Wednesday, September 5, 2018

Mandatory Antiterrorism Training for Government Contractors

The Defense Department just published a proposed rule that, if adopted and most certainly will be adopted, will require its contractors to conduct anti-terrorism training to personnel that require routine physical access to a Federally-controlled facility or military installation.

Routine physical access is considered more than intermittent access, such as when a contractor employee is required to obtain a CAC card (a common access card).

Once implemented, training will need to have been completed withing 30 days and annually thereafter. Training must be completed either through DoD-sponsored and certified computer or web-based distance learning instruction, or under the instruction of a qualified Level I anti-terrorism awareness instructor.

This requirement will apply to all types of contracts, cost-type, fixed price, commercial, simplified, etc. The criteria is not the type of contract but whether contractor employees will require routine physical access to military bases or other Federally-controlled facilities.

DoD does not believe the cost will be significant. The training materials will be developed and disseminated by DoD so contractors will not need to create their own training materials. Training duration at two hours per employee per year however are not specifically reimbursed by DoD. Under a cost-type contract, contractor employees will undoubtedly charge the contract. That doesn't work for other types of contracts. It would probably be prudent to include a provision for anti-terrorism training when putting together price proposals however.

You can get more information on Level 1 Antiterrorism Awareness Training at this website. Training topics include:

  • surveillance detection fundamentals
  • Government facility security fundamentals
  • insider threat
  • active shooter fundamentals
  • residential security
  • air travel 
  • ground travel
  • hotel security
  • hostage survival

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