Thursday, December 17, DHS announced and distributed new requirements for Personnel Surety compliance, a clarification and instructions on CFATS Risk Based Performance Standard 12 – Personnel Surety (basically background screening as it relates to federal terrorism databases). This announcement is attached and went into effect last Friday.
This requirement applies to Tier One and Two High Risk facilities. Each Tier One and Two facility will receive individual letters from DHS giving more detailed requirements and setting individual facility deadlines for compliance, including implementation and amending Security Plans. Requirements for Tier Three and Four facilities will be announced at a later date.
The new requirement relates to RBPS 12(iv) – Measures designed to identify people with terrorist ties, and focuses on Affected Individuals, defined as “facility personnel and unescorted visitors with access to restricted areas or critical assets.” For many of our clients this means almost all employees and contractors working in their plants.
Facilities may choose one of four options to comply or may propose a combination or alternative plan for compliance.
The four options (explained in detail in the instruction) are summarized below:
- Option 1: DHS to Vet Affected Individuals
- Option 2: Affected Individuals Who Possess Certain Credentials
- Option 3: Electronic Verification of TWIC
- Option 4: Visual Verification of Credentials
The requirement is well written and reasonably easy to understand. However the devil is, as always, in the details, and there is a lot of detail. The overriding questions chemical companies will ask are how do we implement these screening requirements for existing employees, what action will we take if existing employees fail the federal checks, and how do we comply with limited people and resources? These questions and the options should to be discussed between Human Resources and Corporate Security.
We are preparing templates now to help facilitate this discussion and to provide suitable amendments for Site Security Plans.