The Water Sector developed the Key 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.
The Key Features
- Assess risks and review vulnerability assessments
- Incorporate resiliency concepts into physical infrastructure
- Prepare, test and update emergency response, recovery and business continuity plans
- Form partnerships with peers and interdependent sectors
- Develop and implement internal and external communication strategies
- Monitor incidents and threat level information
The Features originated as an outcome of a National Drinking Water Advisory Council Water Security Working Group in 2005 and have been updated to reflect the goals and objectives of the Sector-Specific Plan for Water first published in May of 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 Key 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.
Water utilities can differ in many ways including:
- Source of water (ground or surface)
- Number of sources
- Treatment capacity
- Operational risk
- Locational risk
- Protective program budget
- Spending priorities
- Political and public support
- Legal barriers
- Public vs. private ownership
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 Key Features are:
- Sufficiently flexible to apply to all utilities, regardless of size.
- Consistent with the management philosophy of continuous improvement.
The Key Features
1. Integrate protective concepts into organizational culture, leadership, and daily operations
The objective of this feature is to make protection a normal part of day-to-day operations. Utilities should 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. Protection must be established as a priority for the organization and supported by senior leadership. Employees at every level must be attentive to protection and encouraged to report potential issues. This feature also encourages utilities to be well informed of advances in water security and threat information. Utilities should stay informed of improvements in protective practices, utilizing the experience of other utilities that have implemented such practices.
2. Identify and support protective program priorities, resources, and utility-specific measures
Dedicated resources are important to ensure a sustained focus on protective programs. In some circumstances, investment may be as simple as increasing the amount of time and attention that executives and managers give to protective programs. More resources should be invested where threat potential or potential consequences are greater. Utilities should identify specific protective program needs and set aside resources accordingly, through their annual capital, operations and maintenance, and staff resources plans. 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 to self-assess, measure progress, and adjust their protective programs based on performance data. Metrics should measure progress in physical upgrades, as well as personnel and process changes. Utilities are encouraged to develop utility-specific metrics relevant to their unique protective programs. As a starting point, utilities can consider metrics that were developed at the national level.
3. Employ protocols for detection of contamination
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, to identify potential contamination. 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 includes 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.
4. Assess risks and review vulnerability assessments
Utilities should assess potential risks and periodically review and update their vulnerability assessments to reflect changes in potential threats, vulnerabilities and consequences. Protective program enhancement and maintenance priorities should also be adjusted in accordance with changes to the vulnerability assessment. Utilities should consider their individual circumstances and establish and implement a schedule for reviewing their vulnerabilities.
5. Establish facility and information access controls
Utilities should 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-lit 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 Supervisory Control and Data Acquisition (SCADA) and information technology (IT) networks include installing and maintaining fire walls, and screening networks for viruses. Examples of procedural steps include restricting remote access to data networks and safeguarding critical data through backups and storage in safe places.
6. Incorporate resiliency concepts into physical infrastructure
Utilities should incorporate protective program considerations into procurement, repair, maintenance and replacement of physical infrastructure. Consideration of protective issues should begin as early as possible in facility construction, and be factored into 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 how that design would affect the efficiency of day-to-day plant operations and worker safety.
7. Prepare, test and update emergency response, recovery and business continuity plans
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, and of regional and local incident management commands and systems. Adoption of NIMS is required to qualify for protective program funds dispersed through EPA, the Federal Emergency Management Agency (FEMA) and the Department of Homeland Security (DHS).
Utility emergency response and recovery plans should be reviewed annually and updated as needed. Utility plans should be thoroughly coordinated with emergency response and recovery planning in the larger community. Utilities should also test or exercise their emergency response and recovery plans regularly.
8. Develop partnerships with first responders, managers of critical infrastructure, other utilities and response organizations
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. Mutual aid programs should also include neighboring response organizations and interdependent sectors, such as the power sector, on which utilities rely or impact. Mutual aid agreements provide assistance 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 for coordination, to ensure a regular exchange of information, and to outline roles and responsibilities during response to, and recovery from, an emergency. Coordination is important at all levels of the public health community - from national public health and county health agencies, to hospitals, and other local health care providers.
9. Develop and implement internal and external communication strategies
Utilities should develop and implement strategies for regular, ongoing communication about protective programs with employees, customers and the general public. The goal of this communication is to increase overall awareness and preparedness for response to an incident. Effective communication considers key messages; who is best equipped/trusted to deliver the messages; the need for message consistency, particularly during an emergency; and the best mechanisms for delivering messages and receiving information and feedback from key partners. Key audiences to consider are utility employees, response organizations, and customers.
10. Monitor incidents and threat-level information
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 the FBI is critical.
Utilities should investigate what networks and information sources might be available to them locally and at the state and regional levels (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.
Benefits of Implementing The Key Features
There are many benefits of implementing the Key Features into daily operations, including:
- Increased protection of public health
- Ability to more quickly detect, respond to, and recover from any adverse event
- Increased access to resources during an emergency through mutual aid and assistance
- Better coordination between all levels of government and emergency responders
- Improved public confidence in drinking water and wastewater systems
- Better understanding of the interdependencies between the water sector and other critical infrastructure sectors
- Enhanced water security capabilities and infrastructure protection