Evaluate records-storage facilities as purpose-built protective environments

Use this document to connect an official requirement or behavior to observable evidence: Evaluate records-storage facilities as purpose-built protective environments. Only the official source and traced locations below supply facts. Confirm applicability before acting.

Source fact:

The official 36 CFR 1234.10 – Records storage facility requirements from National Archives and Records Administration via eCFR supports the following bounded statements:

• Under 36 CFR 1234, the rule requires that piping (with the exception of fire protection sprinkler piping and storm water roof drainage piping) not be run through records storage areas unless supplemental measures such as gutters or shields are used to prevent water leaks and the piping assembly is inspected for potential leaks regularly. The research record locates this support at 36 CFR 1234.10(h) (eCFR anchor p-1234.10(h)).
• Under 36 CFR 1234, an agency may request a waiver of the requirement specified in paragraph (a) from NARA for an existing records storage facility with combustible building elements to continue to operate until October 1, 2009. The research record locates this support at 36 CFR 1234.10(a)(2) (eCFR anchor p-1234.10(a)(2)).

The source support ends with the statements listed above. Use them to examine critical rooms, power, cooling, water, fire protection, alternate sites, physical barriers, and documented recovery paths in the applicable environment, not to imply a wider guarantee.

What the source does not establish

Federal records-storage regulation; record type, facility status, waivers, incorporated standards, local code, lease or contract, and later amendments require complete review. It does not establish a deployment’s current state, authorize a production change, prove compliance, or show that identity and access control, Windows DNS where networked services use it, time, communications, utilities, life-safety systems, vendors, and authorized responders are healthy. Documented options are review inputs, not universal mandates.

Applicability questions

• For source statement 1 at 36 CFR 1234.10(h) (eCFR anchor p-1234.10(h)), which observable configuration, record, or test can confirm applicability here?
• For source statement 2 at 36 CFR 1234.10(a)(2) (eCFR anchor p-1234.10(a)(2)), which observable configuration, record, or test can confirm applicability here?
• Which owner can attest to the recorded state of critical rooms, power, cooling, water, fire protection, alternate sites, physical barriers, and documented recovery paths, including exceptions?
• What baseline for identity and access control, Windows DNS where networked services use it, time, communications, utilities, life-safety systems, vendors, and authorized responders must accompany the source-specific observation?
• Which success, stop, and escalation criteria are written before testing begins?

DSE recommendation:

DSE recommends using the cited source as the evidence anchor for this decision. Make the source, asset scope, owner, and expected outcome explicit in the review record. Record the source location, examined part of critical rooms, power, cooling, water, fire protection, alternate sites, physical barriers, and documented recovery paths, observed and expected states, owner, and reason for deviation.

An implementation decision needs an owner, approved window, prechecks, observable outcome, stop authority, and rollback path. Validate identity and access control, Windows DNS where networked services use it, time, communications, utilities, life-safety systems, vendors, and authorized responders before and after the test, and store only sanitized operational evidence.

Verification and evidence

Build a reproducible chain from 36 CFR 1234.10(h) (eCFR anchor p-1234.10(h)); 36 CFR 1234.10(a)(2) (eCFR anchor p-1234.10(a)(2)) to the observed environment. Useful domain evidence includes facility inventories, inspection records, alarm and shutdown tests, maintenance history, recovery exercises, and corrective actions; label every item with scope, timestamp, collector, and stable identifier.

Record the decision even when no change is made, including uncertainty and the next trigger. Use safe testing conditions for disruptive work, preserve rollback proof, and revisit the conclusion after relevant platform, dependency, vendor, or ownership changes.

Official references

• 36 CFR 1234.10 – Records storage facility requirements — National Archives and Records Administration via eCFR