GAO-13-222, FACILITY SECURITY: Greater Outreach By DHS

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GAOJanuary 2013United States Government Accountability OfficeReport to the Ranking Member,Committee on Homeland Security,House of RepresentativesFACILITY SECURITYGreater Outreach byDHS on Standards andManagement PracticesCould Benefit FederalAgenciesGAO-13-222

January 2013FACILITY SECURITYHighlights of GAO-13-222, a report to theRanking Member, Committee on HomelandSecurity, House of RepresentativesGreater Outreach by DHS on Standards andManagement Practices Could Benefit FederalAgenciesWhy GAO Did This StudyWhat GAO FoundGAO has designated federal realproperty management as a high-riskarea due, in part, to the continuedchallenge of facility protection.Executive branch agencies areresponsible for protecting about370,000 non-military buildings andstructures; the Federal ProtectiveService (FPS) protects over 9,000 ofthese. ISC—an interagencyorganization led by the Department ofHomeland Security (DHS)—issuesphysical security standards foragencies’ use in designing andupdating physical security programs.GAO was asked to review physicalsecurity programs at executive branchagencies with facilities that FPS doesnot protect. This report examines (1)the sources that inform agencies’physical security programs and (2) themanagement practices agencies use tooversee physical security and allocateresources. GAO reviewed andanalyzed survey responses from 32agencies. GAO also interviewedofficials and reviewed documents from5 of these agencies, which wereselected as case studies for more indepth analysis. The survey and resultscan be found at GAO-13-223SP.Agencies draw upon a variety of information sources in developing and updatingtheir physical security programs. The most widely used source, according tosurvey responses from 32 agencies, is the institutional knowledge or subjectmatter expertise in physical security that agencies’ security staff have developedthrough their professional experience. The second most used source arestandards issued by the Interagency Security Committee (ISC). The standards,which are developed based on leading security practices across the government,set forth a decision-making process to help ensure that agencies have effectivephysical security programs in place. However, according to survey responses,the extent of agencies’ use of ISC standards varied—with some agencies usingthem in a limited way. Agency officials from the case-study agencies said thatcertain conditions at their agencies—such as the types of facilities in theagencies’ portfolios and their existing physical security requirements—contributeto limited use of the standards. ISC officials said that the standards are designedto be used by all agencies regardless of the types of facilities or their existingsecurity programs; the standards can be customized to the needs of individualfacilities and do not require the use of specific countermeasures. ISC has anopportunity to clarify how the standards are intended to be used when it trainsagencies on them; during quarterly meetings with member agencies, where ISCcan share best practices on the use of the standards; or when ISC engages inother outreach on the standards. Clarifying how agencies can use the standardsmay result in their greater use. Greater use of the standards may maximize theeffectiveness and efficiency of agencies’ physical security programs.What GAO RecommendsDHS should direct ISC to conductoutreach to executive branch agenciesto clarify how its standards are to beused, and develop and disseminateguidance on management practices forresource allocation as a supplement toISC’s existing physical securitystandards. DHS concurred with theserecommendations.View GAO-13-222. To view the e-supplementonline, click on GAO-13-223SP. For moreinformation, contact Mark Goldstein at (202)512-2834 or GoldsteinM@gao.gov.Agencies use a range of management practices to oversee physical securityactivities. For example, 22 surveyed agencies reported that they have amanager at the agency-wide level responsible for monitoring and overseeingphysical security at individual facilities. In addition, 22 surveyed agenciesreported that they have some documented performance measures for physicalsecurity. Such performance measures can help agencies evaluate theeffectiveness of their physical security programs and identify changes needed tobetter meet program objectives. Agencies’ use of management practices suchas having a physical security manager responsible for allocating resources andusing performance measures to justify investment decisions could also contributeto more efficient allocation of physical security resources across an agency’sportfolio of facilities. However, some agencies make limited use of suchpractices to allocate resources. For example, only 13 reported that they have amanager for allocating resources based on risk assessments. In contrast, amajority of agencies reported having managers for other aspects of physicalsecurity, including those related to oversight. Greater use of managementpractices for allocating resources is particularly relevant given that the surveyedagencies identified allocating resources as the greatest challenge. As thegovernment’s central forum for exchanging information and disseminatingguidance on physical security, ISC is well positioned to develop and disseminateguidance about management practices that can help agencies allocate resourcesacross a portfolio of facilities. However, ISC’s key physical security standards donot currently address management practices for allocating resources across anagency’s entire portfolio of facilities.United States Government Accountability Office

ContentsLetter1BackgroundAgencies’ Physical Security Programs Are Largely Informed byInstitutional Knowledge and ISC StandardsAgencies Use a Range of Management Practices to OverseePhysical Security Activities, but Make Limited Use of ThesePractices to Help Allocate ResourcesConclusionsRecommendationsAgency Comments414252627Appendix IObjectives, Scope, and Methodology29Appendix IIList of Agencies Surveyed34Appendix IIIComments from the Department of Homeland Security36Appendix IVGAO Contact and Staff Acknowledgments386FiguresFigure 1: Agencies Reported That the Following Sources InformTheir Physical Security ProgramsFigure 2: Agencies Reported That the Following Physical SecurityAspects Are Largely Informed by Institutional Knowledgeor Subject Matter Expertise and Standards Issued by theISCFigure 3: Agencies Reported That They Have a Manager at theAgency-Wide Level Responsible for the FollowingAspects of Physical SecurityFigure 4: Agencies Reported That They Have Documented AgencyWide Guidelines for the Following Aspects of PhysicalSecurityFigure 5: Agencies Reported the Following Resource AllocationActivities as Extremely or Very ChallengingPage i79161721GAO-13-222 Facility Security

OPMUSPSVAclosed-circuit televisionDepartment of Homeland SecurityDepartment of DefenseDepartment of EnergyFederal Communications CommissionFederal Protective ServiceFederal Real Property ProfileGeneral Services AdministrationDepartment of the InteriorInteragency Security CommitteeU.S. Office of Personnel ManagementU.S. Postal ServiceDepartment of Veterans AffairsThis is a work of the U.S. government and is not subject to copyright protection in theUnited States. The published product may be reproduced and distributed in its entiretywithout further permission from GAO. However, because this work may containcopyrighted images or other material, permission from the copyright holder may benecessary if you wish to reproduce this material separately.Page iiGAO-13-222 Facility Security

United States Government Accountability OfficeWashington, DC 20548January 24, 2013The Honorable Bennie G. ThompsonRanking MemberCommittee on Homeland SecurityHouse of RepresentativesDear Mr. Thompson:Protecting federal facilities continues to be a challenge for agencies andis among the major reasons GAO designated federal real propertymanagement as a high-risk area.1 In fiscal year 2010, federal executivebranch agencies were responsible for protecting about 370,000 nonmilitary buildings and structures.2 Over 9,000 of these buildings andstructures are protected by the Federal Protective Service (FPS). Theremainder of the buildings and structures are protected by some threedozen other federal executive branch agencies.The federal government’s approach to physical security is largelydecentralized, with individual agencies generally having the discretion toestablish physical security programs that govern how they will protecttheir people, property, structures, and facilities. Agencies tailor theseprograms to their missions, the types of facilities they occupy, and othercircumstances such as the level of public access needed and whether thefacilities house classified or nuclear materials. The Interagency SecurityCommittee (ISC)—an interagency organization led by the Department ofHomeland Security (DHS)—is a central forum for standards and guidance1GAO, High Risk Series: An Update, GAO-11-278 (Washington D.C.: February 2011). Anupdate to GAO’s High Risk Series will be forthcoming in February 2013.2Federal Real Property Council, FY2010 Federal Real Property Report. The FY2010report was the most recent report available during our review. The Federal Real PropertyCouncil’s report provides summary-level information on government-wide real propertydata, as submitted by federal agencies to the Federal Real Property Profile (FRPP). TheFRPP is a centralized real property database maintained by GSA that contains data onthe federal government’s real property inventory. The data that we provide on the numberof buildings and structures exclude military assets. GAO has conducted previous work onthe reliability of FRPP data, and has found problems with FRPP data collection practices.See GAO, Federal Real Property: National Strategy and Better Data Needed to ImproveManagement of Excess and Underutilized Property, GAO-12-645 (Washington D.C.: June20, 2012). However, we found the FRPP data to be reliable for the purposes of providing abroad overview of the makeup of the government’s federal real property portfolio.Page 1GAO-13-222 Facility Security

that is available for agencies to consult when designing and updating theirphysical security programs. ISC is comprised of 51 federal agencies anddepartments, 21 of which are categorized as primary members that voteto approve the standards, and 30 of which are associate members that donot vote. ISC’s purpose is to enhance the quality and effectiveness ofsecurity and the protection of buildings and facilities in the United Statesoccupied by federal employees for nonmilitary activities. This report andExecutive Order 12977,3 which established the ISC, refer to buildings andfacilities in the United States occupied by federal employees fornonmilitary activities as “federal facilities.” ISC’s purpose is also toprovide a permanent body to address continuing government-widesecurity for these federal facilities.GAO has completed a large body of work on FPS’s protection of over9,000 facilities.4 However, given that many executive branch agencies arealso responsible for the physical security of federal facilities, you asked usto examine the physical security programs at these agencies. Theobjectives of our review were to examine the (1) sources that inform howfederal agencies conduct their physical security programs and (2)management practices that agencies use to oversee physical securityactivities and allocate physical security resources.Our review focused on executive branch agencies that have non-militaryfacilities in the United States and its territories that are not protected byFPS. To address our objectives, we conducted a web-based survey of 36cabinet level and independent agencies; we received responses from all36 agencies, which are listed in appendix II. Four agencies reported thatall of their facilities were protected by FPS, and we therefore did notinclude them in our review. The remaining 32 agencies are included inour review, and in this report we identify these agencies as the agencieswe surveyed. Of these 32 agencies, 16 are primary ISC members, 9 are360 Fed. Reg. 54411 (Oct. 24, 1995).4Recent GAO reports on FPS include: GAO, Federal Protective Service: Actions Neededto Assess Risk and Better Manage Contract Guards at Federal Facilities, GAO-12-739(Washington D.C.: Aug. 10, 2012); GAO, Federal Protective Service: Better Data onFacility Jurisdictions Needed to Enhance Collaboration with State and Local LawEnforcement, GAO-12-434 (Washington D.C.: Mar. 27, 2012); and GAO, FederalProtective Service: Actions Needed to Resolve Delays and Inadequate Oversight Issueswith FPS’s Risk Assessment and Management Program, GAO-11-705R (WashingtonD.C.: July 15, 2011).Page 2GAO-13-222 Facility Security

associate ISC members, and 7 are not members of ISC. This reportpresents survey results in aggregate and does not discuss individualagency responses in a way that would identify them. Summary results foreach survey question, except those requiring narrative responses, areavailable in a supplement to this report, GAO-13-223SP. We alsoconducted interviews with and reviewed documentation from officials atfive case-study agencies for more in-depth analysis: the Department ofEnergy (DOE), the U.S. Postal Service (USPS), the Department ofVeterans Affairs (VA), the Federal Communications Commission (FCC),and the U.S. Office of Personnel Management (OPM). We selected theseagencies because they vary in the level of public access allowed at theirfacilities and the amount of building square footage they have. To obtainfurther information, we conducted site visits at DOE, VA, and USPSfacilities in New Jersey, West Virginia, and Illinois, where we interviewedofficials in charge of physical security at the facility and obtaineddocumentation for review. We selected these locations and facilities toachieve diversity in geographic area, urban and rural environments, andfacility risk levels. This report discusses the results of these case studiesand site visits on an individual agency basis, in which case the agencyreferred to is identified by name, as well as in the aggregate. Since thefive case-study agencies and the facilities we visited were selected aspart of a non-probability sample, the findings from our case studies andfacility visits cannot be generalized to all federal agencies. We alsointerviewed officials and reviewed physical security standards from theISC and ASIS International, an organization for security professionals,5and reviewed GAO reports on facility protection and effective programmanagement. See appendix I for more details on our scope andmethodology.We conducted this performance audit from November 2011 to January2013 in accordance with generally accepted government auditingstandards. Those standards require that we plan and perform the audit toobtain sufficient, appropriate evidence to provide a reasonable basis forour findings and conclusions based on our audit objectives. We believethat the evidence obtained provides a reasonable basis for our findingsand conclusions based on our audit objectives.5Founded in 1955 as the American Society for Industrial Security (ASIS), the organizationofficially changed its name in 2002 to ASIS International. ASIS is dedicated to increasingthe effectiveness and productivity of security professionals by developing educationalprograms and materials that address broad security interests.Page 3GAO-13-222 Facility Security

BackgroundThe federal government’s vast real property portfolio is used for allaspects of operations and includes buildings such as warehouses, officespace, dormitories, and hospitals. Agencies’ physical security programsaddress how agencies approach aspects of physical security for thesebuildings, such as conducting risk assessments to identify threats andvulnerabilities, determining which countermeasures to implement, andcoordinating security efforts within the agency and with other agencies.We have previously reported that because of the considerable differencesin types of federal facilities and the variety of risks associated with each ofthem, there is no single, ideal approach to physical security.6 Forexample, in some instances, an agency’s component offices—which aresubordinate entities such as bureaus, administrations, or other operatingdivisions—have their own physical security programs for the facilities theyuse. In other instances, an agency’s regions or districts play a role inphysical security.ISC was created by Executive Order 12977 in 1995, after the bombing ofthe Alfred P. Murrah federal building in Oklahoma City, to addressphysical security across federal facilities occupied by federal employeesfor nonmilitary activities.7 ISC’s mandate is to enhance the quality andeffectiveness of security in and protection of federal facilities. Toaccomplish this, Executive Order 12977 directs the ISC to, among otherthings, develop and evaluate security standards for federal facilities,develop a strategy for ensuring compliance with such standards, andoversee the implementation of appropriate security measures in federalfacilities. Executive Order 12977 also directs each executive agency anddepartment to cooperate and comply with ISC policies andrecommendations issued pursuant to the order.8 The order, as amended,6GAO, Building Security: Security Responsibilities for Federally Owned and LeasedFacilities, GAO-03-08 (Washington, D.C.: Oct. 31, 2002).7Initially, ISC was chaired by GSA. The Homeland Security Act of 2002 created DHS, and,in 2003, Executive Order 13286 amended Executive Order 12977 to transfer ISC fromGSA to DHS. 68 Fed. Reg. 10619 (March 5, 2003).8According to the executive order, executive agencies and departments are exempt fromcomplying with ISC policies and recommendations if the Director of Central Intelligencedetermines that compliance would jeopardize intelligence sources and methods. Inaddition, individual agencies may have their own specific statutory authorities governingphysical security requirements that may exempt them from complying with ISC policiesand recommendations.Page 4GAO-13-222 Facility Security

gives the Secretary of Homeland Security the responsibility to monitorfederal agency compliance with ISC policies and recommendations.Prior to the creation of ISC, there was no federal body responsible fordeveloping government-wide physical security standards. Consequently,ISC became the government’s central forum for exchanging informationand disseminating standards and guidance on physical security at federalfacilities. ISC’s standards are intended to help agencies integrate securityinto the operations, planning, design, and construction of federal facilitiesand are intended to be customized to address facility-specific conditions.ISC has developed the following security standards and guidance, amongothers:9, 10 Physical Security Criteria for Federal Facilities establishes a processfor determining the baseline set of physical security measures to beapplied at a federal facility and provides a framework for thecustomization of security measures to address unique risks at afacility. Design-Basis Threat establishes a profile of the type, composition,and capabilities of adversaries. It is designed to correlate with thecountermeasures contained in the Physical Security Criteria forFederal Facilities. Facility Security Level Determinations defines the criteria and processto be used in determining the facility security level of a federal facility,a categorization that then serves as the basis for implementing ISCstandards.11 Use of Physical Security Performance Measures directs all federalagencies to assess and document the effectiveness of their physicalsecurity programs through performance measurement and testing.9For a complete listing of ISC standards and guidance, see s-and-best-practices. Accessed January 22, 2013.10ISC officials said that they are in the process of consolidating and streamlining severalof their physical security standards into a single document, which they believe will helpfacilitate agencies’ use of the standards.11Physical Security Criteria for Federal Facilities, Design-Basis Threat, and FacilitySecurity Level Determinations have a status of For Official Use Only and are therefore notpublicly available.Page 5GAO-13-222 Facility Security

This standard provides guidance on how to establish and implement acomprehensive measurement and testing program.12 Security Specialist Competencies provides the range of corecompetencies federal security specialists should possess to performtheir basic duties and responsibilities.13ISC’s 51 member agencies meet quarterly to promote information sharingon physical security. Members serve on working groups andsubcommittees to develop and update physical security standards andguidance, including those listed above. ISC also engages with industryand other government stakeholders to advance best practices andprovides training on its standards to federal facility security professionalsand other stakeholders. Leadership for the ISC is provided by DHS’sAssistant Secretary for Infrastructure Protection, who is the chair of theISC; an Executive Director; and eight standing subcommittees thatidentify long- and short-term priorities and oversee strategic initiatives.Agencies’ PhysicalSecurity ProgramsAre Largely Informedby InstitutionalKnowledge and ISCStandardsAgencies draw upon a variety of information sources in developing andcontinually refining aspects of their physical security programs, such ashow and when to conduct risk assessments, what skills security staffshould have, and how to determine which countermeasures to implementat their facilities. Sources can include an agency’s institutional knowledgeor subject matter expertise in physical security, federal statutes andregulations, physical security standards issued by ISC, and state or localregulations, among others, as shown in figure 1. Characteristics such asagencies’ missions and the type, use, and location of their facilities canaffect which of these sources agencies use. For example, a facility mayadhere to local building codes that affect aspects of physical securitysuch as perimeter fencing, or a facility that is used to house radioactivewaste may be subject to federal requirements on the storage of nuclearmaterials. Institutional knowledge in physical security and ISC’s physicalsecurity standards were the two sources that our survey results and case-12Department of Homeland Security, Interagency Security Committee, Use of PhysicalSecurity Performance Measures (Washington, D.C.: 2009).13Department of Homeland Security, Interagency Security Committee, Security SpecialistCompetencies, An Interagency Security Committee Guideline. 1st edition (2012).Page 6GAO-13-222 Facility Security

study interviews showed to be the most influential in guiding agencies’physical security programs.14Figure 1: Agencies Reported That the Following Sources Inform Their PhysicalSecurity ProgramsNote: Thirty-two agencies responded to the survey question on whether they used any of the sourcesin the figure above to inform their physical security programs.aFederal statutes or regulations of broader applicability are those that apply to multiple agenciesrather than being specific to one agency.14As shown in figure 1, agencies we surveyed cited federal statutes and regulations ofbroader applicability to be the third most influential source for guiding agencies’ physicalsecurity programs. However, when we surveyed agencies about whether they use thissource to inform the specific aspects of physical security as shown in figure 2, a fewernumber of agencies we surveyed cited that they used this source as compared toinstitutional knowledge and ISC standards. Consequently, this objective focuses onagencies’ use of the two most used sources—institutional knowledge and ISCstandards—and not on the use of federal statutes and regulations. Assessing agencies’compliance with federal statutes and regulations was outside the scope of our work.Survey results on use of federal statutes and regulations and other sources can be foundin GAO-13-223SP.Page 7GAO-13-222 Facility Security

Institutional Knowledge,Subject Matter Expertisein Physical Security, andPrior Security ExperienceInform Agencies’ PhysicalSecurity ProgramsAll 32 of the agencies we surveyed reported that institutional knowledgeor subject matter expertise informs their physical security programs. Thiswas the most widely used source cited in our survey, as shown in figure1. For example, officials from three of the agencies we surveyed said thatthe knowledge, experience, and expertise that their security specialistshave in physical security—which they consider institutional knowledge—is reflected in their physical security programs and policies. One of theseofficials said his agency contracts with a security company that hasextensive knowledge and experience in providing security and lawenforcement to high profile institutions across the federal government,and that this knowledge is used in managing the agency’s securityprogram. Another agency official said that the knowledge gained fromemployees’ previous education, training, or work experiences, orhistorical knowledge of the agency has assisted in the development ofseveral security policies and procedures within the agency.Agencies also rely heavily on institutional knowledge or subject matterexpertise to inform specific aspects of their security programs, more sothan any other source we asked about in our survey. As shown in figure2, 26 agencies reported that institutional knowledge informs how theyconduct risk assessments and determine appropriate countermeasures.For example, officials from two of our case-study agencies—DOE andUSPS—said that they use institutional knowledge to inform how theyconduct these activities. DOE headquarters officials told us that whendeveloping and updating agency-wide physical security policies, whichaddress topics such as risk assessments, they obtain input from DOEstaff in their component offices,15 who have knowledge of the particularneeds and constraints of their facilities based on their experienceimplementing security programs. In addition, USPS officials said that theirsecurity staff’s knowledge of the agency’s long-standing security programand their professional education in physical security helps them makedecisions about security measures needed at their facilities, such as onthe location of perimeter fencing and the appropriate brightness forsecurity lights.15Component offices are subordinate entities within an agency, such as bureaus,administrations, and other operating divisions within an agency. At DOE, componentoffices include the Office of Science and the Office of Fossil Energy.Page 8GAO-13-222 Facility Security

Figure 2: Agencies Reported That the Following Physical Security Aspects AreLargely Informed by Institutional Knowledge or Subject Matter Expertise andStandards Issued by the ISCNote: Thirty agencies responded to the survey question on how institutional knowledge informed keyaspects of physical security. Two of the agencies reported in a separate survey question that theyuse institutional knowledge, in general, to inform their physical security programs but did not answerthe survey question on individual aspects of security. Twenty-nine agencies responded to the surveyquestion on how ISC standards informed key aspects of physical security.aDesign-basis threat is an approach that helps agencies establish the type, composition, andcapabilities of adversaries across a range of their facilities.Most Agencies Use ISCStandards, but Only SomeRely Extensively on ThemTwenty-nine of 32 agencies surveyed reported that ISC standards informtheir physical security programs, making it the second most-used sourcebehind institutional knowledge, as shown in figure 1. Officials weinterviewed from our case-study agencies said that they use ISCstandards as one of many sources that inform what they include in theirphysical security programs. ISC has developed a number of governmentwide physical security standards that address topics intended to helpguide agencies’ physical security programs, including determining afacility’s risk level and identifying threats posed by potential adversaries,among other things. Agencies’ use of ISC standards can help ensure thatPage 9GAO-13-222 Facility Security

physical security programs are effective government-wide. The standardsare developed based on the collective knowledge and physical securityexpertise of ISC member agencies and, therefore, reflect leadingpractices in physical security. Every ISC member agency that wesurveyed, as well as four agencies that are not ISC members, reportedthat they use ISC standards at least to some degree. The three agencieswe surveyed that reported that they do not use ISC standards at all arenot ISC members.16 According to our survey, ISC standards are mostoften used for conducting design-basis threat analysis of agency facilities,identifying aspects of facilities that need security measures, anddetermining appropriate countermeasures, as shown in figure 2.Although the majority of agencies we surveyed use ISC standards, theextent of their reliance varies—with some agencies using the standardsextensively to inform their physical security programs and some usingthem in a more limited way. For example, 11 agencies reported that all ofthe physical security aspects shown in figure 2 are largely informed byISC standards, whereas six agencies reported that none of these aspectsare largely informed by ISC standards.17 Instead, these six agenciesgenerally reported that these aspects are somewhat, minimally, or

agency’s entire portfolio of facilities. View GAO-13-222. To view the e-supplement online, click on GAO-13-223SP. For more information, contact Mark Goldstein at (202) . broad overview of the makeup of the gover

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