Understanding Security Site Plans and Risk-Based Performance Standards

The heart of the CFATS program is the Security Site Plans (SSP), which must address, as applicable, the Risk-Based Performance Standards (RBPSs) established by the Department of Homeland Security. These standards include everything from perimeter security to recordkeeping. DHS does not mandate specific security measures or technologies; each facility is free to use any security measures it wants as long as those measures meet the applicable performance standard for the facility's risk-tier.

For example, in most cases, a Tier 1 facility will need to have stricter perimeter security in place than a Tier 3 facility to meet RBPS 1 - Restrict Area Perimeter.

Here is a summary of the 18 RBPSs:

  • Restrict Area Perimeter - Secure and monitor the perimeter of the facility.
  • Secure Site Assets - Secure and monitor restricted areas or potentially critical targets within the facility.
  • Screen and Control Access - Control access to the facility and to restricted areas within the facility by screening and/or inspecting individuals and vehicles as they enter.
  • Deter, Detect, and Delay - Deter, detect, and delay an attack, creating sufficient time between detection of an attack and the point at which the attack becomes successful.
  • Shipping, Receipt, and Storage - Secure and monitor the shipping, receipt, and storage of hazardous materials for the facility.
  • Theft and Diversion - Deter theft or diversion of potentially dangerous chemicals.
  • Sabotage - Deter insider sabotage.
  • Cyber - Deter cyber sabotage, including by preventing unauthorized on-site or remote access to critical process controls, such as Supervisory Control and Data Acquisition (SCADA) systems, Distributed Control Systems (DCSs), Process Control Systems (PCSs), Industrial Control Systems (ICSs), critical business systems, and other sensitive computerized systems.
  • Response - Develop and exercise an emergency plan to respond to security incidents internally and with the assistance of local law enforcement and first responders.
  • Monitoring - Maintain effective monitoring, communications, and warning systems.
  • Training - Ensure proper security training, exercises, and drills of facility personnel.
  • Personnel Surety - Perform appropriate background checks on and ensure appropriate credentials for facility personnel, and, as appropriate, for unescorted visitors with access to restricted areas or critical assets.
  • Elevated Threats - Escalate the level of protective measures for periods of elevated threat.
  • Specific Threats, Vulnerabilities, or Risks - Address specific threats, vulnerabilities, or risks identified by the Assistant Secretary for the particular facility at issue
  • Reporting of Significant Security Incidents - Report significant security incidents to the Department and to local law enforcement officials.
  • Significant Security Incidents and Suspicious Activities - Identify, investigate, report, and maintain records of significant security incidents and suspicious activities in or near the site.
  • Officials and Organization - Establish official(s) and an organization responsible for security and for compliance with these standards.
  • Records - Maintain appropriate records.

To help facilities meet the RBPSs, DHS has developed a guide titled the "Risk-Based Performance Standards Guidance." This document is available online through DHS and it describes the RBPSs in greater detail and provides guidance regarding the level of performance needed for each tier level.

Once a facility's SSP is submitted to DHS it will go through a review process which will be followed by an on-site visit by a DHS chemical security inspector. This inspection is conducted to ensure that all applicable RBPSs have been addressed and that the appropriate security measure or procedure has been implemented or validated. After the inspection the facility will receive a letter approving or disapproving the SSP.

To learn more download the paper "Ten Tips for Completing a Site Security Plan at www.adt.com/whitepaper.

About the Author

Ryan Loughin is director of petrochemical and energy solutions for the advanced integration division of ADT.

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