Monthly Archives: October 2016

TSA Inspectors at MTSA Facilities? – Happening Now

The USCG has issued Marine Safety Information Bulletin (MSIB) 01-16 that specifies that TSA inspectors will be accompanying USCG inspection personnel when inspecting MTSA regulated facilities to verify TWIC compliance. Some of our clients have already experienced this.

The USCG is the lead agency for enforcement for MTSA regulated vessels and facilities, and TSA is the lead agency to pursue civil enforcement against individuals engaged in TWIC credential alteration and fraudulent use. The USCG implements its TWIC Enforcement Program at regulated vessels and facilities to ensure that TWIC programs are in compliance with approved Vessel and Facility Security Plans. The USCG verifies this onsite during inspections both visually and with the use of handheld portable TWIC readers.

TSA’s Office of Security Operations has initiated a field inspection program for their Transportation Security Inspectors-Surface (TSI-S) to conduct visual and electronic TWIC inspections at MTSA regulated facilities. It is anticipated, at least initially, that the TSI Inspectors will accompany Coast Guard personnel during Coast Guard led security inspections. However, the TSA has the authority to conduct inspections independently and should be provided relevant portions of the FSP in the areas of TWIC compliance and overall access control.

It is important to remember that ensuring that only authorized TWIC holders desiring unescorted access into Secure Areas of the vessels and facilities remains the responsibility of the VSO/FSO.

DHS Reinstates Top Screen Requirements

On October 1, 2016, DHS has reinstated the requirement to submit Top Screens using CSAT 2.0.

Starting today, October 4, 2016, DHS will begin notifying facilities that they have to submit a new Top Screen. However, facilities may choose to proactively resubmit a Top Screen prior to receiving notification from DHS.

Facilities are given 60 days to submit a new Top Screen.

To read more about CSAT 2.0, click here.