Friday, June 5, 2009

SSP Submission – RBPS #1 Restrict Area Perimeter

This is another in a series of blog posting on the recently released Site Security Plan Instructions Manual. The other blogs in this series are: Preparing for SSP Submission SSP Submission – Facility Data SSP Submission – Facility Security Measures In this posting I’ll look at the first RBPS, Restrict Area Perimeter, following up yesterday’s blog on the discussion of this RBPS in the Guidance document. As we will see with each RBPS section in the SSP the first question (pg 58) [Note: all page references are to the Questions Manual] is: “Does the facility have any existing, planned, or proposed measures for RBPS 1?” A negative answer to that question completes this section of the SSP. DHS will evaluate the entire SSP submission to determine if the ‘No’ is an adequate method of addressing this RBPS. There certainly may be facilities that require no security measures to protect the area perimeter, but most facilities will not be able to justify such an answer. Mechanics Preparers that worked on the facility’s Top Screen or SVA submission will be familiar with how these sections of the SSP submission work. Most questions require checking off either ‘yes’ or ‘no’ responses. Frequently a yes answer will lead to more detailed questions on that security measure. Many questions will provide a list of possible responses each followed by the typical ‘yes/no’ buttons. The last answer in these lists is usually ‘Other’. A ‘yes’ response will bring up a fill in the blank box where a short description will be used to explain that ‘Other’ response. For example the first security question in RBPS #1 is: “Does the facility have a defined perimeter marked by company property, no trespassing signage, fencing, or other barriers?” There are three response buttons; ‘Yes’, ‘Partial’ and ‘No’. A ‘Yes’ or ‘Partial’ response will lead to a more detailed question about the characteristics of that perimeter. A ‘No’ answer will lead one to the next question, concerning Clear Zones. As I noted in an earlier blog, there are no ‘instructions’ for the RBPS sections of the SSP in the SSP Instructions Manual and only navigation instructions provided in the Questions Manual. This means that Preparers are going to have to make educated guesses about terms like ‘Partial’ in these questions. One would presume in this case that ‘Partial’ means that the perimeter marking does not cover the complete facility perimeter. If the preparation team has questions about terminology they should first refer to the appropriate sections in the RBPS Guidance document (including Appendix C). Most of the questions are labeled with the RBPS Metric number that they support, this should help facility personnel figure out what information is being requested. If there is still confusion contact the CFATS Helpline (866-323-2957; Monday-Friday 7:00 a.m. – 7:00 p.m., Eastern Time). Potential Problem Questions I am not going to discuss every question in the section. Most of them are straight forward with the minimum of ambiguity. Other, however, I would expect to be somewhat confusing to people that work in chemical facilities and have little background in physical security. A word of warning, I am not a trained DHS Inspector so my interpretations may not toe the DHS party line. When in doubt, call DHS. Clear zone: The ‘clear’ zone is the area adjacent to a barrier that is cleared to nearly ground level (think closely cropped lawn) that allows personnel or surveillance equipment a clear view of potential operations near the barrier. Ideally that clear zone would be on both sides of the barrier to allow for the best observation. The ideal width of the clear zone depends on many factors, particularly the terrain, but should be wide enough to allow for ready access to security and maintenance vehicles. ‘Clear zone policy’ refers to the procedures for investigation/response to the detection of movement or penetration of the clear zone. Standoff distance: ‘Standoff distance’ is the distance between a potential target and the closest allowed approach to that target. The RBPS Metric 1.3 only addresses standoff distance for VBIED (vehicle borne improvised explosive devices) suggesting “Sufficient vehicle standoff distance or alternative protective means are provided to ensure that a VBIED is extremely unlikely to be able to compromise a critical asset.” Adequate standoff distance depends on the amount of ‘overpressure’ the target is capable of withstanding and the assumed size of the VBIED. Standoff distance for direct fire weapons like rocket propelled grenades may also be considered. Barriers: There are a large number of questions about a wide variety of possible barriers that might be employed at a high-risk chemical facility. The term ‘partial’ is used for many of the answers and refers to the fact that the ‘barrier’ referred to in that question does not completely surround the facility. Access Points: The way this term is used in the single question may be misleading. It does not refer to gates or doors (those are addressed elsewhere), but instead deals with alternative/clandestine routes through the barrier system. ‘Ditches’ and ‘culverts’ are easy to understand in this context, but ‘public roadways’ is less clear. This almost certainly refers to public roads that traverse the facility. What I don’t understand is why there are no questions about security measures protecting these ‘access points’. Intrusion Detection: Again, there are a large number of detailed questions about IDS or ‘intrusion detection systems’. The ‘partial’ response to these questions means that the system being addressed only covers a portion of the facility perimeter. These questions do not concern IDS systems protecting individual assets (that would be covered in RBPS #2). While there are questions about the existence of ‘back-up power supplies’ nothing addresses the duration these back-up will work. I have no idea what ‘controlled’ and ‘administered’ mean for IDS; they are either on or off. CCTV: The closed-circuit television (video surveillance) coverage question has a ‘new’ ‘Not Applicable’ response. If a facility does not have the type of COI referenced in the question (Theft/diversion or sabotage) or loading/unloading areas the appropriate response is “Not Applicable). The ‘controlled’ and ‘administered’ questions make more sense here. ‘Controlled’ refers to the ability to move cameras or their focus to change the field of view. ‘Administered’ refers to the over-ride authority to take control of a camera. Security Personnel: The term security personnel is used with a very wide definition. This can be seen in the use of the terms ‘dedicated’ and ‘casual’ to describe types of ‘observation’. ‘Dedicated’ observation is provided by personnel with the primary job of security. ‘Casual’ observation is provided by all facility personnel that have received rudimentary security awareness training and have some means for reporting an observed security incident.

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