Tuesday, September 22, 2009

CFATS Training- Security Task List

We continue looking at training development for security forces at high-risk chemical facilities. Many of the concepts, if not the details, we are discussing can be applied to development of any of the security training that needs to be conducted at such facilities. The earlier blogs in this series include: CFATS Training CFATS Training – Security Job List Today we will look at how security procedures are mined for information about the individual task that security personnel will have to be able demonstrate competency at to be considered proficient at their job. Again, we will continue to look at the front gate and actions of the gate guard for the examples used in this discussion. Procedures Book We finished off yesterday’s discussion with a brief look at the procedures book that would be found at each security station. Each book will detail the procedures that will be executed at that station in support of the facility site security plan (SSP). Where security forces are provided by contractor, it will typically be the contractor that writes the actual procedures, but it remains the responsibility of the Facility Security Officer (FSO) to ensure that the procedures properly reflect the requirements of the SSP submitted to DHS. One easy way to do this will be for the FSO to take a copy of the submitted SSP and go through every SSP question to determine which ones pertain to each of the security stations. A copy of the pertinent questions will be made and placed in a requirements book for that station. That way the security supervisor for the guard company and the FSO will have a common understanding of what is required for each station. Since this information is directly abstracted from the SSP it will need to be marked and protected as Chemical-terrorism Vulnerability Information (CVI). The security agreement between the facility and the security company needs to specify that the security company is qualified to handle and store CVI. The facility does need to insure that the security supervisor they provide the requirements data to is a ‘qualified person’ under the CVI rules and that only qualified personnel with a need to know at the security company will have access to the CVI data. One last comment on CVI; it would certainly be possible to write a security procedures manual that is not CVI. It would include no reference to the Site Security Plan or any other document covered in 49 CFR 27.400. Since the information in the security procedures manual needs to be protected against disclosure to potential terrorists anyway, there is probably no reason to adequately sanitize the manual so that it does not include reference to CVI material. If the procedures manual is CVI, the security personnel using that manual will need to be cleared for CVI. Creating the Task List From a training development perspective the purpose of the security station procedures manual is to provide a description of the jobs that need to be accomplished at that station. The training developer can take that job description and develop a list of specific tasks that the security personnel will need to be able to perform to complete that job. First we need to look at an example of a possible job listed in the procedure manual for the front gate; Chemical delivery (inbound) vehicle – tank wagon:
“Every inbound loaded tank wagon will be stopped at the front gate. The driver’s identification and manifest will be checked against the information provided by the facility Receiving Clerk. A walk around inspection will be done and the Inbound Vehicle Checklist will be prepared documenting the results of that inspection. The Unloading Supervisor will be contacted for spotting instructions for the vehicle. The driver will be given a copy of the Inbound Vehicle Checklist and directed to the proper spotting location.”
From this job description we can look for specific tasks that the security guard will have to complete to successfully perform this job. Typically we write tasks in a specific format. They start with an action verb and provide a brief description of what must be done. A list of tasks for this job would include:
Stop inbound vehicle at front gate. Check commercial driver’s license. Check inbound manifest. Conduct walk around inspection of tank wagon. Look for improvised explosive devices. Check seals on locking device. Prepare Inbound Vehicle Checklist. Direct Driver to spotting location. Respond to leaking tank wagon. Respond to security incident at front gate. Contact Security Supervisor.
Many of the tasks in the list are clearly taken directly from the written procedure. Others are taken in a more generic manner from the procedure. For example the requirement to stop every ‘inbound loaded tank wagon’ is changed to the stopping a more generic ‘inbound vehicle’. This is because the task of stopping vehicles at the front gate is generally the same, regardless of the type of vehicle. In the case of checking the driver’s identification, the task became the more specific ‘check commercial driver’s license’. This is because a tank wagon driver is required to have a specific type of identification and the procedure could include checking the driver’s license against a faxed copy of the license, or comparing the number on the license with a number on a provided list. This would be significantly different than checking an employee ID or a visitor’s ID. Two of the tasks on this list, looking for IEDs and checking seals, are tasks that are included in the larger task of conducting a walk around inspection. These are tasks that are common security tasks regardless of the station. Instead of having to re-write the instructions for these tasks in every larger task where they might be included, they are written separately and referenced in the other appropriate tasks. The task list includes one non-security related task; ‘respond to leaking tank wagon’. Every person on a chemical facility has certain emergency response requirements that they are responsible for. Reporting spills and or leaks is one of the most basic. Because the guard is required to conduct a walk around inspection of the tank wagon they will sooner or later find one leaking and have to react accordingly. Each security station will have its own set of emergency response requirements. They may be listed as jobs in the procedure or as tasks that are parts of jobs, depending on the local situation. The next to last task, ‘respond to security incident at front gate’, is a variation of a task that will be found at each security station. A security incident is any violation of security rules. This task will include a listing of the potential violations and the appropriate reactions for each. The list should include a generic ‘other violation’ listing to recognize the fact that security planners are not omniscient. This task will typically be reproduced as a poster (called a ‘job aid’ in the training development community) prominently displayed at the security station, out of public view. This will aid in a quick yet appropriate response to potentially unnerving situations. The last task addresses those inevitable situations that security planners did not foresee. When ever something arises that is not covered in the instructions, yet is not obviously a potential threat, the security guard needs to contact the supervisor for instructions. This task would address that situation, providing routine contact instructions for the Security Supervisor, Facility Security Officer and other appropriate personnel in order of contact priority. Consolidation of Task Lists Once tasks lists have been prepared for every job at every security station, they are brought together for consolidation. Many task will be identical or nearly so at every security station. These similar tasks need to be grouped together before the next step in the process can begin. That step is the fleshing out each task into a description exactly what must be done, a listing of the conditions under which it must be done, and specifying how well it must be done. We’ll cover that in the next installment.

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