Federal Facility Security: Additional Actions Needed to Help Agencies Comply with Risk Assessment Methodology Standards
Released: 2014-04-07T00:00:00

Letter

Background

The ISC was established by Executive Order 12977 following the 1995 bombing of the Alfred P. Murrah Federal Building in Oklahoma City, Oklahoma. Aside from certain intelligence-related exceptions, the Executive Order requires executive branch departments and agencies to cooperate and comply with ISC’s policies and recommendations, including any standards that it sets. ISC’s mandate is to develop and evaluate security standards for federal facilities, develop a strategy for ensuring compliance with these standards, and oversee the implementation of appropriate protective security measures in federal facilities, among other things. ISC member agencies develop and draft ISC policies and standards through participation in sub-committees and working groups. In addition, all ISC member agencies have an opportunity to review and comment on ISC draft standards, and the 21 primary member agencies vote to approve final ISC standards.

From 2008 through 2013, ISC issued a series of standards to assist federal agencies in developing and implementing physical security programs at federal facilities, including standards for facility risk assessment methodologies. In August 2013, ISC combined six existing ISC standards—including The Design Basis Threat, Facility Security Level Determinations for Federal Facilities, and Physical Security Criteria for Federal Facilities—into a single standard, The Risk Management Process for Federal Facilities (RMP). According to ISC, the RMP is intended to provide agencies with an integrated, single source of physical security information and guidance.

The RMP also outlines the risk management process federal agencies must follow to determine which protective measures—such as identification badges, blast resistant windows, and intrusion detection systems—should be in place at their facilities (see fig. 1). The protective measures included in the RMP are intended to mitigate federal facilities’ vulnerabilities to specific undesirable events that ISC has identified as generally applicable to all federal facilities. To determine which undesirable events pose the greatest risk to their facilities and, therefore, which protective measures should be in place, the RMP requires agencies to conduct risk assessments for each of their facilities. Based on the results of a risk assessment, agencies can customize (i.e., add or eliminate) the protective measures included in the RMP to adequately reflect the assessed level of risk.

Because risk assessments play a key role in ISC’s risk management framework, the RMP includes standards for agencies’ facility risk assessment methodologies. Specifically, the RMP requires that agencies’ risk assessment methodologies must: (1) consider all of the 31 undesirable events in the RMP, and (2) assess the threat, consequences, and vulnerability to specific undesirable events. While the sources vary, agencies might obtain threat information through intelligence analyses, vulnerability information from facility site visits, and consequence information from interviews with tenants and facility managers.

In their basic form, risk assessment methodologies involve assigning ratings to each of the three component parts of risk—threat, vulnerability, and consequence—and combining these ratings—such as through multiplication—to produce an overall estimate of risk for each identified undesirable event. In our hypothetical risk assessment example shown in figure 2, each component of risk is assigned a rating between 1 (Very Low) and 5 (Very High) based on the facility’s conditions; these ratings are then multiplied to produce an overall estimate of risk for each undesirable event. This hypothetical assessment identified the “vehicle- borne explosive device” undesirable event as the highest risk to the facility and “kidnapping” as the lowest risk. Facility managers can use this and other information resulting from a risk assessment to make security- related decisions and direct resources to address any unmitigated risk.

Most Selected ISC- Member Agencies’ Risk Assessment Methodologies Do Not Fully Align with ISC’s Risk Assessment Standards

Three of the nine selected agencies’ risk assessment methodologies we reviewed (DOE, DOJ, and State) fully align with ISC’s RMP standard, but six (NRC, OPM, FEMA, FPS, VA, and DOI) do not, as shown in table 1. As a result, these six agencies may not have a complete understanding of the risks facing their approximately 52,000 federal facilities and may be less able to allocate security resources cost-effectively either at the individual facility level or across their portfolio of facilities.

Three of the Nine Selected Agencies’ Risk Assessment Methodologies Fully Align with ISC’s Risk Assessment Standards

ISC’s risk assessment standards require that federal agencies’ risk assessment methodologies (1) consider all of the undesirable events in the RMP and (2) assess the threat, consequences, and vulnerability to specific undesirable events. We found that DOE, DOJ, and State have a risk assessment methodology that meets these standards. DOJ’s methodology, which was also adopted by State, documents that all of the undesirable events in the RMP were considered. It also assesses the threat, consequences, and vulnerability to each undesirable event. Specifically, each undesirable event in the RMP—such as vehicle-borne explosive device—is initially assigned a baseline rating for each component of risk. These baseline ratings —which range from 1 (lowest) to 5 (highest)—are based on information and analysis from the RMP. For example, DOJ uses the facility’s facility security level (FSL) as the baseline consequence rating for each undesirable event. As a result, if a facility’s FSL is determined to be a Level 3, then all of the undesirable events listed in the RMP are initially given a consequence rating of 3. A DOJ official explained that assessors then adjust the baseline ratings up or down as necessary to reflect the facility’s actual conditions. In addition, DOJ officials informed us that the reasoning behind any adjustments to the baseline ratings must be documented as part of the assessment. The final risk scores for each undesirable event reflect the adjusted ratings, if any.

DOE’s methodology also considers all undesirable events in the RMP and assesses the threat, consequences, and vulnerability to specific undesirable events. DOE officials explained that they combine the RMP’s baseline threat ratings for each undesirable event—such as aircraft as a weapon, hostile surveillance, and kidnapping—with consequence ratings to determine a “significance rating” for each undesirable event. Each event also then receives a vulnerability assessment and score, but DOE conducts more comprehensive vulnerability assessments for undesirable events with higher significance ratings. DOE subsequently multiplies all three ratings (threat, consequence, and vulnerability) to obtain an overall estimate of risk for each undesirable event.

Six of the Nine Selected Agencies’ Risk Assessment Methodologies Do Not Fully Align with ISC’s Risk Assessment Standards

The remaining six agencies we reviewed—NRC, OPM, FEMA, FPS, VA, and DOI—do not have a risk assessment methodology that fully aligns with ISC’s standards because as shown in table 1, they contain one or more of the following limitations: they do not consider all of the undesirable events in the RMP, and they do not assess threat, consequences, and/or vulnerability to specific undesirable events.

Some Agencies’ Methodologies Do Not Consider All RMP’s Undesirable Events

Three agencies’ methodologies we reviewed (OPM, VA, and DOI) do not consider all of the undesirable events included in the RMP. According to an ISC official, an agency’s methodology must include, as a starting point or baseline, all of the undesirable events listed in the RMP; however, agencies have the flexibility to omit events they determine are not applicable to their facilities (or a particular facility) or add events that are not included in the RMP as long as these changes are documented. For example, although OPM’s methodology includes some of the RMP’s undesirable events—such as arson, assault, and kidnapping—others are omitted, such as aircraft as a weapon and coordinated or sequential attack. An OPM official informed us that their methodology lacks some of the RMP’s undesirable events because it was developed before ISC issued its risk assessment standards in 2010. However, the official also informed us that they are modifying their methodology to include all of the undesirable events in the RMP. VA’s methodology also does not consider all the undesirable events in the RMP; instead, it incorporates VA’s list of undesirable events: assaults, physical threats of violence, illegal weapons, suicidal behavior, thefts and vandalism, and explosive devices. Officials from VA said that they do not use all of the undesirable events in the RMP because they find it more practical to focus on fewer events and these six events are indicative of a facility’s overall safety and security. Because these agencies do not consider all of the undesirable events in the RMP, they may not have a complete understanding of the risks facing their facilities.

Some Agencies Do Not Assess Threat, Consequences, or Vulnerability to Specific Undesirable Events

Five agencies’ methodologies we reviewed (NRC, FEMA, FPS, VA, and DOI) do not assess one or more of the three components of risk required by ISC. In other words, these agencies’ methodologies do not rate or score specific undesirable events for all three components of risk (threat, consequences, and vulnerability). As shown in table 1, DOI’s methodology does not align with any of ISC’s risk assessment standards. DOI officials told us that the department’s methodology does not align with ISC standards, in part, because of challenges presented by its broad and diverse missions and a lack of resources and expertise to conduct risk assessments.

Although the other four agencies’ methodologies we reviewed (NRC, FEMA, FPS, and VA) are consistent with some aspects of ISC’s risk assessment standards, they lack an assessment of one or more of the components of risk. For instance, as we have previously reported, FPS’s current methodology does not assess consequences. FPS stated that it intends to eventually incorporate consequence into its risk assessment methodology and is exploring ways to do so. NRC’s methodology also does not assess the consequences of specific undesirable events. According to NRC officials, the agency does not believe it is necessary to conduct a consequence analysis for each undesirable event. However, NRC’s vulnerability assessment approach aligns with ISC’s risk assessment standards. Specifically, for each undesirable event in the RMP, NRC calculates a percentage-based vulnerability score that represents the number of protective measures that are currently in place and applicable to that undesirable event. For example, if 50 protective measures are applicable to an active-shooter undesirable event and the facility has 25 of the applicable protective measures in place, it receives a vulnerability score of 50 percent for an active shooter event. In contrast, VA’s methodology does not assess vulnerability to specific undesirable events. VA officials informed us that the department’s vulnerability assessment approach was developed before ISC issued its risk assessment standards in 2010 and that VA is modifying its approach to better align with ISC’s standards.

In contrast to these five agencies, some government agencies in Canada and the United Kingdom have a risk assessment methodology that assesses the consequences of and vulnerability to specific undesirable events, as shown in appendix II.

Because their risk assessment methodologies do not align with ISC’s risk assessment standards, these six agencies we reviewed may not have a complete understanding of the risks facing approximately 52,000 federal facilities located around the country. If, for example, an agency’s methodology does not consider all the undesirable events in the RMP, or does not assess all three components of risk (threat, vulnerability, and consequence), then the agency would have an incomplete picture of risk at facilities assessed using this methodology. Moreover, because risk assessments play a critical role in helping agencies tailor protective measures to reflect their facilities’ unique circumstances and risks, these agencies might not allocate security resources effectively—that is, they might provide too much or too little protection at their facilities or across their facility portfolios.

ISC Does Not Know If Member Agencies Are Complying with Its Standards, and Its Risk Assessment Guidance Could Be Enhanced

ISC Does Not Know Whether Member Agencies Are Complying with Its Standards

ISC has taken some steps to assist member agencies with their risk assessment methodologies. Most notably, since 2008, ISC has issued a series of physical security standards and guidance, including standards and guidance on facility risk assessment methodologies. ISC also started a program in 2012 to certify that member agencies’ risk assessment tools met its standards. As of November 2013, ISC had certified DOJ’s tool as ISC-compliant. However, ISC does not know the extent to which its member agencies are complying with its standards, including its risk assessment standards, because it does not monitor agencies’ compliance with its standards.

According to a senior ISC official, ISC does not monitor agencies’ compliance and has not developed an approach to do so that includes conducting outreach to determine the extent of compliance. Executive Order 12977 places responsibility for monitoring federal agency compliance with the Secretary of DHS; however, this ISC official noted that establishing a monitoring process and ensuring compliance are both goals listed in the Committee’s 2012- 2017 Action Plan.

ISC officials told us that they would like to monitor agencies’ compliance with ISC standards, but limited resources and other priorities, such as developing standards and guidance, have prevented the ISC from doing so. Federal internal-control standards state that monitoring is an essential management control because it allows agencies to assess the effectiveness of a program and take corrective action as necessary. Without monitoring agencies activities via appropriate mechanisms, ISC does not know the extent to which member agencies understand and are complying with its standards, including its risk assessment standards, and whether the standards are effective. Moreover, in the absence of ISC’s monitoring, as illustrated by our examples above, agencies are interpreting or implementing the standards in different ways. As the government’s central forum for sharing information and guidance on physical security, ISC also has the authority to create a working group to help it conduct outreach to determine the extent of compliance with its RMP standard. Such outreach may result in better use of the RMP standard and ultimately enhanced protection of federal facilities.

ISC’s Risk Assessment Guidance in the RMP Is Limited and Could Be Enhanced

ISC’s RMP outlines ISC’s risk assessment standards and related guidance. However, we found that this guidance is limited as compared to federal risk assessment guidance contained in DHS’ National Infrastructure Protection Plan (NIPP). For example, the RMP does not describe how to incorporate threat, consequence, or vulnerability assessments of specific undesirable events into a risk assessment methodology. As a result, some agencies we reviewed may continue to face challenges developing methodologies that align with ISC standards. In addition, federal internal control standards state that federal agencies should have appropriate guidance for each of their activities.

As compared to the NIPP, ISC’s RMP lacks specificity. Although the scope and applicability of the NIPP is broader than the RMP, the NIPP contains more detailed information and guidance on risk assessments. For example, unlike the RMP, the NIPP contains dedicated sections on threat assessment, vulnerability assessment, and consequence assessment. In each of these sections, the NIPP provides “core criteria guidance” that generally covers the scope of the assessments, key factors that should be estimated, and documentation requirements, among other things. In contrast, the RMP does not include these items; it also does not provide examples of risk assessment methodologies that align with ISC’s risk assessment standards.

In addition, officials from three agencies we reviewed told us that the risk assessment section of ISC’s RMP lacks specificity and could be enhanced. For instance, officials from one agency said that although ISC has provided federal agencies with specific information and guidance in many areas, it does not provide detailed guidance on risk assessment methodologies. These agency officials also noted that because ISC’s risk assessment guidance is limited, it might not be useful to agencies that do not have extensive physical-security resources and expertise. Similarly, officials from another agency told us that it would be helpful if ISC expanded its risk assessment guidance to include examples of acceptable risk assessment methodologies, including potential ways to evaluate and categorize threats, vulnerabilities, and consequences.

ISC officials informed us that they have not provided more detailed risk assessment guidance, examples of methodologies that align with its standards, or other resources in the RMP because member agencies have not requested this information. However, agencies may not be requesting additional guidance and information from ISC because they are unaware their risk assessment methodologies, or aspects of their methodologies, are inconsistent with ISC’s standards. Three of the six agencies we reviewed with methodologies that do not align with ISC’s risk assessment standards were unaware that their methodology had limitations.

Without additional guidance and other information in the RMP, such as examples of methodologies that align with ISC’s risk assessment standards (e.g., DOJ’s methodology), some agencies may continue to face challenges developing and implementing appropriate methodologies and, therefore, remain unable to assess risks at their facilities in a manner that aligns with ISC standards. In addition, given the federal government’s current fiscal challenges, additional guidance may help prevent some agencies from expending limited resources on ineffective or non- compliant risk assessment methodologies.

Conclusions

ISC, currently comprised of 53 member federal agencies, was established to enhance the quality and effectiveness of physical security in federal facilities. Its standards, including its risk assessment standards, are collectively developed and approved by representatives from ISC’s member agencies; as a result, these agencies had input in determining how risks to federal facilities should be assessed. However, six of the nine selected ISC member agencies we reviewed do not use a risk assessment methodology that aligns with the standards. As a result, these agencies may not have a complete understanding of risk—and may be ineffectively allocating security resources—at approximately 52,000 federal facilities and across the agencies’ portfolio of facilities.

Although risk assessments play a critical role in ISC’s risk management framework, ISC does not know the extent to which its member agencies’ risk assessment methodologies align with its standards because it does not monitor compliance or have an approach to do so that incorporates outreach to agencies regarding their compliance status. As the government’s central forum for sharing information and guidance on physical security, ISC has the authority to create a working group to help it conduct outreach to determine the extent of compliance with its RMP standard. Such outreach may result in better use of the standard and ultimately better protection of federal facilities. Moreover, given the federal government’s current fiscal challenges, additional risk assessment guidance—that includes examples of methodologies that align with ISC’s standards—could help prevent federal agencies from expending their limited resources on methodologies that are not ISC-compliant.

Recommendations for Executive Action

To help ensure that federal agencies are developing and using appropriate risk assessment methodologies, the Secretary of Homeland Security should direct the ISC to take the following two actions: conduct outreach to identify which member agencies have not developed risk assessment methodologies that align with ISC standards and develop a mechanism to monitor and ensure compliance of all its member agencies, and supplement the risk assessment guidance contained in The Risk Management Process for Federal Facilities with: (1) information on how to incorporate threat, consequence, and vulnerability assessments of specific undesirable events into a risk assessment methodology and (2) examples of risk assessment methodologies that ISC determines comply with its standards.

Agency Comments

We sent a draft of this report to the Department of Homeland Security (including the Federal Protective Service and Federal Emergency Management Agency), Interagency Security Committee, Department of Energy, Department of the Interior, Department of Justice, Department of State, Department of Veterans Affairs, Nuclear Regulatory Commission, and Office of Personnel Management for review and comment. DHS provided written comments and concurred with our recommendations; see appendix IV.

NRC, OPM, FEMA, FPS, DOI, and ISC also provided technical comments, which we incorporated as appropriate. In technical comments, DOI disagreed with our assessment of whether its risk assessment methodology aligns with ISC’s RMP but did not provide any additional documentation for our consideration. We continue to believe that our assessment of DOI’s methodology is accurate based on our understanding and application of ISC’s RMP. DOE, DOJ, State, and VA did not have any comments on the draft report.

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If you or your staff have any questions on this report, please contact me at (202) 512-2834 or GoldsteinM@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Contact information and key contributors to the report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

Our report addresses the following questions: 1) To what extent do selected ISC member agencies’ facility risk assessment methodologies align with ISC’s risk assessment standards? 2) How does ISC assist member agencies in developing risk assessment methodologies and monitor their compliance with these standards? In addition, we describe several risk assessment approaches used by non-federal entities and foreign governments that may inform federal agencies’ risk assessment methodologies.

To determine the extent to which selected ISC-member agencies’ facility risk assessment methodologies align with ISC standards, we selected a non-generalizable sample of nine ISC member agencies (out of 53) and interviewed officials and obtained documentation about their risk assessment methodologies. We limited the scope of our review to federal agencies that are ISC members and required to comply with ISC standards to ensure that each federal agency in our review is familiar with and potentially adhering to ISC’s risk assessment standards (see app. III for a list of ISC member agencies). The nine agencies were chosen to achieve diversity with respect to their missions, ISC membership type, and size. More specifically, we sought to achieve a mix of law- enforcement and non-law-enforcement agencies, primary and associate ISC member agencies, and large, medium, and small agencies. The nine agencies selected include: Department of Energy, Office of Health, Safety, and Security; Department of Interior, Office of Law Enforcement and Security; Department of Justice, Justice Protective Service; Department of State, Bureau of Diplomatic Security; Department of Veterans Affairs; Federal Emergency Management Agency; Federal Protective Service; Nuclear Regulatory Commission; and Office of Personnel Management.

For the number of facilities listed in table 1, we asked agencies to report the number of facilities in their portfolio that meet ISC’s definition of “federal facility” and apply to their risk assessment methodology. Seven agencies provided us with specific numbers. FPS provided an approximate number because it said its number of facilities is continually changing. DOI did not provide a number. Instead, we determined an approximate number of DOI facilities based on our analysis of data from the Federal Real Property Profile, a centralized real property database maintained by GSA that contains data on the federal government’s real property inventory. We identified the number of buildings DOI reported and then excluded categories of buildings that we thought likely did not meet ISC’s definition. We provided the number to DOI for review.

In addition, we reviewed and analyzed ISC’s risk assessment standards, which are outlined in ISC’s Risk Management Process for Federal Facilities (RMP) standard. According to ISC’s RMP, agencies’ risk assessment methodologies must: consider all the undesirable events identified in the RMP as possible risks to federal facilities; assess the threat, consequences, and vulnerability to specific produce similar or identical results when applied by various security provide sufficient justification for deviations from the ISC-defined security baseline.

We limited the scope of this review to the first two standards above because agencies’ adherence to these standards could be objectively verified by reviewing and analyzing agency documentation and interviewing agency officials; and their adherence to the two additional standards could not be verified in this manner. Therefore, for the purposes of this report, risk assessment methodologies that align with ISC standards are those that consider all the undesirable events identified in the RMP, and assess the threat, consequences, and vulnerability to specific undesirable events.

To determine whether agencies’ methodologies align with the above stated criteria, we reviewed and analyzed information regarding each agency’s risk assessment methodology to answer the following four questions: 1. Does the methodology consider all of the undesirable events in the RMP? 2. Does the methodology assess the threat of specific undesirable events? 3. Does the methodology assess the consequences of specific undesirable events? 4. Does the methodology assess the vulnerability to specific undesirable events?

We answered each of these questions as either a “Yes” or “No” for our selected agencies. The “No” answer to question 2, 3, and 4 includes the following two possibilities: a) the agency’s threat, consequence, or vulnerability ratings are not tied to specific undesirable events, or b) the agency does not have a framework or formalized steps within which it collects and analyzes threat-, consequence-, or vulnerability-related information. If the answer to each of the four questions was “Yes,” then the agency’s overall risk assessment methodology aligns with ISC’s risk assessment standards for the purposes of this report. If the answer to one or more of the four questions was “No”, then the agency’s methodology does not to align with ISC’s standards for the purposes of this report.

To determine how ISC assists member agencies in developing risk assessment methodologies and monitors their compliance, we reviewed documentation and interviewed ISC officials about their efforts in these areas. We also interviewed officials from the nine selected ISC member agencies regarding ISC’s risk assessment assistance, including its risk assessment guidance contained in the RMP. In addition, to assess the comprehensiveness of ISC’s risk assessment guidance, we compared the RMP’s guidance to federal risk assessment guidance contained in DHS’s National Infrastructure Protection Plan (NIPP). Like the RMP, the NIPP sets forth a risk management framework, as well as risk assessment standards and guidance. However, the NIPP’s standards and guidance are intended to apply broadly to 16 critical infrastructure sectors, including—but not limited to—government facilities. We also reviewed GAO’s Standards for Internal Control in the Federal Government because internal controls play a significant role in helping agencies achieve their mission related responsibilities.

To identify risk assessment approaches that could inform agencies’ risk assessment methodologies, we interviewed non-federal entities in four locations: Washington, D.C.; Boston, Massachusetts; Dallas/Fort Worth, Texas; and San Francisco, California. We selected these locations because of their geographic diversity and large population. In each location, we interviewed officials from a range of non-federal entities that are potential targets for terrorism because of their symbolism, historical significance, uniqueness, and/ or prominence. For example, we interviewed officials from commercial property-management firms, hospitals, universities, and state and local governments. In addition, we interviewed officials who are responsible for conducting facility risk assessments for several foreign government agencies in Canada and the United Kingdom. These countries were selected based on our review of previous risk assessment and management reports and discussions with industry stakeholders about leading risk assessment practices. Because we selected these non-federal entities and foreign government agencies as part of a non-probability sample, our findings regarding the examples of risk assessment approaches are not generalizable.

Moreover, because ISC is responsible for developing physical security standards and ensuring compliance with them and the selected agencies we reviewed are ISC’s members, any recommendations we make will be to ISC instead of individual federal agencies.

We conducted this performance audit from June 2012 to March 2014 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Examples of Other Organizations’ Approaches to Assessing Vulnerability and Consequence

We identified how foreign governments in Canada, the United Kingdom (UK), and non-federal entities, such as hospitals, are assessing risk at their facilities, specifically their approaches for assessing the consequences of and vulnerability to undesirable events.

Royal Canadian Mounted Police’s Risk Assessment Approach: Risk assessment guidance published by a Canadian government agency includes a basic vulnerability assessment approach. Each undesirable event is rated qualitatively (High, Medium or Low) on two factors: 1. How the vulnerability affects the severity of the undesirable event. 2. How the vulnerability affects the likelihood that a facility will be compromised.

A matrix that reflects both factors is used to determine the final vulnerability rating for each undesirable event. For example, a vulnerability that has a “High” impact on the severity of the undesirable event and “Medium” impact on the likelihood of compromise has an overall vulnerability rating of “High,” according to the vulnerability assessment matrix.

UK Cabinet Office’s Risk Assessment Approach for Local First Responders: The UK Cabinet Office provides “impact scoring scales” to assist local responders in determining the consequences of the undesirable events applicable to their areas of jurisdiction. As explained in the agency’s guidance, each undesirable event should be assigned an impact score between 1 (insignificant) and 5 (catastrophic), depending on its anticipated consequences in the following areas: health: includes direct impacts (numbers of people affected, fatalities, injuries, etc.) and indirect impacts that may arise due to strains on health services; social impacts: includes availability of government programs and services, damage to property, disruption of communications and supply chains (e.g., money, food, water, energy, or fuel); and public disorder due to anger, fear, and/or lack of trust in the authorities; economic impacts: encompasses the net economic cost, including both direct (e.g., loss of goods, buildings, infrastructure) and indirect (e.g., loss of business, increased demand for public services) costs; and environmental impacts: encompasses contamination or pollution of land, water, or air, with harmful biological/chemical/radioactive matter or oil, flooding, or disruption or destruction of plant or animal life.

Another UK government agency rates 14 undesirable events on a scale of 1 (limited) to 5 (catastrophic) based on the estimated number of casualties, reputational damage, and disruption to the business of the agency.

U.S. Hospitals’ Risk Assessment Approach: Two major hospitals we spoke with use a risk assessment methodology developed by a non- profit healthcare organization that includes an event-based consequence assessment approach. Each undesirable event is assigned a separate rating—from 0 (Not Applicable) to 3 (High)—for probability and six consequence factors: human impact, property impact, business impact, preparedness, internal response, and external response. Overall consequence ratings for each undesirable event are obtained by summing the 6 ratings and dividing the total by 30 (the highest possible sum of the 6 ratings).

Appendix III: Interagency Security Committee Primary and Associate Member Agencies

Appendix IV: Comments from the Department of Homeland Security

Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, Tammy Conquest, Assistant Director; Colin Fallon; Geoff Hamilton; SaraAnn Moessbauer; Jaclyn Nidoh; and Travis Thomson made key contributions to this report.