FEMA now has an on-line Chemical Sector Security
Awareness Training
(AWR-912) program available for use by the public,
including personnel working at chemical facilities. This training program is
not specifically targeted at employees at facilities regulated under either the
Chemical Facility Anti-Terrorism Standards (CFATS) program or the Maritime
Transportation Security Act (MTSA) program, but it could be used for general
security awareness training by facilities in either program. Before an individual
attempts to complete the course, they must register with FEMA and obtain a
FEMA Student ID (FEMA SID).

NOTE: Readers who have received the March 2021 Chemical
Security Quarterly email, will already have heard about this training program. You
can sign-up to receive this email (and other CISA information via the https://public.govdelivery.com/accounts/GOVENGAGE/subscriber/new
website).

Commentary

This is the new training program that CISA’s Chemical
Sector-Specific Agency announced
at the 2020 Chemical Security Summit last December. It is actually a rework of
the training program that was originally introduced
in 2008
and then discontinued
sometime in 2015 without notice or explanation.

While this is billed as ‘Chemical Sector Security Awareness
Training’ there is actually very little in this program that is uniquely
targeted at the chemical sector. There are two video scenarios that use
chemical imagery (totebins in one and a chemical railcar in another) to
illustrate the need for individuals to be aware of their surroundings and the
need for reporting unusual situations, but that hardly makes this chemical
sector specific training.

There is no mention of the two federal regulatory programs
that address security at chemical facilities, the Chemical Facility
Anti-Terrorism Standards (CFATS) program and the Maritime Transportation Security
Act (MTSA) program. There are certainly more ‘chemical facilities’ that are not
covered by either program than there are covered facilities, it seems to me
that there should at least have been some mention of these two important
security programs.

Nor was there any discussion of the two specific reasons
that a security awareness program at chemical facilities is important,
deliberate release of hazardous chemicals as a means of attack on the local community
or the theft/diversion of precursor chemicals for the manufacture of improvised
explosives or improvised chemical weapons that could be used in a subsequent
attack.

If CISA is expecting CFATS facilities to use this training
program to satisfy the RBPS 11 annual training requirement for ‘All Remaining
Employees’ it sadly only addresses one of the Training Topics listed in Table
13 of the RBPS
Guidance Document
; “Recognition of suspicious behavior”. Facilities would
have to separately address the remaining training topics:

• Recognition and detection of
dangerous substances and devices,

• Techniques used to circumvent
security measures,

• Relevant provisions of the SSP,
and

• The general meaning and
consequential requirements of the different DHS Threat Levels

This training program hardly seems worth the effort.

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Author Of this post: PJCoyle

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