ISCD Publishes Records Maintenance Guidance – RBPS 18

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) added links to two documents on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center web site. The Documents provide information to help CFATS covered facilities comply with Risk Based Performance Standard (RBPS) 18, Records. The documents are a records reporting template and a fact sheet providing information on the RBPS 18 requirements.

The fact sheet expands on the information provided in the RBPS Guidance Document, providing additional information about what types of documents CFATS facilities need to retain to comply with RBPS 18. The template provides a voluntary tool that facilities can use document some of the records retention requirements covered in RBPS 18. In particular it provides specific examples for reporting formats (with fictitious data samples) for:

• Sample Record of Breaches of Security

• Sample Record of Drills and Exercises

• Sample Record of Maintenance

• Sample Record of Security Threats

• Sample Record of Site Security Plan (SSP) Audit

• Sample Record of Training Delivered

The use of this particular tool is not required for compliance. ISCD is providing the tool as an example of a ‘best practice’. Facilities are free to use their own formats and reporting documents. Based upon my personal experience in the military, however, as both a unit security ‘manager’ and as a security inspector, using a common reporting format makes for easier inspections. Inspectors can spend less time looking for details and are more likely to overlook minor lapses.

NOTE: The example data provided in the template provides some interesting insight into what types of information that ISCD is really looking for.