Friday, February 15, 2019

New Rule Requires Anti-Terrorism Training for Some Contractors

The proposed DFARS (DoD FAR Supplement) rule requiring mandatory anti-terrorism training for Government contractors and subcontractors that we wrote about last September (see Mandatory Antiterrorism Training for Government Contractors), has been finalized.

This new rule applies to contractors and subcontractors who require routine physical access to a Federally-controlled facility or military installation. Routine access is considered more than intermittent access, such as when a contractor employee is required to obtain a CAC card (common access card).

Training must be completed with 30 days from whenever a contractor is awarded a contract with the requisite clause (DFARS 252.204-7004, Antiterrorism Awareness Training for Contractors) 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 1 anti-terrorism awareness instructor. Its our guess that most contractors will go the on-line learning route for its convenience. And anyway, where would one go to find a 'qualified' Level 1 instructor?

Contractors are required to flow-down this training requirement to its subcontractors where the subcontractor personnel requires routine access to a military installation (which by definition includes almost any defense-related facility).

Level 1 training is the most basic of training regimens. Level 1 antiterrorism training includes:

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

Check your contract to see if it includes the DFARS 252.204-7004 antiterrorism clause. If it does, your contracting officer should be able to provide resources to meet the training requirements.

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