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Department of the Interior

Departmental Manual

Effective Date: 7/7/99

Series: Law Enforcement and Security

Part 444: Physical Protection and Building Security

Chapter 1: General Program Requirements

Originating Office: Office of Managing Risk and Public Safety

444 DM 1

1.1 Purpose. This chapter sets forth the policies for that part of the Departmental security program designed to safeguard Departmental personnel and facilities, to include buildings, grounds and property.

1.2 Applicability. The policies established herein are applicable to all Departmental facilities, buildings and grounds whether owned or leased and to all persons entering in or on such property. To the extent applicable, they supplement the regulations published in 41 CFR 101-20, Management of Buildings and Grounds, which prescribe physical protection, conduct on Federal property and building security requirements for buildings and grounds under the charge and control of the General Services Administration (GSA). This Part also supplements the recommended minimum security standards contained in the U.S. Department of Justice study entitled, "Vulnerability Assessment of Federal Facilities," that was implemented for all Federal facilities by Presidential Memorandum, dated June 28, 1995. Nothing in this Part alters or reduces the requirements for information resources security as prescribed by 375 DM 19, Information Resources Security Program, or any other requirement established by law or other authority.

1.3 Responsibilities.

A. The senior Departmental official having jurisdiction over an office, building, or other facility is responsible for safeguarding personnel, and real and personal property under the control of, or assigned to, the facility.

B. Each bureau/office head is responsible for implementing, maintaining, and monitoring facility security procedures necessary to protect the personnel, operation and contents of facilities in accordance with the recommended minimum security standards contained in the U.S. Department of Justice study entitled, "Vulnerability Assessment of Federal Facilities," dated June 28, 1995. Each bureau/office head is also responsible for ensuring that bureau specific physical security review and compliance programs and policies are developed and implemented. Additionally, each bureau/office head is responsible for designating in writing a professional bureau/office security officer (hereafter referred to as the Security Officer) who will perform the duties in 444 DM 1.3D.

C. The Director, Office of Managing Risk and Public Safety (MRPS), is responsible for development, direction, coordination, compliance and implementation of the Department physical security program, including establishing policy and guidelines for the physical security program.

D. The bureau/office Security Officer is responsible for complying with Departmental physical security program policy and developing physical security safeguards at sites occupied by his/her bureau/office employees (see 444 DM 1.4). The Security Officer will be the principal point of contact with the MRPS and the principal advisor within the bureau/office for security related matters. The Security Officer should be responsible for all areas of security (441 DM, Personnel Security and Suitability Requirements; 442 DM, Classified National Security Information; and 443 DM, National Industrial Security Program) for the bureau/office.

E. Each employee is responsible for compliance with the Departmental physical security program and implementing directives developed by the Security Officer for safeguarding property entrusted to his/her care.

1.4 Physical Security Surveys. Physical security surveys to evaluate the security safeguards, in effect or needed, will be conducted or arranged for by the Security Officer, or his or her designee, at sites occupied by his/her bureau/office employees. When a facility is in the planning stage, the Security Officer, or his or her designee, will review the physical security requirements with the architect and builder to assure that necessary safeguards are included in the initial construction. Prior to occupancy of a new building, the Security Officer, or his or her designee, will conduct and record an on-site physical security survey. The survey should identify safeguards which must be installed before occupancy. The Security Officer will retain all documentation, in accordance with General Records Schedule 18, and make that documentation available for review.

When a physical security survey is conducted of a Departmental facility by any other agency; e.g., General Services Administration, Federal Emergency Management Agency, etc., the Security Officer or designated alternate security official will retain all documentation. The Security Officer or designated alternate security official will maintain documentation of the action taken by the senior official indicating whether the recommendations, or any portion thereof, will be accomplished.

1.5 Compliance Evaluations. MRPS will conduct security compliance evaluations, as appropriate, to assist the bureaus in assuring effective physical security safeguards are implemented at Departmentally owned facilities. Vulnerable areas will be discussed with the senior official or a designated representative at the close of the inspection. Following the inspection, the senior official will be provided a written report of findings, with appropriate recommendations (reference 444 DM 1.3A) for action. When a Security Officer conducts an inspection of a site occupied by his/her bureau/office employees, the Security Officer will retain a copy of the report of findings, in accordance with General Records Schedule 18, and make the report available for review by Departmental security personnel upon request.

1.6 Initial Security Assessment. In determining the type and depth of physical security safeguards required, the following items should be considered:

A. The safety and welfare of employees.

B. The effect of a loss of the facility or part of the facility on the mission of the Department and the potential effect of that loss on the national welfare.

C. The vulnerability of the facility to unauthorized access which could lead to the sabotage, theft, or vandalism of Federal real and personal property and/or records.

D. The replacement cost of Federal real and personal property versus the cost of physical security safeguards under consideration.

1.7 Security Requirements. Security levels for Federal facilities and minimum physical security standards are detailed in 444 DM 1, Appendix A, Extracts from the U.S. Department of Justice Study Entitled, "Vulnerability Assessment of Federal Facilities." These are minimum requirements, bureaus/offices may increase security standards and safeguards based on local circumstances and/or a threat vulnerability study indicating a need for increased security of individual facilities.

1.8 Occupant Emergency Program. The senior official at each facility is responsible for developing, implementing and maintaining an Occupant Emergency Plan. The official's responsibilities include establishing, staffing and training an Occupant Emergency Organization with emphasis on training and drilling occupants of the facility (41 CFR 101-20.103-4). All Occupant Emergency Plans will contain procedures for dealing with bomb threats and suspicious devices and packages.

The General Services Administration, Federal Protective Service (FPS) provides sample Occupant Emergency Plans, while the U.S. Postal Service and the Bureau of Alcohol, Tobacco and Firearms provides information on and examples of suspicious packages and bomb threat procedures. A list of FPS regional offices is found in 441 DM 1, Appendix B.

1.9 Conduct on Federal Property. Conduct on Federal property will be in accordance with applicable Federal, State and local laws and regulations.

A. Inspection. Packages, briefcases, and other containers in the immediate possession of visitors, employees, or other persons arriving on, working at, visiting, or departing from Federal buildings and grounds, are subject to reasonable inspection.

B. Admission to Property. Property shall be closed to the public during other than normal business hours. The closing of property will not apply to that space where after-normal-business-hours use/access has been approved by a designated official. Admission to property after normal business hours will be restricted to authorized persons who shall register upon entry to the property and/or shall, when requested, display Government or other identifying credentials to security personnel when entering, leaving, or while on the property.

C. Preservation of Property. The improper disposal of rubbish on property; the willful destruction of or damage to property; the theft of property; the creation of any hazard on property to persons or things; the throwing of articles of any kind from or at a building or the climbing upon statues, fountains, or any part of the building, is prohibited. Applicable Federal, State and local laws and regulations also apply.

D. Conformity with Official Signs and Directions. Persons in or on the property shall comply with official signs of a prohibitory, regulatory, or directory nature, and with the lawful direction of security personnel.

E. Disturbances. Any loitering, disorderly conduct, or other conduct on property which creates loud or unusual noise or a nuisance; which unreasonably obstructs the usual use of entrances, foyers, lobbies, corridors, offices, elevators, stairways, or parking lots; which otherwise impedes or disrupts the performance of official duties by Federal Government employees; or which prevents the general public from obtaining the services provided on the property in a timely manner, is prohibited.

F. Alcoholic Beverages and Narcotics. Operation of a motor vehicle while on the property by a person under the influence of alcoholic beverages or drugs is prohibited. Entering upon or occupying the property while under the influence of or using or possessing any illegal/controlled drugs is prohibited. The prohibition shall not apply in cases where the drug is being used/possessed in accordance with a prescription issued by a licensed physician. Entering upon or occupying the property, under the influence of alcoholic beverages is prohibited. The use of alcoholic beverages on the property is prohibited, except as provided in 41 CFR 101-20.307.

G. Dogs and Other Animals. Dogs and other animals, except seeing eye dogs, hearing dogs, service dogs, and animals used to guide or assist disabled persons, shall not be brought upon the property for other than official purposes.

H. Vehicular and Pedestrian Traffic.

(1) Drivers of vehicles entering or while on the property shall drive in a careful and safe manner and shall comply with the signals, posted traffic signs and directions of law enforcement and security personnel.

(2) The blocking of entrances, driveways, walks, loading platforms and fire hydrants on the property is prohibited.

(3) Except in emergencies, parking on the property is not allowed without a permit. Parking without authority, parking in unauthorized locations or in locations reserved for other persons, or parking contrary to the direction of posted signs is prohibited. Vehicles parked in violation may be subject to removal at the owners' risk and expense.

I. Explosives. No person entering or while on the property shall carry or possess explosives, or items intended to be used to fabricate an explosive or incendiary device, either openly or concealed, except for official purposes.

J. Firearms. Unauthorized possession or transportation of firearms or other dangerous weapons in an Interior facility is prohibited and a violation of Federal law. The carrying of firearms by anyone other than authorized individuals is prohibited. (Weapons, see title 18, U.S.C. 930.)

K. Removal of Government Property. Procedures should be established at Departmental facilities to control the removal of Government property.

1.10 Violence in the Workplace. Violence and threatening behavior in the Federal workplace is prohibited. This includes any behavior that is harassing, intimidating, provoking, or unsafe which could be interpreted as an intent or a threat to cause physical harm to another individual or damage to property.

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444 DM 1

APPENDIX A

Extracts From the

U.S. Department of Justice Study Entitled,

"Vulnerability Assessment

of

Federal Facilities"

June 28, 1995

TABLE OF CONTENTS

1. Introduction

1.1 The Development of Recommended Minimum Security Standards

1.2 The Survey of Existing Conditions

1.3 Conclusions and Recommendations

2. Recommended Minimum Security Standards and Application to Security Levels of

Federal Facilities

2.1 Recommended Minimum Security Standards

2.1.1 Perimeter Security

2.1.2 Entry Security

2.1.3 Interior Security

2.1.4 Security Planning

2.2 Security Levels for Federal Facilities

2.2.1 Level I

2.2.2 Level II

2.2.3 Level III

2.2.4 Level IV

2.2.5 Level V

2.3 Application of Recommended Minimum Security Standards to Security

Levels of Federal Facilities

3. Survey of Existing Security Conditions

3.1 Study Sample

3.2 How the Survey Was Conducted

3.3 Findings

3.3.1 Typical Level I Facilities

3.3.2 Typical Level II Facilities

3.3.3 Typical Level III Facilities

3.3.4 Typical Level IV Facilities

3.3.5 Typical Level V Facilities

3.4 Cost Implications

4. Conclusions and Recommendations

4.1 Conclusions

4.1.1 Comparison of Typical Federal Facilities and Proposed New Minimum Standards

4.1.2 Reasons for the Current Security Situation in Federal Facilities

4.2 Recommendations

4.2.1 Where Feasible, Bring Each Federal Facility up to the Minimum Standards

Recommended for its Security Level

4.2.2 Establish Building Security Committees

4.2.3 Reemphasize GSA's Primary Responsibility for Implementing

Federal Facility Security

4.2.4 Upgrade the Federal Protective Service

4.2.5 Create an Interagency Security Committee

4.2.6 Funding Recommendations

4.2.7 Additional Recommendations

Annex 1 Recommended Standards Chart

Annex 2 Details of Recommended Security Standards

Annex 3 Classification Table

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1. Introduction

The day after the April 19, 1995, bombing of the Alfred P. Murrah Federal Building in Oklahoma City, the President directed the Department of Justice to assess the vulnerability of federal office buildings in the United States, particularly to acts of terrorism and other forms of violence. Because of its expertise in court security, the United States Marshals Service (USMS) coordinated this study.

Prior to the study, there were no government-wide standards for security at federal facilities, and no central data base of the security currently in place in such facilities. A national review of the kind called for by the President on April 20 had never before been undertaken. Given the urgency of the task -- a report was to be made in sixty days -- the study proceeded along two tracks at the same time: (1) the development of recommended minimum security standards in light of the changed environment of heightened risk; and (2) the surveying of existing security conditions.

The USMS assembled two working groups to accomplish these tasks, a Standards Committee and a Profile Committee.

1.1 The Development of Recommended Minimum Security Standards

The Standards Committee consisted of security specialists and representatives of components of the U.S. Department of Justice, including the Federal Bureau of Investigation, and of the U.S. Secret Service, General Services Administration (GSA), State Department, Social Security Administration, and Department of Defense. The Committee identified and evaluated the various types of security measures which could be used to counter potential vulnerabilities.

The product of the Standards Committee's work was a set of minimum standards that can be applied to various federal facilities. The standards cover the subjects of perimeter, entry, and interior security, and security planning. They are set out in Section 2.3 and Annex 2.

Because of the considerable differences among federal facilities and their security needs, the Standards Committee divided federal holdings into five security levels to determine which minimum standards are appropriate for which security levels. These categories are based on such factors as size, number of employees, use, and required access to the public. The categories range from Level I (typically, leased space with ten or fewer employees, such as a military recruiting office in a shopping center or a small post office) to Level V (a building such as the Pentagon or CIA headquarters with a large number of employees and a critical national security mission). The security levels are set out in Annex 3. Section 2.3 shows the recommended minimum security standards applicable to each security level.

1.2 The Survey of Existing Security Conditions

The second working group established by the USMS was the Profile Committee. This Committee's task was to survey a broad and representative sample of federal facilities to determine their existing security situations, and to identify future security enhancements and costs.

There are approximately two million federal civilian employees, of whom approximately one million are housed in GSA space. Almost 75 percent of these one million employees are housed in what GSA describes as a "typical single or multi-tenant federal office building." There are approximately 1,330 such buildings in the continental United States, and these constituted the survey sample. Typically, such buildings are multi-story facilities housing more than 80 employees. They generally contain a mix of federal agencies, most of which have significant contact with the public and require fairly easy access.

The remaining federal employees work in facilities not included in the survey sample, which did not include special use space, such as, laboratories, national parks, nuclear facilities, military installations, and post offices. It also did not include facilities with very small numbers of federal employees, facilities in foreign countries, or facilities leased or owned by agencies with independent real estate authority, such as the Securities and Exchange Commission. It is, nevertheless, a large and representative sample. Many of these excluded facilities have extensive security systems already in place because of the nature of their missions, and many of the others must be addressed independently because of their unique characteristics.

The survey was conducted by USMS Deputies and GSA security specialists, who conducted site visits at the facilities in the survey to obtain the information called for in a specially-developed questionnaire. The questionnaire requested information on a wide variety of security concerns, including facility construction, security screening, protection of utilities, and day care presence. Within approximately a 60 day period, site visits were made to, and data obtained from over 1,200 locations. The data obtained have been consolidated into a data base that can inform future decisions in this area.

The result of the survey was a set of profiles of typical federal facilities, grouped by categories corresponding to the five security classification levels set by the Standards Committee.

1.3 Conclusions and Recommendations

Armed with a set of recommended minimum standards, and a profile of typical federal facilities at different security levels, the Department of Justice is able to make a number of conclusions and recommendations regarding federal facilities security. These are set out in Section 4, Conclusions and Recommendations.

The Department's principal conclusion is that the typical federal facility at each security level lacks some of the elements required to meet the new minimum standards proposed in this Study.

The Department's principal recommendation is that, where feasible, each federal facility should be brought up to the minimum security standards proposed for its security level.

Because each building's security requirements, and the feasibility of upgrading existing conditions to meet the new standards, depend on building-specific facts, we further recommend that these security issues first be addressed by building-level security committees. The resulting building-by-building evaluations should then be assessed by GSA, and the necessary improvements implemented.

2. Recommended Minimum Security Standards and Application to Security Levels of Federal Facilities

The task of the Standards Committee was to establish recommended minimum security standards, and to apply them to the different security levels into which federal buildings fall. The Committee was comprised of security professionals from numerous federal agencies with significant security responsibilities.

2.1 Recommended Minimum Security Standards

Fifty-two (52) standards were developed as a result of these efforts. The standards are set out in Section 2.3, and are described in detail in Appendix A. They fall into the following categories.

2.1.1 Perimeter Security

Perimeter security standards pertain to the areas outside government control. Depending on the facility type, the perimeter may include sidewalks, parking lots, the outside walls of the building, a hallway, or simply an office door.

The elements of perimeter security are:

* Parking

* Closed Circuit Television Monitoring

* Lighting

* Physical Barriers

2.1.2 Entry Security

Entry security standards refer to security issues related to the entry of persons and packages into a facility.

The elements of entry security are:

* Receiving/Shipping

* Access Control

* Entrances/Exits

2.1.3 Interior Security

Interior security standards refer to security issues associated with prevention of criminal or terrorist activity within the facility. This area concerns secondary levels of control after people or things have entered the facility.

The elements of interior security are:

* Employee/Visitor Identification

* Utilities

* Occupant Emergency Plans

* Day Care Centers

2.1.4 Security Planning

Security planning standards refer to recommendations requiring long-term planning and commitment, as well security standards addressing broader issues with implications beyond security at a particular facility.

The elements of security planning are:

* Intelligence Sharing

* Training

* Tenant Assignment

* Administrative Procedures

* Construction/Renovation

2.2 Security Levels for Federal Facilities

Since there are vast differences in types of federal facilities and their security needs, the Standards Committee divided federal holdings into five security levels. The five security levels are set out in detail in 444 DM 1, Annex 3, and are described below.

In this study, the listed security levels have been based primarily on staffing size, number of employees, use, and the need for public access. Final assignment of a security level to a building, will be adjusted based on threat intelligence, crime statistics, agency mission, etc.

2.2.1 Level I

A Level I facility has 10 or fewer federal employees. In addition, the facility likely has:

* 2,500 or less square feet of office space; and

* A low volume of public contact or contact with only a small segment of the population.

A typical Level I facility is a small "store front" type operation such as a military recruiting office.

2.2.2 Level II

A Level II facility has between 11 and 150 federal employees. In addition, the facility likely has:

* From 2,500 square feet to 80,000 square feet;

* A moderate volume of public contact; and

* Federal activities that are routine in nature, similar to commercial activities.

A typical Level II building is the Social Security Administration Office in El Dorado, Colorado.

2.2.3 Level III

A Level III facility has between 151 and 450 federal employees. In addition, the facility likely has:

* From 80,000 to 150,000 square feet;

* A moderate/high volume of public contact; and

* Tenant agencies that may include law enforcement agencies, court/related agencies and functions, and government records and archives.

A typical Level III building is the Pension Building, a multi-tenant, historical building on 5th Street, Northwest, in Washington, D.C. Another example would be the South Interior Building, a single-tenant, historical building on Constitutional Avenue, in Washington, D.C.

2.2.4 Level IV

A Level IV facility has over 450 federal employees. In addition, the facility likely has:

* More that 150,000 square feet;

* High-volume public contact; and

* Tenant agencies that may include high-risk law enforcement and intelligence agencies, courts, judicial offices, and highly sensitive government records.

A typical Level IV building is the Department of Justice Building on Constitution Avenue in Washington, D.C. The Alfred P. Murrah Federal Building in Oklahoma City also fell into this category.

2.2.5 Level V

A Level V facility is a building such as the Pentagon or CIA Headquarters that contains mission functions critical to national security. A Level V facility will be similar to a Level IV facility in terms of number of employees and square footage. It should have at least the security features of a Level IV facility.

The missions of Level V facilities require that tenant agencies secure the site according to their own requirements. The degrees to which these requirements dictate security features in excess of those for a Level IV facility should be set by the individual agency.

2.3 Application of Recommended Minimum Security Standards to Security Levels of Federal Facilities

The recommended minimum security standards applicable to each of the five security levels are covered in 444 DM 1, Annex 1, Recommended Standards Chart. A detailed description of each standard is set out in 444 DM 1, Annex 2, Details of Recommended Security Standards.

3. Survey of Existing Security Conditions

3.1 Study Sample

As noted above, the survey concentrated on GSA-controlled single or multi-tenant office buildings, the typical building in which about 750,000 federal employees work. The sample did not include facilities with very small numbers of employees or special use space, such as laboratories, national parks, post offices, military bases, nuclear facilities, and laboratories, or facilities of agencies with independent real estate authority. Facilities such as military bases and nuclear facilities have extensive security in place. Security at places such as national parks and small post offices must be addressed separately because of their unique characteristics and the necessity that they be very accessible to the public.

3.2 How the Survey Was Conducted

To provide an overview of the typical level of security in place at a multi-tenant federal building, a questionnaire was developed to elicit information about security at 1,330 such facilities in GSA's inventory. USMS Deputies and GSA security specialists then performed an on-site visit to each of these facilities to obtain the information requested in the questionnaire. Ultimately, 1,239 usable surveys were completed within the mandated time frame. The data from those questionnaires are reflected in this analysis.

The overall objective of the survey was to provide a data base from which to evaluate vulnerabilities statistically, focus attention on areas where new security standards may be needed, inform immediate decision-making and assist in long-term planning to re-evaluate those standards.

3.3 Findings

Set forth below is a description of the current security situation in the typical facility at each security level, and a description of the steps needed to bring such a typical facility up to the minimum standards proposed in this Study.

3.3.1 Typical Level I Facilities

A typical Level I facility, a small office with less than ten employees, such as a military recruiting office, currently has the following security-related characteristics:

* The federal organization is a single tenant in a leased office

* The building has no set-back from the surrounding streets

* There are other offices or business establishments in the building

* There is metered and/or public parking immediately adjacent to the building

* It is usually a satellite office

* The standard hours of operation are less than twelve hours a day

* It does not have perimeter lights

* It may have a simple power backup feature for emergency lighting and fire detection systems

* The facility most likely has high-security locks on all exterior doors; these locks are likely the only measure of security for this level facility

To upgrade the typical Level I facility to the new recommended minimum standards, the facility should have, in addition to the high-security locks, the following security features:

* Employee security awareness training

* Perimeter lights, with street lighting an acceptable source and emergency power back-up desirable

* Emergency power backup for interior lighting

* Occupant Emergency Plan Officials assigned and trained

* Background security checks conducted on, or security control procedures established for, service contract personnel

3.3.2 Typical Level II Facilities

A typical Level II facility, a multi-tenant, federally-owned or leased building with between 11 and 150 federal employees, currently has the following security-related characteristics:

* The building is, more likely than not, a multi-story structure

* The building is likely to be older; there are many historical buildings in this category

* With the exception of a sidewalk, the building is likely to have no set-back from the surrounding streets

* Only exterior parking is available and it is adjacent to the building

* The building operates an average of 12 hours a day

* As in the Level I facility, the primary security is locks on all of the perimeter doors

To meet the standards recommended in this Study, the Level II facility should have, in addition to the security features recommended for a Level I facility:

* Perimeter lighting other than street lighting (again, emergency backup power is desirable)

* A visitor control and screening system, such as identification badges or sign-in register

3.3.3 Typical Level III Facilities

A typical Level III facility, a multi-story, federally-owned or leased facility with several federal tenant organizations and between 151-450 federal employees, currently has the following security-related characteristics:

* The building was constructed less than 25 years ago

* Although the building has a greater set-back than would be found at a lower level facility, it still has only a minimal set-back from the street

* It is likely to have an exterior parking lot

* The building is open for use and operation to employees more than 12 hours per day

* As in the lower levels, the primary security in these buildings are locks on all perimeter doors

* It may also have a centrally monitored intrusion detection system

In accordance with proposed standards, the Level III facility should have all the security features of Levels I and II, and:

* As much control as possible over interior parking

* Parking areas adjacent to federal space should be controlled when feasible

* Perimeter lighting (for federally controlled facilities, the perimeter lighting should be attached to the power backup system)

* Magnetometer or x-ray screening at public entrances as determined by local facility evaluations

* Guards, the number and location to be determined by local facility evaluation

3.3.4 Typical Level IV Facilities

A typical Level IV facility, a large multi-tenant, multi-story, federally-owned or leased building with in excess of 450 employees, currently has the following security-related characteristics:

* It may be set back from the street

* It will have some interior underground parking as well as exterior parking

* The building is accessed by employees more than 12 hours a day, and may be open to employees 24 hours per day

* Public access is limited to less than 12 hours a day

* It may have a guard

To upgrade a Level IV facility, it should have all of the security features for Level's I - III, and in addition, should:

* Control adjacent parking as much as possible

* Employ 24-hour closed circuit television with monitoring and video-tape recording of the building's perimeter, and with signs publicizing the use of this equipment

* Mandate that agency photo identification cards be displayed at all times

* Have shatter-resistant exterior glass, or glass treated with a substance such as mylar to resist shattering

* Require x-ray screening of all mail and packages

3.3.5 Typical Level V Facilities

As noted above, the mission of a Level V facility requires tenant agencies to secure the site according to their own requirements, and the degree to which those requirements dictate security features in excess of those for a Level IV facility should be set by the individual agency.

3.4 Cost Implications

The implementation of any of the standards not already in place at a building will require additional funding. Cost figures were obtained by unit price and are reflected in 444 DM 1, Annex 3, Classification Table.

Since most federal buildings have some, but not all of the recommended security features, a total cost for the implementation of the various security levels cannot be determined without a detailed review of the security currently in place in each building. If a Level IV building had none of the minimum recommended security features, the total cost for a retrofit could be just over $3 million. Usually, the cost for a retrofit would be lower. The total cost for equipping a new Level IV building with the necessary security features would be about $2.5 million. This does not include the costs of personnel for access control and patrolling.

4. Conclusions and Recommendations

4.1 Conclusions - As of June 28, 1995.

4.1.1 Comparison of Typical Federal Facilities and Proposed New Minimum Standards

The typical federal facility at each security level lacks some of the elements needed to meet the new minimum security standards proposed in this study. For example:

* Of the 347 buildings in the survey identified as level IV, only 15% x-ray incoming packages and mail as recommended.

* Only 46% of Level IV buildings have parking controls that meet Level IV recommended standards.

* Only about 26% of the Level IV buildings have employee and visitor identification and control systems that meet the standards for that Level.

* Of the 353 Level III buildings, only about one fourth have visitor and employee identification control systems that meet the recommended standards.

* Of the Level II buildings identified in the survey, only 21% have identification and control systems that meet minimum standards for that Level.

4.1.2 Reasons for the Current Security Situation in Federal Facilities

There are a number of reasons for the current security levels at federal buildings.

First, GSA's security efforts, like those of most agencies, were directed at a different kind of threat -- the safety of federal workers and citizens from theft or assault -- than we now face.

Second, before this Study, prompted by the bombing of the Murrah Building, there were no government-wide standards for security at federal buildings, and no centralized data base of the security conditions at federal buildings against which any standards could be measured. The Public Building Service Information System (PBSIS) maintained by the GSA's Federal Protective Service (FPS) is not centralized and needs updating in light of the heightened risks of bombings and other acts of terrorism. Although the PBSIS contains considerable information on GSA-controlled facilities, the data focus primarily on building features and do not include sufficient information on physical security measures currently in place.

Third, to date, security -- particularly security addressed to a threat of terrorism or violence -- has not been an overriding factor in building design. Most buildings were not constructed with a concern for anything like current day threats. Moreover, tight security was seen as inconsistent with the accessibility associated with high service levels. The fact that buildings traditionally have been constructed with an emphasis on ease of access makes security measures difficult to implement.

Fourth, agencies with varying security needs are often co-located. To make effective and efficient security arrangements for a given building, there needs to be greater grouping of agencies with similar risk assessments, and better coordination of security services.

Fifth, FPS security services have been based on a periodic risk assessment process which needs to be reviewed in light of newly identified threats. Security services are provided by uniformed federal officers, contract security guards and electronic security systems. The number of uniformed officers has declined significantly over the last 10 years, increasing the reliance on contract guards and other measures. Pursuant to the risk assessment, a number of facilities have no or only minimal guard services, a situation that may present an unacceptable level of vulnerability in light of current conditions.

Sixth, the typical local organizational structure is insufficient to meet tenant security needs. At single-tenant facilities, the tenant usually takes responsibility to assure that security requirements are met. In multi-tenant buildings, however, there is no on-site organizational structure to interact with the tenants of a facility as a group and consider local and unique security requirements. Further, other than the current risk assessment process, there is no formal structure for the relationship between the tenants and FPS, or for resolving conflicts among the various tenants.

Seventh, security for facilities is sometimes fragmented. For example, in one location the USMS conducts screening for judicial tenants on four floors, while GSA is responsible for the remainder of the building. The needs and desires of the various agencies at a building may conflict with each other.

4.2 Recommendations

4.2.1 Where Feasible, Bring Each Federal Facility up to the Minimum Standards Recommended for its Security Level

As noted above, the typical federal facility at each security level lacks some of the elements needed to meet the new recommended standards at that level. We recommend that the security conditions of each federal facility be upgraded so that all elements meet the recommended standards. We recognize, however, that bringing some facilities up to those minimum standards in all areas may not be feasible, because of the nature of an existing lease, the unwillingness of a landlord to modify a lease, or a major structural problem. Each facility's security requirements and the feasibility of meeting those requirements must be addressed on a building-by-building basis.

4.2.2 Establish Building Security Committees

Specific security needs inevitably will vary from location to location, even among those at the same security level, due to local conditions and changing circumstances. Thus, security concerns must be addressed at each facility and there must be a formal mechanism for so doing.

* GSA should ensure that a Building Security Committee is formed at each facility under GSA control. The Committee should consist of representatives from all of the federal agencies occupying the building. GSA should designate a physical security specialist to assist each committee.

* The Committee should evaluate and apply the appropriate minimum standards developed for each type of federal facility. The Committee should determine which of the minimum requirements need to be implemented at its facility, which of the optional or additional standards applies to the facility, and the feasibility of implementation.

* Each Committee should forward to the GSA its requests and cost estimates for security enhancements to comply with the minimum standards.

* Each Committee should also be responsible for identifying other building-specific security issues, ensuring that appropriate security practices are followed, and training employees regarding the Occupant Emergency Plan (OEP), security awareness, and any special security practices.

4.2.3 Reemphasize GSA's Primary Responsibility for Implementing Federal Facility Security

GSA has historically had this role. Its continuing and enhanced responsibility should be emphasized by a Presidential directive to all Executive Branch agencies. In addition:

* GSA should review the security enhancement requests of each Building Security Committee, to ensure that, to the extent feasible, each building is brought up to the minimum standards recommended for its security level.

* GSA should determine what portion of the requests it approves should be amortized into rents charged to individual tenant agencies, and should work with the tenant agencies and the Office of Management and Budget (OMB) to identify funding for the cost of the security upgrades. Priority should be given to addressing the needs of Level IV facilities.

* In addition, there should be a review of the Risk Assessment Methodology currently in use by GSA. A group of security professionals from the various federal agencies should be formed to review and amend the current GSA assessment form. The security survey and the recommended standards used for this Study should be taken into consideration when revising the methodology.

* GSA should amend its master planning process to evaluate future leasing or construction projects to ensure that functionally similar agencies are housed in the same location. For example, where feasible, agencies requiring a high degree of public contact should not be housed in the same facility as law enforcement agencies.

4.2.4 Upgrade the Federal Protective Service

The Federal Protective Service has the experience and the historical charter to provide security services for much of the federal work force. However, it has limited resources to determine building security requirements to address terrorist threats, and does not have the resources to respond to these requirements, even if the requirements are properly articulated.

The placement of FPS within the organizational structure of GSA may have limited the ability of FPS to obtain the resources to assure appropriate security in large, multi-tenant facilities, even when the security needs have been well-defined. FPS must reestablish its role and take the lead in emphasizing the need for security. The following recommendations are for specific changes in the responsibilities and organizational placement of the Federal Protective Service.

* FPS should be responsible for providing security services for GSA-controlled federal facilities, through the use of both Federal Police Officers and contract security guards.

* FPS should improve the standards for contract guards by raising the hiring qualifications and providing enhanced training.

* FPS should be responsible for the implementation and maintenance of the centralized physical security data base of all federal office buildings. The data collected for this study should be helpful in creating a more comprehensive data base for federal office buildings.

* Consistent with its added responsibilities, consideration should be given to elevating FPS to a different level within GSA. Alternatively, a modified funding mechanism for FPS should be established to lessen its competition for real property resources.

4.2.5 Create an Interagency Security Committee

To provide a permanent body to address continuing government-wide security concerns, an Interagency Security Committee (ISC) should be created by Executive Order.

FPS should be authorized to chair and staff the ISC and be responsible for implementing and monitoring any ISC recommendations.

Membership should include permanent representation by the USMS, GSA and each cabinet-level agency currently in the President's Management Council (PMC).

An interagency working group, similar to the Standards Committee that worked on the building survey in this report, should be established to report regularly to the ISC and perform tasks as directed by the ISC.

The immediate, initial responsibility of the ISC should be to evaluate the suitability of the 52 security standards set out in Section 2.3 and Annex 2 of this study, for applicability to non-GSA space. Thereafter, the ISC should recommend a plan for priority implementation of appropriate minimum security standards in all non-GSA government facilities, along the lines recommended above for GSA space.

The ISC charter should empower it to oversee the implementation of the security standards recommended in this Study and approved by the PMC through:

* Establishing policies for building security including but not limited to those recommended in this Study.

* Developing a strategy for ensuring compliance with the approved standards.

* Overseeing the implementation of appropriate security measures in federal buildings.

The ISC should also:

* Encourage agencies with security responsibilities to share security-related intelligence in a timely and cooperative manner.

* Access technology and information systems as a means of providing cost-effective improvements to building security.

* Assist in the oversight of budgeting for physical security by assisting in yearly budget formulation to support GSA's and other agencies requests by prioritizing federal security needs.

* Develop long-term construction standards for those locations with threat levels or missions that require blast resistant structures.

* Evaluate standards for the location of, and special security related to, day care centers in federal facilities.

* Assist the GSA in developing and maintaining a centralized security data base.

4.2.6 Funding Recommendations

Consideration should be given to adjusting the rents charged to tenant agencies, and ensuring adequate funding to cover the added costs of upgrading security to the recommended standards. A sufficient portion of the rental revenue stream should be devoted to security.

Through this mechanism, the costs of improvements necessary for implementation of minimum security standards may be amortized partially into the rent.

4.2.7 Additional Recommendations

The following additional recommendations are based on the findings of this Study:

* GSA should modify the existing policy of allowing permanent contract staff to work in federally-controlled space prior to obtaining the appropriate background investigations.

* The USMS should be delegated the authority to determine the level of access at the perimeter of any federal facility housing a judicial officer. This includes, but is not limited to, the placing of screening posts at any authorized entrance regardless of the multi-tenant make-up of the building.

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ANNEX 1

M - MINIMUM STANDARD S - STANDARD BASED ON FACILITY EVALUATION D - DESIRABLE

N/A - NOT APPLICABLE

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ANNEX 2

Details of Recommended

Security Standards

A.1 Perimeter Security

A.2 Entry Security

A.3 Interior Security

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ANNEX 3

CLASSIFICATION TABLE

NOTE: *Assignment of levels to be based on an "on-site" risk assessment/evaluation

**Examples of Typical (but not limited to) Tenant Agencies for this Level Facility

Security Measures for any given Level include Measures for Prior Levels

For Budgetary Purposes, Building Occupancy was used to quantify GSA's existing inventory into Levels I-IV.

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444 DM 1

APPENDIX B

General Services Administration

Federal Protective Service Regional Offices

Central Office

General Services Administration

Office of Federal Protective Service - PS

1800 F Street, NW Room 2341

Washington, DC 20405

202-501-0907

National Capital Region - NCR

Washington, D.C.

GSA, Federal Protective Service Division - NCR

Building 74 E., Room 211

Southeast Federal Center

Third and M Streets, SE

Washington, DC 20407

202-690-9632

Region 1

Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island and Vermont

GSA, Federal Protective Service Division - 1PS

Thomas P. O'Neil Federal Building

10 Causeway Street, Room 108

Boston, MA 02222

617-565-5776

Region 2

New Jersey, New York, Puerto Rico and U.S. Virgin Islands

GSA, Federal Protective Service Division - 2PS

26 Federal Plaza, Room 17-130

New York, NY 10278

212-264-4255

Region 3

Delaware, Maryland, New Jersey, Pennsylvania, Virginia and West Virginia

GSA, Federal Protective Service Division - 3PS

Wanamaker Building

100 Penn Square, Room 7171

Philadelphia, PA 19107

215-656-6043

Region 4

Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina and Tennessee

GSA, Federal Protective Service Division - 4PS

Peachtree Summit Building

401 West Peachtree Street, NW, Suite 2339

Atlanta, GA 30365-2550

404-331-5132

Region 5

Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin

GSA, Federal Protective Service Division - 5PS

Kluczynski Federal Building

230 South Dearborn Street, Room 3540

Chicago, IL 60604

312-353-1496

Region 6

Iowa, Kansas, Missouri and Nebraska

GSA, Federal Protective Service Division - 6PS

1500 East Bannister Road, Room 2211

Kansas City, MO 64131

816-926-7025

Region 7

Arkansas, Louisiana, New Mexico, Oklahoma and Texas

GSA, Federal Protective Service Division - 7PS

819 Taylor Street, Room 12A01

Ft. Worth, TX 76102

817-978-3559

Region 8

Colorado, Montana, North Dakota, South Dakota, Utah and Wyoming

GSA, Federal Protective Service Division - 8PS

Denver Federal Center, Building 41, Room 258

West 6th Avenue & Kipling Street, Box 25546

Denver, CO 80225-0546

303-236-7931

Region 9

Arizona, California, Guam, Trust Territory of the Pacific, Hawaii and Nevada

GSA, Federal Protective Service Division - 9PS

450 Golden Gate Avenue, 7th Floor, Room 5205

San Francisco, CA 94102

415-522-3440

Region 10

Alaska, Idaho, Oregon and Washington

GSA, Federal Protective Service Division - 10PS

400 15th Street, SW

Auburn, WA 98001

253-931-7288

Federal Law Enforcement Training Center (FLETC)

Glynco, GA

GSA, Federal Protective Service

Federal Law Enforcement Training Center

305 Kiefer Circle

Glynco, GA 31524

912-267-2831

7/7/99 #3270

Replaces 2/15/94 #2995

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