Thursday, October 27, 2016

NISPOM Chapter 5, physical protection of classified material at cleared contractor locations

In our continuing effort to bring you the latest in protecting national security, we feel it is important to include articles reviewing the latest SUMMARY OF CHANGES TO DoDM 5220.22, “National Industrial Security Program Operating Manual” (NISPOM).

Our intent is to address major changes, excluding admin updates. Many of the changes are simply administrative such crossed out references no longer used, updated table of contents, or renumbered paragraphs. Only major changes not otherwise written about in previous articles will be added.

The first topic in this article is NISPOM Chapter 5, physical protection of classified material at cleared contractor locations.

This begins where paragraph 5-303 is completely obliterated. No comment here except to say they drew the line in the sand in 2006 and finally erased it in 2016. Hopefully, four years to the month after expiration date these steel cabinets and sub-par containers are no longer an issue.

5-303. SECRET Storage. SECRET material shall be stored in a GSA-approved security container, an approved vault, or closed area. Supplemental controls are required for storage in closed areas. The following additional storage methods may be used until October 1, 2012:
a. A safe, steel file cabinet, or safe-type steel file container that has an automatic unit locking mechanism. All such receptacles will be accorded supplemental protection during non-working hours.
b. Any steel file cabinet that has four sides and a top and bottom (all permanently attached by welding, rivets or peened bolts so the contents cannot be removed without leaving visible evidence of entry) and is secured by a rigid metal lock bar and an approved key operated or combination padlock. The keepers of the rigid metal lock bar shall be secured to the cabinet by welding, rivets, or bolts so they cannot be removed and replaced without leaving evidence of the entry. The drawers of the container shall be held securely so their contents cannot be removed without forcing open the drawer. This type of cabinet will be accorded supplemental protection during non-working hours.

Paragraph 5-311 also removes reference to the era by-gone and rearranges sub paragraph structure.

The second topic is Chapter 9 Special Requirements.

Chapter 9 section 1 is completely removed and language concerning RD and FRD is re-written guidance in a new Appendix D. We will cover the specific changes when we write about appendix updates at a later date.

Similarly, Chapter 9 section 3 is completely removed and a new paragraph is added:

Paragraph 9-300. Background General. This section was prepared by CIA in accordance with reference (a) and is provided for information purposes only. It contains general information on safeguarding intelligence information. Intelligence information is under the jurisdiction and control of the DNI, who establishes security policy for the protection of intelligence information, sources, methods, and analytical processes. General. National intelligence is under the jurisdiction and control of the DNI, who establishes security policy for the protection of national intelligence and intelligence sources, methods, and activities. In addition to the guidance in this Manual, contractors shall follow IC directives, policy guidance, standards, and specifications for the protection of classified national intelligence and SCI. Contractors are not authorized to further disclose or release classified national intelligence and SCI (including to a subcontractor) without prior written authorization of the originating IC element.

The NISPOM provides much less guidance on protecting national intelligence than previously provided. In this latest change, NISPOM recognizes the jurisdiction of the Director of National Intelligence and defers to DNI’s requirements. All definitions and guidance is removed and contractors are advised to follow Intelligence Community guidance and instructions concerning working with intelligence information. Contractors should also request guidance from the originating Intelligence Community element and receive it in writing prior to disclosing or releasing classified intelligence and SCI.

Contractors should closely work with the government contracting agency issuing the contract, the government program office, DNI guidance and instructions, DD Form 254, and security classification guidance to ensure proper handling and protection while working with national intelligence.

This completes the major updates to safeguarding classified information given through the NISPOM Conforming Change 2.

Cleared contractors who need assistance with NISPOM requirements can visit for books such as the NISPOM and ITAR. Additionally, take a look at our print version of the Self-Inspection Handbook for NISP Contractors as a training and self-inspection aide. We also have Initial Security Briefings, Refresher Training, Insider Threat training and more. You can purchase our NISPOM training, download and present to cleared employees. The presenter can read notes word for word or edit the notes to provide a tailored briefing appropriate for their organization.

Have a book ready to publish? Why not contact us?

Jeffrey W. Bennett, ISP is the owner of Red Bike Publishing Red Bike Publishing . He regularly consults, presents security training, and recommends export compliance and intellectual property protection countermeasures. He is an accomplished writer of non-fiction books, novels and periodicals. Jeff is an expert in security and has written many security books including: "Insider's Guide to Security Clearances" and "DoD Security Clearances and Contracts Guidebook", "ISP Certification-The Industrial Security Professional Exam Manual", and NISPOM/FSO Training".

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