Pipeline Security Guidelines

Pipeline Security Guidelines
April 2011

Transportation
Security
Administration

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Table of Contents
1 Introduction ............................................................................................................................... 1
1.1
1.2

Purpose ........................................................................................................................... 1
Scope .............................................................................................................................. 1

2 Corporate Security Program .................................................................................................... 3
3 Corporate Security Plan ........................................................................................................... 5
3.1
3.2

Introduction .................................................................................................................... 5
Security Plan Elements .................................................................................................. 5

4 Risk Analysis .............................................................................................................................. 7
4.1
4.2
4.3

Introduction .................................................................................................................... 7
Criticality Assessment ................................................................................................... 7
Security Vulnerability Assessment ................................................................................ 8

5 Criticality ................................................................................................................................... 9
5.1
5.2

Introduction .................................................................................................................... 9
Facility Criticality .......................................................................................................... 9

6 Facility Security Measures ..................................................................................................... 11
6.1
6.2
6.3

Introduction .................................................................................................................. 11
Baseline and Enhanced Security Measures .................................................................. 11
Site-Specific Security Measures .................................................................................. 11

7 Cyber Asset Security Measures.............................................................................................. 16
7.1
7.2
7.3
7.4

Introduction .................................................................................................................. 16
Critical Cyber Assets Identification ............................................................................. 16
Security Measures for Cyber Assets ............................................................................ 16
Cyber Security Planning and Implementation Guidance ............................................. 19

8 National Terrorism Advisory System (NTAS) Threat Level Protective Measures ........... 20
Appendix A – Recurring Actions ............................................................................................... 21
Appendix B – TSA Notification Criteria ................................................................................... 22
Appendix C – Acronyms ............................................................................................................. 23
Appendix D – Reference Documents ......................................................................................... 24

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TSA Pipeline Security Guidelines
Introduction

1

INTRODUCTION

Under the provisions of the Aviation and Transportation Security Act (Public Law 107-71), the
Transportation Security Administration (TSA) was established on November 19, 2001 with
responsibility for civil aviation security and “security responsibilities over other modes of
transportation that are exercised by the Department of Transportation.” To fulfill this mandate in
the pipeline mode, on September 8, 2002, TSA formed the Pipeline Security Division within what
is now the Office of Transportation Sector Network Management (TSNM).

1.1

Purpose

In executing its responsibility for national pipeline security, TSNM Pipeline has utilized the
Pipeline Security Information Circular, issued on September 5, 2002, by the Department of
Transportation’s (DOT) Office of Pipeline Safety as the primary Federal guideline for industry
security. Complementing this document, and also adopted by TSA, was the DOT-issued Pipeline
Security Contingency Planning Guidance of June 2002.
Recognizing that the Security Circular required updating, TSA initiated a process to amend the
Federal security guidance. After TSA commenced the document revision effort, Congress enacted
the Implementing Recommendations of the 9/11 Commission Act of 2007, P. L. 110-53 (9/11
Act). Sections 1557 and 1558 of the 9/11 Act directed TSA to review adherence to the 2002
guidance and to undertake other initiatives.
The revised Pipeline Security Guidelines were developed with the assistance of industry and
government members of the Pipeline Sector and Government Coordinating Councils, industry
association representatives, and other interested parties. This document supersedes the Pipeline
Security Information Circular and the Contingency Planning Guidance.
The 2002 Circular incorporated by reference the consensus guidance contained in petroleum and
natural gas industry association security publications. Building upon these documents, TSA’s
intention is not to make significant substantive changes to this guidance but to provide explicit
agency recommendations for pipeline industry security practices. Based on its Corporate Security
Reviews and other information, TSA believes that pipeline operators already employ most of these
recommendations in their security plans and programs.
NOTE: Nothing in this document shall supersede Federal regulatory requirements. This
document is guidance. It does not impose mandatory requirements on any person. The
term “should” means that TSA recommends the actions described.

1.2

Scope

These guidelines are applicable to natural gas and hazardous liquid transmission pipelines, natural
gas distribution pipelines, and to liquefied natural gas facility operators. Additionally, they apply
to pipeline systems that transport materials categorized as toxic inhalation hazards (TIH). TIH
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TSA Pipeline Security Guidelines
Introduction
materials are gases or liquids that are known or presumed on the basis of tests to be so toxic to
humans as to pose a health hazard in the event of a release during transportation. (See the
Hazardous Materials Regulations: 49 CFR parts 171-180.)
Operators of pipeline systems not included in the descriptions above are encouraged to implement
the security measures contained herein to the extent appropriate to their particular system.

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TSA Pipeline Security Guidelines
Corporate Security Program

2

CORPORATE SECURITY PROGRAM

A risk-based corporate security program should be established and implemented by each pipeline
operator to address and document the organization’s policies and procedures for managing
security related threats, incidents, and responses. In addition, each operator should:


Ensure sufficient resources, to include trained staff and equipment, are provided to
effectively execute the corporate security program;



Assign a qualified primary and alternate staff member to manage the corporate security
program;



Provide TSA with the 24/7 contact information of the primary and alternate security
manager, and the telephone number of the company’s security operations or control
center;



Develop a corporate security plan as described in Section 3;



Develop and maintain a cyber/Supervisory Control And Data Acquisition (SCADA)
security plan, or incorporate cyber/SCADA security measures in the corporate security
plan;



Develop and maintain security elements within the corporate incident response and
recovery plan;



Implement appropriate threat level protective measures upon receipt of an applicable
National Terrorism Advisory System (NTAS) alert; and



Notify TSA of all security incidents by phone or e-mail as soon as possible. (Notification
criteria and contact information are provided in Appendix B.)

Figure 1 identifies the major steps that each pipeline operator should take in creating and
implementing a corporate security program and the relevant sections in the guidelines where
specific details are provided.

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TSA Pipeline Security Guidelines
Corporate Security Program

Corporate Security Program Overview
Pipeline operators should develop a corporate security plan
for their organization.
(Section 3)
Pipeline operators should conduct a criticality assessment
for all facilities.
(Section 4.2)

Critical Facility?
Yes
No

Pipeline operators should adopt
baseline security measures at all
facilities.
(Sections 6 and 7)

Pipeline operators should conduct a
SVA for each critical facility.
(Section 4.3)

Pipeline operators should adopt
baseline and enhanced security
measures at each critical facility.
(Sections 6 and 7)

When appropriate, pipeline operators should implement NTAS
threat level protective measures.
(Section 8)

Figure 1: Corporate Security Program Overview

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TSA Pipeline Security Guidelines
Corporate Security Plan

3

CORPORATE SECURITY PLAN

3.1

Introduction

Operators should develop and implement a security plan customized to the needs of the
company. The corporate security plan should be comprehensive in scope; systematic in its
development, and risk based reflecting the security environment. At a minimum, the plan should:


Identify the primary and alternate security manager or officer responsible for executing
and maintaining the plan;



Document the company’s security-related policies and procedures, to include, but not
limited to, methodologies used and timelines established for conducting criticality
assessments and security vulnerability assessments (SVAs), if applicable;



Reference other company plans such as the business continuity plans, incident response
and recovery plans;



Be reviewed on an annual basis, and updated as required based on findings from
assessments, significant modifications to the system or any of its facilities, substantial
changes to the environment in which it operates, or other significant changes;



Be protected from unauthorized access based on company policy, and;



Be available for review and copying by TSA upon request.

3.2

Security Plan Elements

This section identifies and provides a brief description of the recommended elements of a
corporate security plan. In developing their plan, operators should incorporate these elements in
a format that is most suitable to their organization.


System(s) Description - Identify the pipeline system(s) to which the plan applies.



Security Administration and Management Structure - Identify the person(s) primarily
responsible for the corporate security program, and describe the responsibilities and
duties of personnel assigned to security functions.



Risk Analysis and Assessments - Describe the methodology used to conduct security risk
analysis to include criticality assessments and SVAs.



Physical Security and Access Control Measures - Describe the corporate policies and
procedures employed to reduce security risks throughout the company.



Equipment Maintenance and Testing - Discuss policies and procedures for ensuring
security systems and equipment are maintained and function properly. Information
contained in this section may address performance of equipment preventive maintenance
as well as inspection and testing of security systems.
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TSA Pipeline Security Guidelines
Corporate Security Plan


Personnel Screening - Describe policies and procedures for conducting employee
background checks, including criteria for disqualification and process for appeal, in
compliance with Federal and state laws. Describe company policies for contractor
personnel background checks.



Communications - Describe the policies and procedures employed to ensure effective
communication is maintained on both a routine and emergency basis. The description
should include, but not be limited to, types of equipment used, communication methods
between employees, facilities, and offsite responders, and procedures for notification of
government and law enforcement agencies.



Personnel Training - Describe security training, to include training in security equipment
operation, and security awareness training requirements for company personnel,
including routine contractors and part-time employees.



Drills and Exercises - Describe company policies and procedures for conducting security
drills and exercises. Establish requirements for after-action reports, communication of
lessons learned, and implementation of security improvement efforts based on exercise
results.



Security Incident Procedures - Describe procedures for responding to security incidents
and emergencies. Define the types of events that constitute a breach of security, describe
the procedures for investigating security incidents, and who should be notified. In
addition, the emergency response plan may be referenced in this section.



NTAS Response Procedures - Describe the operator’s protective measures for periods of
heightened threat corresponding to the Department of Homeland Security (DHS) NTAS
elevated and imminent alert levels.



Plan Reviews - Describe policies and procedures for the review, validation, and updating
of the corporate security plan.



Recordkeeping - Describe security-related recordkeeping requirements, such as for
criticality assessments and SVAs, as well as measures to prevent unauthorized disclosure.



Cyber/SCADA System Security Measures - Describe the corporate policies and
procedures employed to reduce security risks to cyber/SCADA systems and assets
throughout the company. If a separate cyber/SCADA security plan is maintained, it
should be incorporated by reference.



Essential Security Contact Listings - List internal and external emergency contact
information for reporting and responding to a security incident or suspicious activity.



Security Testing and Audits - Describe policies and procedures for self-inspection,
auditing, and testing of the effectiveness of the company's security plan and procedures,
to include documentation of results.

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Risk Analysis

4

RISK ANALYSIS

4.1

Introduction

The intent of these guidelines is to bring a risk-based approach to the application of the security
measures throughout the pipeline industry. As stated in the National Infrastructure Protection
Plan, DHS assesses risk as a function of threats, vulnerabilities, and consequences. With this in
mind, the most effective security programs employ a risk management process that facilitates
proactive planning and decision making to mitigate risks for pipeline assets. General steps
include:


Criticality assessments (determine facility criticality);



Threat assessments (identify known or potential adversaries);



Vulnerability assessments (identify security weaknesses);



Risk assessments (based on threat, vulnerability, and criticality assessment findings);



Risk mitigation (determine and implement appropriate risk reduction countermeasures);
and



Ongoing risk management (monitor, reassess, and modify the program).

Recognizing that there are multiple risk assessment methodologies, each operator should
determine the process and methodology most appropriate for implementation of their corporate
security plan and the facilities comprising their pipeline system. The operator’s risk assessment
methodology is subject to review by TSA.

4.2

Criticality Assessment

Determining facility criticality is an essential first step in the security risk management process.
Information and findings gathered in the criticality assessment assist operators with prioritizing
assets and implementing risk reduction countermeasures. Operators should evaluate each
operating facility within their system using the criteria outlined in Section 5.2 to determine or
validate criticality. Operators should:


Conduct facility criticality assessments on a periodic basis, not to exceed 18 months, for
all facilities;



Document the methodology used, and retain the criticality assessment until no longer
valid;



Conduct an SVA or the equivalent as outlined in Section 4.3 of this document for
facilities determined to be critical; and



Maintain and secure the company’s list of critical facilities.

The operator’s list of critical facilities is subject to review and evaluation by TSA. Operators and
TSA will work together towards concurrence on the facilities listed.
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Risk Analysis

4.3

Security Vulnerability Assessment

A security vulnerability assessment is one of the risk assessment methodologies pipeline
operators may choose. The SVA serves as a planning and decision support tool to assist security
managers with identifying, evaluating, and prioritizing risks; and determining effective security
measures to mitigate threats and vulnerabilities to their critical facilities. Common steps
performed while conducting an SVA include:


Asset Characterization - identification of hazards and consequences of concern for the
facility, its surroundings, and its supporting infrastructure; and identification of existing
layers of protection;



Threats Assessment - description of possible internal and external threats;



Security Vulnerability Analysis - identification of potential security vulnerabilities and
existing countermeasures and their level of effectiveness in reducing identified
vulnerabilities;



Risk Assessment - determination of the relative degree of risk to the facility in terms of
the expected effect on each asset and the likelihood of a success of an attack; and



Countermeasures Analysis - strategies that reduce the probability of a successful attack or
reduce the possible degree of success, strategies that enhance the degree of risk reduction,
the capabilities and effectiveness of mitigation options, and the feasibility of the options.

Pipeline operators of critical facilities should:


Conduct an SVA or the equivalent on a periodic basis, not to exceed 36 months, and
within 12 months after completion of a significant enhancement or modification to the
facility;



Document findings from each assessment and retain until no longer valid;



Implement appropriate findings from the SVA in a timely fashion but no later than 18
months after SVA completion; and



Document the methodology used and make the documentation available for TSA review
upon request.

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Criticality

5

CRITICALITY

5.1

Introduction

The objective in determining which pipeline facilities are critical is to ensure that reasonable and
appropriate security risk reduction measures are implemented to protect the most vital assets
throughout the pipeline industry.

5.2

Facility Criticality

Given the diverse operational and market settings within which the pipeline industry exists,
applying a definition of critical to the nation’s pipeline infrastructure presents a significant
challenge.
To the maximum extent possible, the approach these guidelines take regarding the determination
of pipeline facility criticality is to acknowledge that no entity is more familiar with and able to
judge the importance of industry assets than the operator of the facility. However it is necessary
for operators to determine the criticality of their facilities using consistent criteria.
Pipeline facilities meeting one or more of the criteria below are considered to be critical:
A facility or combination of facilities that, if damaged or destroyed, would have the potential to:


Disrupt or significantly reduce required service or deliverability to installations identified
as critical to national defense;



Disrupt or significantly reduce required service or deliverability to key infrastructure
(such as power plants or major airports) resulting in major economic disruption;



Cause mass casualties or significant health effects;



Disrupt or significantly reduce required service or deliverability resulting in a state or
local government’s inability to provide essential public services and emergency response
for an extended period of time;



Significantly damage or destroy national landmarks or monuments;



Disrupt or significantly reduce the intended usage of major rivers, lakes, or waterways.
(for example, public drinking water for large populations or disruption of major
commerce or public transportation routes);



Disrupt or significantly reduce required service or deliverability to a significant number
of customers or individuals for an extended period of time;



Significantly disrupt pipeline system operations for an extended period of time, i.e.,
business critical facilities.

Figure 2 is provided to illustrate the facility criticality determination pathway.
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TSA Pipeline Security Guidelines
Criticality

Criticality Determination Pathway
Does damage or destruction of a facility or combination of
facilities have the potential to:

Disrupt or significantly reduce required service or deliverability to
installations identified as critical to national defense?

Yes

No

Disrupt or significantly reduce required service or deliverability to key
infrastructure (such as power plants or major airports) resulting in
major economic disruption?

Yes

No

Cause mass casualties or significant health effects?

Yes

No

Disrupt or significantly reduce required service or deliverability
resulting in a state or local government's inability to provide essential
public services and emergency response for an extended period of
time?

Yes

Critical
Facility

No

Significantly damage or destroy national landmarks or monuments?

Yes

No

Disrupt or significantly reduce the intended usage of major rivers,
lakes, or waterways (for example, public drinking water for large
populations or disruption of major commerce or public transportation
routes)?

Yes

No

Disrupt or significantly reduce required service or deliverability to a
significant number of customers or individuals for an extended period
of time?

Yes

No

Significantly disrupt pipeline system operations for an extended
period of time, i.e., business critical facilities?

Yes

No

Non-Critical Facility

Figure 2: Facility Criticality Determination
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Facility Security Measures

6

FACILITY SECURITY MEASURES

6.1

Introduction

Upon completion of the risk analysis process, operators should determine the appropriate
mitigation measures for their assets. Section 6.2 provides recommended measures for both
critical and non-critical facilities. Recurring program actions are summarized in Appendix A.

6.2

Baseline and Enhanced Security Measures

Pipeline operators should implement baseline security measures at all of their facilities.
Operators should implement both baseline and enhanced security measures at each of their
critical facilities.
Table 1 identifies the baseline and enhanced security measures for operators to implement at
appropriate pipeline facilities.

6.3

Site-Specific Security Measures

Operators should develop, document, and implement site-specific security measures for each of
their critical facilities. These measures should be tailored explicitly for each individual facility,
with emphasis on specific procedures and actions to be taken at the elevated and imminent
NTAS threat levels. On a periodic basis, not to exceed 18 months, these facility specific
measures should be reviewed and updated as necessary.

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TSA Pipeline Security Guidelines
Facility Security Measures
Table 1: Baseline and Enhanced Security Measures

BASELINE SECURITY
MEASURES

ENHANCED SECURITY
MEASURES
Barriers

Maintain fences, if used, without gaps
around gates or underneath the fence
line. Ensure that there is a clear zone for
several feet on either side of the fence,
free of obstructions, vegetation, or objects
that could be used to scale the fence.
Employ measures to deter unauthorized
vehicles and persons from penetrating
facility perimeters.

Create a security perimeter that deters
unauthorized vehicles and persons from
entering the facility perimeter or critical areas
by installing and maintaining barriers (for
example, fences, bollards, jersey barriers, or
equivalent.)

Physical Security and Access Controls

Access Controls
Employ measures to deter unauthorized
persons from gaining access to a facility
and restricted areas within a facility.

Implement procedures (such as manual
and electronic sign in/out) for controlling
access to the facility and restricted
buildings or areas within the facility (for
example, visitors, contractors, or
employees.)

Close and secure doors, gates, or
entrances when not in use.

Monitor and escort visitors at critical
facilities.

Post “No Trespassing” or “Authorized
Personnel Only” signs at intervals that are
visible from any point of potential entry.

Gates
Install and maintain gates of an
equivalent quality to the barrier to which
they are attached.

Locks and Key Control
Establish and document key control
procedures for key tracking, issuance,
collection, and loss.
Use patent keys to prevent unauthorized
duplication.
Conduct key inventories every 24 months.

Facility Lighting
Provide sufficient illumination for human or
technological recognition of intrusion.

Intrusion Detection & Monitoring
Equip critical facilities or critical areas within
a facility with 24/7 monitoring capability to
detect and assess unauthorized access.

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Facility Security Measures

BASELINE SECURITY
MEASURES

ENHANCED SECURITY
MEASURES

Personnel Identification and Badging
Develop identification and badging
policies and procedures for employees
and on-site personnel who have access
to secure areas or sensitive information.
These policies should address:

Ensure that company or vendor
identification is visibly displayed by
employees and contractors while on-site.

 Lost or stolen identification cards or
badges;
 Termination; and
 Temporary badges.

Personnel Security

Ensure employee and contractor
identification cards or badges are secure
from tampering and contain the
individual’s photograph and name.

Background Investigation
Establish policies and procedures for
applicant pre-employment screening
and behavioral criteria for
disqualification of applicants and
employees.

Conduct pre-employment background
investigations of applicants for positions
that are:
 Authorized regular unescorted access
to control systems or sensitive areas;
 Authorized access to sensitive
information;
 Assigned security roles;
 Assigned to work at or granted access
rights to critical facilities.
At a minimum, investigations should:
 Verify and validate identity;
 Check criminal history*; and
 Verify and validate legal authorization
to work.
* NOTE: Operators should consider using
the Federally-established list of
disqualifying crimes applicable to
transportation workers at ports (see 49
CFR 1572.103) to assess the suitability of
their employees and contractors for these
positions.
Verify that contractors have background
investigation policies and procedures at
least as rigorous as the pipeline
operator’s.

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Facility Security Measures

BASELINE SECURITY
MEASURES

ENHANCED SECURITY
MEASURES
Conduct recurring background
investigations on a regular basis, not to
exceed 10 years, for employees
occupying security positions or who have
access to sensitive information or areas.

and Testing

Design &
Construction

Equipment Maintenance

Equipment Maintenance and Testing
Develop and implement a maintenance
program to ensure security systems are
in good working order.

Verify the proper operation and/or
condition of all security equipment on a
quarterly basis.

Identify and respond to security
equipment malfunctions or failures in a
timely manner.

Conduct an annual inventory of security
equipment.
Provide alternate power sources
(for example, generators or battery backup) or equivalent equipment to minimize
interruption of security equipment
operation.

Design and Construction
Integrate security measures during the
design, construction, or renovation of a
facility.

Update the facility SVA within 12 months
following significant modifications.

Personnel Training

Communication

Communication
Develop internal and external notification
requirements and procedures for security
events.

Ensure primary and alternate
communication capabilities exist for internal
and external reporting of all appropriate
security events and information.

Document and periodically update contact
(who) and communication (how)
information for Federal, state, and local
homeland security/law enforcement
agencies. (See Appendix B for TSA
contact information.)

Establish a defined process for receiving,
handling, disseminating, and storing
security and threat information.

Personnel Training
Provide security awareness briefings for
all employees and contractors with
unescorted access upon hire and every
2 years thereafter.

Provide security training, to include
incident response training, to all full-time,
part-time, and contract employees
assigned security duties upon hire and
annually thereafter.

Document and maintain records for all
security training in accordance with
company record retention policy.

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Facility Security Measures

BASELINE SECURITY
MEASURES

ENHANCED SECURITY
MEASURES

Security Incident
Procedures

Exercises & Drills

Exercises and Drills
Conduct periodic security drills or
exercises, to include unannounced tests
of security and incident plans. These can
be conducted in conjunction with other
required drills or exercises.

Conduct or participate in an annual security
drill or exercise.

Develop and implement a written postexercise report assessing security
exercises and documenting corrective
actions.

Security Incident Procedures
Implement procedures for responding to
security incidents or emergencies and to
National Terrorism Advisory System
(NTAS) threat alerts. These procedures
should include the appropriate reporting
requirements.

Recordkeeping

Recordkeeping
Develop and document recordkeeping
policies and procedures for security
information. Protection of Sensitive
Security Information (SSI) in accordance
with the provisions of 49 CFR part 1520
should be specifically addressed.
At a minimum, the following documents,
as appropriate, should be retained until
superseded or replaced:
 Corporate Security Plan;
 Criticality assessment(s);
 Training records;
 Exercise reports;
 Incident response plan(s);
 Security testing and audits;
 Security equipment maintenance
and testing records.
Make security information records
available to TSA upon request.

In addition to the documents specified for
non-critical facilities, the following
documents, applicable to critical facilities,
should be retained until superseded or
replaced:
 SVA(s);
 Site-specific measures.
Make security information records available
to TSA upon request.

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Cyber Asset Security Measures

7

CYBER ASSET SECURITY MEASURES

7.1

Introduction

The control systems used by operators to manage their infrastructure and products are vital to the
pipeline’s safe and efficient operation. The growing convergence of information technology (IT)
and control systems brings with it increased capabilities, but also increased exposure to cyber
attacks against infrastructure. Developing and implementing appropriate security measures
reduces the risk to control systems. In the case of legacy components with few or no security
features, compensatory controls should be applied as part of an overall defense-in-depth
approach.
In this section, the term “system” refers to interconnected hardware and software components,
comprising computers, databases, applications, and control and monitoring devices that together
perform a particular function or interrelated set of functions. The term “control systems” refers to
Supervisory Control and Data Acquisition (SCADA) systems, Process Control Systems (PCS),
and Distributed Control Systems (DCS).
To implement an effective cyber security strategy, pipeline operators should take advantage of
industry and government efforts to develop methodologies, industry standards, and best practices
for securing control systems. A list of planning and implementation guidance is provided in
Section 7.4.

7.2

Critical Cyber Assets Identification

Operators should evaluate cyber assets and classify them using the following criteria:


Pipeline control system cyber assets that are essential to safety and/or reliability
objectives are classified as critical cyber assets. Baseline and enhanced security
measures should be applied to these assets.



Pipeline control system cyber assets that are not essential to safety and/or reliability
objectives are classified as non-critical cyber assets for the purposes of this guideline.
Baseline security measures should be applied to these assets.

7.3

Security Measures for Cyber Assets

Table 2 shows the baseline and enhanced cyber security measures that pipeline operators should
apply to cyber assets based on their criticality designation.

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Cyber Asset Security Measures
Table 2: Baseline and Enhanced Cyber Security Measures

System Lifecycle

Information Security
Coordination and
Responsibilities

General Cyber
Security Measures

BASELINE CYBER SECURITY MEASURES
The baseline measures should be applied to all pipeline control system
cyber assets.
Provide physical security and access controls to cyber assets.
Monitor and periodically review, not to exceed 18 months, network connections,
including remote and third party connections.
Evaluate and assess the role of wireless networking for risk before implementation.
Review and reassess all cyber security procedures annually. Update as necessary.
Review and reassess cyber asset criticality periodically, not to exceed 18 months.
Develop a cross-functional cyber security team and an operational framework to
ensure coordination, communication, and accountability for information security on
and between the control systems and enterprise networks.
Define information and cyber security roles, responsibilities, and lines of
communication among the operations, IT, and business groups, as well as with
outsourcers, partners, and third-party contractors.
Establish and document standards for cyber security controls for use in evaluating
systems and services for acquisition. Encourage vendors to follow software
development standards for trustworthy software throughout the development
lifecycle.
Incorporate security into cyber system design and operation, whether designing a
new system or modifying an existing system. Secure design and operation of the
SCADA control system architecture is critical for the creation of a sustainable and
reliable system. Mitigate any security deficiencies found in control system hardware
and software.
Establish and document policies and procedures for assessing and maintaining
system status and configuration information, for tracking changes made to the control
systems network, and for patching and upgrading operating systems and
applications.

System
Restoration &
Recovery

Establish and document policies and procedures for the secure disposal of
equipment and associated media.
Plan and prepare for the restoration and recovery of control systems in a timely
fashion as specified in the operator’s recovery procedures.

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Cyber Asset Security Measures

Access Control and
Functional Segregation

Training

Intrusion
Detection &
Response

BASELINE CYBER SECURITY MEASURES
The baseline measures should be applied to all pipeline control system
cyber assets.
Establish policies and procedures for cyber intrusion monitoring, detection, incident
handling, and reporting.

Provide training in information security awareness for all users of control systems
before permitting access to the control systems and on an annual basis or as
necessitated by changes in the control system. Individuals with significant control
systems security roles should have training specific to their roles.
Segregate and protect the control systems network from the business network and
the Internet through the use of firewalls and other protections. This applies both to
wired and wireless networks.
Use control systems hosts and workstations only for approved control system
activities.
Establish and enforce access control policies for local and remote users, guests, and
customers. Procedures and controls should be in place for approving and enforcing
policy for remote and third-party connections to control networks.

Vulnerability
Assessment

Access Control

ENHANCED CYBER SECURITY MEASURES
In addition to baseline measures, operators should apply enhanced measures to all
cyber assets that have been designated critical.
Restrict physical and logical access to control systems and control networks through
the use of an appropriate combination of locked facilities, passwords,
communications gateways, access control lists, authenticators, and separation of
duties, invocation of least privilege, and/or other mechanisms and practices.
Conduct a risk assessment to weigh the benefits of implementing wireless networking
against the potential risks for exploitation. Evaluate the need for enhanced
networking control technologies for wireless networks prior to implementation.
Conduct periodic vulnerability assessments of the control system security, including
testing as appropriate in a non-production environment, not to exceed 36 months.

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TSA Pipeline Security Guidelines
Cyber Asset Security Measures

7.4

Cyber Security Planning and Implementation Guidance

The following is a list of planning and implementation guidance developed by industry and
government entities:


American Chemistry Council, Guidance for Addressing Cyber Security in the Chemical
Industry



American Gas Association (AGA) Report Number 12, Cryptographic Protection of
SCADA Communications, Part 1: Background, Policies and Test Plan



American National Standards Institute (ANSI)/International Society of Automation (ISA)
– 99.00.01 – 2007, Security for Industrial Automation and Control Systems:
Terminology, Concepts, and Models



ANSI/ISA – 99.02.01 – 2009, Security for Industrial Automation and Control Systems:
Establishing an Industrial Automation and Control System Security Program



American Petroleum Institute (API) Standard 1164 Pipeline SCADA Security



U.S. Department of Commerce, National Institute of Standards and Technology (NIST),
Special Publication 800-82, Guide to Industrial Control Systems (ICS) Security



U.S. Department of Homeland Security, National Cyber Security Division, Catalog of
Control Systems Security: Recommendations for Standards Developers

Because of ongoing technological changes, operators should consult these and other cyber
security references on a frequent basis in developing and reviewing their company’s security
measures.

19

TSA Pipeline Security Guidelines
National Terrorism Advisory System (NTAS) Threat Level Protective Measures

8

NATIONAL TERRORISM ADVISORY SYSTEM (NTAS)
THREAT LEVEL PROTECTIVE MEASURES

The Department of Homeland Security’s National Terrorism Advisory System (NTAS), effective
April 2011, provides a framework to disseminate information regarding the threat of terrorist acts
to the nation.
TSA has developed a supplement to this document containing recommended security measures
to reduce vulnerabilities to pipeline systems and facilities during periods of heightened threat and
to establish a consistent security posture within the pipeline industry. This supplement is
unclassified but sensitive and is marked as Sensitive Security Information (SSI). The passwordprotected document may be obtained by email request to [email protected].

20

TSA Pipeline Security Guidelines
Appendix A – Recurring Actions

APPENDIX A – RECURRING ACTIONS
RECURRING ACTIONS

Enhanced

Baseline

12 Months

18 Months

Perform an annual
review of the
corporate security
plan and update as
required. (Security
Plan, p.5)

Conduct / update
facility criticality
assessments on a
periodic basis, not
to exceed 18
months. (Criticality
Assessments, p.7)

Review and assess
all cyber security
procedures
annually. (Baseline
Cyber Security
Measures, p.17)

Review network
connections
periodically, not to
exceed 18 months.
(Baseline Cyber
Security Measures,
p.17)

Conduct annual
information security
and control system
security training for
appropriate
personnel.
(Training, p.18)

Review cyber asset
criticality
periodically, not to
exceed 18 months.
(Baseline Cyber
Security Measures,
p.17)

Conduct a SVA
within 12 months of
significant
modification to a
critical facility.
(Security
Vulnerability
Assessment, p.8)

Implement
appropriate findings
NLT 18 months
after SVA
completion.
(Security
Vulnerability
Assessment, p.8)

Conduct annual
security equipment
inventories.
(Equipment
Maintenance and
Testing, p.14)

Review site-specific
security measures
periodically, not to
exceed 18 months.
(Facility Security
Measures, p. 11)

Provide annual
security training to
all security
employees.
( Personnel
Training, p.14)

24 Months

36 Months

Provide security
awareness briefings
for all employees
and contractors
every two years.
(Personnel
Training, p.14)

Other
Periodically update
contact and
communications
information for
government
agencies.
(Communications,
p.14)
Conduct security
drills and exercises
on a periodic basis.
(Exercises and
Drills, p.15)

Periodically review
facility staffing
requirements at
elevated and
imminent threat
levels. (NTAS
Supplement, p.1)
Conduct key
inventories every 24
months. (Locks and
Key Control, p.12)

Conduct periodic
SVAs, not to
exceed 36 months.
(Security
Vulnerability
Assessment, p.8)

Conduct recurring
background
investigations, not
to exceed 10 years,
for employees in
sensitive positions.
(Background
Investigation, p.14)

Conduct control
system vulnerability
assessments, not to
exceed 36 months.
(Vulnerability
Assessment, p.18)

Verify the proper
operation and/or
condition of all
security equipment
on a quarterly
basis. (Equipment
Maintenance and
Testing, p.14)

Conduct or
participate in an
annual security drill
or exercise.
(Exercises and
Drills, p.15)
Note: 1. Baseline measures apply to all pipeline operators. Enhanced measures apply to operators’ critical facilities.
2. All baseline and enhanced security measures are detailed in Section 6 of this document.

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TSA Pipeline Security Guidelines
Appendix B - TSA Notification Criteria

APPENDIX B - TSA NOTIFICATION CRITERIA
As the lead Federal agency for pipeline security, TSA desires to be notified of all incidents
which are indicative of a deliberate attempt to disrupt pipeline operations or activities that could
be precursors to such an attempt. Pipeline operators should notify the Transportation Security
Operation Center (TSOC) via phone at 866-615-5150 or email at [email protected] as soon as
possible if any of the following incidents occurs or if there is other reason to believe that a
terrorist incident may be planned or may have occurred:


Explosions or fires of a suspicious nature affecting pipeline systems, facilities, or assets



Actual or suspected attacks on pipeline systems, facilities, or assets



Bomb threats or weapons of mass destruction (WMD) threats to pipeline systems,
facilities, or assets



Theft of pipeline company vehicles, uniforms, or employee credentials



Suspicious persons or vehicles around pipeline systems, facilities, assets, or right-of-way



Suspicious photography or possible surveillance of pipeline systems, facilities, or assets



Suspicious phone calls from people asking about pipeline system, facility, or asset
operations, vulnerabilities, or security practices



Suspicious individuals applying for security-sensitive positions in the pipeline company



Theft or loss of sensitive security information (detailed pipeline maps, security plans,
etc.)



Actual or suspected cyber attacks that could impact pipeline SCADA or enterprise
associated IT systems

When contacting the TSOC, provide as much of the following information as possible:


Name and contact information



The time and location of the incident, as specifically as possible



A description of the incident or activity involved



Who has been notified and what actions have been taken



The names and/or descriptions of persons involved or suspicious parties and license
plates as appropriate

For questions or concerns, email TSA Pipeline Security Division at [email protected]

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APPENDIX C – LIST OF ACRONYMS
AGA
ANSI
APGA
API
CFR
DCS
DHS
DOT
FEMA
HSEEP
HSIN
ICS
INGAA
ISA
IT
NIST
NPRA
NTAS
PCS
SCADA
SSI
SVA
TIH
TSA
TSNM
TSOC
WMD

American Gas Association
American National Standards Institute
American Public Gas Association
American Petroleum Institute
Code of Federal Regulations
Distributed Control System
U.S. Department of Homeland Security
U.S. Department of Transportation
Federal Emergency Management Agency
Homeland Security Exercise and Evaluation Program
Homeland Security Information Network
Industrial Control System
Interstate Natural Gas Association of America
International Society of Automation
Information Technology
National Institute of Standards and Technology
National Petrochemical and Refiners Association
National Terrorism Advisory System
Process Control System
Supervisory Control and Data Acquisition
Sensitive Security Information
Security Vulnerability Assessment
Toxic Inhalation Hazard
Transportation Security Administration
Transportation Sector Network Management
Transportation Security Operations Center
Weapons of Mass Destruction

23

APPENDIX D – REFERENCE DOCUMENTS
Operators should consult the current edition of these and other security references on a frequent
basis in developing and reviewing their company’s security program.
American Chemistry Council, Guidance for Addressing Cyber Security in the Chemical Industry
American Gas Association (AGA), Interstate Natural Gas Association of America (INGAA) &
American Public Gas Association (APGA), Security Guidelines: Natural Gas Industry,
Transmission and Distribution
AGA Report Number 12, Cryptographic Protection of SCADA Communications, Part 1:
Background, Policies and Test Plan
American National Standards Institute (ANSI)/International Society of Automation (ISA) – 99.00.01
– 2007, Security for Industrial Automation and Control Systems: Terminology, Concepts, and
Models
ANSI/ISA – 99.02.01 – 2009, Security for Industrial Automation and Control Systems: Establishing
an Industrial Automation and Control System Security Program
American Petroleum Institute (API) & National Petrochemical & Refiners Association (NPRA),
Security Vulnerability Assessment Methodology for the Petroleum and Petrochemical Industries
API Standard 1164, Pipeline SCADA Security
API, Security Guidelines for the Petroleum Industry
Homeland Security Presidential Directive 7: Critical Infrastructure Identification, Prioritization,
and Protection.
Presidential Policy Directive 7: National Terrorism Advisory System (NTAS)
U.S. Department of Commerce, National Institute of Standards and Technology (NIST), Special
Publication 800-82, Guide to Industrial Control Systems (ICS) Security
U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA),
Homeland Security Exercise and Evaluation Program (HSEEP) Vols. 1 - 4
U.S. Department of Homeland Security, National Infrastructure Protection Plan
U.S. Department of Homeland Security, National Cyber Security Division, Catalog of Control
Systems Security: Recommendations for Standards Developers
U.S. Department of Homeland Security, Transportation Security Administration (TSA), Pipeline
Security Smart Practices
U.S. Department of Homeland Security, TSA, Transportation Systems Sector-Specific Plan:
Pipeline Modal Annex

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