1. Purpose.

Once the vital records are identified, the Vital Records Officer works with his or her manager and office staff to decide on the best way to protect the records, and who is responsible for the different parts of the process. The decisions made in this part of the process are added to the vital records inventory.

The Vital Records Officer reviews and updates the inventory at least annually, and more frequently if there are major events, such as an office reorganization.

  1. Protection methods. There are three basic choices for protecting vital records:
    1. Dispersal. Dispersal is the act of placing copies of vital records in locations other than those housing the originals. An extra copy of the vital record is made for storage in a secure location, usually remote from the organization's primary place of business.
    2. System backups. Electronic records determined as vital records are protected by creating an extra copy of the vital data resident on a computer and placing that copy in a secure location remote from the site where the computer is located.
    3. Duplication. There are basically two types of duplicating, each of which may also involve dispersal.
      1. The first type of duplication involves preparing extra copies at the time the vital record is originally created. These copies generally serve several purposes besides protection.
      2. The second type of duplication involves scheduled reproduction of existing records by any process, such as microfilming, electronic imaging or photocopying for the specific purpose of dispersing to a remote storage location in compliance with the vital records program.
  2. Each method has its advantages and disadvantages. When making the decision on which method to use, consider these factors:
    1. Can these records be found in other locations as extra copies are made for multiple distribution? For example: A state office or FAA regional office.
    2. Is the information contained in these records available in an electronic system or database?
    3. What will the proposed protection method cost, including ongoing maintenance? For example: Electronic images saved on CD-ROM.
    4. What equipment and/or software is needed to access the records? For example: Equipment and software would be needed to read the CD's.
    5. What is the electronic format of the records? Consider the hardware, software, and operating system. For example: If the records are already in electronic format, copying them onto a disk is inexpensive.
    6. How would the records be accessed or retrieved? For example: If the vital records are stored off-site, is there 24 hour/7 day access?
    7. How often does the information need to be updated? For example: An emergency telephone tree may need to be updated every time there is a personnel change.
    8. Are there special considerations? For example: Do the records contain sensitive information such as confidential business information which require special handling?
  3. Mitigation Plan. In addition to determining how the records will be dispersed or duplicated, offices also need to take actions to prevent or soften the effects of man-made or natural disasters by implementing a mitigation plan. More details on this plan can be found in the next chapter.

2. Off-site and On-site Storage.

  1. Selecting an Off-Site Storage Facility. When vital records are protected by duplicating and storing them at an off-site storage facility, there are several things to consider.

    1. Check to see if an off-site facility has already been chosen as part of the COOP effort.
    2. Cost of storage may depend on the volume and format of the materials to be stored.
    3. Equipment and electricity to run the equipment may be needed to read the records.
    4. Copies of emergency operating records may be needed immediately. For example, the emergency telephone tree may be stored in a manager's home. However, it is important that another copy be stored in the off-site facility with 24-hour access so there is access if the manager is not available.
    5. Off-site facilities used to store copies of legal and financial rights vital records may be stored at an off-site location in accordance with NARA regulations (36 CFR 1228.156). It is recommended that they be stored at a facility meeting standards in accordance with NARA regulations (36 CFR 1228.156).
    6. Other FAA offices, local federal records centers (FRCs), or commercial off-site storage may be appropriate choices.
    7. The facility should have temperature and humidity control and 24-hour security.
    8. The facility should have a sprinkler system and/or a smoke detection system which alerts emergency officials when activated. Either or both should alert the local enforcement officials that the system has been activated. The area should have one or more fire extinguishers.
    9. The facility should have equipment to reproduce records, should the need arise.
    10. The facility should offer access to appropriate officials at any time of the day or night in the case of an emergency.
    11. On an annual basis, or more often, the area that vital records are stored in should be inspected for water leaks. Leaks may appear on ceiling or floor tiles, or along walls or windows.
    12. Ensure that the area where vital records are stored are not located in a flood plain designation.
  2. On-Site Storage Options. On-site storage options include fire resistant cabinets, safes, or vaults.
    1. Fire resistant cabinets and safes are best used for small quantities of very active vital records that need to be kept close to the user.
    2. Vaults are used for larger quantities of records. These devices should be in a building with a sprinkler system and/or a smoke detection system which alerts emergency officials when activated.
    3. The National Fire Protection Association (NFPA) classifies records protection equipment in two elements: (1) interior temperature limit and;(2) time in hours. The temperature limit selected should be determined by the contents: paper – 350 degrees Fahrenheit (177 degrees Centigrade),photographs – 150 degrees Fahrenheit (66 degrees Centigrade), electronic- 125 degrees Fahrenheit (52 degrees Centigrade). Time limits range from 1/2 hour to 4 hours. This means that the equipment must sustain sudden exposure to high temperatures to the extent described in the requirements without exploding.
    4. No vital records are to be stored on-site in standard file cabinets or open-shelf files, unless there is a duplicate of the record off-site.
    5. On an annual basis, or more often, the area that vital records are stored in should be inspected for water leaks. Leaks may appear on ceiling or floor tiles, or along walls or windows.
    6. The facility should be inspected for insects and rodents on an annual basis.
    7. There should be an evacuation plan at the emergency facility that is tested annually. Emergency lights should be installed and tested annually.

3. Alternative Media.

There are several common types of alternative media, such as microfilm, photographs, and electronic media.

  1. Microfilm. In some cases, microfilm is the safest and most economical media, but problems can occur without proper attention to maintenance of the film. Good microfilm produced in accordance with American National Standards Institute/Association for Information and Image Management (ANSI/AIIM) MS23-1998, Standard Recommended Practice – Production, Inspection, and Quality Assurance of First-Generation, Silver Microforms of Documents, will give a better chance of storage. If possible, air should be filtered to remove chemically reactive duct (ANSI IT9.11 for further explanation). A 5-10 percent sampling of the film should be randomly inspected on an annual basis. Microfilm should be stored in temperatures not to exceed 70 degrees Fahrenheit (21 degrees Centigrade) with a relative humidity of 30-40 percent. Temperature and humidity should not fluctuate over 5 percent within 24 hours.
  2. Electronic. One of the advantages of using electronic media for storage of vital records is that it is compact and easily duplicated. However, electronic media can be affected by electrical, magnetic and atmospheric influences, as well as temperature and humidity. Storage of media should be around 70 degrees Fahrenheit (21 degrees Centigrade) with a relative humidity of 30-40 percent. Temperature and humidity should not fluctuate over 5 percent within 24 hours.
  3. Photographic. Material should be maintained at around 70 degrees Fahrenheit (21 degrees Centigrade) with a relative humidity of 45-50 percent.
  4. Mixed Media. The best temperature for an area containing more than one type of vital record would be between 65-70 degrees Fahrenheit (18-21 degrees Centigrade).

4. Fly-away Kits

Essential employees who must be at the COOP site within two hours of the emergency should be provided with "fly-away" kits containing copies of the essential tier one documents in the event they are away from the office. Examples of the documents to be included are: COOP plan, delegations of authority, directions to the COOP facility, media procedures, emergency telephone lists, vital records plan, passwords, access codes, emergency passes, etc. It is critical that the information in these kits is updated and current.