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    Is there any policy, DoD Manual or regulatory guidance that would prevent DoD/Army Contractor being issued Keys to a Government Building? Is a Contractor allowed to be in a Government Building without Government present? Can a Contractor secure a Government Building at the end of the day without Government Present? I've heard yes to the above as long is its in the PWS, however is the above in writhing in any Government regulatory?


    Answer

    Originally Posted - 9/4/2014 2:43:00 PM
     
    Subject Area - Other - Security
     
     Answer:
     
     Each DoD component has its own specific physical security guidelines.  It is important to check with your Command security manager since local organizations often have their own additional security requirements beyond DoD and service level regulations.  Generally speaking, contractors who are under contract to the organization can complete the required SF 701 "end of day" checks, provided the (unclassified) contract under which they perform has  specific security requirements included as part of the performance work statement.  This eliminates any doubt as to responsibility as well as providing the government and the contractor additional surety.  The overarching DoD policy can be found at DoD 5200.08-R Security of DoD Installations and Resources; Service and Component Guidance will generally amplify this guidance. 
     
     
    Here is an excerpt under Industrial Security from the AF's Guide for the Government-Contractor Relationship (it's old but it was on the DPC website and available through a google search.
     
    "4.6 Requiring contract personnel to perform end-of-day security checks may place the contractor in a position of liability for property or information over which it has no control.  Therefore, security checks should be the responsibility of government employees who are authorized to control the physical premises.  As a general rule, it is preferable to have only government employees perform end-of-day security checks; however, situations may arise when contractor personnel may end up accomplishing this activity.  Contractor personnel may not be delegated the responsibility for end-of-day security checks unless their contract specifically provides for such delegation.  Before placing an end-of-day security check requirement in the contract, the multi-functional team should address issues that may arise in the following situations:
     
      (a)  One contractor performs the end-of-day security check for another contractor.
     
      (b)  A contractor potentially has access to classified, sensitive
      unclassified or company proprietary information while performing an end-of- day security check.
     
      (c)  Contractor personnel are placed in a position of liability for property over which
      they may have no accountability or control."
     
     CRS link at https://fas.org/sgp/crs/homesec/R43570.pdf.  It's a report the Congressional Research Service did on Federal Building and Facility Security: Frequently Asked Questions which might be helpful to the student as well.  Essentially, although I can't find anything in writing that prohibits turning over the keys of a fed building to a contractor, and private contractors provide a lot of security for federal buildings, I don't necessarily believe it's in the government's best interest to turn over the keys to the building.  Can they be present without a gov't presence, yes.  However, the facility should ensure that all classified, sensitive unclassified or proprietary information is routinely secured and therefore not subject to inadvertent disclosure by the contractors.
     


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