Category Archives: Uncategorized

State of Texas Abandons Licensing Requirements

State of Texas abandonment of Licensing Requirements now allows anyone to be a Security Consultant – effective 9/1/2019

Why is this significant for you as a client?

Changes in Texas regulations – Security Consultants No Longer Need a State License:

  • No requirement to be insured – this is significant
  • State background checks no longer required.
  • ID and Fingerprint Checks no longer required.
  • No longer a requirement for license examinations
  • No requirement for proof of experience.
  • No more Qualified Manager exams.

In the past, Security Consultant and Consulting Companies, needed all of the above. Now all of this has gone away.

Here are some key questions you should ask when retaining security consultants:

  • Can you provide a resume of relevant experience?
  • Can you provide an insurance certificate and proof of adequate insurance?  Important – it is likely if they get sued for your project, your company will also be sued.
  • Can you provide five references from companies for whom you have done similar work in this past year?
  • Understand, we will do a background check on you and your company. Incidentally, licensing was also abandoned for Security Salespersons, Branch Office Managers, Guard Dog Training Companies, and Employees of License Holders.
  • Use your standard Contractor Master Services Agreements which accomplish some of the above.

Feel free to call or email us if you need support in hiring security consultants.

House Committee to markup CFATS Bill

From Chemical Facility Security News

The House Homeland Security Committee have scheduled a mark-up hearing of HR 3256, the Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2019. The bill would reauthorize the Chemical Facility Anti-Terrorism Standards (CFATS) program for another 5 years. The new bill will also provide a number of amendments to the current bill.

To read an in-depth review of the bill, please click here and here.

Thanks again to PJ Coyle for the detailed analysis of the bill.

To read more about CFATS, click here.

TWIC Advisr App Beta Release

The TSA has released a beta version of their TWIC Advisr app. The app allows individuals to scan a TWIC using their phone. The app will scan the barcode on the back of the TWIC, or the CIN can be entered manually, and verify if the TWIC is on the Canceled Card List (CCL).

This is a huge improvement for the TWIC program and for facility personnel to verify if a TWIC is on the CCL. Previously the only way to do this accurately was to have a TWIC Reader and the supporting software to run the check against the CCL.

Click here for a link to the TWIC Advisr Beta Release presentation.

Cyber Adversaries Targeting Commercial Vessels

From Coast Guard Maritime Commons:

The Office of Commercial Vessel Compliance issued Marine Safety Information Bulletin 04-19, “Cyber Adversaries Targeting Commercial Vessels,” to inform the maritime industry of recent email phishing and malware intrusion attempts that targeted commercial vessels.

Cyber adversaries are attempting to gain sensitive information including the content of an official Notice of Arrival (NOA) using email addresses that pose as an official Port State Control (PSC) authority such as: port @ pscgov.org. Additionally, the Coast Guard has received reports of malicious software designed to disrupt shipboard computer systems. Vessel masters have diligently reported suspicious activity to the Coast Guard National Response Center (NRC) in accordance with Title 33 Code of Federal Regulations (CFR) §101.305 – Reporting, enabling the Coast Guard and other federal agencies to counter cyber threats across the global maritime network.

As a reminder, suspicious activity and breaches of security must be reported to the NRC at (800) 424- 8802. For cyber attempts/attacks that do not impact the operating condition of the vessel or result in a pollution incident, owners or operators may alternatively report to the 24/7 National Cybersecurity and Communications Integration Center (NCCIC) at (888) 282-0870. When reporting to the NCCIC, it is imperative that the reporting party notify the NCCIC that the vessel is a Coast Guard regulated entity in order to satisfy 33 CFR §101.305 reporting requirements. The NCCIC will in turn forward the report to the NRC, which will then notify the cognizant Coast Guard Captain of the Port.

The Coast Guards urges maritime stakeholders to verify the validity of the email sender prior to responding to unsolicited email messages. If there is uncertainty regarding the legitimacy of the email request, vessel representatives should try contacting the PSC authority directly by using verified contact information. Additionally, vessel owners and operators should continue to evaluate their cyber defense measures to reduce the effect of a cyber-attack.

To read more on Coast Guard Maritime Commons, click here.

Port Security Grant-Themed Malicious Email (TLP-GREEN)

MPS-ISAO Warning Report, “Malicious Port Security Grant-Themed Email“.  The MPS-ISAO received an email sample from a U.S. Port customer this morning, and have confirmed that it is malicious.  The distribution list for this port security grant-themed email was over 500.  Please click here to see the report for email indicators.

Thanks Lester Millet for the report.

Lester J. Millet III, LEM
Safety Agency Risk Manager / FSO Workgroup Chairman
Port of South Louisiana

The Persistent Threat of Terrorism

Since 2013 there has been 159 homegrown jihadist cases in 30 states. Recent examples of homegrown terror-related incidents cited in the report include the case of a 28-year-old Ohio resident, Laith Alebbini, who was arrested Sept. 5 and charged with attempting to provide material support to ISIS. Also on Sept. 5, 26-year-old Alexander Ciccolo of Adams, Mass., was sentenced to 20 years in prison for the same crime. According to the snapshot, Ciccolo “planned to use pressure cooker explosives and firearms to target places where large numbers of people congregated, such as college cafeterias.” Ciccolo is the son of a Boston police captain.

To read more, click here.

Do I Need to Resubmit a Top-Screen?

There are still circumstances which may require your facility to resubmit a Top-Screen today, even if you have already resubmitted using CSAT 2.0. For example, a facility must report material modifications to its chemical holdings or facility operations, as these changes may alter a facility’s tier. Material modifications may include:

  • The addition or removal of COI at the STQ and concentration
  • Changes to quantity, location, or packaging of a COI as previously reported on a Top-Screen

Facilities are encouraged to report the highest expected quantity and concentration of COI they anticipate possessing over the lifecycle of their operations. By taking this approach, facilities can maintain a more efficient reporting process as they will not need to resubmit a Top-Screen when the quantity or concentration of a COI is reduced through normal operations.

Additionally, CFATS-covered facilities are required to update their Top-Screens on a regular basis, as determined by their tier:

  • A Tier 1 or Tier 2 facility must update its Top-Screen two years after its SSP is approved
  • A Tier 3 or Tier 4 facility must update its Top-Screen three years after its SSP is approved

Let us know if we can help you prepare and submit your CFATS Top Screen and prepare your facility for a Compliance Inspection.

To read about what to expect from a CFATS CI, click here.

The Adversary Sets the Agenda

Security planning must take into consideration that the Adversary sets the agenda and is better informed when plotting than the security strategist.

The threat adversary sets the agenda.  This is an important and too little discussed reality.

Building occupants, even building security, do not know that an adversary is considering an adverse attack or criminal intrusion.  The building and suite occupants “blindly” implement security measures that are customary and often “cosmetic”.  However, the adversary has an agenda:

  • They have an objective ranging from simple theft of purses and wallets to incidents of workplace violent, including rage killings.
  • They know the “territory” – they have studied and surveilled the building and avenues of access.  They know how ineffective the lobby guard is.  They have a target and a plan.
  • They want to enter incognito – their observations of building activity show they what to do to maintain a low profile.
  • In active shooter situations, they may be suicidal and have no plan of escape, which makes them very dangerous.
  • They will likely identify the same vulnerabilities that have been identified during a security assessment.

Security countermeasures must mitigate these risk as far as is reasonable and possible.  They should be deterred by at least two access-controlled perimeters to complicate their plan and increase their risk of detection.

Watch for our series of blogs on the security assessment process.

TWIC Reader Rule Officially Put On Hold

On August 2nd, President Trump signed into law the Transportation Worker Identification Credential Accountability Act of 2018 (HR.5729).  This formally prohibits the Coast Guard from implementing the Rule until DHS submits a satisfactory assessment of the TWIC program to Congress.

Furthermore, a U. S. District Court (Eastern, Virginia) issued a court order delaying the Rule at certain CDC facilities “until a further order of the court.”  This is in response to lawsuits from several industry groups.

We will track this activity closely and keep you all informed.

Don Greenwood

TSA Begins Issuing New TWIC Cards

The Transportation Security Administration (TSA) began issuing the new TWIC NexGen cards on July 10, 2018. The new cards incorporate enhanced security features (click here to read more).

Details about the new TWIC NexGen card:

  • Current TWIC card holders do not need to replace a valid TWIC card with the new TWIC card design.
  • Regulated entities that require TWIC for access will accept and recognize both the current and new TWIC designs until the card’s expiration.
  • The new card design is compatible with qualified TWIC readers.
  • To deter alteration of the card’s expiration date, the new card includes a color-coded expiration date box that will update on an annual basis.
  • The fee for the newly re-designed TWIC card remains unchanged ($125.25) and the credential is valid for five years.

Click here to read more about the TWIC NexGen cards.

Click here for a TWIC NexGen Authentication Guide