Thursday, June 11, 2009

Reader Comment – 06-10-09 – Identification of Assets

I got an interesting telephone call from a long time reader last night. He wanted to point out an apparent error in my posting yesterday about the SSP requirements for RBPS #2. I stated that the Facility Notification Letter included identification of assets. This reader, who has seen a number of these letters, noted that there is no listing of assets in any of the letters that he has seen. I have gone back and read the appropriate discussion in the Instructions Manual and can confirm that there is nothing there that indicates that DHS will identify covered assets. Actually, I find this kind of surprising because facilities did identify potential assets in their SVA filings and I would have thought that DHS would have used that information to provide a listing of assets that would have to be addressed in the SSP. This is especially true because of the amount of information that was collected in the SVA about individual assets. To clarify the actual requirement then, paragraph 5.0 (pg 37) of the Instructions Manual states that:
“A facility should complete this section [RBPS #2] if it has identified an asset or assets for special security treatment relevant to satisfying an RBPS and did not provide information about all relevant security measures for that RBPS in the facility-wide section. The security measures unique to an asset in this section should be clearly distinguishable from facility-wide security measures.”
The reader did provide some additional information about the Final Notification Letters. These letters provide a listing of the COI that must be addressed in the SSP (no news there). Along with the listing of the COI, DHS has provided the Tier Level ranking for each COI. A Tier 1 facility may have COI on site that only ‘requires’ protection appropriate to a Tier 2, 3, or 4 facility. This means that when doing asset specific security measures that Tier 1 facility should look at the metrics for the tier appropriate to that COI.

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