Federal Records Management

File 3: Records Stored in a Commercial Records Storage Facility

(version 2.0 issued July 27, 2012)

1. When do I use this Toolkit File?

  • If your agency stores or plans to store Federal records in a commercial records storage facility, you must document that the facility meets the 36 CFR 1234 storage standards (formerly numbered 36 CFR 1228, subpart K) and send the documentation to the National Archives and Records Administration (NARA). See "Documentation Requirements" section below for details. A copy of 36 CFR 1234 is found in File 5 of this Toolkit and at here.
  • See File 2 of this Toolkit if you store records in an agency-operated records center. See File 4 of this Toolkit if you store records in your agency office space.

2. What are the documentation requirements?
At least 45 days before beginning to transfer records to a commercial records storage facility, an agency must provide documentation to NARA demonstrating that the commercial facility meets the storage standards set in 36 CFR 1234 (formerly numbered 36 CFR 1228, subpart K). Submit separate documentation for each individual facility that you will use. The documentation can be either:

  • A copy of your contract with a commercial records storage facility that incorporates the requirements of 36 CFR 1234 into the contract requirements; or
  • A statement from the agency's records officer certifying the facility meets all of the requirements of 36 CFR 1234. As part of the certification, the agency must submit information about the fire-safety detection and suppression system.
    • You may complete and submit the Facility Standards for Records Storage Facilities Inspection Checklist and Supplemental Checklist contained in this File 3 or you may complete a certification statement containing the information found at the end of this File.
    • You may have the Checklists prepared by the vendor, knowledgeable agency facility staff, or an engineering firm or fire protection firm. However, NARA will not review documentation sent directly by commercial vendors nor does NARA inspect commercial facilities upon request by the agency or the vendor. The certification statement, if used, must be prepared by a Federal records officer or other agency staff member.

3. Where do I send the documentation?
The agency records officer or designee must send the documentation for each commercial facility where its records will be stored to:

Business Support Services, Real Property Planning Division
National Archives and Records Administration
8601 Adelphi Road, Room 1200
College Park, MD 20740-6001

or by e-mail to: scott.birckhead@nara.gov

4. How does NARA review my documentation?
NARA reviews the documentation to ensure the facility demonstrates full compliance with the 36 CFR 1234 standards. NARA will notify you within 30 days if the documentation is not adequate or if NARA has other information that suggests that the facility is not compliant with the standards.

5. What facility inspection requirements must be met for commercial records storage facilities?
Agencies must ensure, by contract or otherwise, that agency and NARA officials, or their delegates, have the right to inspect commercial records storage facilities to ensure that such facilities fully comply with the standards. NARA may conduct periodic inspections of commercial records storage facilities so long as agencies use such facilities to store agency records. The using agency, not NARA, will be responsible for paying any fee or charge assessed by the commercial records storage facility for NARA's conducting an inspection. NARA will contact the agency holding a contract with a commercial records storage facility in advance to set a date for the inspection.

6. Questions?

Contact Scott Birckhead by e-mail at scott.birckhead@nara.gov, by phone on (301) 741-5037.