Wednesday, August 08, 2007

Does Homeland Security have eyes for you?

Just as Homeland Security spends endless days and nights listening to "chatter" by those who might do us harm, Asset Control stays up all night listening to Department of Homeland Security "chatter" to see just what they have in mind for employers in the battle against illegal immigration. Recently, we've picked up some chatter that might be of specific interest to you if you haven't been diligent in verifying the identity of new or existing employees!

While employers may have gotten away with ignoring the Social Security Administration's "no match" letters in the past, a new partnership between the Department of Homeland Security and the S.S.A. may put a damper on this approach. These are letters sent to employers with more than 10 workers, informing them that a particular employee's name does not match the SSN used. They are sent when the no matches for an employer is .5% or more of the company's total workforce. Sources inside the Bush administration now indicate that the President is planning new enforcement initiatives, even in the absence of new enforcement legislation. According to Russ Knocke, the spokesman for the Department of Homeland Security, " We are tough and we are going to be even tougher." "There are not going to be any more excuses for employers, and there will be serious consequences for those that choose to blatantly disregard the law."

New enforcement guidelines are expected to give employers a fixed period of time to investigate and resolve any discrepancies between the identification provided by workers and records held by the Social Security Administration. Chatter has it that employers will have 90 days to resolve the discrepancy, fix the problem, or fire the employee. Employers that ignore the letters will risk fines up to $10,000 for each illegal worker. According to the Social Security Administration, over 140,000 no match letters, covering more than eight million workers, will be sent to employers this year.

But the Fed has threatened aggressive enforcement of immigration law in the past. In reality, the threats translated into token arrests, or photo opportunities, intended to do nothing more than give the perception that an enforcement program exited. What has changed? First, the Bush administration is being pressured by the conservative base to do something, anything, in the war against illegal immigration. One measure, to enforce existing law, can be taken without new legislation. Clearly, this has been a battle cry heard from both Republican and Democrat conservatives since the attack on 9/11. But the Fed must pick its battles, and the possibility of a great photo op is still a significant drawing card. This means that the day of the raid on wooden pallet manufacturing plants is probably past.

On August 2, just one day after the tragic I-35 bridge collapse in Minnesota, Jose S. Gonzalez was arrested at his office in Greenville, Mississippi. Gonzalez, owner of Tarrasco Steel, was a subcontractor who provided re-bar and installation services to major highway bridge construction projects. On March 29, 2007, ICE agents conducted worksite enforcement actions at the Greenville-Arkansas Highway 82 bridge in Greenville Mississippi; the Huey P. Long bridge in New Orleans, Louisiana; the US 90 bridge in Biloxi, Mississippi; the I-40 seismic retro-fit in Memphis, Tennessee, and the LA-1 bridge in Leeville, LA. These structures are all part of our nation's critical infrastructure and are closely scrutinized when it comes to security matters. During the March raid, several employees were arrested for using bogus Social Security Numbers. The investigation also revealed that the employees did not have proper welding certifications.

Did the Fed choose the timing of the arrest in light of the bridge collapse the previous day? Hard to say. It may have been the sensible action under the circumstances, particularly, from a public relations perspective. Note, that the investigation and subsequent enforcement action at bridges in Louisiana began very early in the year. So, it appears that the Fed was ahead of the curve in this particular case. Protecting infrastructure is a credible objective. Regardless, if what we have observed is part of an overall strategy by Homeland Security, we should expect to see more enforcement actions targeting aspects of our infrastructure; particularly, actions involving contractors receiving federal or state revenue.

So, where should we expect to see more enforcement efforts? If your company provides services in support of bridges, dams, roadways airports, hazardous waste, our food supply, the movement of cargo over land or water, water or water treatment, power generation, schools, security, or liquid or solid waste, do not take the "no match" letters lightly as many employers have in the past. And, expect that state and local authorities will partner with federal agencies to go after employers who hire skilled workers who may have bogus licenses or certificates.

Asset Control can assist employers in their efforts to hire legal workers. To find out how, call our offices at 940-891-1919. Don't let the Fed have a photo opportunity at your expense.

Wednesday, August 01, 2007

Soft Targets, Hard Lessons - Why terrorists value your school as a target and what you can do!

Shortly after 9/11 I was asked by the Director of the Texas School Safety Center, a legislated branch of the Texas governor’s office to develop a strategy for deterring potential terrorist attacks in Texas public schools. My reputation for developing preventive programs was known. At the time, the law enforcement community had concluded, for whatever reason, that little could be done to deter or prevent a terrorist attack on schools. As a result, their focus would be wholly reactive in nature. This was not altogether acceptable to the TXSSC. Subsequently, Asset Control signed a consulting agreement to develop steps that any school district could take to mitigate their attractiveness to terrorists seeking a soft target. I undertook the project understanding that having a well developed and coordinated response plan was critical in the event of a school attack, but knowing that basic steps could be taken to lessen the likelihood that a particular school might be targeted. The result: in 2002 the “Proactive Guide for the Prevention of Terrorism in Public Schools” was distributed to all Texas public schools. Subsequently, the “Guide” was adopted by several school districts and suport service organizations nationwide.

Unfortunately, the recent trend on the part of some law enforcement and many security consultants has been to minimize the likelihood that a school(s) in the US may be subject to attack by terrorists. In fact, those who attempt to keep the idea of a potential terror attack at school alive in the minds of school administrators and security personnel have been criticized as trying to “hype” the threat to increase their own value. The fact of the matter is that the thought of our children being targeted in a place where they should be most safe is so frightening that is has been rendered unmentionable, if not unthinkable. Some even speculate that terrorists fear that an attack on a U.S. school(s) would cause a reverse affect. That is to say, that the fear and panic created by such an attack would motivate the American people (rather than de-motivate) to exterminate radical Islamic extremists throughout the world.

Yet, we have no evidence that the terrorist fears that the killing of children would have any affect beyond their stated goal(s). In fact there is evidence to the contrary. Video tapes have been found in Afghanistan showing al-Qaeda terrorists training to take over schools. Subsequently, al-Qaeda spokesman Suleiman Abu Gheith declared al-Qaeda's "right" to kill 2 million American children in retaliation for Muslim civilian deaths in the war on terror. Recently, CNN reported that local law enforcement agencies received a “routine” FBI and Homeland Security Department advisory relating to “Foreigners under recent investigation include ‘some with ties to extremist groups’ who have been able to purchase (school) buses and acquire licenses.”

But the greatest evidence to date is the horrific Belsan school massacre in Russia during which 700 people were wounded and 338 killed, including 172 students. This terrorist attack was perpetrated by Muslim extremists with definite historical links to al-Qaeda. Whether al-Qaeda assisted in the planning of this particular attack is under investigation. It was noted that several Arabs were among the terrorists killed by Russian Special Forces during the massacre.

Be Proactive: The Awareness / Prevention Checklist

The Awareness/Prevention checklist highlights areas of school operations, maintenance, security, and personnel that may pose opportunities for risk reduction. Use this checklist as a proactive tool to generate awareness over the potential for terrorist acts, at a time when it is needed most.

The recommendations contained in this checklist are not intended to represent or to replace a comprehensive school security program. Such a program would include much more. Many of the procedures included in the checklist are routine in districts with full-time security operations. Whether your school district has full-time security coverage, or has minimal security resources, these recommendations may be used as a focal point around which to build an appropriately renewed sense of awareness. The recommendations have been constructed in several “modules” each of which depicts the basic recommendation, the audit point or “question” to be addressed for each recommendation and the departments that would potentially be involved in the addressing the recommendation.

Module 1: Review Employment Screening Policy & Procedure
  • Does your screening process include volunteers, cafeteria workers, mechanics, bus drivers, and security, in addition to educational staff?
  • Does your procedure allow for actual courthouse searches, rather than database searches, which are typically not accurate?
  • Do your searchers do Social Security Number traces to identify any out-of-state venues that should be checked?
  • Do your outside contractors use due-diligence screening procedures to check the backgrounds of their workers who regularly visit your school?

Departments Involved:

  • Security
  • Human Resources

Module 2: Review the physical security of bus yards and garages; review transportation security in general.


  • Are vehicle garages alarmed, and are the alarms in working order?
  • Are fenced-in areas gated, locked, and adequately illuminated at night?
  • Do drivers do “pilot inspections” of their vehicles before placing them into service each day? Is this done again after each time the vehicle has been left unattended?
  • Are bus drivers equipped with two-way radios or cell phones?
  • Are drivers trained to be aware of and to report suspicious vehicles that appear to be following their busses during their routes?
  • Do drivers keep a student roster for each bus route, to include student name, address, primary and secondary emergency contact numbers, and medical authorization information?

Departments Involved:

  • Security
  • Contract or proprietary bus operators
  • Health Services

Module 3: a) Review the adequacy of physical security in and around campus buildings; b) Review placement of security cameras and review monitoring practices


  • Review the adequacy of physical security in and around campus buildings
  • Review placement of security cameras and review monitoring practices
  • Are alarm systems working and have they been tested? This should include main campus buildings as well as maintenance and storage facilities.
  • Are keys to campus and administration buildings adequately controlled?
  • Are alarm pass codes changed when an employee leaves the school district?
  • Make sure pass codes are not shared.
  • Is exterior lighting working and is illumination adequate?
  • Is interior lighting (night lighting) working and is illumination adequate?
  • If security cameras are used, coverage should include main doors and building exteriors, as well as interior locations.
  • Make sure recording equipment is in working order and that a reasonable archive is maintained.
  • If cameras are not live monitored, make sure that a periodic or spot review of critical areas takes place.
  • Encourage students and staff to report suspicious activity quickly, so that video archives can be reviewed for evidence.

Departments Involved:

  • Security
  • Maintenance
  • H.R.
  • Operations

Module 4: Review access control procedures and heighten employee awareness

  • Are doors that should remain locked from the outside during the day kept locked, and are these doors checked periodically to make sure they are secure? Train all employees to check these doors but consider assigning someone to check them as well.
  • Are staff members trained to approach and to “assist” strangers of any age who are observed in and on school property? Report those who have difficulty explaining their presence.
  • Are students trained to report suspicious persons or persons who may not be authorized on campus?
  • Has a visitor log and ID badge system been implemented?

Departments Involved:

  • Everyone

Module 5: Train everyone to recognize and report suspicious activities on campus.


  • Are persons taking pictures or filming campus activities questioned about their authorization to do so?
  • Be alert for suspicious vehicles that seem to have no apparent purpose for being on campus, or, that come, go, and then reappear again.
  • Are specific individuals assigned to inspect the outside of campus buildings throughout the day, and to report unattended packages or vehicles near building perimeters?
  • Have you developed a plan to handle reports of suspicious activity?
  • Is everyone trained to report unattended or otherwise suspicious packages found inside campus buildings? Is this specific issue placed on routine checklists for maintenance and janitorial personnel?
  • Do personnel know what to do if a suspicious package is found?
  • Have you considered a policy that requires staff and students to visibly identify backpacks, book bags, briefcases and gym bags with luggage style ID tags?

Departments Involved:

  • Everyone including students, janitorial, teachers, volunteers, & Student Resource Officers

Module 6: Implement a “tip-line” program that allows students, teachers, parents, staff, and other members of the school community to report issues anonymously, if they choose.


  • Do you have a zero tolerance for verbal threats of any kind?
  • Do all members of the school community know that any threat, or information about a potential threat, must be reported? And, do they understand that there is no such thing as a threat intended as a joke?
  • Do students and staff know that they are responsible for informing the building principal about any information or knowledge of a possible or actual terrorist threat or act?
  • Have you communicated a hard stand on hoaxes intended to mimic terrorist acts?
  • Do students know that these hoaxes are crimes in themselves?

Departments Involved:

  • Student Services
  • Students/Clubs
  • PTA / PTO
  • Resource Officers

Module 7: Work closely with local law enforcement, health officials, and first responders


  • Have you made local law enforcement a partner in your district’s plans?
  • Are parking regulations, particularly fire zone regulations, strictly enforced?
  • Does local law enforcement have copies of building blueprints, to include ventilation system, and electrical plans?
  • Has local law enforcement been given the opportunity to conduct exercises on school property and on busses?
  • Have you determined contact protocol with local health officials if bio-terrorism is suspected?

Departments Involved:

  • Security
  • Clinical Staff
  • Crisis Management Team
  • Local Law Enforcement
  • First Responders
  • SRO’s
  • Local Health Officials

Module 8: Train staff on identifying and handling suspicious packages and letters.


  • Have you download and posted the FBI advisory (poster) regarding suspicious packages from
  • Or, the US Postal Inspection Service poster on identifying suspicious packages from
  • Have you considered publicizing the availability of this information to others in the school community for personal use?
  • Have you ordered ATF forms: P 3320.5; P 7550.2; and 1613.1, regarding bomb threat planning?

Departments Involved:

  • Mail Room
  • Secretarial
  • Security
  • Parents
  • Students
  • Janitorial

Remember, terrorists place their intended targets under surveillance prior to attack. They will study various potential targets as part of the target selection process in order to identify those with fatal weaknesses. While vigilance alone will not prevent a terrorist attack on a U.S. school, it may prevent your school from being selected for attack. Terrorists will likely select the softest amongst all of the targets considered. These may be rural schools serviced primarily by county sheriff departments or state police agencies. In other words, in places where the closest swat team or other first responders may not be just around the corner.

If you haven’t considered the possibility of a terrorist attack on a school in your district, or if your plans up to now have been solely reactive in nature, now is the time to act. Awareness is inexpensive and one of the most effective tools we have in the war on terror. However, we have to overcome the “it won’t happen here” thinking that paralyzes many Americans with an apparent reluctance to think or act. Moreover, don’t expect that the Fed, or for that matter your state will step in with a reasonable and proactive program to render your school or district a less soft target. All such efforts must come from within and must come now!