R 261355Z MAR 25
MARADMIN 164/25
MSGID/GENADMIN/CMC DCI WASHINGTON DC//
SUBJ/PROCEDURES FOR UNSERVICEABLE GSA CONTAINERS//
REF A/ DODM 5200.01, VOLUME 3, DATED: 28 JUL 2012//
REF B/ ISOO NOTICE 2021-01, DATED: 29 JUN 2021//
REF C/ ISOO NOTICE 2022-03, DATED: 18 AUG 2022//
REF D/ FEDERAL STANDARD 809E, DATED: 17 FEB 2023 //
REF E/ MCO 4400.201, VOLUME 6, DATED: 03 NOV 2016//
REF F/ ISOO NOTICE 2014-02, DATED: 04 APR 2014//
NARR/ REF A IS THE DEPARTMENT OF DEFENSE INFORMATION SECURITY
PROGRAM: PROTECTION OF CLASSIFIED INFORMATION. REF B IS THE
INFORMATION SECURITY OVERSIGHT OFFICE NOTICE REGARDING PHASE
OUT OF CERTAIN GSA CONTAINERS. REF C IS THE INFORMATION SECURITY
OVERSIGHT OFFICE NOTICE REGARDING REPLACEMENT OF GSA VAULT DOORS.
REF D IS THE FEDERAL STANDARD FOR NEUTRALIZATION AND REPAIR OF GSA
CONTAINERS. REF E IS THE MARINE CORPS ORDER ON MANAGEMENT OF
PROPERTY IN THE POSSESSION OF THE MARINE CORPS VOLUME 6. REF F IS
THE INFORMATION SECURITY OVERSITE OFFICE NOTICE REGARDING PURCHASE
OF NEW GSA CONTAINERS.//
POC/DC 1/M. RIEGER/CIV/IID, DC I/TEL: 703-692-0157/EMAIL:
MARK.RIEGER@USMC.MIL//
GENTEXT/REMARKS/ 1. Purpose: This MARADMIN provides guidance for
unserviceable General Service Administration (GSA) containers and
vault doors.
2. Background: Command Security Managers and Special Security
Officers maintain containers and
vault doors for the protection of classified information. The
Information Security Oversight
Office (ISOO) has determined that GSA containers and vault doors
manufactured prior to 1989 no longer meet the standards for
protection of classified material and cannot be repaired/updated
for continued use. All pre-1989 GSA containers must be removed from
service NLT 1 October 2028, and vault doors NLT 1 October 2035.
3. Execution:
3.a. Authorities.
3.a.1. Reference (b) and (c) only apply to GSA containers and vault
doors used for the protection of classified information. Containers
and vault doors used for protection of AA&E are not subject to this
requirement.
3.a.2. Per references (b) and (c), class five and six containers
and class five vault doors manufactured
prior to 1989 no longer meet the standards for protection of
classified material and must be removed from service. These
containers and vault doors may be visually identified by black
lettering on the silver GSA approval label and are commonly referred
to as "black label" containers or doors. The phase out of "black
label" containers must be complete NLT 1 October 2028.
3.a.3. Reference (c) extends the phase out for “black label” vault
doors to 1 October 2035.
3.b. NLT 30 April 2025, Command Security Managers and Special
Security Officers will inventory all GSA containers and vault doors
under their control, recommend consolidation of classified
information where practical, formulate a plan for purchase of new
GSA containers where necessary, and begin disposal of all black
label containers ensuring that all black label containers are
removed from service NLT than 1 October 2028.
3.b.1. NLT 31 May, 2025, commands will identify GSA approved
black label vault doors to the servicing facilities office and
coordinate necessary actions to remove and replace the vault
door NLT 1 October 2035.
3.c. During the phase out period, black label containers may not
be repaired. As directed in reference (d), neutralization of a
locked-out container and replacement of the lock is considered a
repair and is no longer authorized. Locked out black label
containers will be neutralized and removed from service per
paragraph 3.d.8. below. Reference (d) does provide for certain
limited and minor field adjustments which do not meet the definition
of a repair. GSA certified inspectors and technicians can assist in
determining if these adjustments are authorized for the container
in question.
3.d. Procedure for containers.
3.d.1. Command Security Managers and Special Security Officers will
coordinate consolidation of classified material into GSA containers
manufactured after 1989. These containers can be visually identified
by red lettering on the GSA approval label. Where purchase of new
containers is required, follow the procedures in para 3.d.8 of this
MARADMIN. Due to the high cost and long lead time for procurement of
new containers, purchases should be included in the command's
budgetary cycle.
3.d.2. Where a container has been recertified, that container will
always be identified by black lettering on the GSA approval label;
however, the label will specifically state "recertified container".
The servicing GSA inspector will indicate the original label color
on the recertification label and this original color will be used
when complying with reference (b).
3.d.3. Any uncertainty regarding the container manufacture date may
be confirmed from information found on the manufacturer's label
which can be located on one side or the other of the control drawer
when open, or on the back of the door for GSA approved vault doors.
The manufacturer's label will include the container's class and date
of manufacture along with other data.
3.d.4. Where there are continued concerns over a container or vault
door, commands may obtain installation or local locksmith services
provided the responding locksmith has the proper GSA credentials.
3.d.5. Commands are reminded that GSA containers with blue
lettering on the GSA approval label may only to be used for the
storage of classified ADP equipment such as classified servers and
may not be used for the storage of hard copy classified material.
3.d.6. Where black label containers containing the current model
high security lock the commands may elect to repurpose the lock
for use on future repairs of post 1989 containers. The approved high
security locks are the Kaba X10 and the Sergeant and Greenleaf S&G
2740. Approved locks may be removed by GSA certified locksmiths and
retained for reuse. Kaba X07, X08, and X09 locks may not be
repurposed and will be disposed of with the container or vault door.
For assistance with lock identification review the security hardware
section of the DOD Lock Program noted in paragraph 3.d.8 below.
3.d.7. To dispose of unserviceable containers the Command Security
Manager and/or Special Security Officer will inspect the container
to ensure no classified material remains inside, reset the lock
combination to the "out of service" combination of 50-25-50, and
remove the GSA approval label. Dispose of the container per
reference (e) using a condition code of "S" for scrap. Disposal of
vault doors will be included in the planning for door replacement.
3.d.8. IAW reference (f), new GSA containers and vault doors may
only be purchased through GSA global supply. NSNs and instructions
for procurement of new GSA containers and vault doors may be found
on the DOD Lock Program website at https:(Slash)(Slash)exwc.navfac.
navy.mil/DoD-Lock-Program/SecurityHardware/
GSA-Approved -Security-Containers.
When ordering new containers and vault doors ensure use of the
correct NSN for the desired lock type. Style, one locks are the
Kaba X10, style two locks are the S&G 2740.
3.d.9. Assistance in locating a GSA certified locksmith, inspector,
or technician may be found from any of the following sources: The
DOD Lock Program website; Kaba Mas (X10): www.kabamas.com;
Sergeant and Greenleaf (S&G 2740): www.sargentandgreenleaf.com/
product/2740b/; GSA approved training centers: Lockmasters Security
Institute: 859-887-9633, or MBA USA: 859-887-0496
4. Reporting requirements.
4.a. All actions and documentation required by this MARADMIN will
be held locally. Compliance with this MARADMIN will be added to the
functional area checklist 5510.3 and included in all future
inspections though October 2028 for containers, October 2035 for
vault doors.
5. Direct all questions to this MARADMIN’s point of contact.
6. Release authorized by Lieutenant General M. G. Carter,
Deputy Commandant for Information, U.S. Marine Corps.//