By Ed Page, Executive Director, Marine Exchange of Alaska
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By now many of us have read considerable complex regulations, Navigation and Vessel Inspection Circulars (NVICs) and policy letters regarding the implementation of the International Ship and Port Facility Security Code (ISPS) and the Maritime Transportation Security Act (MTSA) and welcome a clear, straightforward summary of what needs to be done to pass muster. Simply said, here’s what you need to do to meet the new Maritime Security Regulations to avoid the risk of being subject to penalties or being shut down for non-compliance.

VESSELS

To ensure you meet the Coast Guard’s requirements including the on board validation inspections that will be conducted this summer I recommend the following.

Plans:

1. Ensure you respond to any feedback from the Coast Guard on your plan(s) and make any changes required in time to meet the compliance date. At the end of the process you should have both an approved Plan and an International Ship Security Certificate (ISSC) issued by the Coast Guard (46 CFR 2.05) as required by IMO.

2. Ensure “approved Vessel Security Plans” are held by the Company Security Officer and the Vessel Security Officer for each vessel required to have a “Plan”.

3. Ensure appropriate entries are made in your Plan or other Records for MARSEC level changes, training held, drills and exercises, security incidents, Declarations of Security (DoS) and testing of security equipment.

4. Ensure Security Audits are conducted annually and copies retained and entries made. An initial security audit before 1 July 04 would be a good idea.

Training:

1. Ensure the Company Security Officer (CSO) Vessel Security Officer and others on the crew receive some level of training and understand what the MARSEC levels are, what security measures are required at each level as outlined in the vessel’s plan, and what Coast Guard MARSEC directive is in effect and how it impacts your vessel’s security measures.

2. Ensure the CSO, VSO and crew are familiar with the Vessel’s Security Plan, the processing of Declarations of Security and reporting of incidents.

Drills and Exercises:

1. Conduct some type of security drill before 1 July 04 and make an entry in your records about the drills, lessons learned, etc. The drill could simply entail having the crew address a fictitious suspicious activity such as delivery of unanticipated ship stores.

Signage, Equipment and Security Measures:

1. Ensure signs are posted identifying “Restricted Areas” and other signs that reflect Security Measures are in effect and screening may be conducted. The recommended signage at the end of this article can be modified for vessels.

2. Ensure barriers, locked spaces, sensors and other security measures identified in the Vessel Security Plan are complied with, operational and in place.

3. If the vessel is subject to the SOLAS regulations, ensure a Ship Security Alert System (SSAS) is installed an operational as per the installation time frames outlined in the ISPS code or NVIC 03-03.

4. Ensure a Continuous Synopsis Record is received from the Coast Guard, carried on board and updated as required.

Declaration of Security:

1. Where required, ensure a DoS is processed, the measures agreed to are followed and copies of the DoS are retained.

FACILITIES

To ensure you meet the Coast Guard’s requirements including the on site validation inspections that will be conducted this summer, I recommend the following.

Plans:

1. Ensure you respond to any feedback from the Coast Guard on your plan and make any changes required in time to meet the compliance date.

2. Ensure “approved Facility Security Plans” are held by the Facility Security Officer.

3. Ensure appropriate entries are made in your Plan or other Records, for MARSEC level changes, training held, drills and exercises, security incidents, Declarations of Security (DoS) and testing of security equipment.

4. Ensure Security Audits are conducted annually and copies retained and entries made. An initial security audit before 1 July 04 would be a good idea.

Training:

1. Ensure your Facility Security Officer (FSO) and others at the facility who have security responsibilities receive some level of training and understand what the MARSEC levels are, what security measures are required and what Coast Guard MARSEC directive is in effect and what it entails for your facility’s operation.

2. Ensure the FSO and other facility personnel are familiar with the Facility’s Security Plan, the processing of Declarations of Security and reporting of incidents.

Drills and Exercises:

1. Conduct some type of security drill before 1 July 04 and make an entry in your records about the drills, lessons learned, etc. The drill could simply entail having the crew address a fictitious suspicious activity such as the discovery of an unauthorized person on the facility.

Signage and Security Measures:

1. Ensure signs are posted identifying “Restricted Areas” and other signs that reflect Security Measures are in effect and that screening may be conducted. The entrance to the facility should clearly indicate this.

2. Ensure barriers, locked spaces, sensors and other security measures identified in the Facility Security Plan are complied with, operational and in place.

Declaration of Security:

1. Where required, ensure a DoS is processed, the measures agreed to are followed and copies of the DoS are retained.

SIGNS

With respect to signage, I suggest something to the effect of what is outlined below modified as appropriate to a vessel or a facility.

The regulations require the following:

“Conspicuously post signs that describe security measures currently in effect and clearly state that:

(i) Entering the facility is deemed valid consent to screening or inspection; and

(ii) Failure to consent or submit to screening or inspection will result in denial or revocation of authorization to enter;”

and

“The facility owner or operator must ensure restricted areas are designated within the facility. They must also ensure that all restricted areas are clearly marked and indicate that access to the area is restricted and that unauthorized presence within the area constitutes a breach of security.”

In light of the above, the following signage is recommended for posting at facilities:

Placement at entrance(s) to facility the following 3’ high, 4’ long sign:

With respect to “Restricted Areas” of a facility the following signage is recommended with dimensions of 2’ high and 3’long

I also recommend the above signs be posted at the dock approach areas when a vessel is approaching the pier, berthed or engaged in transfer operations subject to the Maritime Security Regulations.

Additionally, I recommend the following sign of approx 18” by 30” be posted at the entrance to the facility.

If you do all of the above your vessel or facility should meet the Coast Guard requirements and more importantly, provide a level of increased deterrence and detection of Transportation Security Incidents and ensure incidents can be readily reported to the Coast Guard.