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Request for Information for the National Integration Center

Solicitation Number: HSFEEM-11-RFIEC
Agency: Department of Homeland Security
Office: Federal Emergency Management Agency
Location: Preparedness Branch
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HSFEEM-11-RFIEC
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Special Notice
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Added: Apr 21, 2011 10:47 am
 

Synopsis:


Request for Information (RFI) to support the Department of Homeland Security (DHS), Federal Emergency Management Agency's (FEMA) National Integration Center (NIC) to inform the structure and management of a Self-Declaration of Conformity (SDOC) process for small businesses as part of the Voluntary Private Sector Preparedness and Accreditation Program (PS-PrepTM).


 


NO PHONE CALLS PLEASE. ALL QUESTIONS MUST BE IN WRITING AND EITHER MAILED, FAXED OR EMAILED TO THE POINT OF CONTACT LISTED BELOW.


 


Objective:


The objective of this RFI is to solicit information and ideas regarding the optimal approaches to developing and managing SDOC for small business entities as part of PS-PrepTM. This is a sources-sought synopsis for information and planning purposes for PS-PrepTM.  The responses to this RFI will be used for informational purposes only.


 


This is not a solicitation.  This notice does not constitute a Request for Proposal, nor does it restrict the Government as to the ultimate acquisition approach, nor should it be construed as a commitment by the Government.  The Federal Emergency Management Agency (FEMA) National Integration Center (NIC) is neither seeking nor accepting unsolicited proposals.  DHS will not pay for information solicited. Since this is a sources-sought announcement, no evaluation letters and/or results will be issued to the respondents. However, DHS may issue a Request for Proposal (RFP) as a result of responses to this RFI.


 


DHS identifies managing entity(ies) as one or more professional organizations, businesses, and/or non-profit organizations selected to develop and manage the process to identify and orient participants to conformity assessment using a self declaration process, support their use of related web-based systems, and assess and confirm their convergence with International Organization for Standardization/International Electrotechnical Commission standard 17050, Parts 1 and 2. The managing entity(ies) will also establish a system for managing the integrity of the SDOC process, execute user partnership agreements, and randomly verify the authenticity of attestations in accordance with the adopted standards. In addition, the managing entity(ies) will ensure  that the PS-PrepTM provides low-cost alternative for standards conformity to small business.


 


Following a review of the responses received from this request, the government may issue an RFP that will establish the requirements for the management of the SDOC process for PS-PrepTM.  The government expects to license the use of the PS-PrepTM trademark to recognized participants who self-attest conformity to one or more of the DHS adopted PS-PrepTM standards, and empower the entity(ies) to issue the mark. The contractor will be allowed to assess and collect a fee for services performed from the participants self-attesting conformity.  Consequently, the government does not envision paying a direct fee to the contractor.


 


Background:


The Voluntary Private Sector Preparedness Accreditation and Certification Program (PS-PrepTMis mandated by Title IX of the Implementing Recommendations of the 9/11 Commission Act of 2007. Congress directed DHS to designate one or more standards for assessing private sector preparedness. The standards will be used by accredited certification bodies to assess private sector preparedness and planning in the areas of organizational resilience, disaster management, emergency management and business continuity programs.  The purpose of PS-PrepTMis to enhance nationwide resilience in the all-hazards environment by fostering a culture of greater private sector preparedness. PS-PrepTMprovides a mechanism for a private sector entity-a company, facility, not-for-profit corporation, hospital, stadium, university, etc.-to take the preparedness action required by one of the DHS selected standards. The two methods of participation currently envisioned for PS-PrepTM are: (1) self-declaration of conformity, and (2) third party certification.  The option of making a self-declaration will be available to small business participants, defined pursuant to 15 U.S.C. 632, and other non-governmental entities with fewer than 500 employees that do not meet the requirements of 13 CFR part 121 and 15 U.S.C. 632.  All other private sector entities will be eligible for third party certification. Entities that are in compliance with one of these methods will be recognized by DHS under PS-PrepTM.  PS-PrepTMrecognition is still under consideration and more information will be provided in subsequent announcements or notices. Title IX requires that DHS consider the needs of small business, specifically to encourage small business participation in PS-PrepTM, by creating separate classifications and methods of certification for small businesses.


 


Public meetings were held and criteria established to identify the standards that most represented the preparedness goals of PS-PrepTM. After a public comment period, the following three standards were formally adopted in June 2010: 


•1.       ASIS SPC.1- 2009,


•2.       BS25999, and


•3.       NFPA 1600 2007 and 2010.


 


Small Business and Self Declaration:


According to the Small Business Administration, small business contributes significantly to U.S. economic well-being.  Small business, generally defined as those with fewer than 500 employees, totaled 27.3 million and accounted for nearly 50 percent of all private sector jobs in 2008. 


 


Considering the resources required to obtain third party certification for small business, alternative methods for conformity might be needed to promote preparedness for small business.  Congress directed DHS to establish separate classifications and methods of certification for small business. Such processes must be complementary to third party certification and make use of existing preparedness programs,  including those that currently support preparedness for small business. The SDOC process provides a less costly option for small businesses, allowing organizations to declare compliance to a standard without an independent certification from a third party. 


 


Summary of the Functional Requirements for SDOC Management:


DHS has indentified six functional requirements necessary for the creation, implementation, and management of the PS-PrepTM SDOC process. 


 


1.            Knowledge of the SDOC Process


Participants will require background and introductory information on the SDOC process prior to the selection and implementation of a self-declaration. Useful knowledge may include (a) eligibility requirements, (b) terms and responsibilities of participation, (c) business justification for participation, (d) answers to frequently asked questions, and (e) guidance on where to obtain more information related to self-assessment and preparedness.


 


2.            Clear Roles and Responsibilities


PS-PrepTM will clearly establish the expectations and obligations for all parties developed in the SDOC process. Roles and responsibilities for which clarification are most necessary include (a) eligibility requirements, (b) any and all obligations assumed by the entity making a self-declaration of conformity, (c) the managing entity(ies) to which self-declarations of conformity will be made, (d) the process to conduct a self-assessment and later self-declare conformity to a standard, and (e) any and all obligations assumed by the managing entity(ies) in connection to those that successfully declare conformity to a preparedness standard.


 


3.            Clearly Defined Standards Requirements


PS-PrepTM will establish the standards requirements in plain language to assist participants in determining their suitability to make a self-declaration of conformity. The standards requirements (checklist) should identify (a) the specific expectations of the adopted standards, and (b) acceptable responses (e.g., "best practices") to meet those expectations.


 


4.            Participant Recognition


To fulfill the requirements of Public Law 110-53 and provide a business justification for participation, PS-PrepTM will require a process and mechanism for formally recognizing SDOC completion, recording this achievement, and ensuring the fair use of recognition materials. This will provide both (1) metrics by which to evaluate PS-PrepTM SDOC process success; (2) preservation of brand value and PS-PrepTM SDOC process credibility.


 


5.            Conformity Verification


To preserve the integrity of the PS-PrepTM SDOC process ,  managing entity(ies) must determine whether all parties  involved in the SDOC process are fulfilling applicable expectations, requirements, and obligations, and take corrective action where required. This process can also be called integrity management.


 


6.            SDOC Validation


To serve the national interest, the PS-PrepTM SDOC process must determine whether it has successfully provided a low-cost method for conformity assessment consistent with the adopted standards and the goals of PS-PrepTM. This will require an understanding of the national preparedness objective, the state of national preparedness at the time of an assessment, and the overall impact of PS-PrepTM SDOC process activity on national preparedness efforts, including but not limited to direct participation in standards conformity.


 


SDOC Registration and Orientation:


The managing entity(ies) shall provide a registration process, background and introductory material on the SDOC to prepare small business to use the system. Registration shall be required to determine participant eligibility to use SDOC as a method of certification under PS-PrepTM, consistent with definition of small business outlined above, and other descriptive information such as the type of business and location. The managing entity(ies) shall provide a government-approved orientation intended to prepare participants for the self-declaration process which should include at a minimum: (a) a business justification detailing estimates of organizational cost to comply with standards; (b)  guidance for selecting different conformity assessment and third-party certification options; (c) terms and responsibilities for participation in the SDOC process; (d) frequently asked questions; (e) guidance on where to obtain additional information on subjects related to self assessment and preparedness; and (f) common elements of adopted standards such as PS-PrepTM SDOC process policies and management, analysis, planning, implementation, testing and evaluation, and maintenance, review, and improvement.


 


Roles and Responsibilities:


The managing entity(ies) will develop an agreement with the participant that outlines the respective roles and responsibilities of each.  The obligations in any agreement between the managing entity(ies) and participants should be based on conventional requirements of SDOC processes found in the marketplace.  The managing entity(ies) should expect PS-PrepTM to mature over time. Any changes to PS-PrepTM will be reflected in the SDOC process.  The agreement should include:  (a) obligations assumed by the entity making self declaration of conformity to a standard; (b) the entity to which the conformity assessment is being made; (c) the process to conduct a self assessment and self declaration of conformity; and (d) obligations assumed by the managing entity(ies) in connection to those that successfully declare conformity to a preparedness standard.


 


The managing entity(ies) will (a) develop the process of self-declaration of conformity to one or more DHS-designated PS-PrepTM standards, consistent with ISO/IEC 17050, Parts 1 and 2.  Preference will likely be given to any entity(ies) that (a) offer a process that meets the requirements for all adopted standards, (b) provide a certificate to participants, using the PS-PrepTM mark, who successfully attest to conformity, (c) conduct periodic and random checks of small businesses that self-declare as a means of upholding the integrity of the PS-PrepTM SDOC process, (d) maintain appropriate records of those self-declaring, (e) share related statistics with DHS and (f) take corrective action for noncompliance. DHS will provide the essential elements that need to be included in the self-declaration of conformity certification as well as a trade mark license for selected managing entity(ies) to use in issuing certifications of compliance.


 


Data Integrity and Reporting:


The managing entity(ies) will be responsible for maintaining a record of participants who have received certification. This record will not be made public unless approved by the participant.  The managing entity(ies) will be expected to safeguard any personal identifiable information received from PS-PrepTM SDOC process stakeholders, maintain records of all documentation associated with the PS-PrepTM SDOC process and report agreed upon results of the PS-PrepTM SDOC process to DHS on a quarterly basis.


 


Issuance of the Mark:


DHS shall provide a mark for use by small businesses that have successfully self-declared to a DHS-designated PS-PrepTM standard; recognition that shall be different in substance and form from the mark private sector entities will receive for being assessed by an accredited third party certifying body. The conformity assessment shall be valid for a period not to exceed 3 years from the date of the original self-declaration. As a consequence the authority to use the PS-PrepTM mark associated with SDOC process shall also expire after 3 years from the date of the self-declaration, unless and until the small private sector entity(ies) has reassessed its preparedness level and self-declared conformity to the current edition of one of the PS-PrepTM adopted standards. The mark shall not be transferable either within an organization (across divisions) or between organizations and shall only apply to those parts of an organization that have been included in the self-declaration of conformity process.


 


Mark Representation:


The managing entity will have a system to maintain the integrity of the self-declaration of conformity process that will reduce and potentially eliminate misrepresentation of compliance or misuse of PS-PrepTM SDOC process recognition. The managing entity will be expected to have an electronic mechanism whereby organizations could pass on allegations of non-conformity by small businesses that self-declare and a system for confirming those allegations. DHS will provide guiding principles for minimum integrity management activities.


 


Branding and Marketing:


DHS intends to develop a branding and promotional marketing campaign for PS-PrepTM to include messaging to small business through a variety of venues including outreach to media outlets, use of social media, public service announcement and information provided at events, conferences, and through other educational material.


 


Information Requested:


In an effort to understand the industry's knowledge of and opinions on SDOC process management, DHS is soliciting ideas concerning the optimal approaches to developing and managing PS-PrepTM Self Declaration of Conformity. DHS requests answers to the following questions that may assist in the development of qualifications and requirements for entities interested in defining and managing the SDOC process.


 


Specific Questions:


•1.       Explain concerns, questions, or issues about the goals of SDOC (including DHS's expectation not to provide direct compensation to the SDOC managing entity(ies)), and the expected roles and responsibilities of participants and/or the managing entity(ies).


•2.       Explain concerns, questions, or issues about DHS's expectation not to provide direct compensation  to the SDOC managing entity(ies).


•a.       Given the absence of direct compensation from DHS, what period of performance should the contract consider for the managing entity(ies) and why.


•3.       Identify additional requirements beyond those presented within this RFI that should be included in the PS-PrepTM SDOC process.


•4.       Once managing entity(ies) take responsibility for the SDOC process management, are there other suggestions related to DHS's role and responsibility in program management, in  addition to those outlined in this RFI?


•5.       What methods of post-market surveillance should the managing entity(ies) be expected to employ to ensure  a high level of confidence in the PS-PrepTM self-declaration of conformity program?


•a.       How should the managing entity(ies) demonstrate  that the declaring entity tested/reviewed its compliance process and integrated the necessary changes to warrant declaration?


•b.      What type of post-market surveillance is appropriate?


•c.       How often should post-market surveillance occur?


•d.      What percentage of PS-PrepTM SDOC process participants should be subject to post-market surveillance?


•6.       What should be the corrective actions for non-compliance, as  a result of post-market surveillance activities? 


•a.       What types of non-compliance would require corrective action?


•b.      What types of corrective actions would be appropriate?


•7.       In selecting a managing entity what should be the priorities for expertise?


•a.       Knowledge of and experience with the DHS adopted standards;


•b.      Use and familiarity with SDOC processes; or


•c.       Other considerations.


•8.       DHS will use the ISO/IEC standard 17050-1 to provide the framework for managing the PS-PrepTM SDOC process. 


•a.       How would the proprietary interests of the declaring entity protected?


•b.      What supporting documentation will be submitted by the declaring entity?


•c.       How will this information managed and protected by the managing entity(ies)?


•9.       What capabilities should the managing entity(ies) have for developing and providing resources (personnel, orientation material, process guidance, technical support, etc.) to support PS-PrepTM SDOC process participants that want to self-declare?


•10.   To further assist DHS with understanding the cost implications to small businesses for participating in this SDOC process, what costs would a small business potentially incur by participating in the SDOC process (both internal activity costs and process participation costs)?


 


All responses to this RFI should be received by  May 13, 2011.  All submittals should be submitted by email to _erin.cotter@dhs.gov.  


 


Alternate Point of Contact:


                Marcus Pollock


 


Email:                    marcus.pollock@dhs.gov


 


Phone:                                 301-646-2801


Fax:                       


 


Mailing:                999 E. St. NW


Washington, DC, 20472


 


IMPORTANT:  PLEASE USE THE ATTACHED TEMPLATES IN COMPLETING YOUR SUBMISSION. 

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Template for Submission of Response

Type:
Other (Draft RFPs/RFIs, Responses to Questions, etc..)
Label:
Template for Submission of Response
Posted Date:
April 21, 2011
Description: Template for Submission of Responses
:
Office of Acquisition Management
16825 South Seton Avenue
Emmitsburg, Maryland 21727
United States
:
Erin Cotter
Phone: 3014471921
:
James Chestnut,
Contracting Officer
Phone: 301-447-1412
Fax: 301-447-1242