“She did everything right!” – The great benefit of security awareness, training, and common sense

On Tuesday, February 21, there was a report of an active shooter at Ben Taub Hospital in Houston.  The subsequent “Code White”, broadcast on the hospital PA system, prompted an immediate evacuation and Houston PD launched a full SWAT response.  It was great to hear how one articulate, smart employee reacted when panic spread among her co-workers.  She told a KHOU reporter:

  • I locked and barricaded my door
  • I turned off my light
  • I put my phone on silent
  • I turned off my computer
  • I pushed my chairs against the door
  • I texted other employees
  • If your phone is on silent he may not even know where you are and you can communicate safely with others
  • It is unfortunate and it is just a different time. The world is constantly changing and we just have to be ready.

She remained in this self-imposed lockdown until the Doctor for whom she worked told her it was time to, and safe, to evacuate.

Whether she learned from a formal training session, from TV, from a poster on the wall, I am not certain.  I know she responded well and I know that basic awareness and response training can save lives by giving people the confidence to react calmly, organize their thoughts, and do the right thing under pressure.

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.

TSA Inspectors at MTSA Facilities? – Happening Now

The USCG has issued Marine Safety Information Bulletin (MSIB) 01-16 that specifies that TSA inspectors will be accompanying USCG inspection personnel when inspecting MTSA regulated facilities to verify TWIC compliance. Some of our clients have already experienced this.

The USCG is the lead agency for enforcement for MTSA regulated vessels and facilities, and TSA is the lead agency to pursue civil enforcement against individuals engaged in TWIC credential alteration and fraudulent use. The USCG implements its TWIC Enforcement Program at regulated vessels and facilities to ensure that TWIC programs are in compliance with approved Vessel and Facility Security Plans. The USCG verifies this onsite during inspections both visually and with the use of handheld portable TWIC readers.

TSA’s Office of Security Operations has initiated a field inspection program for their Transportation Security Inspectors-Surface (TSI-S) to conduct visual and electronic TWIC inspections at MTSA regulated facilities. It is anticipated, at least initially, that the TSI Inspectors will accompany Coast Guard personnel during Coast Guard led security inspections. However, the TSA has the authority to conduct inspections independently and should be provided relevant portions of the FSP in the areas of TWIC compliance and overall access control.

It is important to remember that ensuring that only authorized TWIC holders desiring unescorted access into Secure Areas of the vessels and facilities remains the responsibility of the VSO/FSO.

DHS Reinstates Top Screen Requirements

On October 1, 2016, DHS has reinstated the requirement to submit Top Screens using CSAT 2.0.

Starting today, October 4, 2016, DHS will begin notifying facilities that they have to submit a new Top Screen. However, facilities may choose to proactively resubmit a Top Screen prior to receiving notification from DHS.

Facilities are given 60 days to submit a new Top Screen.

To read more about CSAT 2.0, click here.

CSAT 2.0 Update: Changes Coming in October

DHS has released an update to the upcoming launch of Chemical Security Assessment Tool 2.0 (CSAT 2.0). They state that in the coming months, DHS will be reaching out directly to facilities believed to maintain Chemicals of Interest (COI) at or above the threshold quantities. These facilities will be required to submit new Top Screens to DHS using the new CSAT 2.0 online tool.

What does this mean for you and your facility?

DHS suspended the requirement to submit Top Screens and Security Vulnerability Assessments (SVA) on July 20, 2016 to prepare for the launch of CSAT 2.0.

After the transition to CSAT 2.0 and the improved risk tiering methodology in October 2016, DHS will begin to individually notify “chemical facilities of interest” to resubmit a new Top Screen using CSAT 2.0. They state that chemical facilities of interest include facilities that were previously determined not to be high-risk. The letters will be issued through CSAT 2.0 to each facility’s designated CFATS Authorizer and Submitter in a phased manner over the course of several months.

DHS states that CSAT 2.0 will improve the integration between the CSAT SVA and Site Security Plan (SSP) surveys, streamlining the compliance process and reducing the burden associated with completing these surveys.

Next Steps

 DHS will replace the current CSAT surveys with the revised surveys this fall.

  • On October 1, 2016, DHS will reinstate the Top-Screen and SVA submission requirements.
  • DHS will individually notify facilities in a phased manner to resubmit their Top-Screens using the new tool.

Training on CSAT 2.0

DHS will be hosting several webinars and presentations at several cities around the country to demonstrate the new tool.

Webinars:

In-Person Demonstrations:

  • In September, DHS will post session dates, times, and locations

Final Rule – Transportation Worker Identification Credential (TWIC) Reader Requirements

Yesterday, the Department of Homeland Security and the U.S. Coast Guard published the Final Rule for TWIC Reader inspection requirements. This amendment to the Maritime Transportation Security Act requires owners and operators of certain regulated vessels and facilities to conduct electronic inspections of TWICs as an access control measure.

The finale rule is effective August 23, 2018, and facilities have up to two years to be in compliance.

This final rule only affects vessels with more than 20 crew members (only 1 regulated vessel is identified at this time) and about 525 facilities that are in “Risk Group A”.

Risk Group A includes:

Vessels that carry or tow a vessel carrying Certain Dangerous Cargoes (CDC) in bulk.

  • Vessels certified to carry more than 1,000 passengers.
  • Facilities that handle CDCs in bulk or receive vessels carrying CDC in bulk.
  • Facilities that receive vessels certified to carry more that 1,000 passengers also are in Risk Group A.
  • As of now, no Outer Continental Shelf (OCS) facility is considered Risk Group A.

This final rule clarifies that for Risk Group A facilities, electronic TWIC inspection is required each time a person is granted unescorted access to a secure area (a limited exception is permitted for Recurring Unescorted Access, or RUA). For Risk Group A vessels, electronic TWIC inspection is only required when boarding the vessel, even if only parts of the vessel are considered “secure areas”.

The regulation states that each person who has been issued or possesses a TWIC must have their TWIC verified through an electronic inspection. They must also submit their biometric and Personal Identification Number (PIN) when requested from the TSA, USCG, DHS, or Federal, State, or local law enforcement.

Facilities and vessels will need to update their Facility Security Plans to meet this ruling.

TSA List of Cancelled TWICs

At MARSEC Level 1, facilities and vessels will have to ensure that the TWIC verification is conducted using information from TSA that is no more than 7 days old. At MARSEC Levels 2 and 3, the information from TSA must be no more than 1-day old. If the MARSEC increases, the TSA information must be updated within 12 hours, no matter when the information was last updated.

We will continue to review the final rule and provide more detailed summaries in future posts.

The Security Guard Audit

A few weeks ago, USCG officers arrived at a regulated facility, and observed the main gate security officer not inspecting and validating TWIC cards, and not conducting vehicle inspections as required in the Facility Security Plan. For a moment, the USCG considered shutting down the facility. Recently the USCG also released a list on common MTSA Facility Violations.

We are often retained to conduct brief audits and training moments with entry guards. It works like this: one of us arrives at the entry point and observes security checking in and admitting people to the facility. Then we check in ourselves and spend a few moments with security management to relay our findings. Within moments, we return to the security post, explain that we just conducted an audit and spend a few moments renewing their training. These moments are powerful training tools that will not soon be forgotten. Ken Blanchard, the author of The One Minute Manager, said that supervisors should make every encounter with their staff a learning moment:

  • Catch them doing something wrong, quickly reprimand and then take a moment to retrain.
  • Catch them doing something right, quickly praise and let them know what they did so well.
  • Or, just stop by for a one minute reminder on a procedure or conduct that is important.

Penetration audits can give some indication of how well personnel are performing, but the real value comes from the training that results.

The Penetration Audit – A Powerful Training Tool

Picture a large manufacturing facility with a robust security infrastructure: access controlled gates and entry doors, security guards on post and roving, monitoring with CCTV cameras, and perimeter intrusion alarms. Here all employees have participated in security awareness briefings. Management decided to test their employee’s response to intrusion by conducting a Penetration Audit, and the results were disappointing. On the flip side however, the after action review with the employees was in itself a powerful training tool.

A consultant was hired who during the daytime climbed over the fence wearing street cloths and carrying a backpack and a clipboard. He wandered through various buildings and processing areas. As he walked he encountered more than a dozen employees. Many greeted him with a nod. Two employees stopped him and said that fire resistant attire (FRC) was required. The consultant said his FRC gear and hardhat were in the backpack and he would go change into them. One employee showed him the location of a change room for that purpose but did not stay with him.

No one asked what he was doing, who he was, and no one reported him to Security. The positive benefit came when management met with employees for an after-action review. One can bet that in the future strangers on site in this facility will be challenged and reported to security. One can also ask how different the outcome of the audit would have been if it were pre-announced.

Years ago, the security department at Apple hired a smart PI to test security. His mission was to get into the many facilities without screening by the lobby security guards, then leave out the same lobby obviously carrying a large box. On his first audit run nine of ten security officers failed to stop him. He was a glib talker wearing a suit and his demeanor intimidated most of the guards. Again, no one reported him to security management. As a Security Manager, I always preferred to pre-announce penetration audits and did so for the second run of the audit in a different set of buildings. This time, the auditor found the guard force tuned up and 90% of the guards did the job right, stopping the man, asking for ID, and escorting him out of the building.

The results of penetration audits can be surprising to management whether pass or fail. The value of these exercises as training moments that become imbedded in their long-term conduct is significant; either way – surprise audits or pre-announced penetration tests.