ISOO Notice 2021-01 GSA Black Label Phase Out

By Colene King

At the beginning of this year, GSA (General Services Administration) along with the Information Security Oversight Office (ISOO) developed a 4-year phase-out plan for all GSA-approved black label security cabinets and vault doors manufactured prior to 1989. The phase-out is set to begin on October 1st 2024 and be completed by October 1st 2028. These black label containers cannot be recertified or relabeled; they will become obsolete. See chart below for details.



GSA ClassFed SpecRevision Years
Produced
Years of
Service
End of Service
1AA-F-357A-F1968 – 198246 – 601 October 2028
2AA-F-357 A-F 1954 – 197050 – 701 October 2024
3AA-F-358 A-F 1956 – 196852 – 691 October 2025
4AA-F-358 A-F 1956 – 1968 52 – 691 October 2025
5AA-F-358 A-F 1968 – 198931 – 601 October 2028
5AA-F-363A-B1963 – 198957 – 65 1 October 2028
5AA-D-600A-B 1963 – 1989 57 – 65 1 October 2028
6AA-D-600A-C 1963 – 1989 57 – 65 1 October 2028
6AA-F-358 A-F 1963 – 1989 52 – 60 1 October 2028

The process commences with phasing out black label Class 2 cabinets; these Class 2 cabinets must be replaced by October 1, 2024. Class 3 and Class 4 must be replaced by October 1, 2025. Lastly, all other black label containers (class 5 and class 6) and GSA approved vault doors will lose their GSA approval by October 1, 2028.




The regulation of containers to meet GSA guidelines began in 1954, with some of these items having been in continuous use since their implementation. Over the years, these containers degrade and can become a liability. Specifically, those manufactured between 1954 and 1989 are considered to be past their life expectancy. These black label containers and vault doors are now between 30 and 70 years old.   As we all know, it’s not easy getting old.


There are several things to be concerned about with these aging containers and vault doors. Not only are you minimizing the protection of your property, but you could potentially set yourself up for a costly container lockout, which would require a GSA locksmith. It should also be mentioned that several of the manufacturers that created these containers are no longer in operation, and many of the container parts (drawer heads, locks, slides, handles, etc.) needed for the repair of these products are no longer available.


The soon to be outdated GSA approved containers and vault doors are easily recognizable by the silver and black GSA approval label located on the outside of the cabinet or vault. (See picture below) Each container/door should also include the certification labels and manufactured dates.



Here at KL Security, we are able to provide the most up to date GSA approved containers and vault doors. We offer full replacement cabinets for Black Label GSA Containers that will be considered obsolete in the near future.



 Below is a list of all current GSA Requirements:


Class 5 GSA Approved Container requirements 

  • The Class 5 is an uninsulated security container
  • 20 man-hours against surreptitious entry (increased from 30 man-minutes on containers produced after March 1991)
  • 10 man-minutes against forced entry
  • 20 man-hours against manipulation of the lock
  • 20 man-hours against radiological attack
  • 30 man-minutes against covert entry (added to containers produced after March 1991)


    Class 6 GSA Approved Container requirements 

  • The Class 6 is an uninsulated security container
  • 20 man-hours against surreptitious entry (increased from 30 man-minutes on containers produced after March 1991)
  • no forced entry test requirement
  • 20 man-hours against manipulation of lock
  • 20 man-hours against radiological attack
  • 30 man-minutes against covert entry (added to containers produced after March 1991)

Now would be a great time to formulate a company plan for container and vault replacement.

Call 866-867-0306 or email [email protected]


Sources

Removal of GSA Approved Black Label (archives.gov)

NISPPAC meeting April 14, 2021 (archives.gov)

Safe & Vault | History of GSA Containers | Class 2 | Class 3 | Class 4 | Class 5 | Class 6 (safeandvault.com)

GSA Approved Security Containers (navy.mil)


Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. The information contained in this site is provided for informational purposes only.

Storage of Monetary Funds: Changes and Updates


The storage requirements of secured monetary funds has been updated and revised in 2018 by the U.S. Department of Defense. These updates and revisions are summarized below and can be found in Department of Defense 7000.14-R Financial Management Regulation Volume 5, Chapter 3. The DoD administrative revisions—hyperlink format and updated policy memo—are not noted below.


In DoD 7000.14-R, a subparagraph has been amended to provide a little more clarification on determining cash requirements than in the previous version. Specifically including “managing foreign government contributions (burdensharing funds)” as a type of disbursement.


In addition to this revision, there have been two additions to DoD 7000.14-R. The first and most significant addition is a section on the establishment of the DoD’s Treasury Account Symbol (TAS) for disbursing officer (DO) cash to a cash/investment account that is outside of the U.S. Treasury. Both the Office of Management and Budget and the Treasury determined that TAS needs to be recorded for non-fiduciary, non-budgetary activities with government/federal sources or funds.


A TAS is created for each DoD component to “document the balance of DO cash held outside the Treasury.” Defense Finance and Accounting Services (DFAS) uses monthly SF 1219 data to report the DO cash to the proper Treasury Account Symbol. Below are the TASs for disbursing officer cash.


  1. 017 X 6950 disbursing officer cash: Department of Navy
  2. 021 X 6951 disbursing officer cash: Department of Army
  3. 057 X 6952 disbursing officer cash: Department of Air Force
  4. 097 X 6953 disbursing officer cash: Defense Agencies
  5. 096 X 6954 disbursing officer cash: Corps. Of Engineers (Civil)

The second addition ties in with the burdensharing revision mentioned above. An example is given at the end of the 7000.14-R for Foreign Currency Cash or Limited Depositary Account (LDA) Balance Requirements. A “Burdensharing Funds (If Applicable)” row has been added to the table.

Monetary Funds Lock and Storage Requirements

The monetary funds lock and storage requirements listed in DoD 7000.14-R remains unchanged from the previous version which are listed below.


  • Funds less than $7,500
    • Lock requirement(s): UL Std 768, Group 1R
    • Storage requirements: Vault (must be fire-resistant for two hours), Burglary resistant safe (if vault isn’t available), Class 5 GSA-approved container
      • Note: If GSA-approved container has been manufactured after 2007, it must have a FF-L-2740 or FF-L-2937 lock
  • Funds greater than $7,500 but less than $50,000
    • Lock requirement(s): UL Std 768, Group 1R
    • Storage requirements: Burglary resistant safe with UL TL-15 rating, Class 5 GSA-approved container
  • Funds greater than $50,000
    •  Lock requirement(s): UL Std 768, Group 1R
    • Storage requirements: Burglary resistant safe with UL TL-30 rating, Vault (must be fire-resistant for two hours)
X-10 Lock for GSA Approved Containers and Safes

Call 866-867-0306 or email [email protected]


Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. The information contained in this site is provided for informational purposes only.