- Written by Elise Allen
What do Hidden Valley Dressing, Kingsford Charcoal, Burts Bees and Glad Bags all have in common? They are all a part of the Clorox family. I know I thought of Clorox as just the chlorine folks, and was amazed at the products the company produces.
John started with talking about his former facility that was on W130th here is CLE. they had been using chlorine gas to make their product but moved to using high strength bleach (12-25%) as their feed stock. The reasons were many (transportation issues, safety) but also to move away from a DHS regulated chemical. We learned some new “TLA’s” (three letter acronyms) as well as great details on how to put security plans together.
John said doing your homework and making sure you have a clear direction on the project scope is a great foundation. A diverse team is also needed with finance, legal, IT, cyber security included on the team. He had a CHSE (chemical, health, safety and environmental) point person to ensure all of the ENV government regulations were met. Some of the alphabet soup of regulations needed are EPA, OSHA, FDA, FSMA, DHS, SPCC etc.
John used this process to set up a Corporate standard and then to aid other facilities in the development and audit of their plans. He traveled to many of the other plants assisted them in the process.
1. Do your homework on the scope and direction
a. Build a diverse team of participants and review support
2. Site Visits
3. Write a standard and gain the approval of upper management. This needs to be a good tool for each plant to use. One stop shopping for security questions. (Should’s and shall’s in the language).
4. Key items in the security standard –
a. Purpose statement
b. Compliance responsibility – make sure to run compliance responsibilities by your legal department.
i. WORK PLACE ANALYSIS. Invite first responders in and know their response time. Let workers know what is expected of them.
c. Site security Plan
i. Vulnerability Assessment
ii. Physical security
iii. Access Control and Personnel Identification Plan
iv. Alarm, Camera and Monitoring System (as applicable)
v. Security Guards (as applicable)
vi. Bomb Threat and Suspicious Package Protocol
vii. Investigative Services (Workplace Violence and other Threats)
viii. Other Investigative Services
ix. Vendor, Contractor and Supplier Contracts
x. Searches (Vehicles, and personal search)
xi. Site Security Grid (as applicable)
xii. Local Emergency Response and Planning (Police, DHS, LEPC)
xiii. Security Threat Response
xiv. Administrative Policy and Procedures
xv. Employee Security Awareness Training
xvi. Hazardous Materials Transportation and Onsite Storage (as applicable)
xvii. Cyber Security (network, etc)
xviii. Security Systems Audits (as applicable)
xix. Federal Regulation Requirements
1. List of regulatory requirements for DOT, FDA, FSMA, DHS etc.
xx. Security System Impairment
xxi. Variance Procedure (Management of change)
xxii. Roles and Responsibilities
John had examples of badges that were designed for regular workers, contractors, visitors, temporary staff etc. Clear and well marked that the designation could be seen from a distance. He also showed an example of a warning notice for suspect letters and packages. Posted in a mail room or other areas where mail and packages were delivered.
We have some photographs of his slides outlining the thought process. My takeaway was that this process of planning would work for most of the multi-disciplined plans we are involved in. All of the details and thought process would also be beneficial to any plan that needs to be put together or revised. This was very well thought out and detailed.