CFATS Training- Task Definition

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 CFATS Training- Security Task List In earlier postings we looked at how security procedure books for each security station at a high-risk chemical facility provides a listing of the security jobs that security personnel at that station need to be able to perform. Then we looked at how those jobs can be broken down into their component tasks. Today we will look at how those tasks are fleshed out into useable training tools. Task Definition Once the task list for all of the jobs at all of the security stations is compiled we need to further define what those tasks entail beyond just their task name. In the 1970’s the US Army revolutionized its training development with the realization that before they could define how a job needed to be done they first had to determine the conditions under which the job would be required to perform and how well the job needed to be done. This led them to the use of the Task-Condition-Standard method of defining a job task. When determining the task performance conditions, one of the first things that one needs to determine is if the task is a knowledge task or a performance task. Knowledge tasks are more passive and require the person completing the task to know something and process information based on that knowledge. This type of task is ideally suited to classroom type instruction and written tests. A performance task is one that requires physical action to complete. Most security duties predominantly utilize performance tasks. These tasks are better suited to hands on training with the equipment that will be utilized in a real world situation. Task performance evaluation is best done by requiring the person to actually perform the task with the provided equipment. This also lends itself to periodic on-the-job evaluation of task performance by observing the task completion in an actual job situation. Condition Statement For knowledge based tasks the condition statement for the task will explain under what conditions the knowledge will be applied in the field and the type decision that the person performing the task will be expected to make. For example the ‘Respond to a Security Incident’ task identified in an earlier blog would be a knowledge based task requiring the security person to correctly identify the type and severity of the situation before responding. The condition statement for a performance task details the equipment and information that must be available to complete the task as well as the conditions under which the task will be performed. In the “Conduct walk around inspection of tank wagon” task we listed earlier we would obviously need to have a tank wagon stopped at the security station. It would also require the presence of a shipping manifest or other document for the vehicle that describes essential information that the guard would be expected to check during the inspection Standard Statement The standard statement provides a measurable description of adequate performance of the task. For many tasks this is a relatively easy statement to define. On the “Check inbound manifest” the standard statement would require the detection of 100% of the differences between the offered manifest and the file manifest. Other tasks are more difficult to define measurable standards. On the “Check seals on locking device” the standard statement could require the detection of 100% of tampered seals but this would require the careful definition of ‘tampered seals’. Specific measurable performance standards typically lend themselves to realistic performance evaluations. A properly developed performance standard provides an unambiguous measure of task competency. This is an essential requirement for an effective training program. Knowledge based tasks are potentially the hardest to write performance statements for. What is frequently done is to use a standard written test and require a set number of correct answers to demonstrate adequate performance. While simple multiple choice tests for this type standard are easy to write, they are seldom good measures of a person’s knowledge of the information. A more thorough written test follows the case study model. A detailed description of a real life type situation that the person could be expected to respond to is provided. Pictures and short videos can be used to enhance the written description of the situation. If multiple choice answers are used to check responses, the provided responses need to be developed carefully. Providing incorrect responses that are obviously wrong defeats the purpose of the evaluation. These case study type evaluations can be useful for some hands-on type tasks. Where setting up a hands-on evaluation would be expensive or dangerous a properly designed case study written evaluation is probably a good choice. Other Supporting Information Once the task list is developed and the task definition is complete, the training developer begins to collect additional information about the task. Instructions on how to complete a task, safety information and, in some cases, legal requirements all need to be collected before the training developer can begin to develop the training plan.

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.

CFATS Training – Security Job List

As I mentioned on Saturday’s blog I did receive an encouraging comment on Friday’s blog about CFATS training. As is expected with positive reinforcement comments like this are a sure way to get me to revisit a topic. Today I would like to take a closer look at CFATS training for security personnel. RBPS #11 and Security Personnel The Risk-Based Performance Standard Guidance document does make two specific mentions of training for security personnel. The first is in an explanation of how training topics need to be adjusted to the target audience. RBPS #11 (pg 91) notes that: “Typically, if the audience consists of designated security personnel, the details of security procedures, operations, communications, etc., will warrant extended discussion.” A more significant discussion of security team training is found in Metric 11.1, Security Training Program for Security Personnel. For all four Tier levels, this metric provides the following guidance (pg 95):

“The facility has a documented security awareness and training program and a corresponding set of minimum skills and competencies for security personnel, as well as a testing program through which security personnel can demonstrate their ability to perform their security-related tasks in a reliable and effective manner. A typical training program will include such features as: “Training is provided on recognition of a security incident, reporting of a security incident, emergency procedures, and operation of security equipment. “Training is held on a regular basis for security personnel. “Objectives are established for each element of the training plan. “Training records are maintained in accordance with 6 CFR § 27.255(a)(1).”

The security metric does not provide a list of what would be considered to be a ‘set of minimum skills and competencies for security personnel’. Part of the reason for lack of such a listing can be found in the §550 prohibition of DHS requiring any specific security measures. A more important reason would be that a comprehensive listing of such skills would vary widely from facility to facility depending on its specific security needs. Additionally, there will be some variation based on what State and local laws allow security guards to do and require in the way of training. Security Job List The first thing that must be done in developing a security personnel training program is to develop a listing of the jobs that security personnel are going to have to perform. We generally start with the high-level task. For example we would start with a security guard at the front gate of the high-risk facility. A list of jobs at the front gate might include:

Maintain security equipment Check pedestrian traffic entering facility Check vehicles entering the facility Check vehicles exiting the facility Respond to security incidents Respond to safety incidents Conduct countersurveillance activities

The facility security officer, the security supervisors, and security guards should all provide input during the development of the of the job list. Most facilities will remember to include the first two, but most will forget to include the most important, the experienced security guard. No one knows better what is actually done on a day-to-day basis than the person actually doing the job. Once a basic job list is developed take a close look at each job listed to see if the listing is too general. For example the listing for ‘Check vehicles entering the facility’ may cover too much, depending on the facility. A different process might be used depending on the type of vehicle being checked. That could be divided into more jobs depending on the type vehicle. For example:

Employee/contractor vehicles Non-chemical delivery vehicles Chemical delivery (inbound) vehicle – dry box Chemical delivery (inbound) vehicle – tank wagon Chemical delivery (outbound) vehicle – dry box Chemical delivery (outbound) vehicle – tank wagon

Once the job list is developed it needs to be carefully checked against the Site Security Plan (SSP) and its supporting procedures. Every time the plan or procedures mentions something that must be done or accomplished at the front gate there needs to be a corresponding job on the job list. A single job might cover multiple listings in the SSP or procedures, but there does need to be a job on the list for every mention of the front gate. Anytime that there are changes made to the SSP or its supporting procedures, the job list needs to be reviewed and updated as necessary. One other thing needs to be included in this job list, actions required to be taken in emergency situations. This absolutely needs to include non-security emergencies such as fires, injuries, and chemical releases. The security guard at the front gate typically has a number of critical jobs to perform in each of these situations, but all security personnel will have specific tasks to perform in each of the typical facility emergencies. Front Gate Procedures Book The Security Job List for the Front Gate will be the basis for determining what must be included in the procedures book for that location. That procedure book will provide information of a general nature for all security personnel as well as the detailed procedures necessary for the performance of all of the jobs in the Job List. There should be a separate procedures book for each security station. Tomorrow we will look at how the Security Job List will allow us to develop a list of specific tasks that the front gate guard needs to be able to perform to successfully meet the requirements of the job list.