Tuesday, June 16, 2009

SSP Submission – RBPS #3 Screen and Monitor

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 SSP Submission – RBPS #2 Secure Site Assets This posting looks at the SSP sections that deal with Screening and Monitoring access to the facility. Questions for this RBPS may be found in both the Facility and Asset level sections of the SSP. If the facility has indicated that there are asset specific security provisions at the site, they will be asked if there are RBPS #3 measures for each of the identified assets. An affirmative answer will require the answering of a series of questions about those measures. Screening Questions The first real question asks about the general level of screening conducted at the facility. With answers ranging from all vehicles and personnel entering the facility to no screening, it seems to be fairly easy to select an appropriate response. One slight draw back; the answers assume that similar levels of screening are being done for both personnel and vehicles. If one is being required to undergo a significantly higher level of screening than the other, use the “Other” response and explain the situation in the provided block. Then there will be individual questions about the use of screening on inbound and outbound vehicles and personnel. An affirmative answer to any of these questions will bring up additional detailed questions about how that screening is performed. The first question in the series asks about the methods used to perform the screening with four possible answers:
Not allowed on site Cursory inspection Random inspection Not applicable
These answers do not appear to include 100% screening, but that is misleading. If the facility were to select ‘Random inspection’ the subsequent question asking about the frequency of inspection includes an answer of ‘100%’. Thus a facility that does 100% screening should select ‘Random inspection’ for their response to the initial question. There is a special area for ‘Inbound Trucks and Railcars’. It is not clear from the information available in the Questions Manual whether these questions are limited to tank trucks and tank cars or if they also include dry-box trucks and rail cars. Looking at the earlier questions about inbound inspections, there are questions about inbound ‘delivery vehicles’ which could include dry-box trucks picking up shipments. I would probably tend to answer questions about dry-box trucks under the ‘delivery vehicle’ question and any boxcar rail shipments under the ‘Inbound Trucks and Railcars’ question. I base this assumption on the fact that both types of railcars are required to be inspected before loading under TSA rail security regulations (49 CFR §1580.107(a)) if they are being loaded with Rail Security-Sensitive Material. For facilities with Theft/Diversion COI there will be a series of question about inspections of outbound vehicles. It may seem strange to see the question about POV (personally/privately owned vehicles) outbound from ‘Theft COI Areas’, but this would be an appropriate question if POVs were allowed to be parked near warehouse areas where Theft/Diversion COI are stored or loaded onto trucks. If one of the vehicle types addressed in this section is not allowed to be parked near an area where Theft/Diversion COI are stored or handled, the appropriate answer would be ‘Not Applicable’. Similar questions are asked for a variety of personnel and their hand carried items. Again, there are separate questions for inbound and outbound inspections. The answers to these questions are essentially the same as those answered for vehicle inspections. Identification Verification The other area included in this section deals with the procedures that the facility uses to verify the identity of personnel entering the facility. The first set of questions in this section concern ‘General Identification Methods’. Two of the questions in this section seem to be out of place since they ask about checks of vehicles and hand carried items to prevent “the introduction of weapons, explosives, drugs, etc. into the facility” (pgs 116-7, Questions Manual). These questions were dealt with in great detail in the earlier ‘Screening’ section of the SSP. Most of the questions are fairly straight forward items asking about procedures for checking identification and the uses of badges and passes. One question seems a little bit odd in the way it is presented. On page 120 of the Questions Manual there is a matrix that looks at the types of badges and passes that might be used on one axis and the people that might be required to use those badges and passes on the other axis. Where the columns cross you find the typical ‘Yes’ and ‘No’ buttons. This is a an economical way of presenting these questions. The odd thing is the last entry on the ‘personnel’ axis; ‘N/A’. The only thing that I can think of is that a check in the ‘Yes’ box in the ‘N/A’ column automatically marks ‘No’ for all of the personnel responses for that ID type. Access Control System While Access Control Systems (ACS) are technically part of the ‘identification verification process’ they do deserve their own unique discussion. I was disappointed that Access Control Systems were not addressed in the RBPS Guidance document, but they are addressed here in the SSP. Unfortunately, from the information presented in the Questions Manual, it is not possible to tell if there will questions on the use of ACS in the asset security portion of this RBPS section. There are a similar series of questions to those seen in the CCTV and Alarm Systems section of the RBPS #1 questions. They ask where the ACS will be ‘controlled’, ‘administered’ and ‘monitored’. The way the ‘monitored’ question is presented (a ‘Yes’/’No’ choice for each location) that multiple answers to that question are expected. I have the same complaints about the lack of explanation for the distinction between ‘controlled’ and ‘administered’ that I expressed in the SSP RBPS #1 posting. Vehicle Restrictions The vehicle restrictions section of the RBPS #3 portion of the SSP looks at how the facility controls the movement of vehicles into and within the facility. This section uses a term that is derived from the design of European Castles; the ‘sally port’. In castle construction this was an area between the inner and outer walls of the castle where a force could assemble to ‘sally forth’ and conduct their counter attack It was distinguished by two sets of gates; one in each wall. In modern security usage it describes a protected area where an inspection can be conducted between two closed gates. Under high-threat conditions only one gate will be opened at a time. This section also includes questions about parking areas on and off site. There are questions about the parking situation allowed for a variety of classes of vehicles, including employee, contractor and visitor POVs. The other class of vehicles listed is ‘Delivery’ vehicles, so I guess this covers both pick-up and deliveries (answering a question earlier in this posting). One class of vehicles that is missing from this section is ‘Service Vehicles’; those vehicles driven by a wide variety of vendors that make deliveries and provide technical services at high-risk chemical facilities. They may include uniform, food and office supply vendors that do not typically make their deliveries to normal loading docks. They may also include a wide variety of technicians providing service to a wide range of specialty equipment. This may be especially critical since these vehicles are frequently parked in or adjacent to operational areas of chemical facilities.

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