Category Archives: Security Awareness Training

3 Tips for a Successful USCG Inspection

Many companies aren’t prepared when they receive a letter from the U.S. Coast Guard notifying them of an upcoming facility security inspection. You might have documents that are out of date, or you may be missing the necessary forms. If left unchecked, you could be forced to waste time and money in enforcing corrective actions. When it comes to advising our clients to be prepared, these are the top three tips we give them for a successful USCG Inspection.

Review Your Documents

When you receive a notice from the USCG about an upcoming inspection, this is always a good time to review your FSP and required documents to make sure that you have everything in order. Also, this is a good time to verify that you have conducted the required quarterly drills, annual exercise, and annual audit of the FSP.

Training Moment

Training is very important for facility personnel and this is a good opportunity to make sure all your training is up to date and to have a general discussion regarding security of the facility. The training can focus on topics that will most likely be covered during the inspection; including TWIC, screening, security personnel (who is the FSO, Alt. FSO?), MARSEC security measures, etc.

Organize

One thing that we recommend and develop for majority of our clients is to have a single security plan binder with all relevant documents and forms. This is a perfect, centralized place to store and secure all the forms and documents that the USCG will want to review during the inspection. We have had great success with these binders for all of our regulated clients; MTSA, CFATS, TSA, DOT, etc. As we tell our clients, it is best to get the inspectors the requested material in a timely fashion and get the inspection over with as quickly as possible.

Recently one of our clients had a US Coast Guard inspection that they passed without any issues, “We went through our MARSEC book while the USCG was here and we were complimented on how all the files for MARSEC were in one book and not in different locations.  We didn’t spend much time with it, because everything was in the binder that they had questions about. “

Let us know if we can help you prepare for USCG Security Inspection and develop a security binder for you and help you succeed with your inspections.

CFATS Quarterly Update

Recently DHS released their Fall Quarterly Update providing more detail on the implementation of the CFATS program.

CFATS Update

As of September 1, 2017, CFATS covers 3,478 facilities. DHS has completed more than 2,700 Compliance Inspections (to read more about Compliance Inspections, click here). Since launching CSAT 2.0 a year ago, DHS has received more than 25,000 CSAT Top Screens. DHS is continuing to issue tiering letters to facilities as their Top Screens are received and reviewed.

You can read more about CSAT 2.0 here.

SVA/SSP Questions

One topic discussed in the update in the new questions that facilities will need to answer when submitting a new or revised SVA/SSP.

When submitting the SSP, the new questions facilities will need to address include:

  • Q3.10.050 Personnel Presence
  • Q3.10.400 through Q3.10.420 Inventory Controls
  • Q3.40.400 through Q3.40.430 Cyber Control and Business Systems
  • Q3.50.320 Personnel Surety, Types of Affected Individuals
  • Q3.50.710 Recordkeeping Affirmation

In addition to these new SSP question, facilities are asked to select whether a certain detection and delay security measure applies to perimeter and/or critical assets. The following SSP questions should be reviewed to ensure the location(s) are correctly associated with the security measures applied:

  • Q3.10.070 Mobile Patrols
  • Q3.10.120 Intrusion Detection Systems
  • Q3.10.180 through Q3.10.230 Intrusion Detection Sensors
  • Q3.10.290 and Q3.10.310 Closed Circuit Television
  • Q3.20.030 through Q3.20.160 Perimeter Security
  • Q3.20.430 and Q3.20.440 Access Control Systems
  • Q3.20.560 Anti-Vehicle Measures

Personnel Surety Program (PSP)

Tier 1 and Tier 2 facilities will see questions that address RBPS 12(iv), screening for terrorist ties. Questions Q3.50.330 through Q3.50.550 allow facilities to identify the option(s) chosen and measure(s) used to implement those options for compliance with RBPS 12(iv). To read more about those options, click here.

Additionally, DHS is going to integrate the Personnel Surety Program into the CSAT 2.0 Portal. This should make it much easier and provide better functionality for the user.

Chiefs of Regulatory Compliance

DHS also announced in this update that they have hired Chiefs of Regulatory Compliance (CRCs) for majority of their Regional Offices. CRCs will serve as the lead DHS representatives administering the CFATS regulation and serving as advisors to the Office of Infrastructure Protection Regional Directors.

Region CRCs:

  • Region 1 (VT, RI, ME, NH, CT, MA) – Charles Colley charles.colley@hq.dhs.gov
  • Region 2 (VI, PR, NJ, NY) – John Dean john.dean@hq.dhs.gov
  • Region 3 (DC, DE, WV, MD, VA, PA) – Don Keen donald.keen@hq.dhs.gov
  • Region 4 (MS, SC, AL, KY, FL, NC, TN, GA) – Cheryl Louck cheryl.louck@hq.dhs.gov
  • Region 5 (MN, WI, IN, MI, IL, OH) – Kathy Young kathryn.young@hq.dhs.gov
  • Region 6 (NM, OK, LA, AR, TX) – Steve Shedd steven.shedd@hq.dhs.gov
  • Region 7 (NE, KS, IA, MO) – Dave Martak david.martak@hq.dhs.gov
  • Region 8 (WY, ND, SD, MT, UT, CO) – Jim Williams james.williams@hq.dhs.gov
  • Region 9 (MP, GU, HI, NV, AZ, CA) – Marcie Stone marcie.stone@hq.dhs.gov
  • Region 10 (AK, ID, OR, WA) – Marc Glasser marc.glasser@hq.dhs.gov

Feel free to contact us if more information or support is needed.

Chemical Sector Security Summit

For the first time after 10 years, the annual Chemical Sector Security Summit will be held outside the D.C. area in Houston, Texas. The summit is scheduled to take place in July 2017.

This year’s Summit will feature vital chemical security information for 2017 and beyond, while bringing together industry owners and operators, key government officials, first responders, and law enforcement to engage in face-to-face discussions and share the latest in security best practices.

Summit registration will open in spring 2017, along with updates on the venue, agenda, and speakers.

For more information, click here.

CFATS Quarterly Update

On April 4, 2017, the Department of Homeland Security (DHS) began issuing tiering notifications to Chemical Facility Anti- Terrorism Standards (CFATS) regulated facilities based on the results of DHS’s new enhanced risk-tiering methodology.

To date, approximately 12,000 updated Top-Screens have been received from the 27,000 facilities that previously reported holdings of chemicals of interest (COI) at or above the screening threshold quantity.

DHS has sent out over 10,000 tiering determination letters to facilities that have submitted new Top-Screens. Tiering letters are being prioritized based on when DHS received the facility Top-Screen, upcoming compliance inspection schedules, and to consider workload for submitters that have a high number of covered facilities with changes.

Over the next 18 months we will continue to notify facilities of the requirement to submit new Top-Screens and issue tiering decisions on a rolling basis.

I’ve Received a Tiering Letter, Now What?

As facilities receive tiering letters, their next steps will depend on their results.

Facilities new to the CFATS program will be required to submit security plans. If a current facility receives a revised tiering assessment, it does not necessarily mean that it will be required to submit a Site Security Plan (SSP)/Alternative Security Program (ASP).

Facilities should review their tiering letter along with their approved SSP/ASP to determine whether it meets the security measures associated with all the chemicals of interest (COI), specific security issues (Theft/Diversion, Release, or Sabotage), and tiers in the letter. If not, an SSP/ASP update may be required.

Examples of situations in which a facility will need to update its SSP may include:

  • Facilities that add a newly tiered COI, which is located in a new asset area not currently addressed in the SSP/ASP;
  • Facilities that increase in tier and do not have sufficient security measures to account for the higher tier;
  • Facilities with an added security concern from a current COI that lacks sufficient security measures to account for the new security concern.

For example, if a facility possesses chlorine tiered for “theft/diversion” but now must also account for chlorine as a “release” concern, the existing SSP/ASP would need to be revised to include security measures to address risks associated with release COI.

DHS will assess facilities on a case-by-case basis to ensure security measures are appropriate to their level of risk.

2017 Port Security Grant Program (PSGP) Update 2.0 – May 2017

Port Security Grants possibly announced in two weeks.

FEMA Grant Programs Directorate provided a presentation regarding the FY2017 Port Security Grant Program (PSGP).

Summary:

  • Announcement expected May 19, 2017.
  • Grants will need to be submitted to FEMA by June 19, 2017.
  • Anticipated to be for the same amount as FY2016, $100,000,000.00.
  • Funding priorities remain the same as 2016:
    • Enhancing Maritime Domain Awareness
    • TWIC Readers
    • Cybersecurity Capabilities
    • Training and Exercises, etc.
  • Cost sharing remains the same as 2016, 25/75 split.

To read more about the PSCP, click here and here.

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.

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.

USCG Inspections and FSO Readiness

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.

The Facility Security Officer (FSO) should expect the USCG to conduct at least two inspections per year. Typically, one inspection will be scheduled with the facility and the other will be an unannounced inspection. These unannounced inspections typically occur at night. The FSO must ensure that their facility, FSP, and records are prepared for the USCG inspections.

Prior to the inspection, the FSO should review the FSP and confirm that all information is up to date and correct. The FSO should also verify that all pertinent documents and records are in order and have the required Sensitive Security Information (SSI) labeling. The FSO will need to ensure that all drills, exercises, audits, security equipment tests, etc. have been properly conducted and recorded.

The FSO will also want to ensure that facility personnel, including security guards, have been properly trained according to the regulation and are prepared to answer questions if asked by USCG officers.

Most deficiencies are typically discovered during the required Annual Audit of the FSP. The MTSA regulation requires facilities to conduct an annual audit and that the person(s) conducting the audit are independent of any security measures being implemented at the facility.

Don Greenwood & Associates, Inc. has provided security assessments, plans and training for hundreds of Facility Security Officers and security-related personnel as mandated in the Maritime Transportation Security Act (MTSA). We also have a full set of compliance tools including training PowerPoints, Assessment Templates, and have produced employee training videos for several petrochemical companies.

Security Awareness Training Video Trailer

This is a short trailer with clips from our “All Employees Security Awareness Training” video. This video is in compliance with the CFATS, MTSA, TSA Pipeline, and DOT security standards.

We can customize the video with client and/or site specific images and video branding.

DG&A Security Awareness Video Trailer from Don Greenwood & Associates, Inc. on Vimeo.