On February 15, 2019 DOD issued a final rule, effective immediately amending the DFARS to implement the requirement for contractors to complete Level I anti-terrorism awareness training.  On August 24, 2018, DOD issued a proposed rule that created a new subpart in the DFARS to advise contracting officers of the training requirement, the authorized sources of training, and when contractors must complete training.  This subpart, now at DFARS 252.204-7004, “DOD Anti-terrorism Awareness Training,” is now required for use in solicitations and contracts when contractors’ personnel require for use in solicitations and contracts when contractor personnel require routine physical access to a federally controlled facility or military installation.  There is not exemption for the acquisition of commercial items. The new DFARS clause advises contractors of the training requirements, provides a reference to additional information and the guidance available on the internet, and instructs contractors to include the clause in all subcontracts.  

The rule intended to ensure that contractors that required routine physical access to federally controlled facilities or military installations as a condition of contract performance are aware of the requirement for contractor personnel to complete Level I DOD anti-terrorism awareness training.  The training is required within 30 days of requiring access and annually thereafter and must be completed either through the DOD-sponsored and certified computer or web-based distance learning instruction or under the instruction of a qualified Level I anti-terrorism awareness instructor. 

Reference:  Contract Management magazine pg. 69 /April 2019 edition

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