Saturday, December 7, 2019

Planning for the Facility Security Clearance (FCL)

Once a defense contractor is granted a facility clearance, they can begin to prepare to perform on the classified contract. This preparation could identify potential additional costs. The costs associated with performing on classified contracts will vary by contract and depends on whether or not the Cleared Defense Contractor (CDC) is a possessing or non-possessing facility. The possessing facility is one that performs classified work at the CDC location and may require the storage of classified documents or material on site. 

Depending on the contract, this could involve purchasing multiple security containers or acquiring large storage areas for oversized material such as weapons systems or computers. For non-possessing facilities, this does not require the storage of classified information at the CDC. However, the organization will provide cleared employees to perform classified work at locations other than at the home facility. 

The FSO can help reduce costs associated with protecting classified information by being involved and preparing as early in the acquisition process as possible. This is where an experience FSO can anticipate expenses, perform risk assessment while implementing National Industrial Security Program Operating Manual (NISPOM), and advise on ways to reduce costs while being compliant. The more money saved on overhead expenses, the greater the overall company profit. The earlier into the process the assessment is conducted the better the company performs. 

Conducting a cost impact study or coordinating with the GCA and CSO later than necessary may place the contractor in the tough position of last minute work and higher associated expenses while building closed areas, ordering more GSA approved containers (safes), and meeting tough governmental compliance with short notice.

One good idea is for the FSO to form a working team to consider the costs. These could be program managers, engineers, security, contract and other managers responsible for developing business with the prime contractor or government agency. This team would consider the contract, security requirements, have decision authority and the ability to commit the company to the developing security plan. The FSO contributes by providing information and guidance on protecting classified information in the process and such planning could translate into significant cost reduction.

Understanding how to advise and assist in the development of the Contract Security Classification Specification (DD Form 254) and Security Classification Guides (SCG) brings the CDC into the planning process early and can benefit the government and the CDC by reducing time and resources. It provides the ground work for ensuring the customer security requirements are clear, applicable, and understood. Since the government provides the protection requirements, getting in on the ground level development can only benefit the contractor.

The FSO can use the DD Form 254 requirements as a baseline in assessing the current state of security to determine whether or not the company has enough classified storage space, the right type of storage space, whether or not alarms are needed and other physical security needs to support the contract, and the adequate security or support staff is on hand. Other performance requirements may indicate the need for classified computer processing, upgrading facility and personnel clearances, and increasing storage level and capability.

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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