Personnel surety, the vetting of facility personnel and unescorted visitors who have or are seeking access to restricted areas and critical assets at high-risk chemical facilities, is a key aspect of chemical facility security.
Under CFATS, all covered facilities must submit for approval to DHS a security plan (Site Security Plan (SSP) or Alternative Security Program (ASP)) containing security measures that sufficiently meet all the Risk-Based Performance Standards (RBPS).
RBPS 12–Personnel Surety requires facilities to account for four types of background checks on facility personnel and unescorted visitors who have or are seeking access to restricted areas and critical assets at high-risk chemical facilities. These checks include measures designed to:
i) Verify and validate identity
ii) Check criminal history
iii) Verify and validate legal authorization to work, and
iv) Identify people with terrorist ties
Part iv—screening for terrorist ties—is implemented through the CFATS Personnel Surety Program (PSP), and is currently limited to Tier 1 and Tier 2 facilities (80 FR 79058).
RBPS 12(iv) - Screening for Terrorist Ties
On December 18, 2015, a notice was published in the Federal Register to inform Tier 1 and Tier 2 high-risk chemical facilities that the Department would begin implementing the terrorist ties screening portion of RBPS-12 through the PSP. The notice provides:
- Statutory and regulatory history
- Four options available to facilities in order to comply with RBPS 12(iv)
- Program requirements and details
- Chemical Security Assessment Tool (CSAT) user roles and responsibilities, and
- Privacy considerations
The notice authorizes the Department to collect information about affected individuals from high-risk facilities (or their designees) in Tier 1 and Tier 2 for three years. The Department is in the process of seeking approval to collect information from Tier 3 and Tier 4 facilities.
High-risk chemical facilities will be individually notified of when the Department expects them to begin updating their security plans and begin implementing RBPS 12(iv).
How to Comply with RBPS 12(iv)
The PSP notice describes four options for facilities to consider in implementing RBPS 12(iv). Facilities may propose additional options of their own design as part of their security plan to meet this RBPS, and DHS will review and approve on a case-by-case basis.
Note: In December 2014, Congress noted in Section 2102(d)(2)(B)(ii) of the Homeland Security Act (PDF, 60 pages - 102 KB) that facilities choosing to meet RBPS 12(iv) via a visual inspection of credentials (Option 4 below) should note that visual verification has inherent limitations and provides less security value than the other options available. Therefore, facilities should consider other means of verifying a credential's validity.
Tier 1 and Tier 2 chemical facilities can employ one of the four options to comply with RBPS 12(iv).
- Option 1- Direct Vetting: High-risk chemical facilities (or their designees) may submit certain information about affected individuals through a PSP application located in the Chemical Security Assessment Tool (CSAT).
- Option 2 - Use of Vetting Conducted under Other DHS Programs: High-risk chemical facilities (or their designees) may submit information (via the PSP application in CSAT) about affected individuals possessing the appropriate credentials to enable the Department to electronically verify the affected individuals’ enrollments in other DHS programs.
- Option 3 - Electronic Verification of Transportation Worker Identification Card (TWIC): High-risk chemical facilities (or their designees) can use electronic readers, like TWIC readers, to verify the validity of existing credentials.
- Option 4 - Visual Verification: High-risk chemical facility may identify individuals with terrorist ties using any federal screening program that periodically vets individuals against the Terrorist Screening Database (TSDB) if:
- The federal screening program issues a document or credential
- The high-risk chemical facility is presented a credential or document by the affected individual, and
- The high-risk chemical facility verifies the credential or document is current in accordance with its security plan
- Read or download the CSAT 2.0 Personnel Surety Program Instructions
- Read or download the RBPS12(iv) – Screening for Terrorist Ties Fact Sheet
Visit the CFATS Knowledge Center for an online repository of frequently asked questions, articles, and the latest CFATS program news.
If you have additional questions, please call the CFATS Help Desk at 866-323-2957 Monday through Friday (except federal holidays) from 8:30 a.m. to 5 p.m. (ET).