Monthly Archives: January 2017

USCG Issues Policy Regarding Reporting Suspicious Activity and Breaches of Security

This is CG-5P Policy Letter 08_16.   It discusses requirements and guidelines as summarized below for MTSA regulated ports.  The regulatory standing is quoted as 33 CFR 46, 70103.  It is dated December 14 and was distributed on January 16.  This renewed focus includes reporting requirements for cyberattacks and Unmanned Aircraft Systems activity.

The stated purpose of the letter is to “Promulgate policy for use by Maritime Transportation Security Act (MTSA) regulated vessels and facilities outlining the criteria and process for suspicious activity (SA) and breach of security (BoS) reporting”.

It states, “An owner or operator of a vessel or facility that is required to maintain an approved security plan . . . (a) shall, without delay, report activities that may result in a Transportation Security Incident (TSI) to the National Response Center (NRC), including SA or a BoS. And, (b), the Facility Security Plan (FSP) shall . . . be consistent with the requirements of the National Transportation Security Plan and Area Maritime Transportation Security Plans.”

“The COTP will affirm consistency to help ensure alignment of SA and BoS communication procedures within FSPs throughout their area of responsibility.” 

Regarding cyber activity the letter states, The target and intent of malicious cyber activity can be difficult to discern. The fact that business and administrative systems may be connected to operational, industrial control and security systems further complicates this matter. The Coast Guard strongly encourages vessel and facility operators to minimize, monitor, and wherever possible, eliminate any such connections.

The letter goes on to describe U. S. Coast Guard requirements for reporting BoS and SA for both physical and network or computer-related events.  The U.S. Coast Guard regulations define a breach of security as “an incident that has not resulted in a TSI but in which security measures have been circumvented, eluded, or violated.” This definition includes the breach of telecommunications equipment, computer, and networked system security measures where those systems conduct or support functions described in vessel or facility security plans or where successful defeat or exploitation of the systems could result or contribute to a TSI.

BoS incidents may include, but are not limited to, any of the following:

  •  Unauthorized access to regulated areas;
  • Unauthorized circumvention of security measures;
  • Acts of piracy and/or armed robbery against ships;
  • Intrusion into telecommunications equipment, computer, and networked systems linked to security plan functions (e.g., access control, cargo control, monitoring), unauthorized root or administrator access to security and industrial control systems, successful phishing attempts or malicious insider activity that could allow outside entities access to internal IT systems that are linked to the MTS;
  • Instances of viruses, Trojan Horses, worms, zombies or other malicious software that have a widespread impact or adversely affect one or more on-site mission critical servers that are linked to security plan functions; and/or
  • Any denial of service attacks that Any denial of service attacks that adversely affect or degrade access to critical services that are linked to security plan functions.

 The letter contains lists of Suspicious Activities and Breaches of Security that should be reported and concludes with a Glossary of Terms.

Click here  for the complete document.

Policy Procedures and Standards Made Simple

As a public safety officer, I was once tasked with writing instructions for loading pre-connected hose lines on fire trucks.  While a straight forward task, a mistake or simple misunderstanding by a firefighter could have serious consequences, delaying rescue and/or getting water on the fire. Writing clear step by step procedures was a challenge and also great training, especially when the procedures would be tested on the fire academy training ground.

I have been engaged in policy and procedure development for security, safety, environmental, and chemical management functions since 1981.  I believe I have learned a few things:

Clarity and Enforceability – keep it simple and straight forward, not only to help employees understand the rules and guidelines, but to enable enforceability for violations of company policy, a key concern today of Human Resources.  How well will the policy stand up in court?

Consistency in Format and Template – Following a consistent template for all policy and procedures makes it easy for employees to find the information they need and enhances their understanding of requirements.

The Distinction between Policy, Procedure, Standard and Guideline.

Definitions based on NIST (National Institute of Standards and Technology) and SANS Institute standards include:

  • Policy – A policy is a system of principles to guide decisions and achieve rational outcomes. A policy is a statement of intent, and is implemented as a procedure or protocol.   Policy is generally drafted to foster enforceability.
  • Procedure – A set of business processes, activities and tasks that, when implemented, contribute to accomplishing a policy goal. Procedures are often step by step instructions and are drafted to be enforceable.
  • Standard – A document that provides requirements, specifications, or characteristics that can be used consistently to ensure that materials, products, processes and services are fit for their purpose. Often a minimum standard that must be followed.
  • Guideline – Recommended practice that allows some discretion or leeway in its interpretation, implementation, or use.

The Policy Catalogue – How does a company make it easy for employees to find the policy and procedures they need?  During a project last year, we conceived the idea of a “Policy Catalogue”, a well indexed online document that contained all IT policies and the subordinate procedures, standards, and guidelines for each policy.  The catalogue Table of Contents, in one quick glance, showed not only where to find what was needed, but how the whole policy system was organized.

Don Greenwood & Associates, Inc. has an extensive library of asset protection and security policies and procedures, as well as model security standards, manuals, and post orders.  We also have a well catalogued collection of IT governance and IT security policy, procedures and standards.  For procedure review and development ideas, contact us at don@greenwoodsecurity.com.

Get Ready Now for 2017 Port Security Grants

It is not too soon to start the registration processes.

The Administration has budgeted $93 million for port security grant awards in 2017.
It is not too soon to begin the application process. Typically, the schedule goes like this:

  • Mid-February the Grant Program is announced, Instructions are posted, and the application period begins. The 2016 application period began on February 17.
  • Late April – the application period closes. In 2016 the application deadline was April 25th.

However, before a facility can upload a grant application they must:

  • Obtain and/or verify the DUNS number for the specific facility and business unit involved. Your legal or tax department may be able to help with this.
  • Register in the government’s System for Award Management (SAM.gov).  FEMA states, “It may take 4 weeks or more after the submission of a SAM registration before the registration becomes active in SAM.gov, then an additional 24 hours for Grants.gov to recognize the information.”
  • Once the SAM’s registration is complete, register and set up an account in a second government web-portal, Grants.gov.  Receive an account log in and password.
  • Once the Grants.gov registration is complete and approved, use that account to set up a third registration in a third government web portal, NDGrants.gov (the site to specifically upload “non-disaster” grants.  All application documentation will be uploaded through NDGrants.gov.  This is also the portal wherein the FEMA officials will communicate with the applicant.

Is it worth doing? Absolutely YES!

Don Greenwood & Associates Inc. has an excellent track record in applying for and winning grants for our clients. In 2016, we developed and submitted several grant applications for a total of $3 million in awards.

Of special interest to DHS in 2016 were applications that included funds for cyber security protections, as well as the fundamentals – access control, gates, TWIC readers, etc.

Let’s get started. Before we can develop an application we need to discuss your facility, what is needed, and whether or not your needs meet the grant priorities. Successful grant writing is more an art than a science. Give us a call at 832-717-4404 or email don@greenwoodsecurity.com.