Storing classified material and alarm systems

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1. The general safeguarding duty

The National Industrial Security Program Operating Manual (NISPOM), 32 CFR part 117, makes contractors responsible for safeguarding classified information in their custody or under their control (32 CFR 117.15(a)). Storage requires approval from the cognizant security agency (CSA). Individuals are responsible for the classified information entrusted to them. Contractors provide protection sufficient to reasonably protect it from loss or compromise.

Contractors ensure all cleared personnel know the prohibition on discussing classified information over unsecured telephones, in public conveyances or places, or in any other way that permits interception by unauthorized persons (32 CFR 117.15(a)(1)).

2. End of day checks

Contractors that store classified material set up a system of security checks at the close of each working day (32 CFR 117.15(a)(2)(i)). The checks verify that all classified material and security repositories are appropriately secured. With multiple shifts, the check takes place at the end of the last shift in which classified material was removed from storage for use (32 CFR 117.15(a)(2)(ii)). No checks are required during continuous 24-hour operations.

3. Perimeter controls and emergencies

Contractors authorized to store classified material maintain a system to deter and detect its unauthorized introduction into or removal from the facility (32 CFR 117.15(a)(3)(i)). Technical means such as an intrusion detection system are encouraged, and if they can reasonably prevent unauthorized introduction or removal, no further controls are needed (32 CFR 117.15(a)(3)(ii)). Personnel with a legitimate need to remove or transport classified material receive authorization to pass through designated entry or exit points.

Contractors post notices at pertinent entries and exits that people entering or leaving are subject to inspection, except where access to classified material is remote (32 CFR 117.15(a)(3)(iii)). Inspections are limited to buildings or areas where classified work is performed. Their extent, frequency and location fit contractual obligations and operational efficiency, and random sampling may be used. Contractors seek legal advice when drafting the procedures and report significant problems to the CSA.

Contractors develop simple, practical procedures for safeguarding classified material in emergencies, adaptable to any emergency that may reasonably arise (32 CFR 117.15(a)(3)(iv)). They promptly report to the CSA any emergency that leaves them unable to safeguard classified material.

4. Equipment and storage standards

Contractors follow 32 CFR part 2001 when procuring storage and destruction equipment (32 CFR 117.15(b)). Repairs to General Services Administration (GSA)-approved security containers and vaults follow Federal Standard 809. Classified material is stored in GSA-approved security containers, vaults built to Federal Standard 832, or open storage areas built under 32 CFR 2001.53 (32 CFR 117.15(c)).

Where an open storage area has a false ceiling or raised floor, contractors develop procedures to ensure its structural integrity. Nothing in part 2001 should be read to contradict local laws or building codes, but the contractor notifies the CSA of any conflicting issues that would inhibit compliance. Storage for CONFIDENTIAL, SECRET and TOP SECRET material follows the specific paragraphs of 32 CFR 2001.43.

5. Intrusion detection systems

The rule sets minimum standards for an intrusion detection system (IDS) used as supplemental protection for TOP SECRET and SECRET material (32 CFR 117.15(d)). CSA approval is needed before installation (32 CFR 117.15(d)(1)(i)). Approval rests on Intelligence Community Directive 705 and related standards, Underwriters Laboratories Standard 2050, or written CSA standards. Installation is by an alarm services company certified by a nationally recognized testing laboratory (NRTL), and the equipment must be NRTL-tested or CSA-approved (32 CFR 117.15(d)(1)(ii) and 32 CFR 117.15(d)(1)(iii)).

Monitoring may come from a government contractor monitoring station, a cleared commercial central station, a cleared protective signal service station, a cleared residential monitoring station or a national industrial monitoring station (32 CFR 117.15(d)(2)(i)). SECRET-cleared station employees attend in sufficient number, and a U.S. citizen eligible for SECRET supervises continuously (32 CFR 117.15(d)(2)(ii) and 32 CFR 117.15(d)(2)(iii)). The IDS is activated at close of business whenever cleared personnel are not present (32 CFR 117.15(d)(2)(iv)). Alarm records are kept for 12 months (32 CFR 117.15(d)(2)(v)).

6. Responding to alarms

If an alarm resets in a reasonable time and no damage is visible, an uncleared initial response team may respond without entering (32 CFR 117.15(d)(3)(i)). If it does not reset and damage is seen, a cleared team must be dispatched. The uncleared team stays until relieved, and if the cleared team does not arrive within 1 hour, a report goes to the CSA by close of the next business day.

Uncleared guards from a commercial, signaling or residential station stay until a cleared facility representative arrives, or for at least 1 hour, whichever comes first (32 CFR 117.15(d)(3)(ii)). Subcontracted guards must be under a classified contract with the alarm company or the cleared facility. Where traffic or distance legitimately prevent meeting the TOP SECRET response time, the CSA may authorize up to 30 minutes (32 CFR 117.15(d)(3)(iii)). Response must meet the limits 80 percent of the time.

Line security is part of the service when the system connects to a commercial central station, a government contractor monitoring station, a national industrial monitoring station or a residential monitoring station. It means the connecting lines are electronically supervised for tampering or malfunction (32 CFR 117.15(d)(4)). Protection covers all points of probable entry with magnetic contacts, and motion detectors along the probable intruder paths. CSA authorization is needed where line security is unavailable and two independent transmission means are used instead. It is also needed where protection relies on patrolling employees, where police are the primary responders with written assurance on response time, where signals travel over data networks, or where response time exceeds the limits.

No IDS sensors are installed on GSA-approved security containers (32 CFR 117.15(d)(4)). Evidence of compliance is a current NRTL certificate issued through the alarm company (32 CFR 117.15(d)(5)). If the standard requirements cannot be met, the contractor may ask the CSA to approve a police-monitored or police-response system in defined cases (32 CFR 117.15(d)(6)). Handling and transmission rules are covered in controlling and transmitting classified information.

Key terms

End of day check	The daily verification that classified material is secured.
Perimeter controls	Measures to deter and detect removal of classified material.
Open storage area	An area built to 32 CFR 2001.53 for open storage.
IDS	An intrusion detection system for supplemental protection.
NRTL	A nationally recognized testing laboratory that certifies alarm work.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Secure storage is a core part of any facility that holds sensitive material. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.