Chemical Sector Security Awareness Training – March 2021

FEMA now has an on-line Chemical Sector Security Awareness Training (AWR-912) program available for use by the public, including personnel working at chemical facilities. This training program is not specifically targeted at employees at facilities regulated under either the Chemical Facility Anti-Terrorism Standards (CFATS) program or the Maritime Transportation Security Act (MTSA) program, but it could be used for general security awareness training by facilities in either program. Before an individual attempts to complete the course, they must register with FEMA and obtain a FEMA Student ID (FEMA SID).

NOTE: Readers who have received the March 2021 Chemical Security Quarterly email, will already have heard about this training program. You can sign-up to receive this email (and other CISA information via the https://public.govdelivery.com/accounts/GOVENGAGE/subscriber/new website).

Commentary

This is the new training program that CISA’s Chemical Sector-Specific Agency announced at the 2020 Chemical Security Summit last December. It is actually a rework of the training program that was originally introduced in 2008 and then discontinued sometime in 2015 without notice or explanation.

While this is billed as ‘Chemical Sector Security Awareness Training’ there is actually very little in this program that is uniquely targeted at the chemical sector. There are two video scenarios that use chemical imagery (totebins in one and a chemical railcar in another) to illustrate the need for individuals to be aware of their surroundings and the need for reporting unusual situations, but that hardly makes this chemical sector specific training.

There is no mention of the two federal regulatory programs that address security at chemical facilities, the Chemical Facility Anti-Terrorism Standards (CFATS) program and the Maritime Transportation Security Act (MTSA) program. There are certainly more ‘chemical facilities’ that are not covered by either program than there are covered facilities, it seems to me that there should at least have been some mention of these two important security programs.

Nor was there any discussion of the two specific reasons that a security awareness program at chemical facilities is important, deliberate release of hazardous chemicals as a means of attack on the local community or the theft/diversion of precursor chemicals for the manufacture of improvised explosives or improvised chemical weapons that could be used in a subsequent attack.

If CISA is expecting CFATS facilities to use this training program to satisfy the RBPS 11 annual training requirement for ‘All Remaining Employees’ it sadly only addresses one of the Training Topics listed in Table 13 of the RBPS Guidance Document; “Recognition of suspicious behavior”. Facilities would have to separately address the remaining training topics:

• Recognition and detection of dangerous substances and devices,

• Techniques used to circumvent security measures,

• Relevant provisions of the SSP, and

• The general meaning and consequential requirements of the different DHS Threat Levels

This training program hardly seems worth the effort.