DHS published a number of new questions (#1489 thru #1513) about the completion of SVAs on their FAQ page. It is interesting that these Frequently Asked Questions were posted within a little more than a day after the SVA documents were released. I doubt that these were recently asked questions. More likely these questions come from Phase I facilities that have been working on their SVAs for almost three months now (see: "Vulnerability Assessments are Underway").
For most facilities there is no point in covering these FAQ questions and answers until they get a chance to review the new instructions (or read my continuing reviews of the same). There are a couple of interesting points that we can look at without confusing a complex situation.
One thing that comes up frequently in these questions is how to use the various attack scenarios provided in the SVA. For personnel without experience in looking at how attacks are conducted this requirement could be confusing. There is little specific guidance about these scenarios in the SVA instructions. There is a good reason for that, the details of those scenarios is considered Chemical-Terrorism Vulnerability Information (CVI).
Thinking about that for just a moment, it makes a great deal of sense to ‘classify’ this information. The attack scenario would give the budding terrorist ideas about how an attack could be conducted. It would also provide insights into how facilities were expecting to be attacked. Attacking in an unexpected manner is the surest way to achieve operational surprise.
DHS does have a document available with more information on the attack scenarios. It is available only to registered-users of CSAT that are CVI trained and certified. It can be obtained by contacting the Help Desk at 866-323-2957 from 7:00 a.m. - 7:00 p.m., Eastern Time, Monday-Friday. The document will have to be protected as CVI.
Knowing Your Customers
For theft/diversion chemicals one of the ways that a terrorist might obtain these COI would be to set up a phony company (see: "Chemical Incident Review – 3-03-08") to buy the chemicals from a reputable company. DHS provides references to a number of documents from various industry associations and government agencies that deal with this issue.
- American Chemistry Council Responsible Care Implementation Guide for the Responsible Care Security Code Management Practices: Value Chain Activities
- Compressed Gas Association, Inc. Security Standard for Qualifying Customers Purchasing Compressed Gases (CGA P-51-2007).
- FBI Community Outreach Program for Manufacturers and Suppliers of Chemical and Biological Agents and Equipment
- The Fertilizer Institute’s brochure, "America’s Security Begins with You"
- The Drug Enforcement Agency’s Chemical Handlers Manual