Category Archives: Uncategorized

Complete Active Shooter and Workplace Violence Program

“I knew this was going to happen.” That is the statement given in more than 50% of workplace and school rage killings.

We have learned that employees are unlikely to report emerging situations to management unless they feel confident that management has a plan and an organized response to address the issue.

Don Greenwood & Associates has supported clients with workplace violence prevention and response programs since 1995 – companies in oil & gas, field services, manufacturing, business, chemicals and computing.

Our program is comprehensive, ready for rapid deployment throughout the workforce, and includes:

  • A template for establishing a Threat Management Team (consistent with ASIS and SHRM guidelines) that includes specific responsibilities for Security, HSE, HR, Legal, and Operations.
  • A Quick Action Guide addressing active shooter situations – ready for distribution to your employees immediately.
  • A PowerPoint training program for employees that encourages reporting, engagement, and concise standards of behavior.
  • A PowerPoint for managers and supervisors with guidelines and standards for intervening in and managing workplace disruption.
  • Training materials to help employees formulate their own plans for run, hide, and fight – based on their immediate workplace environment.
  • Guidelines on assessing the potential for violence in emerging situations and strategies for managing these threats.

The program is complete, cost effective, and ready to tailor to your company’s needs and culture.

Send me an email or give me a call for more information – Don Greenwood, don@greenwoodsecurity.com, 281-435-2339.

Check out our website – www.greenwoodsecurity.com

Don Greenwood & Associates, Inc. – Full Service Security Management Consultants since 2003

2018 Port Security Grant Program Posted

Yesterday, the Department of Homeland Security and FEMA posted the 2018 Port Security Grant Notice of Funding Opportunity (NOFO).  Federal allocation this year is $100 million, more than last year.  However, for private, for profit companies, the federal match is 50/50 vs the 25%/75% if last year.  Which means, that if a recipient applies for $100,000 in funding for an appropriate security project, DHS will award $50,000 and the company receiving the award will need to provide $50,000 in matching funds.

That may make the grants program less attractive for many companies; however, it is logical that fewer will apply, so the chances of winning an award may be better than last year.

The deadline for filing applications is June 20th – we have less than 30 days.

In the last few years, Don Greenwood & Associates Inc. has help clients write and submit ten grant applications and have won awards for eight of the ten, including the largest award given to a private company in 2016 – just under $1 million dollars.  Writing successful grant applications depends on the consultant’s ability to draft a persuasive argument that the facility in question needs the award to support the goals of the larger community, the Area Maritime Committee, as well as the submitting company and port facility.

Contact us at 281-435-2339 or don@greenwoodsecurity.com for more information.

Get Ready Now for 2018 Port Security Grants

It is not too soon to start the registration processes:

The Administration has budgeted $100 million for port security grant awards in 2018.

When:

  • Likely before the end of May
  • Like last year, there will be a short window to submit applications
    • Last year grants were announced on June 2 and applications due by June 22, only 20 days to prepare and submit applications.

Grant priorities will probably remain the same.

  • Enhancing Maritime Domain Awareness
  • TWIC Technology
  • Cybersecurity Capabilities
  • Training and Exercises

Let’s get started.  Before we can develop an application, we need to discuss your facilities, what is needed, and whether or not the 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.

To read more on preparing a grant application, click here.

TWIC Reader Rule Delay

TWIC Reader Rule Delay

On April 18, 2018, the Office of Management and Budget’s Office of Information and Regulatory Affairs announced that they received a proposed rule to delay the implementation date for the USCG TWIC Reader Rule.

To read more about the TWIC Reader Rule click here, here and here.

To read more about the delay, click here.

 

TWIC UPDATES

From TWIC Stakeholders Communications Committee Meeting – March 2018

TWIC Reader Requirements Final Rule

  • As we are now within 6 months of the implementation date of the TWIC Reader Rule, CG-FAC wanted to reiterate a Maritime Commons Blog post dated March 31, 2017 (http://mariners.coastguard.dodlive.mil/2017/03/31/3312017-twic-reader-rule- update/), and where units should expect to enforce TWIC reader rule “on time” at:
    • a) Facilities that receive vessels certificated to carry more than 1,000 passengers; and
    • b) Facilities subject to 33 CFR 105.295.
  • USCG is still working to establish how/when all other facilities that were captured by the Final Rule language will have to comply with the TWIC Reader requirement; however, until then, facility inspectors should be socializing the above guidance for “on time” enforcement with industry.

USCG TWIC Handheld Reader Status

USCG is currently conducting technical evaluations of potential vendors for TWIC Handheld Readers. The current plan is once a vendor is selected, 250 readers will be issued out to the field. The current projected award date is late March to early April with distribution out to the field shortly thereafter.

State Bill 1871, signed into law by Governor Abbott

Titled:  An Act relating to the creation of the offense of petroleum product or oil and gas equipment theft.   This penal code addition takes effect on September 1, 2017.

Definitions include: “Oil and gas equipment means machinery, drilling equipment, welding equipment, pipe, fittings, pumps, vehicles, or other equipment used in the drilling or maintenance of oil and gas wells, in the production of oil and gas, or to transport petroleum products.  Petroleum product means crude oil, natural gas, or condensate”.

The offense is committed by unlawfully appropriating oil and gas equipment “without the owner’s effective consent.”  A felony.

This is a finely crafted penal code addition – simple and direct, easy to understand, and comprehensive to our industry’s concerns.  John P. Chamberlain, Executive Director of the Energy Security Council, posted this morning:

Texas Governor Abbott signed State Bill 1871 into law. This bill applies to the theft of oil and oilfield equipment and the penalties for those committing oilfield crimes.  This law is another very useful tool for corporate security teams and law enforcement to use in the ongoing fight against oilfield theft and crime.   

 Much thanks are due to those who spent many hours helping research, craft and promote this timely legislation, including Rob Ream of BHP Billiton Petroleum; LC Wilson, Clete Buckaloo, and Kevin Pullen of Anadarko Petroleum; Mike Peters of Lewis Energy; Robert Butler from the Texas Attorney General’s office; and Paula Barnett from BP.  

2017 Port Security Grant Program (PSGP) Update 3.0 – May 18, 2017

The American Association of Port Authorities hosted a webinar regarding the FY2017 Port Security Grant Program. Duane Davis, East Section Chief for the Port Security Grant Program presented during the webinar.

Summary:

  • Notice of Funding Opportunity announcement expected June 2, 2017.
  • Grant applications will need to be submitted to FEMA by June 21, 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.

The timeframe from the NOFO announcement to application due date is only 21 days or 3 weeks. This is a very tight timeframe to get all the necessary registrations and Investment Justification (IJs) completed.

Failing to complete the following steps will likely result in an invalid application:

  • Verifying, updating, or applying for a DUNS
  • Updating or verifying SAM
  • Register and establish a AOR
  • Submit application in Grants.gov
  • Applying for, updating or verifying your EIN (can take up to 2 weeks!)
  • Submitting the final application in NDGrants

Mr. Davis stated to get the above done as soon as possible, hopefully already started. Don’t wait or it might be too late.

To read more about the PSCP, click here.

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.