Responsibilities for Implementation of Facility Security Assessment Countermeasures

Purpose

This Order changes the responsibilities of the Public Buildings Service (PBS) and the Office of Mission Assurance (OMA) in relation to the use of Facility Security Assessment (FSA) information in the implementation of Facility Security Committee (FSC) countermeasure decisions in U.S. General Services Administration (GSA) controlled facilities.

Background

The Interagency Security Committee (ISC) Risk Management Process outlines the responsibilities of the FSC chair, the owning/leasing authority, and the security organization [in most cases the Department of Homeland Security - Federal Protective Service (FPS)]. In GSA-controlled facilities, GSA is the owning/leasing authority responsible for coordination with the FSC chairperson and the security organization to develop the Facility Security Level (FSL), attend FSC meetings, provide technical guidance, and assist with vendor access to the facility. 

Applicability

This Order applies to all GSA employees as they perform their duties except the Office of Inspector General (OIG), given its independence under the Inspector General Reform Act of 2008 (5 U.S.C. §§ 401-424).

Cancellation

This Order supersedes OMA 1000.3 CHGE 1.

Summary of Changes

1. Updated the format of the order to align with OAS 1832.1C, Internal Directives Management.
2. Updated roles and responsibilities throughout to adhere to current policy and procedures.
3. Updated references throughout.
4. Updated required training for facility managers.
5. Updated training requirements for OMA.
6. Updated the Note on countermeasure responsibilities for clarity.

Authorities

• 1000.1A OMA Document Security for Handling Facility Security Assessments.
• 3490.3 PBS CHGE 1 Security for Sensitive Building Information Related to Federal Buildings, Grounds, or Property.
• Title 6 Domestic Security - 232(a): Functions of Administrator of General Services.
• Executive Order 14111 Interagency Security Committee.

Roles and Responsibilities

As the owner/leasing authority, GSA has facility security responsibilities. The PBS Commissioner and the OMA Associate Administrator will determine the proper individuals to complete the below tasks. These responsibilities are listed for PBS and OMA:

1. Designated PBS Personnel must:
   1. Complete required training.
      1. Internal training for facility managers on the use of FSA reports; Refresher training on the use of FSA reports will be developed and included annually in the set of required training courses for all GSA Facility Managers in GSA Online University (OLU).
      2. Complete initial ISC designated training on the risk management process prior to supporting FSC operations, and at a minimum, at least every five years thereafter.
   2. Provide facility information to assist the security organization with the initial FSL and the FSA.
   3. Review the FSA for operational impacts and recommended countermeasures.* 
      
      Note: For details on countermeasure responsibilities shared between FPS and GSA, see the current Memorandum of Agreement between the U.S. Department of Homeland Security Federal Protective Service, and the U.S. General Services Administration (GSA-DHS/FPS MOA). In leased facilities, PBS will be the liaison between the security organization and the lessor to coordinate any implementation of proposed countermeasures. Funding for any such work must be provided by GSA, the members of the individual FSC, or other entity as appropriate.
       
   4. Meet with the FSC Chairperson, the security organization (the FPS Inspector in most cases), childcare center director (as applicable), and OMA to review FSAs prior to presentation of findings and recommendations to the FSC. In anticipation of a vote with funding implications, facility managers should obtain accurate square footage information from their asset manager and provide it to the FSC Chairperson.
   5. Coordinate with the FSC Chairperson, the security organization, and OMA during the development of the Occupant Emergency Plan (OEP).
   6. Support facility tenant training and exercises related to Active Shooter, OEP, Insider Threat, evacuation, and all other exercises as appropriate for that facility.
   7. Attend FSC meetings and notify the zonal OMA physical security specialist about upcoming meetings for their possible attendance and support.
      1. Serve as a voting member of the FSC in a facility where GSA is a tenant, or tenant supporting an outlease tenant, or paying for vacant space in a GSA-owned facility.
      2. Serve as the Chairperson/Designated Official (DO) of the FSC where GSA is the primary tenant. This could include incorporating vacant space and outlease space when determining the GSA as the primary tenant.
   8. Monitor and track countermeasures recommended in FSA reports in conjunction with OMA.
   9. Follow-up with FPS, in coordination with OMA, when reports are not received. 
       
2. Designated OMA Personnel must:
   1. Complete the below required training if serving as a Physical Security Specialist
      1. Complete the same internal training that facility managers take on the use of FSA reports; Refresher training on the use of FSA reports will be developed and included annually in the set of required training courses for all GSA Facility Managers in GSA OLU.
      2. Complete initial ISC designated training on the risk management process prior to FSC supporting operations, and at a minimum, at least every five years thereafter.   
   2. Act as a technical resource for PBS on FSA countermeasures, the GSA-DHS/FPS MOA, and FSL questions.
   3. Assist PBS during the planning phase of facility projects that will impact facility security.
   4. Assist PBS with any technical development of the OEP, as requested.
   5. When available, the physical security specialist will attend FSC meetings in support of the PBS facility manager virtually or in person. When the physical security specialist is not available to attend the FSC, the facility manager will provide the physical security specialist with the meeting notes for review and coordination.
   6. Review the FSA provided to PBS for countermeasure recommendations and coordinate with PBS, the FSC, and the security organization on implementation.
   7. Coordinate crime prevention and security awareness training offered by the security organization.
   8. Provide second or third level review of the FSC decision-making process, if invoked by the Chairperson/DO or requested by the PBS facility manager.
   9. Establish and maintain Agency Risk Register.
      1. Email notices will be sent to GSA ServiceNow points-of-contact via automation notifying them of a potentially new FSA for their facility.
      2. Coordinate scheduled FSA’s and follow up with FPS in the event an electronic or hardcopy has not been provided.
      3. Monitor and track countermeasures, in conjunction with PBS, recommended in FSA reports.

* For assistance with any items outlined above, please contact the OMA Physical Security Helpdesk (OMA.Physicalsecurity.helpdesk@gsa.gov).