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Features of an Active and Effective Protective ProgramThe water sector has developed the Features of an Active and Effective Protective Program to assist owners and operators of drinking water and wastewater utilities (water sector) in preventing, detecting, responding to, and recovering from adverse effects of all hazards, including terrorist attacks and natural disasters.
BackgroundThe Features originated as an outcome of a National Drinking Water Advisory Council Water Security Work Group in 2005 and have been updated to reflect the goals and objectives of the Sector Specific Plan for Water published in May 2007. The features use the terms "protective program," "protection," and "protective" to describe activities that enhance resiliency and promote continuity of service, regardless of the exact type of hazard or adverse effect a utility might experience. The 10 features describe the basic elements of a "protective program" for owners/operators of utilities to consider as they develop utility-specific approaches. They address the physical, cyber, and human elements of prevention, detection, response, and recovery. The 10 features:
Water utilities can differ in many ways including:
The goal in identifying common features of active and effective protective programs is to achieve consistency in protective program outcomes among water utilities, while allowing for, and encouraging, utilities to develop utility-specific protective program approaches and tactics. The features are based on an integrated approach that incorporates a combination of public involvement and awareness, partnerships; and physical, chemical, operational, and design controls to increase overall program performance. The FeaturesFeature 1. Encourage awareness and integration of a comprehensive protective posture into daily business operations to foster a protective culture throughout the organization and ensure continuity of utility services.The objective of Feature 1 is to make protection a normal part of day-to-day operations. Utility-specific efforts that help incorporate protection concepts into organizational culture might include:
Feature 1 Resources
Feature 2. Annually identify protective program priorities and resources needed; support priorities with utility-specific measures and self-assess using these measures to understand and document program progress.Dedicated resources are important to ensure a sustained focus on protective programs. Investment should be reasonable and consider utilities' specific circumstances. In some circumstances, investment may be as simple as increasing the amount of time and attention that executives and managers give to protective programs. Where threat potential or potential consequences are greater, increased financial investment is likely warranted. This feature establishes the expectation that utilities should, through their annual capital, operations and maintenance, and staff resources plans; identify and set aside resources consistent with their specific identified protective program needs. Priorities should be clearly documented and should be reviewed with utility executives at least once per year as part of the budgeting process. This feature also encourages utilities to use metrics [link to metrics page] to self-assess and measure progress and to adjust their protective program based on performance data. Metrics should measures progress in physical upgrades, as well as personnel and process changes. Utilities are encouraged to develop utility-specific metrics relevant to their specific protective programs. As a starting point, utilities can consider metrics that were developed at the national level, provided later in this brochure as examples. Utility specific efforts might include:
Feature 2 Resources
Feature 3. Employ protocols for detection of contamination while recognizing limitations in current contaminant detection, monitoring, and public health surveillance methods.Until progress can be made in development of practical and affordable online contaminant monitoring and surveillance systems, most utilities must use more traditional approaches, such as monitoring chlorine residual. Water quality monitoring, sampling and analysis, enhanced security monitoring, consumer complaint surveillance, and public health syndromic surveillance are different, but related, elements of an overall contamination warning system. Water quality monitoring include monitoring data of physical and chemical contamination surrogates, pressure change abnormalities, free and total chlorine residual, temperature, dissolved oxygen, and conductivity. Many utilities already measure these parameters on a regular basis to control plant operations and confirm water quality. More closely monitoring these parameters may also create operational benefits for utilities that extend far beyond protective programs, such as reducing operating costs and chemical usage. Utilities also should thoughtfully monitor customer complaints and improve connections with local public health networks to detect public health anomalies ("public health syndromic surveillance"). Customer complaints and public health anomalies are important ways to detect potential contamination problems and other water quality concerns. Utility specific efforts might include:
Feature 3 Resources
Feature 4. Assess risks and periodically review (and update) vulnerability assessments to reflect changes in potential threats, vulnerabilities, and consequences.Utilities should maintain their understanding and assessment of vulnerabilities as a "living document," and continually adjust their protective program enhancement and maintenance priorities. Utilities should consider their individual circumstances and establish and implement a schedule for review of their vulnerabilities. Utility specific efforts might include:
Feature 4 Resources
Feature 5. Establish physical and procedural controls to restrict access only to authorized individuals and to detect unauthorized physical and cyber intrusions.Physical access controls include fencing critical areas, locking gates and doors, and installing barriers at site access points. Monitoring for physical intrusion can include maintaining well-lighted facility perimeters, installing motion detectors, and utilizing intrusion alarms. Neighborhood watches, regular employee rounds, and arrangements with local police and fire departments can support identifying unusual activity in the vicinity of facilities. Procedural access controls include inventorying keys, changing access codes regularly, and requiring security passes to access gates and sensitive areas. In addition, utilities should establish the means to readily identify all employees, including contractors and temporary workers, with unescorted access to facilities. Protecting cyber systems involves using physical hardening and procedural steps to limit the number of individuals with authorized access and prevent access by unauthorized individuals. Examples of physical steps to harden SCADA and IT networks include installing and maintaining fire walls, and screening the network for viruses. Examples of procedural steps include restricting remote access to data networks and safeguarding critical data through backups and storage in safe places. Utility specific efforts might include:
Feature 5 Resources
Feature 6. Incorporate protective program considerations into procurement, repair, maintenance, and replacement of physical infrastructure decisions.Prevention is a key aspect of enhancing protective programs. Consideration of protective issues should begin as early as possible in facility construction (i.e., it should be a factor in facility plans and designs). However, to incorporate protective considerations into design choices, utilities need information about the types of protective design approaches and equipment that are available and the performance of these designs and equipment. For example, utilities should evaluate not just the way a particular design might contribute to protection, but also would look at how that design would affect the efficiency of day-to-day plant operations and worker safety. Numerous resources are available to provide information for designers and owners/operators of water utilities on design approaches and upgrades that improve protection and reduce vulnerability. Utility specific efforts might include:
Feature 6 Resources
Feature 7. Prepare emergency response, recovery, and business continuity plan(s); test and review plan(s) regularly, update plan(s) as necessary to ensure NIMS compliance; and to reflect changes in potential threats, vulnerabilities, consequences, physical infrastructure, utility operations, critical interdependencies, and response protocols in partner organizations.Utilities should maintain response and recovery plans as "living documents." In incorporating protective program considerations into their emergency response and recovery plans, utilities also should be aware of the National Incident Management System (NIMS) guidelines, established by the Federal Emergency Management Agency (FEMA) within the Department of Homeland Security (DHS)/, and of regional and local incident management commands and systems, which tend to flow from the national guidelines. Adoption of NIMS is required to qualify for protective program funds dispersed through EPA, FEMA and DHS. Utilities should consider their individual circumstances and implement a schedule for review of emergency response and recovery plans. Utility plans should be thoroughly coordinated with emergency response and recovery planning in the larger community. The emergency response and recovery plans should be reviewed annually and updated as needed. Utilities should test or exercise their emergency response and recovery plans regularly. Utility specific efforts might include:
Feature 7 Resources
Feature 8. Forge reliable and collaborative partnerships with first responders, managers of critical interdependent infrastructure, other utilities, and response organizations to maintain a resilient infrastructure.Effective partnerships build collaborative working relationships and clearly define roles and responsibilities, so that people can work together seamlessly if an emergency should occur. It is important for utilities within a region, and within neighboring regions, to collaborate and establish a mutual aid program with one another and with neighboring response organizations; as well as with interdependent sectors, such as the power sector, on which utilities rely or which they impact. Mutual aid agreements provide for help from other organizations that is prearranged and can be accessed quickly and efficiently in the event of an emergency. Developing reliable and collaborative partnerships involves reaching out to managers and key staff in other organizations to build reciprocal understanding and to share information about the utility's concerns and planning. Such efforts will maximize the efficiency and effectiveness of a mutual aid program during an emergency response effort, as the organizations will be familiar with each others' circumstances, and therefore will be better able to serve each other. Utilities and public health organizations should also establish formal agreements on coordination to ensure the regular exchange of information between utilities and public health organizations; and outline roles and responsibilities during response to, and recovery from, an emergency. Coordination is important at all levels of the public health community--national public health, county health agencies, and health-care providers, such as hospitals. Utility specific efforts might include:
Feature 8 Resources
Feature 9. Develop and implement strategies for regular, ongoing communication about protective programs with employees, customers, and the general public to increase overall awareness and preparedness for response to an incident.Effective communication considers key messages; who is best equipped/trusted to deliver the key messages; the need for message consistency, particularly during an emergency; and the best mechanisms for delivering messages and for receiving information and feedback from key partners. The key audiences to consider are utility employees, response organizations, and customers. Utility specific efforts might include:
Feature 9 Resources
Feature 10. Monitor incidents and available threat-level information; escalate procedures in response to relevant threats and incidents.Monitoring threat information should be a regular part of a protective program manager's job; and utility-, facility- and region-specific threat levels and information should be shared with those responsible for protective programs. As part of their planning efforts, utilities should develop systems to assess threat information and procedures that will be followed in the event of increased threat levels. Utilities should be prepared to put these procedures in place immediately, so that adjustments are seamless. Involving local law enforcement and FBI is critical. Utilities should investigate what networks and information sources might be available to them locally, and at the state and regional level (e.g. fusion centers). If a utility cannot gain access to some information networks, attempts should be made to align with those who can and will provide effective information to the utility on a timely basis. Utility specific efforts might include:
Feature 10 Resources
Example Self-Assessment MeasuresThe Features establish the expectation that utilities should self-assess to measure progress and adjust their protective program based on performance data. The water sector has developed measures of utility activities that roughly correspond with the activities described in the Features. These measures are provided as examples for utilities to consider as a starting point as they develop their own self-assessment measures.
More information on the full suite of measures developed for utilities. |
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