Contract Security Classification Specification DD-254 Guidance
DD 254 Roadmap Justification Step by Step Common DSS findings
Why a DD-254? The document provides the basis for a contractor to have a facility clearance (FCL) and have access to classified information. DD-254 is the GCA s direction for how to handle classified at the contractor s location. The document may be the only classification guidance provided to a contractor for a government contract. The document may be used by a contractor to flow down classified requirements to a cleared sub-contractor or use as a basis to sponsor an uncleared sub-contractor. The DD-254 can be used to have GCA s concurrence when a contractor needs to flow down certain information to a sub-contractor, i.e. NATO, COMSEC, Top Secret, SAP, SCI, CNWDI. DD-254s can be classified or unclassified as required. Normally they are unclassified.
DEPARTMENT OF DEFENSE CONTRACT SECURITY CLASSIFICATION SPECIFICATION (The requirements of the National Industrial Security Program Operating Manual apply to all security aspects of this effort) 1. CLEARANCE AND SAFEGUARDING a. FACILITY CLEARANCE REQUIRED: SECRET b. LEVEL OF SAFEGUARDING REQUIRED: N/A Block 1b is checked N/A. This indicates that there will be no classified work performed at the sub-contractor s cleared facility. If this block is N/A blocks 11b, c, and d should be checked NO.
2. THIS SPECIFICATION IS FOR: ( and complete as applicable) a. PRIME CONTRACT NUMBER b. SUBCONTRACT NUMBER c. SOLICITATION OR OTHER NUMBER Due Date (YYYYMMDD) Block 2a should show the Prime Contract number but should not be checked for a sub-contract DD-254. Block 2b should be checked and show the subcontract number. Block 2c is normally not used with a sub-contract.
3. THIS SPECIFICATION IS: ( and complete as applicable) a. ORIGINAL (Complete date in all Date cases) (YYYYMMDD) b. REVISED (Supersedes all previous specs) Revision No. Date (YYYYMMDD) c. FINAL (Complete item 5 in all cases) Date (YYYYMMDD) Block 3a should be checked and show the date the original DD-254 was signed. Block 3b should be checked if it is a revised DD-254, show a revision number and a date that the revision was issued. Block 3a in a revised DD-254 should show the original date of the DD-254 but with no check mark.
4. IS THIS A FOLLOW-ON CONTRACT? [ ] YES [ ] NO, If yes, complete the following Classified material received or generated under N00189-02-D-0037 (Preceding Contract Number) is transferred to this follow-on contract 5. IS THIS A FINAL DD FORM 254 [ ] YES [ ] NO, If yes, complete the following: In response to the contractors request dated,retention of the identified classified material is authorized for a period of: These two blocks are self-explanatory.
6. CONTRACTOR (Include Commercial and Government Entity (CAGE) Code) a. NAME, ADDRESS, AND ZIP Your Company 123 Wherever Drive Dallas, T 75000 b. CAGE CODE 12345 c. COGNIZANT SECURITY OFFICE (Name, Address, and Zip Code) DEFENSE SECURITY OFFICE (IOFSI) 5800 East Campus Circle Drive, STE 218A Irving, T 74063 7. SUBCONTRACTOR a. NAME, ADDRESS, AND ZIP b. CAGE CODE c. COGNIZANT SECURITY OFFICE (Name, Address, and Zip Code) N/A 8. ACTUAL PERFORMANCE a. LOCATION b. CAGE CODE c. COGNIZANT SECURITY OFFICE (Name, Address, and Zip Code) SEE BLOCK 13 Blocks 6a, b, & c should show the prime contractor s name, cage code and CSA. Blocks 7a, b, & c should show the sub-contractor s name, cage code and CSA. Blocks 8a, b, & c should show the actual place of performance. If it this a Military base then the cage code is left blank and the CSA will be a military Security office. The Military normally has security cognizance on military installations. Block 8 can have See attached or See Block 13 if there are multiple places of performance.
9. GENERAL IDENTIFICATION OF THIS PROCUREMENT LETHALITY TESTING AND CRITERIA DEVELOPMENT Block 9 gives an unclassified description of the work to be performed.
10.THIS CONTRACT WILL REQUIRE ACCESS TO YES NO a.communications SECURITY (COMSEC) INFORMATION b. RESTRICTED DATA c. CRITICAL NUCLEAR WEAPON DESIGN INFORMATION d. FORMERLY RESTRICTED DATA e. INTELLIGENCE INFORMATION (1) Sensitive Compartmented Information (SCI) (2) Non-SCI f. SPECIAL ACCESS INFORMATION g. NATO INFORMATION h. FOREIGN GOVERNMENT INFORMATION i. LIMITED DISSEMINATION INFORMATION j. FOR OFFICIAL USE ONLY INFORMATION k. OTHER (Specify) (CLASSIFIED IS PROCESSING) Requires GCA approval NISPOM 9-304 Blocks 10a if checked YES requires GCA approval for access to classified COMSEC NISPOM 9-407 Blocks c, e (1), and g, if checked yes require GSA approval NISPOM 9-204, 9-304, and 10-708 respectively. Block e(2) checked yes gives the contract authority to access NOFORN. Blocks 10f may require PSO approval prior to sub-contracting.
11. IN PERFORMING THIS CONTRACT, THE CONTRACTOR WILL: YES NO a. HAVE ACCESS TO CLASSIFIED INFORMATION ONLY AT ANOTHER CONTRACTORS FACILITY OR GOVERNMENT ACTIVITY b. RECEIVE CLASSIFIED DOCUMENTS ONLY c. RECEIVE AND GENERATE CLASSIFIED MATERIAL d. FABRICATE, MODIFY, OR STORE CLASSIFIED HARDWARE e. PERFORM SERVICES ONLY f. HAVE ACCESS TO US CLASSIFIED INFORMATION OUTSIDE THE U.S., PUERTO RICO, U.S. POSSESSIONS AND TRUST TERRITORIES g. BE AUTHORIZED TO USE THE SERVICES OF THE DEFENSE TECHNICAL INFORMATION CENTER (DTIC) OR OTHER SECONDARY DISTRIBUTION CENTER h. REQUIRE A COMSEC ACCOUNT (TRADITIONAL ACCOUNT) i. HAVE TEMPEST REQUIREMENTS j. HAVE OPERATIONS SECURITY (OPSEC) REQUIREMENTS k. BE AUTHORIZED TO USE THE DEFENSE COURIER SERVICE l. OTHER (specify) SEE BLOCK 13 REMARKS This sub-contract was issued for work to be performed on a military installation. Blocks 11a should be checked YES. 11c should be checked NO. Block 1b of this sub-contract is checked N/A. 11e is always be checked YES if block 11a is checked YES. 11j is checked yes and OPSEC guidance should be provided the sub-contractor by the prime contractor.
12. PUBLIC RELEASE. Any information (classified or unclassified) pertaining to this contract shall not be released for public dissemination except as provided by the National Industrial Security Program Operating Manual or unless it has been approved for public release by appropriate U.S. Government authority. Proposed public releases shall be submitted for approval prior to release. [ ] DIRECT [ ] THROUGH (Specify) Commander Naval Air Force, Atlantic to the Directorate for Freedom of Information and Security Review, Office of the Assistant Secretary of Defense (Public Affairs)* for review. *In the case of non-dod User Agencies, requests for disclosure shall be submitted to that agency. This is a self-explanatory box.
13. SECURITY GUIDANCE. The security classification guidance needed for this classified effort is identified below. If any difficulty is encountered in applying this guidance or if any other contributing factor indicates a need for changes in this guidance, the contractor is authorized and encouraged to provide recommended changes; to challenge the guidance or the classification assigned to any information or material furnished or generated under this contract; and to submit any questions for interpretation of this guidance to the official identified below. Pending final decision, the information involved shall be handled and protected at the highest level of classification assigned or recommended. (Fill in as appropriate for the classified effort. Attach, or forward under separate correspondence, any documents/guides/extracts referenced herein. Add additional pages as needed to provide complete guidance.) Block 13 is used to provide security guidance to the sub-contractor. It can also be used to show additional locations of performance and any security relevant information.
14. ADDITIONAL SECURITY REQUIREMENTS. Requirements, in addition to NISPOM requirements, are established for this contract. [ ] YES [ x ] NO (If Yes, identify the pertinent contractual clauses in the contract document itself, or provide an appropriate statement which identifies additional requirements. Provide a copy of the requirements to the cognizant security office. Use Item 13 if additional space is required.) Block 14 is used to provide additional security guidance.
15. INSPECTIONS. ELEMENTS OF THIS CONTRACT ARE OUTSIDE THE INSPECTION RESPONSIBILITY OF THE COGNIZANT SECURITY OFFICE. (If yes, explain and [ ] YES [ ] NO identify specific areas or elements carved out and the activity responsible for inspections. Use Item 13 if more space is needed.) This block provides guidance on who has security oversite of the contract or sub-contract. This block may be checked yes when there is SAP or SCI.
16. CLASSIFICATION AND SIGNATURE. Security requirements stated herein are complete and adequate for safeguarding the classified information to be released or generated under this classified effort. All questions shall be referred to the official named below. a. TYPED NAME OF CERTIFYING OFFICIAL b. TITLE c. TELEPHONE (Include Area Code) d. ADDRESS (Include Zip Code) 17. REQUIRED DISTRIBUTION e. SIGNATURE [ ] a. CONTRACTOR [ ] b. SUBCONTRACTOR [ ] c. COGNIZANT SECURITY OFFICE FOR PRIME & SUBCONTRACTOR [ ] d. U.S. ACTIVITY RESPONSIBLE FOR OVERSEAS SECURITY ADMINISTRATION [ ] e. ADMINISTRATIVE CONTRACTING OFFICER [ ] f. OTHERS AS NECESSARY These blocks are self-explanatory.
Conclusion A prime contractor can never flow to a sub-contractor greater responsibility than what is listed on the prime contract DD-254. A prime contractor can flow down lesser responsibilities. All classified work performed at a other contractor s facility or government activity is services only unless the contractor or subcontractor has a cleared facility at the other site. Do not flow down requirements to your sub-contractor if that subcontractor has no reason to have the information at that facility.
DSS Noted DD-254 Errors Contracting Officers and Contractors writing DD-254s showing that work will be on a government location or other contractor s facility but show that possessing of classified will not be required at the contractor or sub-contractor facility. Conflicting information within the DD-254s. No indication where the actual performance will conducted. No actual guidance is provided by the DD-254 to the contractor. Contractors using incorrect DD-254s received from the GCA s Contracting Officer to flow down incorrect information to the sub-contractor. Sub-contract DD-254s giving the sub-contractor more that is shown on the prime contract DD-254. Flowing down requirements to the sub-contractor that is not required or necessary. Generating prime and sub-contract DD-254s that are for unclassified work. GCA s approval to flow down to sub-contractors not granted for COMSEC, CNWDI, SCI, SAP, NATO, & LIMDIS. Requirements for DTIC, COMSEC Account, Tempest and OPSEC at the contractor s facility but really required at the remote location, i.e. government activity or other contractor s facility.
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Brought to you by: ISR Tom Morgan ISR Kathi Varner Ronald Dimicco