Wednesday, June 10, 2009

SSP Submission – RBPS #2 Secure Site Assets

This is another in a series of blog posting on the recently released Site Security Plan Instructions Manual and Questions Manual. The other blogs in this series are: Preparing for SSP Submission SSP Submission – Facility Data SSP Submission – Facility Security Measures SSP Submission – RBPS #1 Restrict Area Perimeter The Final Facility Notification Letter will include a list of facility assets with the associated COI that the facility must address in their site security plan (SSP). Section 5 of the Instructions Manual provides some over-all directions for the completion of this RBPS in the SSP. Unfortunately, there seems to be a serious disconnect between how the Instruction Manual and the Questions Manual address RBPS #2. The confusion caused by this disconnect is at least partially cleared up by referring to pages 52 thru 56 of the SSP Screenshots available on the CSAT SSP web page. Given the importance of the Screenshots document in understanding this RBPS, DHS should have listed the document in the Key Documents section of the CSAT web page. Incomplete Instructions The Instruction Manual notes that “DHS expects that RBPS 2 (Secure Site Assets) typically will be applicable to all facilities at either the facility-wide level or the asset level (or both). However, a facility must address RBPS 2 for each asset whether or not facility-wide security measures were previously entered” (pg 34, IM). This implies, and later discussion confirms, that the facility will be required to identify and describe each asset. The Questions Manual only mentions identification of assets obliquely, stating after the first “Are there any security measures…” question that the Preparer should if “answering at the Asset level, write the name of the asset for which you are providing answers.” There is no indication that each asset identified in the Notification Letter must be named and described as identified in page 52 of the Screenshots. Nor is there any mention of the long list of questions about each asset that are shown on page 53 of the Screenshots. Additionally, there is no indication in RBPS #2 the Questions Manual that the facility will have to identify those RBPS that have “asset-specific security measures that are different from the facility-wide security measures” (pg 39, IM). There are brief mentions in later RBPS sections that questions may apply to either facility or specific assets. If the facility is planning on using the Questions Manual as a workbook for data collection for their SSP submission I have some suggestions for modifying that manual. Copies should be made of pages 53 thru 55 of the Screenshots; one copy for each asset identified in the Notification letter and any other assets that the facility might wish to report upon. Then the same number of copies should be made of each of the pages in the Questions Manual for the following RBPS numbers 3, 5, 6 and 7. A copy set should be labeled and grouped together for each asset and tabbed for easy access. Barriers Most of the questions dealing with barriers are very similar to the questions in RBPS #1. The reason for that is relatively simple; barriers are very much the same whether they are located on the facility perimeter or on the perimeter of a restricted area within the facility. There are some new questions such as the one dealing with skylights in roofs because the assumption was made that buildings roofs would be inside the facility perimeter. Surprisingly there are a number of new questions that probably should have been included in RBPS #1. For example there are detailed questions about anti-vehicular barriers, which certainly are applicable to internal barriers, but would also apply to facility perimeter barriers. Other questions in this category include the questions on barrier upgrades. There are two questions about internal barriers that are surprising in their sophistication. There are two internal barrier questions that deal with movable barriers utilizing ‘dispensed liquids, foams’. I have only seen these obliquely mentioned in the literature and they are not addressed at all in the RBPS Guidance document. I would certainly be interested in hearing from anyone that sells or uses such barriers. Intrusion Detection Systems The questions about intrusion detection systems for this RBPS are nearly duplicates of the ones used in RBPS #1. There are some minor changes in wording, but the intent on the questions remains the same. Given the similarity in questions it is imperative that Preparers keep in mind that they should not duplicate the answers from RBPS #1 unless there are similar sensor systems in use around internal restricted areas. Security Lighting I hadn’t noticed that there were no questions about security lighting in RBPS #1 until I read the questions on security lighting in this RBPS. I have no idea why these questions were not included the RPBS #1 Questions; the subject is certainly addressed in nearly identical language in the two RBPS sections in the Guidance document. The questions here focus on where the security lighting is, the level of lighting provided at specific areas (site perimeter, gates, and other critical locations), and the percentage of gates and critical locations that are lighted.

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