Tuesday, May 12, 2009

Reader Comments – 05-11-09 – Video Escort

As I had hoped, John Honovich has responded to yesterday’s blog on using video systems to monitor non-TWIC personnel. John writes (in part, see the whole comment attached to yesterday’s blog):
1. It's very hard to set up video surveillance cameras to cover all areas of a facility. Lots of logistical barriers exist - some permanent, like trees, walls and storage areas and some temporary like trucks, containers, etc. The risk is high that significant gaps will exist in coverage. Designers may try to use PTZ (controllable cameras) but then someone needs to control them and they may still have issues with barriers preventing them from seeing areas. 2. If video analytics are used (such as Siemen's SiteIQ), there will certainly be issues where the system losses sight of an unescorted person. This could be because of inclement weather or more frequently, bright sunlight or darkness obscuring a person. 3. One of the key benefits of a human escort is that the human escort can instantly respond and intercept an unregistered visitor from causing damage or violating regulations. With video surveillance, an operator will have to dispatch a responder which costs critical amounts of time.
John and I also traded a series of emails about this subject yesterday (most of the points John made there were included in his posting). Those conversations brought out some information that was lacking in the original blog posting.


To keep this discussion clear and understandable we need to look at three definitions in 33 CFR Part 101 – Maritime Security. These definitions are for the terms, ‘escort’, ‘secure area’ and ‘restricted area’ come from §101.105:
“Escorting means ensuring that the escorted individual is continuously accompanied while within a secure area [emphasis added] in a manner sufficient to observe whether the escorted individual is engaged in activities other than those for which escorted access was granted. This may be accomplished via having a side-by-side companion or monitoring [emphasis added], depending upon where the escorted individual will be granted access. Individuals without TWICs may not enter restricted areas [emphasis added] without having an individual who holds a TWIC as a side-by-side companion, ****” “Restricted areas mean the infrastructures or locations identified in an area, vessel, or facility security assessment or by the operator that require limited access and a higher degree of security protection.” “Secure area means the area on board a vessel or at a facility or outer continental shelf facility over which the owner/operator has implemented security measures for access control in accordance with a Coast Guard approved security plan.”
For purposes of this discussion we will assume that the same terms and restrictions apply to high-risk chemical facilities under CFATS. That isn’t strictly true, but it is close enough for our purposes. For example, TWICs are not required for most high-risk chemical facilities, but the underlying identification and vetting requirements do apply. There are two other terms that I will use that are not included in the regulations list of terms, so I will provide the definitions for their use in this discussion. Those terms are ‘monitoring’ and ‘video escorting’:
“Monitoring means the use of a video system by a trained operator to track the movements of personnel through the non-restricted areas of the facility.” “Video escorting means the use of video system and a software based security management system to automatically track personnel movements through non-restricted areas of the facility. The system will alarm when tracked individuals leave a designated area or enter areas other than those designated for that individual.”
While ‘video escorting’ is a form of ‘monitoring’ it turns more control to the software for moment to moment observations allowing the human monitor to track more people at one time. The human monitor remains in the loop to respond to alarms, direct security personnel and watch for non-standard conditions that might interfere with software observation.

Identification of Targets 

One of the problems that John pointed out in our email exchange is that for video escorting you need to have a way to initially identify the escorted ‘target’ to the system. This would typically take place at one of the entrances to the facility. A security guard would establish the identity of the person and verify that the person was authorized some level of access to the facility using whatever controls required by that facility security plan.

This would have to include a clear designation of what areas that person was authorized to go without side-by-side monitoring. All of that information would have to be entered into the security management system. This would effectively establish an electronic tag for that individual containing the essential security information about that individual. A more sophisticated system could include a copy of the individual’s ID and a photo of the individual.

SPECIAL NOTE: privacy rules would probably require that the individual be informed that the facility would maintain these records in their security files. Then there would have to be some way to link the information tag to the virtual location of the individual on the facility map. The details of this would vary by the system used, but it could be as simple as having the person stand in a designated position at the gate while the security system acquired with the video tracking system. As noted in the original article this could get more involved by including an RFID tag on the visitor’s badge with sensors/readers scattered around the facility to add location verification capabilities to the system. Even something as simple as using a different color head gear for these targets would be an aid for the system identification.

Response Requirements 

A key part of the escort definition in §101.105 is the requirement to be able to “to observe whether the escorted individual is engaged in activities other than those for which escorted access was granted”. Missing from that definition is the derived necessity of being able to take appropriate responses to the unapproved activity. The vast majority of these ‘security breaches’ are going to be unintentional errors by the person moving about the facility on authorized business.

The appropriate response would be to have someone intercept and talk to the individual to set them on the proper path. The small number of intentional breaches is going to require a different level of response, but would still begin with interception. To differentiate between the two types of breaches will most often require some level of investigation. Unless all escortees are going to be given communications devices, this will require a security person to find and intercept the person doing the unexpected. This may become manpower intensive as the number of escortees rises and erase the personnel gains realized by installing a video escort system.

To Be Continued – This entry is getting more than a little long, and there is much more to discuss, so we will take this as a natural stopping point and resume this tomorrow.

1 comment:

John Bennett said...

Hi Patrick,

You’ve got a great blog going.

On the issue of escorting/monitoring non-TWIC holders: It is true that the definition of escorting doesn’t include a response capability. Going out on a precarious limb, I’ll assume that’s because the rule drafters figured that the physical escort would respond appropriately as part of his/her escort duties. While 33 CFR 101.105 doesn’t include a definition of monitoring, and it ought to, there is some guidance for the maritime transportation sector in the Coast Guard’s Navigation and Inspection Circular 03-07,

In secure, but non-restricted, areas persons without TWICs may be escorted or monitored. According to Section 3.3c.(2)(b) of Enclosure (3):

"Protocols for monitoring must enable sufficient observation of the individual with a means to respond if they are observed to be engaging in unauthorized activities or in an unauthorized area."

The examples then provided include allowing:

1) A supervisor to send a TWIC-less employee on a short task, with the monitoring apparently consisting of the supervisor’s knowledge of the length of the task and undertaking to look for the employee if the latter does not check back with the supervisor within that length of time allowed for the task;
2) TWIC holding crew members to monitor a work group or “persons in addition to crew” on a vessel underway by observing them while they are carrying out their assigned tasks and by ensuring that they do not enter any spaces where they are not authorized while the work group is off duty;
3) Use of CCTV systems as long as they are monitored (by TWIC holders) and permit the operators to see in sufficient detail if the TWIC-less person is moving into an unauthorized area or is engaging in unauthorized activities. Additionally, “adequate measures (e.g. security patrols) must be in place to respond to unauthorized activities; and
4) Other arrangements, including security patrols or roving watches, automatic intrusion-detection devices, or surveillance equipment, so long as they provide a reasonable assurance that an individual under escort is not engaging in activities other than those for which access was granted.

One can question whether the response capabilities that appear acceptable in the eyes of the Coast Guard would prove adequate in the case of a real life “bad guy,” but the requirement for a response capability is in fact set forth in the guidance (non-binding, to be sure, but ignored in its prescriptive areas at one’s peril). John Honovich is absolutely correct in pointing out the critical time lost when dispatching a response as compared to the escort already on scene.

John Bennett

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