R 212244Z JAN 16
MARADMIN 039/16
MSGID/GENADMIN/CMC WASHINGTON DC PPO PS//
SUBJ/UPDATE TO THE MARINE CORPS PHYSICAL SECURITY WAIVER/EXCEPTION POLICY//
REF/A/MCO 5530.14A//
REF/B/DTM 13-005//
REF/C/DODI 2000.12//
REF/D/DODI 2000.16//
REF/E/DODM 5200.01 VOL 2//
REF/F/SECNAV M-5210.1//
NARR/REFERENCE A THE MARINE CORPS PHYSICAL SECURITY PROGRAM MANUAL. REFERENCE B IS THE DIRECTIVE-TYPE MEMORANDUM (DTM); DEVIATIONS FROM THE DOD PHYSICAL SECURITY PROGRAM.  REFERENCE C IS THE DOD INSTRUCTION; DOD ANTITERRORISM (AT) PROGRAM.  REFERENCE D IS THE DOD INSTRUCTION; DOD ANTITERRORISM (AT) STANDARDS.  REFERENCE E IS THE DOD MANUAL; DOD INFORMATION SECURITY PROGRAM: MARKING OF CLASSIFIED INFORMATION. REFERENCE F IS THE SECNAV MANUAL; DEPARTMENT OF THE NAVY RECORDS MANAGEMENT POLICY.//
POC/JOSHUA ROWE/SSGT/UNIT: PP&O PS/EMAIL: JOSHUA.J.ROWE(AT)USMC.MIL/TEL: (703) 692 4272//
POC/TONY PIERCE/CIV/UNIT: PP&O PS/EMAIL: CHARLES.A.PIERCE1(AT)USMC.MIL/TEL: (703) 695 7202//
GENTEXT/REMARKS/1. THIS MESSAGE ESTABLISHES NEW PROCEDURES FOR WAIVER OR EXCEPTION REQUESTS FOR DEVIATIONS TO ALL PHYSICAL SECURITY, CRIME PREVENTION, ANTI-TERRORISM CONSTRUCTION STANDARDS, AND FORCE PROTECTION STANDARDS IAW REFERENCE A AND B.  THIS GUIDANCE WILL BE INCLUDED IN THE UPDATE OF REFERENCE A. 
2. BACKGROUND.  PHYSICAL SECURITY IS A PRIMARY COMMAND OBLIGATION.  HEADS OF DOD COMPONENTS AND COMMANDERS HAVE THE RESPONSIBILITY TO APPLY APPROPRIATE PHYSICAL SECURITY MEASURES TO PROTECT DOD ASSETS, INCLUDING PERSONNEL, PROPERTY, AND INFORMATION.
COMMANDERS MUST MAINTAIN A STRONG PHYSICAL SECURITY POSTURE.  HOWEVER, VARIED CONDITIONS MAY DICTATE THE NECESSITY FOR DEVIATIONS TO POLICY.  DEVIATIONS TO PHYSICAL SECURITY STANDARDS REQUIRE A STRONG MITIGATION STRATEGY COUPLED WITH COMPENSATORY MEASURES.  THIS MARADMIN CLARIFIES CATEGORIES OF DEVIATION, ADDRESSES COMPENSATORY MEASURES, REVIEW AND APPROVAL OF DEVIATION REQUESTS, DEVIATION DOCUMENTATION, AND A CENTRAL REPOSITORY FOR ALL APPROVED/DENIED REQUESTS.  
3.  CATEGORIES.
3.A. INSTALLATION COMMANDERS OR FACILITY DIRECTORS MUST REQUEST A WAIVER WHEN COMPLIANCE WITH A PRESCRIBED MINIMUM STANDARD IS NOT CURRENTLY ACHIEVABLE, AND THE DEFICIENCY IS NOT CORRECTABLE WITHIN 90 DAYS, BUT CAN BE CORRECTED WITHIN 1 YEAR.
3.B. WAIVER: AN APPROVED TEMPORARY DEVIATION (NO LONGER THAN 365 DAYS) OF THE SECURITY REQUIREMENTS OF REFERENCES A, C, AND D.
3.C.  LIMITED EXCEPTION:  AN APPROVED LONG-TERM DEVIATION (NO LONGER THAN 3 YEARS) OF SECURITY AND CONSTRUCTION REQUIREMENTS OF REFERENCES A, C, AND D.
3.D. PERMANENT EXCEPTION:  A WRITTEN, APPROVED PERMANENT DEVIATION OF THE SECURITY AND CONSTRUCTION REQUIREMENTS.  ALTHOUGH IDENTIFIED IN REFERENCE B, THE MARINE CORPS WILL NOT APPROVE PERMANENT EXCEPTIONS.
3.E.  WAIVERS AND EXCEPTIONS ARE SELF-CANCELING AT THE END OF THE ALLOTTED TIME.  COMMANDS ARE RESPONSIBLE TO SUBMIT ALL REQUESTS FOR AN EXTENSION PRIOR TO THE DATE OF EXPIRATION AND WILL BE STAFFED IN THE SAME MANNER AS THE ORIGINAL REQUEST.
3.F. THE DEPUTY COMMANDANT (DC), PLANS, POLICIES, AND OPERATIONS (PP&O), COMMANDER, MARINE FORCES (COMMARFORS), COMMANDER, MARINE CORPS INSTALLATIONS COMMAND (COMMCICOM) WILL FORMALLY REVIEW WAIVERS EVERY 9 MONTHS AND DOCUMENT PROGRESS MADE TO CORRECT THE WAIVERED DEFICIENCY.  IF SECURITY STANDARDS OR THE SITUATION AFFECTING THE SECURITY OF THE USMC ASSETS OR RESOURCES CHANGES, ANOTHER DEVIATION REQUEST MUST BE SUBMITTED BY THE ORIGINATING COMMAND. THE DC, PP&O WILL COORDINATE WITH DEPUTY COMMANDANTS (DC), COMMARFORS, AND COMMCICOM AS IT RELATES TO THEIR RESPECTIVE AREA OF RESPONSIBILITY (AOR).
3.G.  SUBMITTED AND APPROVED WAIVER REQUESTS MUST BE RETAINED ON FILE, TO INCLUDE PERIODIC REVIEWS OF WAIVERS, IN ACCORDANCE WITH REFERENCE F.
4.  COMPENSATORY MEASURES
4.A.  DEVIATION REQUESTS WILL CONTAIN AN ANALYSIS OF THE PROBLEM AND A DETAILED DESCRIPTION OF COMPENSATORY SECURITY MEASURES THAT THE COMMANDING OFFICER HAS IMPLEMENTED.  A SINGLE COMPENSATORY MEASURE MAY BE APPLIED FOR MORE THAN ONE DEVIATION.
4.B.  ACCEPTABLE COMPENSATORY MEASURES MUST MITIGATE OR COMPENSATE FOR VULNERABILITIES CREATED BY THE INABILITY TO ACHIEVE A MINIMUM PHYSICAL SECURITY STANDARD.
4.C.  COMPENSATORY MEASURES MUST BE DESIGNED TO COMPENSATE FOR THE SPECIFIC VULNERABILITY CREATED BY THE DEFICIENCY, AND MUST PROVIDE AN EQUIVALENT OR GREATER LEVEL OF PROTECTION AS THE STANDARD FOR WHICH THE DEVIATION WAS GRANTED.
4.D.  COMPENSATORY MEASURES MUST GO ABOVE AND BEYOND ROUTINE SECURITY MEASURES ALREADY REQUIRED OR IN PLACE AT THE SITE.
SECURITY FORCES, FACILITIES, EQUIPMENT, AND PROCEDURES CURRENTLY IN PLACE TO MEET MINIMUM STANDARDS ARE NOT NORMALLY ADEQUATE AS COMPENSATORY MEASURES.  HOWEVER, USE OF EXISTING DOD ASSETS OR RESOURCES IN A NEW WAY TO PROVIDE PROTECTION FOR A DEVIATION MAY CONSTITUTE COMPENSATORY MEASURES AS LONG AS THEIR USE DOES NOT CREATE VULNERABILITIES IN OTHER AREAS.
4.E.  LOCAL INSTRUCTIONS CONSISTING OF NON-SPECIFIC ORDERS SUCH AS “INCREASED VIGILANCE” ARE INADEQUATE AS COMPENSATORY MEASURES.
4.F.  COMPENSATORY MEASURES WILL BE IMPLEMENTED IMMEDIATELY UPON DETECTION OF A VULNERABILITY AND WILL NOT BE DELAYED PENDING A REQUEST FOR DEVIATION.
5.  REVIEW AND APPROVAL OF DEVIATION REQUESTS.
5.A.  ALL REQUESTS FOR DEVIATION OF PHYSICAL SECURITY REQUIREMENTS WILL BE FORWARDED FROM THE AFFECTED UNIT VIA THE INSTALLATION COMMANDER THROUGH THE APPROPRIATE CHAIN OF COMMAND TO THE DC, PP&O FOR CONSIDERATION.
5.B.  IN THE CASE OF MARINE CORPS UNITS NOT LOCATED ABOARD A USMC INSTALLATION, THE REQUEST WILL BE COORDINATED WITH THE HOST INSTALLATION COMMANDER AND FORWARDED VIA THE CHAIN OF COMMAND TO THE APPROPRIATE DC OR COMMARFOR TO THE DC, PP&O.
5.C.  ALL DEVIATION REQUESTS THAT ALTER OR UNDERMINE THE STANDARDS IN REFERENCES C AND D WILL BE FORWARDED VIA THE CHAIN OF COMMAND TO THE DC, PP&O.  THE DC, PP&O WILL ENDORSE AND FORWARD THE REQUEST TO THE APPROPRIATE MARFOR FOR COORDINATION WITH THE APPROPRIATE GEOGRAPHIC COMBATANT COMMANDER (GCC) FOR CONSIDERATION.
5.D.  DEVIATIONS FROM MINIMUM PHYSICAL SECURITY STANDARDS DUE TO SPECIAL CIRCUMSTANCES OF LIMITED DURATION (E.G. AIRSHOWS, OPEN HOUSES, ETC.) REMAIN THE RESPONSIBILITY OF THE HEAD OF THE DOD COMPONENT AND REQUIRE APPROVAL BY THE DC, PP&O IN ACCORDANCE WITH REFERENCE B.  DEVIATIONS FROM MINIMUM PHYSICAL SECURITY STANDARDS DUE TO SPECIAL CIRCUMSTANCES OF LIMITED DURATION THAT AFFECT FORCE PROTECTION CONDITIONS REQUIRE APPROVAL FROM THEIR RESPECTIVE GCC.  COMMANDS ARE DIRECTED TO ADDRESS WAIVER REQUESTS DURING THE INITIAL PLANNING PROCESS.
5.E. COMMANDERS AND THE APPROVING AUTHORITY WILL CAREFULLY WEIGH ALL FACTORS, TO INCLUDE POTENTIAL VALUE OF PROTECTION REQUIRED TO MEET PHYSICAL SECURITY/FORCE PROTECTION CONDITIONS.
5.F.  COMMANDERS AND THE APPROVING AUTHORITY WILL REVIEW EACH DEVIATION TO ENSURE ADEQUATE COMPENSATORY MEASURES HAVE BEEN IDENTIFIED AND CAN BE IMPLEMENTED.
5.G. DEVIATION REQUESTS WILL BE DOCUMENTED AT A CLASSIFICATION LEVEL APPROPRIATE TO ITS ASSOCIATED VULNERABILITY. THE APPROVING AUTHORITY WILL ENSURE THAT ALL APPROPRIATE DOCUMENT HANDLING, MARKING, OR CLASSIFICATION DESIGNATIONS ARE CONSISTENT WITH APPLICABLE SECURITY CLASSIFICATION GUIDES.  DEVIATION REQUESTS CONTAINING CLASSIFIED INFORMATION MUST CONTAIN THE REQUIRED SECURITY CLASSIFICATION MARKINGS IN ACCORDANCE WITH REFERENCE E.
5.H.  WHEN CONSIDERING A DEVIATION REQUEST FOR A PARTICULAR INSTALLATION OR FACILITY, THE APPROVING AUTHORITY WILL REVIEW ALL OTHER APPROVED DEVIATIONS CURRENTLY IN EFFECT FOR THAT INSTALLATION OR FACILITY.  THIS REVIEW IS TO ENSURE THAT, COLLECTIVELY, THE DEVIATIONS DO NOT ESTABLISH AN OVERALL SITE VULNERABILITY GREATER THAN THE DESIGNATED COMPENSATORY MEASURES.
5.I.  EACH DEVIATION MUST BE EVALUATED AND APPROVED ON A CASE-BY-CASE BASIS.  BLANKET DEVIATION APPROVALS (APPROVALS FOR MORE THAN ONE FACILITY) ARE NOT AUTHORIZED.
5.J.  UNITS WITH MULTIPLE DEFICIENCIES MUST REQUEST A SEPARATE DEVIATION FOR EACH DEFICIENCY.
5.K.  APPROVAL OF WAIVERS OR EXCEPTIONS DOES NOT RELIEVE COMMANDERS OF THEIR SECURITY RESPONSIBILITY, ENSURING THE IMPLEMENTATION OF COMPENSATORY SECURITY MEASURES, AND THE DEVELOPMENT OF A PLAN OF ACTION AND MILESTONES TO CORRECT THE IDENTIFIED DEFICIENCY.
5.L.  COMMANDS ARE DIRECTED TO NOTIFY THE APPROVING AUTHORITY ONCE THE WAIVER/EXCEPTION DEFICIENCY(IES) HAS BEEN CORRECTED AND THE REQUIREMENT NO LONGER EXISTS.
5.M.  WAIVERS OR EXCEPTIONS WILL NOT BE GRANTED FOR NEW CONSTRUCTION, MILCON PROJECTS, OR RENOVATIONS EXCEEDING THE FIFTY PERCENT THRESHOLD.
6. DEVIATION DOCUMENTATION.
6.A.  DEVIATION REQUESTS WILL BE SUBMITTED IN THE FORMAT OUTLINED IN REFERENCE A (APPENDIX C).
6.B.  EACH REQUEST WILL ADDRESS THE CONDITION, CAUSE, NEED, AND REASONS WHY APPLICABLE STANDARDS CANNOT BE MET.
6.C.  ALL DEVIATION REQUESTS MUST PROVIDE A DETAILED DESCRIPTION OF THE IMPACT ON MISSION AND ANY OTHER PROBLEMS THAT WILL INTERFERE WITH SAFETY OR OPERATION REQUIREMENTS IF THE DEVIATION REQUEST IS NOT APPROVED.
6.D. ALL REQUESTS WILL INCLUDE THE MOST RECENT PHYSICAL SECURITY/CRIME PREVENTION SURVEY FOR THE AFFECTED FACILITY.
7.  CENTRAL REPOSITORY FOR APPROVED/DENIED DEVIATION REQUESTS.
7.A.  THE DC, PP&O WILL MAINTAIN A CENTRAL REPOSITORY OF ALL WAIVERS AND EXCEPTIONS TO PHYSICAL SECURITY/CRIME PREVENTION REQUIREMENTS.
7.B.  ACCESS TO THE CENTRAL REPOSITORY WILL BE MANAGED BY THE DC, PP&O.  DC’S, COMMARFORS, COMMCICOM WILL BE GRANTED ACCESS TO THE CENTRAL REPOSITORY AS IT RELATES TO THEIR RESPECTIVE AOR.
7.C.  COMMARFORS WILL FORWARD APPROVED GCC DEVIATIONS TO THE DC, PP&O FOR CONSOLIDATION INTO THE CENTRAL REPOSITORY.
8.  ANY QUESTIONS REGARDING THIS MARADMIN NEED TO BE DIRECTED TO THE MESSAGE POINTS OF CONTACT.
9.  SIGNAL.  THIS MARADMIN IS APPLICABLE TO THE TOTAL FORCE.
10.  RELEASE AUTHORIZED BY LIEUTENANT GENERAL RONALD L. BAILEY, DEPUTY COMMANDANT, PLANS, POLICIES, AND OPERATIONS//