Monthly Archives: July 2019

CFATS PSP for Tier 3 and 4 Facilities

On July 9, 2019, the DHS Cybersecurity and Infrastructure Security Agency (CISA) published a notice in the Federal Register that announced the implementation of the Personnel Surety Program for all cover CFATS facilities, including Tier 3 and 4 facilities. Regulated CFATS facilities that have an approved SSP/ASP, will be notified by the Agency in a phased manner of the need to update their security plans with measures to comply with RBPS 12(iv).

To read more about the PSP requirements, click here and here.

To download a copy of the notice, click here.

Contact us if you need help revising your SSP/ASP and implementing your Personnel Surety Program.

SEAFARERS ACCESS TO MARITIME FACILITIES

On April 1, 2019, the USCG issued a final rule, “Seafarers Access to Maritime Facilities” requiring owners or operators of a maritime facility regulated by the Maritime Transportation Security Act (MTSA) to implement a system providing seafarers, pilots, and representatives of seamen’s welfare and labor organizations access between vessels moored at the facility and the facility gate. Access between the vessel and the gate has to be provided in a timely manner and at no cost to the seafarer or other individuals.

These access procedures must be documented in the Facility Security Plan (FSP) for each regulated Part 105 facility and approved by the local Captain of the Port (COTP). Facility owners or operators will need to amend or update their FSP to ensure that they are in compliance with these requirements. The COTP will then review the submitted amendments to ensure they are in compliance with the requirements listed in 33CFR105.237 (c)-(e).

Important dates associated with the regulation:

  • May 1, 2019 – Seafarers’ Access to Maritime Facilities regulation became effective;
  • February 3, 2020 – The system of access must be documented in the FSP; and,
  • June 1, 2020 – The facility owner or operator must implement their system of access.

33CFR105.237 (c)-(e) Requirements:

(c) Timely access

(d) Access methods

(e) No cost to individuals