Monday, April 20, 2009

Draft SSP Review – Risk Based Performance Standards

This is the last in a series of blogs describing the draft SSP Template that was provided by a reader of this blog, not DHS. Just a quick reminder, this means that there might be differences between this template and the one that DHS will shortly be opening on the CSAT web site. The previous blog in the series were: Draft SSP Review – General Facility Information Draft SSP Review – Facility Operations Draft SSP Review – Facility Security Measures Draft SSP Review – Asset Security Measures The bulk of the SSP Template consists of questions and answers regarding the Risk-Based Performance Standards. Any legitimate detailed discussion of the questions will require reference back to the RBPS Guidance document. Unfortunately, the Office of Management and Budget has still not yet approved the final version of this Guidance Document. With the amount of time that it has taken to get OMB approval, it is very possible that there will be some significant required by OMB before the guidance document can be published. That would require at least some changes form the draft version of the SSP that I currently have. Even trying to divine the contents of the Guidance documents from the questions available in the draft SSP Template that I have would be difficult at best and unfair at worst. For example, one of the controversies raised in the Draft RBPS Guidance document was the issue of ‘requiring’ an on-site armed response force. Question 10.33 in RBPS # 4 asks about security force weapons. This is a legitimate question even if there is no indication in the RBPS Guidance that DHS would like to see some facilities have an armed response force. So, until the RBPS Guidance document is published, there isn’t much else I can say about the draft Site Security Plan Template.

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