3.1 Risk assessments

The physical integrity of records can be affected by exposure to risks such as fire, flood, earthquake, and hazards like dangerous industries and vandalism. Records are an important information asset for an organisation, so every effort must be made to identify potential dangers and to ensure that records are not stored in their vicinity. Client or staff convenience should also be a consideration when choosing a location, but guarding against dangers is also a primary concern.

Before your organisation purchases or leases a building for records storage, engages a commercial storage provider, or designates an area within a building to be used for records storage, a documented risk assessment should be undertaken in order to identify risks and dangers to records and the strategies required to mitigate risks.

Any risks to records identified in the assessment process will also need to be identified and managed in your organisation’s risk register and business countinuity plan.

Records should not be stored in locations that risk exposure to high or fluctuating temperatures or the likelihood of water incursions, such as attics or basements. These areas can only be used for records storage if appropriate measures are undertaken to mitigate risks.

Assessing records storage locations for hazards and risks

Records storage areas and facilities should not be located near known natural and man-made hazards:

• heavy atmospheric pollution
• hazardous industries
• flood plains, rivers and creeks
• land liable to subsidence
• land liable to flooding in a tsunami event
• strategic installations such as fuel depots or munitions factories, and
• bush fire prone areas.

Other risks, such as the presence of flight paths and the risks of vandalism, should also be taken into account.

The proximity of a records storage facility to known risks should be calculated as part of the assessment process. Methods of collecting information about the site may include:

• checking newspapers and other literature to determine any known local problems (natural, industrial or social)
• inspecting the site and its surrounds
• examining local government records, such as contour and flood maps, and
• discussing the site with those with local or specialist knowledge.

Once potential hazards in the locality have been identified, estimates of how far the site should be located away from each known hazard will pinpoint the most suitable area to locate the facility or storage area. Research, inspections and decisions regarding the location of sites should be documented. Sometimes an organisation may have little choice about where buildings are located, however the locality should be investigated thoroughly in order to identify risks.

If risks are identified, then these need to be included in the public office’s risk register and mitigated through a range of protection measures:

• inclusion in the organisation’s business continuity and counter disaster plan
• choosing an alternative building at a lower risk location
• modifying an existing building to ensure risks are removed or minimised
• modifying existing services and practices, e.g. not storing records on the ground floor, changing security and access arrangements or undertaking building maintenance
• implementing protective mechanisms such as:
  • detection and suppression systems and security systems
  • boxes or secure packaging for all records and fire proof safes for business critical records
  • developing policy and procedures to address risks in practices or service provision, and
  • developing and implementing a counter disaster plan for records for each storage area and facility.

For example, if a records storage facility is to be located in proximity of a flood plain, then records should not be placed on lower floors of the building or in the basement, and shelving should be at least 85-150 mm above the level of the floor.

Records storage areas within buildings should be isolated from hazards and not co-located with:

• kitchens and toilets
• overhead plumbing
• drainage pipes
• chemical storage areas
• flammable materials
• electrical plants
• machinery or air conditioning units.

Ideally, records storage should not be located under plumbing or water pipes. All electrical wiring should pass through conduits. Adjacent activities should pose no risks to records.

Buildings and spaces within buildings to be used as potential storage areas should be investigated for potential risks. Methods of collecting information about a building include:

• inspecting the site and its surrounds, including drainage
• checking building plans
• discussing the building and potential storage areas with those with relevant or specialist knowledge, like the facilities manager, building maintenance staff, structural engineers, fire inspectors, and disaster management experts.

Research, inspections or decisions regarding the location and construction of records storage buildings and storage areas should be documented.

If compromises regarding a building or storage areas must be made, steps should be taken to protect records. Your organisation must introduce protection measures. For example, if records are stored in a basement as this is the only storage space available, then the basement must be waterproof and well ventilated, humidity levels must be managed so that mould is not encouraged, and storage shelving must be raised off the floor by 85-150mm as a flood/disaster precaution. Risks should also be managed as part of the organisation’s risk register, Business Continuity Plan and Counter Disaster Reaction and Recovery Plan. It may also be necessary to remove or relocate records to a safe environment until all the risks have been mitigated.

NSW State Archives and Records staff should be consulted when a repository for State archives is designed or built, or when an existing building is to be refurbished for this purpose.[1]

3.2 Dedicated storage

Records storage areas and facilities should be dedicated to the storage of records or library materials. AS/NZS 1015: 2011 Records management - Physical storage requires that records storage facilities should be in a ‘dedicated building or subsection within, used solely for records storage and processing’.[2]

Other equipment or supplies, such as furniture and chemicals, should not be stored in records storage areas. The main reasons for creating a dedicated space for records are to:

• avoid additional risks (e.g. if chemicals were stored in the area the risk of contamination would be heightened; if computers were stored in the area the risk of theft would be greater)
• restrict access to the area more rigorously (e.g. if furniture and stationery were stored in the area more people would require keys or access passes).

As suitable storage conditions for library materials and paper-based records are similar, records and library materials may be stored together. However, records requiring additional security should be placed in lockable shelving or equipment. See Section 8 Security.

3.3 Buildings and construction

It is important to undertake a thorough building inspection. Buildings chosen for records storage facilities should:

• be suitable and appropriate for the storage of records
• be conveniently located for user needs
• be soundly constructed of appropriate materials so that the records are not in danger of exposure to the elements, including risks of fire or infestation by vermin
• be weatherproof
• have good guttering, drainage and water run-off
• be insulated to assist in controlling temperature and relative humidity in storage areas
• have sufficient floor loading capacity to safely support the weight of fully loaded shelving and racking for the storage of records and any other equipment required in the storage area
• be secure against intruders
• have controlled access, and
• be ‘fit for purpose’.

Wherever possible, within the building, walls should divide storage areas from non-storage areas such as work spaces. Storage areas should not open onto loading docks, as this can expose records to pollutants from engines.

Storage areas and facilities, and equipment should be lockable, monitored and access controlled in accordance with NSW Government and Australian Government security requirements.

New storage facilities built since 2011 to house records, should meet the Building Code of Australia that applied at the time of construction and associated codes and standards. Organisations should ensure that they have appropriate documentation or access to certified copies for facilities built since 2011.

AS/NZS 1015:2011 Records management - Physical storage recommends that a building used for records storage should be made of steel, reinforced concrete or concrete blocks. These recommendations also apply to the walls that separate the storage areas from office areas.[3]

The building should have good drainage, including a pitched roof, as flat-roofed buildings tend to collect rainwater and may have issues with leaks from the roof. Guttering should be checked to ensure that there is no deterioration, and box guttering avoided if possible, as it can cause water to leak into the building. Drainage pipes should not pass through storage locations within the building. Door and window frames should be checked to make sure that they properly seal and will not let water into the building. [4]

Environmental conditions should be in accordance with the recommendations in Principle 2 of the Standard on the physical storage of State records (see Section 4 Environmental conditions for further details).

3.4 Records storage areas

Wherever possible, fire rated walls should divide records storage areas from non-storage areas such as work spaces. Storage rooms or equipment should be lockable and access controlled. Furnishings and floor coverings should not be made of materials that will attract insects into the storage areas.

If the quantity of records to be stored is very large, then the storage area/facility should be subdivided into smaller units by the use of dividing fire resistant walls. This enables fire protection measures to be introduced more easily and environmental conditions to be maintained at constant levels[5] (see also Section 4 Environmental conditions). These measures will also allow the storage area to be better secured (see Section 8 Security).

The arrangement of storage areas and shelving units should allow for ventilation (see Section 5 Shelving and packaging for more details). Other factors, such as wheelchair access, trolley movement and access for ladders should be considered when deciding the width of aisles.

Any waste should be taken away promptly and any structural obstacles should be removed to ensure that the storage area is safe.

When procuring commercial storage, it is important to visit the storage facility and inspect and evaluate the storage areas against the Standard on the physical storage of State records to ensure that the storage areas used for storing your organisation’s records meet the requirements of the Standard.

Doors

Doors to storage areas should be kept closed and, if possible, be fire resistant. If doors need to be kept open during use, then they should be fitted with magnetic devices designed to automatically close doors upon activation of the building fire alarm/detection system. Doors should be lockable and wide enough to allow for the movement of trolleys.[6]

Ceilings and floors

Ceilings should be high enough to allow a 500mm clearance between the top of shelves and fire sprinkler heads.[7] This is to ensure that the sprinklers are not accidentally activated.

It is vital to ensure that the load bearing capacity of the floor is adequate to cope with full shelves of records. Organisations should ensure that they seek the advice of a structural engineer to ensure that storage areas and facilities have sufficient floor loading capacity to support records and equipment when at full capacity. Organisations should also ensure that shelving contractors confirm that shelving will not exceed agreed floor loading limits.[8]

Ideally, the materials used for walls, ceilings and doors should be hard-wearing and not likely to shed dust or grit. Internal structures should be in good condition. They should also not emit substances, such as acidic gases, when they decompose or are subject to fire.[9]

Windows

Ideally, buildings or rooms used for records storage should not have windows or skylights. West facing windows should be avoided as they present dual dangers to records from heat and light. If there are windows or skylights, measures should be taken to prevent natural light by fitting windows with:

• heavy curtains, shutters or blinds, preferably of heat reducing fabric, to reduce or eliminate illumination
• screens to prevent ultra violet light from entering, or
• ultra violet filtering film.

3.5  Fire detection and protection

One of the prime dangers to paper records is fire.

Storage areas and facilities should have appropriate and comprehensive fire detection and protection systems and equipment. These should be implemented in accordance with the Building Code of Australia and Australian standards. A regular fire inspection should be undertaken in a storage area or facility by a qualified fire safety expert to ensure that the area or facility meets the standards and is safe.

Risk assessments should include the likelihood of fire spreading through buildings and storage areas and the risks from adjacent premises and activities. Hazards like smoking, old wiring and the unnecessary storage of flammable materials should be eliminated. Make sure you advise the fire brigade that the building is a records storage facility and holds paper-based records.

Records storage areas and facilities should be fitted with heat/smoke detectors, fire alarms and fire suppressant systems. Sprinklers provide the highest level of protection and should be installed with approximately 500mm clearance between the top shelf and the sprinkler head. Automatic chemical fire suppressant systems are generally used for areas storing magnetic media and are also recommended for archival storage and storage spaces which can be made airtight.[10] Generally these types of suppressant systems pose less risk of damage to records than water-based systems.

It is important that your organisation holds regular ‘practice’ fire evacuations so that staff working in the records storage area or facility can practice evacuating the building in an emergency. Regular inspections of the building and storage area should also include inspections of the fire detection and suppressant systems, check that fire exits are free of obstacles, and that storage areas do not contain any combustible materials such as nitrate film or chemicals.

3.6    Counter disaster reaction and recovery plans

All records storage areas and facilities, including storage facility and services provided under a commercial contractual arrangement, should have current counter disaster reaction and recovery plans[11]. These plans should be linked to the public office’s business continuity plans. Staff responsible for the management of records in storage areas and facilities should be trained in the counter disaster reaction and recovery plan and procedures for salvaging records.

The public office should have appropriate insurance coverage for the recovery and restoration of records in the event of a disaster.

Further information on counter disaster reaction and recovery plans is available from the NSW State Archives and Records’ website.

Notify NSW State Archives and Records

The Senior Responsible Officer (SRO) for the public office should notify NSW State Archives and Records if there is damage or loss to records as a result of a natural disaster, storm, flooding, fire, contamination or technology disruption. This official notification should be made as soon as practically possible after the event has occurred.

NSW State Archives and Records will also be able to provide advice and guidance on salvaging the records (contact our Senior Conservator on telephone 02 9673 1788)

Further information on counter disaster reaction and recovery plans is available from the NSW State Archives and Records’ website.

3.7    ‘Active’ records

Increasingly NSW Government is creating records in digital format, not paper.

If the public office is creating paper records, we recommend that the organisation establish business rules for the creation, management and storage of ‘active records’.

3.8  Authorising records storage

The Senior Responsible Officer for records management (SRO) or delegate, should ensure that all records storage areas and facilities used by the public office, including arrangements with commercial providers, have been inspected to ensure that they are appropriate for the storage of records and approved for use by the public office.

The records management policy should identify that the Senior Responsible Officer or delegate has the authority to inspect and approve all records storage areas and facilities to be used by the public office, including commercial storage arrangements. The records management policy should also identify that records should only be stored in approved and appropriate storage areas and facilities.

The Senior Responsible Officer (SRO) is also responsible for the organisation’s records storage plan. The storage plan for the organisation will include

• details of all storage areas and facilities used by the organisation for the storage of records
• measures and safeguards implemented to protect records from fire and water influx (from above, below or through walls or openings)
• quantities of records in each storage location, and
• whether the records have been sentenced for disposal.

Making decisions about and authorising where records are stored should involve a detailed assessment of each potential or existing records storage area and facility using the Standard on the physical storage of State records to ensure that State records are stored in appropriate conditions. This should also include any commercial storage facilities being used by your organisation. Records of assessments and inspections reports should be maintained in order to demonstrate compliance with the Standard.

Inspections and assessments of potential storage areas and facilities should also involve your organisation’s Records Manager or senior staff with responsibility for and expertise in records management. It is important that records storage services and activities are undertaken by appropriate staff with relevant skills and knowledge.

In some cases, organisations located near or adjacent to State borders will be using commercial storage providers outside of New South Wales as there are no suitable options located nearby. Authorisation processes must ensure that an organisation is meeting the requirements of General authority for transferring records out of NSW for storage with or maintenance by service providers based outside of the State (GA35) and that any facilities for storing records located outside of New South Wales meet the requirements set out in the State Records Act 1998 and the Standard on the physical storage of State records.

Further information on storing records outside of New South Wales is available from Storage of State records with service providers outside of NSW.

Organisations should also ensure that all storage areas and facilities are regularly inspected and assessed for ongoing compliance with the Standard on the physical storage of State records.

Under section 15 of the State Records Act, NSW State Archives and Records has the authority to inspect storage areas and facilities being used by the public office for the storage of State records.

3.9  Keeping records about storage locations and buildings

It is important to keep records of your organisation’s assessment and authorisation of each storage area and facility.

Your organisation should document the authorisation and approval of appropriate records storage area and facilities. This documentation will assist your organisation in demonstrating compliance with the Standard. Types of documentation to keep include:

• the assessment and/or inspection report on establishing and maintaining dedicated area/facility for storing records
• reports to senior management on records storage
• records management policy statement authorising the Senior Responsible Officer or delegate to inspect and approve records storage areas and facilities for use
• risk assessment and mitigation documentation, including reports that demonstrate that the facility (if built since 2011) meets the Building Code requirements, including relevant fire-resistance levels
• risk register identifying risks and the mitigation strategies undertaken to minimise risks
• assessment/inspections records of storage areas/facilities used by the public office
• risk assessment reports of commercial storage facility identifying conformity with requirements of the Standard on physical storage of State records
• storage plan which details design measures and safeguards implemented in storage areas and facilities which protect records from fire and water influx (from above, below or through walls or openings)
• structural engineer’s report identifying that storage area/facility has sufficient floor loading capacity to support records and equipment when at full capacity
• shelving contractor’s report that installed shelving does not exceed agreed floor loading limits
• certificates of occupancy
• fire safety logs or inspection reports showing that smoke detectors meet requirements of AS 1670 ad fire extinguishers, hose reels and hydrants meet the requirements of the Building Code of Australia
• documented and up-to-date disaster reaction and recovery plan along with records of tests, results and evidence that it is reviewed
• procedures for responding to disasters affecting records
• documentation of insurance coverage for the recovery and restoration of records in the event of a disaster.

[1] See Ted Ling, Solid, Safe and Secure: Building Archives Repositories in Australia, National Archives of Australia, 1998; Bettington et al, Keeping Archives, 3rd Edition, Australian Society of Archivists, 2008; National Archives of Australia, Standard for the storage of archival records, June 2014; relevant Australian and international standards including ISO 11799: 2015 Information and documentation – Document storage requirements for archive and library materials, BS 4971(2017): 2017 Conservation and care of archive and library collections, and AS/NZS 1015: 2011 Records management - Physical storage.

[2] AS/NZS 1015: 2011 Records management - Physical storage, clause 2.3.2

[3] AS/NZS 1015, Clause 2.3.2

[4] National Archives of Australia, Storing to the Standard: Guidelines for Implementing the Standard for the Physical Storage of Commonwealth Records, Canberra, 2002, pages 13-14

[5] See ISO 11799, Clauses 4.2 – 4.3

[6] Ling, Solid Safe, Secure, p.37

[7] Ling, Solid, Safe, Secure, p.39

[8] ISO 11799, Clause 4.3

[9] ISO 11799, Clause 4.2

[10] ISO 11799, Clause 5.4

[11] AS/NZS 1015, Clause 2.3.7 and ISO 11799, Clause 8