Effective March 28, 2013, the Department of Defense issued a revised National Industrial Security Program Operating Manual (NISPOM) with significant changes. Much of these changes result from Executive Order (E.O.) 13526 “Classified National Security Information” that was issued on December 29, 2009. The resultant changes to the NISPOM were supposed to have been issued over two years ago, but who’s counting. The bottom line is that organizations holding facility security clearances must comply with virtually all of these changes to the NISPOM within 6 months of that March 28, 2013 date. The only one of these changes that cleared contractors must comply with immediately is the new section 8 of chapter 10 of the NISPOM. We address the other changes to the NISPOM below.
The Department of Defense’s summary of changes to the NISPOM is thirteen pages long! It’s also not especially user-friendly. To make cleared contractors’ and their FSOs’ jobs a bit easier, we’ve summarized these changes in a more succinct and practical fashion here:
• There are significant changes to chapter 1 of the NISPOM, however they are not changes that NISP contractors really need to mind in day to day operations. These clauses are also more for reference’s sake versus compliance-related clauses.
• Most of the compliance-related changes to the NISPOM are in chapter 4 and pertain to derivative classification and marking classified materials.
• Derivative classification entails incorporating, paraphrasing, restating, or generating in new form, information that is already classified; then marking the newly developed material consistently with the classification markings that apply to the source information. If you or your organization’s personnel perform such derivative classification, you need to read and pay close attention to these changes in chapter 4 of the NISPOM.
• The clause pertaining to classified e-mail messages (4210(b)) was rewritten, and there’s a new clause (4-214) covering classified working papers.
• The DSS now offers free, online Derivative Classification and Marking Classified Information courses via its STEPP site. These courses are a quick, convenient method to help ensure your organization’s and personnel’s compliance with the above classification and marking changes in the NISPOM.