Suitability Assessment Program Guidance:
Visitors for short term training with Tier 1 BSAT
A visitor may visit a registered entity to receive specific training on Tier 1 BSAT. Typically in these circumstances a visitor for training (“trainee”) is hosted by another entity (the “host” entity) on a one-time basis of a limited duration for training. These individuals will have access to Tier 1 BSAT as part of their training. Their access is not specifically limited to any time period, but it is usually less than 30 days.
The regulatory requirements do not change for this situation but there are additional personnel security options. Host entities must still verify that each trainee has an SRA, is on the host entity’s registration, and has a justification for the training. Since the training involves access to Tier 1 BSAT, trainees must receive entity specific training on the host entity’s policies and procedures concerning personnel suitability, however this may be specific training for trainees and different than training for permanent employees. All personnel who have access to the Tier 1 BSAT must have gone through pre- access suitability and are subject to on-going assessments. However, with trainees, entities have options when addressing pre-access suitability and ongoing assessment.
The hosting entities have options on how to address pre-access suitability for trainees. Host entities can always enroll trainees into its pre-access suitability program. However, if that is not feasible, an entity can rely on the home entity’s checks. This may include:
- Verify with the home entity or organization that the trainee has gone through a pre-access suitability program and is subject to ongoing assessment.
- Verify with the home entity or organization that the trainee has gone through similar pre-access checks (references, employment, criminal) and accept those checks as sufficient.
- Verify with home entity which pre-access checks have been accomplished and work with the home entity to complete any checks which were not done. Hosting entities are strongly encouraged to adjudicate any new derogatory information with the home entity prior to making an access decision.
Note: The host entity can deny access to Tier 1 BSAT to any trainee if the host entity cannot verify the trainee’s status.
Options for the ongoing assessment requirement in for trainees include:
- Ensure training is monitored. For example, an instructor observes the work and verifies that the trainee in engaged only in that work.
- Limit access to the registered area. Trainees should only have access to the registered area during specific work or training times.
- Limit access within the registered areas. Trainees should not be given access to storage freezers or other registered areas not directly involved in the training program.
The host entity is responsible for maintaining records outlined in Section 17. If an entity chooses to rely on the home entity’s checks, that must be documented and retained as well.