaults, safes and storage devices meet or exceed Underwriters' Laboratories specifications. Underwriters' Laboratories tests and rates storage and filing equipment on the basis of impact resistance and internal fire and humidity levels during various lengths of exposure to fire. As a general rule, paper begins to deteriorate at 350EF., and magnetic media and photographs begin to deteriorate at 150EF. Storage devices for magnetic media must also be able to maintain an internal relative humidity of below 85%. See the "Vault Operations: Equipment" section for more details.

3. Procedural considerations. Routinely update vital records; prohibit food, beverages and smoking in records areas; do not store combustible materials with records; conduct periodic electrical, building and fire inspections; and periodically test the vital records program through simulation of post-disaster scenarios. See the "Vault Operations" section for routine procedural considerations.

The vital records program should not rely exclusively on on-site storage: there is always the risk that a single area can be destroyed or suffer near total destruction in a disaster. Duplication and dispersal of vital records must be part of the vital records program.

2. Duplication and Dispersal
Off-site storage of original, record copies of public records is forbidden under Massachusetts statutes. Duplication of vital records and storing the copies away from the central or primary office if one method of protecting vital records. This strategy is most effective for records that have been microfilmed and for records that are maintained in electronic format.

The environmental requirements for storing master microfilm negatives are very stringent; see the "Threats to Records" section for more detail. To ensure the safety of master microfilm and to ensure proper environmental controls, consider storing the master negatives with the Massachusetts State Records Center or with a private vendor. The State Records Center provides this service free of charge; please see the Additional Information section for contact information. In the event of a disaster, the off-site repository should be able to rapidly retrieve and copy the master negative. The master negative should never be used as a use copy. The master copy should only be used to produce duplicate film.

Electronic records should be backed up at frequent intervals; see the Records Management Unit publications for more detail. Backup copies should be stored off-site; reciprocal arrangements should be made between offices to store their backup copies. Programs and documentation needed to retrieve and read the backup copies should be secured at an off-site location. Agencies and departments should be aware of others who are using the same hardware and software: in the event of a disaster, it may be possible to utilize their hardware and/or software. Electronic archiving may also be investigated as a security measure.

In all cases, the dispersed records should be retained for their full retention periods and should be made available to the appropriate officers.

Program Staff
The Vital Records Coordinator
If the office already has a comprehensive records management program, the records manager is the most appropriate person to coordinate the vital records protection program. If a comprehensive records management program does not exist, appoint a coordinator who has experience with records management e.g., a staff member of the Clerk's office. It is essential that all members of the organization recognize the authority of the coordinator: the coordinator should act with the administrationís authority and should have authority over vital records for all departments.

Most local governments have emergency response procedures for dealing with disasters. Public safety, public works and other personnel are all assigned a role in safeguarding lives and property. These procedures typically do not involve a long-term plan for preserving information and restoring severely disrupted operations, except for physical services such as water, electricity and public safety. A vital records program should be designed to preserve information that is essential to governmental functions. The vital records program should be part of the emergency response program and/or local disaster plans. The vital records coordinator should be part of the overall emergency planning process.

The Vital Records Team
The vital records team assists the program coordinator and is an important part of a successful vital records program. The major function of the team is to help the coordinator determine which functions and supporting records are vital to the organization, and to ensure that they are properly safeguarded. Administration, finance, law, information systems, and records management experience are important background for team members.

Communications
All officials should be aware of the importance of their vital records, and how critical they are to the survival of the organization. In larger organizations, it may be desirable to have a vital records manual; smaller organizations may find a simple master list to be sufficient. Vital records should be designated on the master records inventory. It is essential that the vital records program is part of management policy.

Summary
A vital records management program:
* Prevents the loss of information that is critical to the daily operations of government organizations.
* Begins with a records inventory that describes the function of the record within the organization.
* Classifies records into one of four categories: vital, important, useful or nonessential.
* Selects appropriate protection methods to safeguard vital records.
* Permits the organization to continue functioning during a disaster and to reestablish services after the disaster.
* Should be part of management policy, and should be part of community emergency response and local disaster plans.

ADDITIONAL INFORMATION
For more information, please see Northeast Document Conservation Centerís Preservation of Library and Archival Materials: A Manual at www.nedcc.org/newman.htm and see the Massachusetts Historical Records Advisory Board (MHRAB) technical leaflet "Preservation Basics" at www.magnet.state.ma.us/sec/arc/arcaac/aacipre.htm. Also watch the Records Management Unitís Web page at www.sec.state.ma.us/arc/arcrmu for new technical bulletins.

For more information, please contact the Records Management Unit.

The Records Management Unit is available to help government officials and their staffs with records management. Analysts can assist you with:

Technical Assistance including:
* Development of records management programs
* Records inventory
* Analysis of record-keeping systems
* Appraisal and scheduling of records
* Implementation of schedules

Training Sessions and Presentations. Analysts will plan an agenda tailored to the records management needs of the agency/department. Analysts frequently speak at meetings of professional associations. Sample topics include:
* Records Retention and Disposition
* Safety and Security of Records
* Records Lifecycle
* Care and Handling of Records
* Public Records Issues

Workshops. Let the Records Management Unit teach a workshop at your next professional association meeting.

For more information, please contact:
Massachusetts State Archives
Records Management Unit
220 Morrissey Blvd.
Boston, MA 02125
617-727-2816 Phone
617-288-8429 Fax
www.sec.state.ma.us/arc/arcrmu
recman@sec.state.ma.us

For information on storing microfilm at the State Records Center, please contact:
State Records Center
220 Morrissey Blvd.
Boston, MA 02125
617-727-2816 Phone
617-288-4505 Fax