Warehouse Security Plans for CCC Storage Agreement Compliance

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Published: October 28, 2004

Updated: March 26, 2009

Why Warehouse Operators Need To Know About Facility Security Plans

Homeland Security is an issue on everyone's agenda and agriculture is in the forefront when it comes to providing safe, secure food, feed and fiber production and storage. The Bioterrorism Act of 2002 directly concerned all food and feed and the FDA regulations that were issued in 2003 cover gins and cottonseed oil mills (see NCC Fact Sheet regarding the Bioterrorism Act of 2002 at www.cotton.org/tech/safety/ncc-bioterrorism-memo.cfm).

Presidential Directives and USDA expectations make it clear that cotton warehousemen must have functioning security plans. Cotton warehouses are affected by the same safety, homeland security and bioterrorism issues other sectors in our nation face. The National Cotton Council developed this fact sheet for our warehouse members to inform them about the steps they need to consider when attempting to comply with Presidential Directives and USDA reporting requirements, as well as identify useful security plan resources.


HOMELAND SECURITY Presidential Directives HSPD-7 (Dec. 17, 2003) and HSPD-9 (Jan. 30, 2004) caused the USDA Commodity Credit Corporation (CCC) to amend Cotton Storage Agreements regarding Security Plans. On April 14, 2004, the CCC notified cotton warehousemen with Cotton Storage Agreements (CSA) of an amendment [CGC-823 (Amendment 1)] to their CSA regarding Security Plans.

Presidential Directive HSPD-7 (GENERAL)

Subject: Critical Infrastructure Identification, Prioritization and Protection
Purpose: Establishes a national policy for Federal departments and agencies to identify and prioritize U.S. critical infrastructure and key resources and to protect them from terrorism.

HSPD-7 KEY COMPONENTS

  • Cooperation between Federal and State governments and private sectors to identify, prioritize and coordinate protection of critical infrastructure.
  • Prevent, deter and mitigate effects of deliberate attempts to destroy, incapacitate or exploit our nation’s infrastructure.

Presidential Directive HSPD-9 (AGRICULTURE)

Subject: Defense of U.S. Agriculture and Food
Purpose: Establishes a national policy to defend the agriculture and food system against terrorism attacks, major disasters and other emergencies.

HSPD-9 KEY COMPONENTS

  • Awareness and Warning
  • Vulnerability
  • Mitigation Strategies
  • Response Planning and Recovery
  • Outreach and Professional Development
  • Research and Development

USDA-CCC Expectations

  • Warehouse operators were informed that written security plans would be required when their Cotton Storage Agreements were renewed (See Part III, R below).
  • Security plans must identify and protect (key components of their operation) against vulnerabilities. 
  • Security plans should address physical plants as well as computer databases and other records.
  • Indications are that the agency will be flexible when defining what constitutes security plans for cotton warehouses. There is no sense that uniform security plans will be required across or within commodity sectors. Instead security plans should be tailored to fit the warehousing operation based on the commodity the warehouseman is storing.
  • Complex security plans are not expected. Rather the agency is promoting simplicity when it comes to compliance.
  • Form CCC-823 (Amendment 1):

Part III, R. Security Plan –WAREHOUSE OPERATOR’S RESPONSIBILITY
The warehouse operator must:

  1. Have a security plan that includes measures to protect cotton handled and stored under this Agreement.
  2. Conduct a facility vulnerability assessment and establish procedures that address:
    1. General security of the physical structures and grounds of the warehouse,
    2. Shipping and receiving procedures to ensure that cotton is not subject to tampering,
    3. Action to be taken in the event of a national emergency and
    4. Contact information for local security authorities.

Where Can Warehouse Operators Go For Help?

  1. The first place to look is the USDA Homeland Security web page, or Keep America’s Food and Agriculture Safe
  2. Next, contact your insurance carrier. They may already have a Security Plan on file that will fit your needs.
  3. The Internet provides other sites that have useful Homeland Security links, such as:

    Extension Disaster Education Network (EDEN)
    http://www.agctr.lsu.edu/eden

    International Association of Emergency Managers
    www.iaem.com

    National Fire Protection Association (NFPA). NFPA 1600, Standard on Disaster/Emergency Management and Community Programs (2004 edition).
    www.nfpa.org/Research/FireInvestigation/Homeland/homeland.asp
  4. The NFPA Journal Vol. 98 No. 5, September/October 2004 states the following regarding the 9/11 Commission Report and NFPA 1600:

    “Based on the existing NFPA 1600, the proposed National Preparedness Standard establishes a common set of criteria and terminology for preparedness, disaster management, emergency management, and business continuity programs. The National Commission on Terrorist Attacks upon the United States, also known as the 9/11 Commission states that "The experience of the private sector in the World Trade Center emergency demonstrated the need for these standards."
  5. Contact the National Cotton Council: Dale Thompson (901-274-9030) or Phillip Wakelyn (202-745-7805).

Some Suggested Security Practices

  • Awareness/Security Assessment
    • Conduct a security assessment of your facility. Have a designated person in charge of security.
  • Access
    • Have all visitors sign in. Escort all visitors.
    • Establish a system to distinguish employees from visitors.
  • Signage
    • Post signs in highly visible locations for “no trespassing;" “private property;" “all visitors must check-in with front office and must be escorted."
  • Alarms
    • Use a security alarm monitoring system.
  • Barriers
    • Install fencing and access gates where appropriate.
    • Have restricted access to driveways, etc.
    • Assure an open area around facility so the facility is open to view by law enforcement and passers-by.
  • Lighting
    • Have sufficient exterior lighting for law enforcement and passers-by to see the property.
  • Locks
    • Establish a procedure and responsibility for locking up if facility is closed or unattended.
  • Records and Files
    • Keep backup copies of electronic and paper documents off site in a secure location.
    • Secure phone lines and other electronic communication devices in locations within your facility; it is equally important that computer "fire walls" and other barriers are in place.
    • Keep fire walls and virus protection software current; during peak usage, make sure virus protection software is updated regularly or when a new release is available.
    • Secure computer system access with passwords that are changed routinely (e.g., monthly).
    • Never leave a computer unattended with work displayed on the screen.
    • Always sign-off/logout of the system when not using the computer.
    • Position computer monitors for privacy.
    • Use passwords to protect directories and documents.
    • Ensure computers (servers, desktops, laptops, handheld devices) are physically secured (easily stolen).
    • Do not display facility diagrams or private company information such as details about company operations, facility layout or products on the company’s web site.
    • Have in place a procedure for discarding of unused computer equipment (servers, desktops, laptops, handheld devices) as well as diskettes and CDs to ensure sensitive company information is secure.
  • Inventory Control
    • Know your inventory; have ongoing process for control of materials stored at the facility.
    • Use trained watch service or warehouse staff to visually inspect inventory each day; more frequent inspections may be prudent during peak receiving period.
    • Do not allow unattended trailers on site.
    • Inspect any fuel and chemical storage each day.
  • Law Enforcement
    • Establish and maintain relationships with local law enforcement, fire department and other emergency responders. Provide them with current emergency contact information for the facility and keep this information current.
    • Immediately report unusual or suspicious persons, vehicles or activity to law enforcement.
  • Training
    • Involve employees in security planning; train employees to spot suspicious individuals and behavior; conduct emergency drills with employees for fire, evacuation and security.
  • Vendors
    • Know vendors that service your facility; require them to check in; escort vendors.

DISCLAIMER:

This document is for informational purposes only. It is intended to provide guidelines that warehouse operators should consider when developing a security plan. It does not purport to be the correct or the only way to implement a cotton warehouse security plan. Each warehouse operation is unique in many respects and its own operating procedures. Therefore, before finalizing security plans, warehouse operators are urged to seek the advice of counsel or other experienced professionals.

Citations or references to web sites and organizations in this fact sheet shall not to be construed as endorsements of these policies or programs by the National Cotton Council.