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TWIC Reader Rule Officially Put On Hold

On August 2nd, President Trump signed into law the Transportation Worker Identification Credential Accountability Act of 2018 (HR.5729).  This formally prohibits the Coast Guard from implementing the Rule until DHS submits a satisfactory assessment of the TWIC program to Congress.

Furthermore, a U. S. District Court (Eastern, Virginia) issued a court order delaying the Rule at certain CDC facilities “until a further order of the court.”  This is in response to lawsuits from several industry groups.

We will track this activity closely and keep you all informed.

Don Greenwood

Preparing for a CFATS Compliance Inspection

Many companies aren’t prepared when they receive a letter from the DHS Infrastructure Security Compliance Division (ISCD) notifying them of an upcoming facility Compliance Inspection (CI). You might have documents that are out of date, or you may be missing the necessary forms. If left unchecked, you could be forced to waste time and money in enforcing corrective actions. When it comes to advising our clients to be prepared, these are the top three tips we give them for a successful CFATS Compliance Inspection.

Review Your Documents

When you receive a notice from DHS about an upcoming inspection, this is always a good time to review your security plan and required documents to make sure that you have everything in order. Also, this is a good time to verify that you have conducted the required drills and/or exercises, and an annual audit of the security plan.

Training Moment

Training is very important for facility personnel and this is a good opportunity to make sure all your training is up to date and to have a general discussion regarding security of the facility. The training can focus on topics that will most likely be covered during the inspection; including access control, monitoring, screening, security personnel (who is the FSO, Alt. FSO?), NTAS security measures, etc.

 Organize

One thing that we recommend and develop for majority of our clients is to have a single security plan binder with all relevant documents and forms. This is a perfect, centralized place to store and secure all the forms and documents that the inspectors will want to review during the inspection. We have had great success with these binders for all of our regulated clients; CFATS, MTSA, TSA, DOT, etc. As we tell our clients, it is best to get the inspectors the requested material in a timely fashion and get the inspection over with as quickly as possible.

Recently one of our clients had a Compliance Inspection that they passed without any issues, “We went through our security plan book while the inspector was here and we were complimented on how all the files were in one book and not in different locations.  We didn’t spend much time with it, because everything was in the binder that they had questions about.”

Let us know if we can help you prepare for your CFATS Compliance Inspection and develop a security binder for you and help you succeed with your inspections.

To read about what to expect from a CFATS CI, click here.

TSA Begins Issuing New TWIC Cards

The Transportation Security Administration (TSA) began issuing the new TWIC NexGen cards on July 10, 2018. The new cards incorporate enhanced security features (click here to read more).

Details about the new TWIC NexGen card:

  • Current TWIC card holders do not need to replace a valid TWIC card with the new TWIC card design.
  • Regulated entities that require TWIC for access will accept and recognize both the current and new TWIC designs until the card’s expiration.
  • The new card design is compatible with qualified TWIC readers.
  • To deter alteration of the card’s expiration date, the new card includes a color-coded expiration date box that will update on an annual basis.
  • The fee for the newly re-designed TWIC card remains unchanged ($125.25) and the credential is valid for five years.

Click here to read more about the TWIC NexGen cards.

Click here for a TWIC NexGen Authentication Guide

New Coast Guard Facility Inspection Form

Effective immediately, USCG facility inspectors are going to start using a new form for facility inspections. The new form, CG-835F, replaces CG-Form 835, “Vessel/Facility Inspection Requirements”. CG-835F is specifically formatted for facility inspections. There are no major changes to the new form or the information collected during the inspection.

Facility owners and operators may start seeing Coast Guard facility inspectors using the new form immediately, but some inspectors may still use the older CG-835 form during the transition.

Click here for a link to the new CG-385F form.

TWIC Reader Delay for Certain Facilities

The Coast Guard has proposed to delay the effective date for implementation of TWIC Readers for certain facilities. The proposed delay is for two categories of facilities:

  • Facilities that handle certain dangerous cargoes in bulk, but do not transfer these cargoes to or from a vessel, and;
  • Facilities that receive vessels carrying certain dangerous cargoes in bulk, but do not, during that vessel-to-facility interface, transfer these bulk cargoes to or from those vessels.

The Coast Guard proposes delaying the effective date for these two categories of facilities by 3 years, until August 23, 2021.

Other vessels and facilities, including facilities that receive large passenger vessels and facilities regulated under 33 CFR 105.295 that handle certain dangerous cargoes in bulk and transfer it to or from a vessel, would be required to comply with the final rule by August 23, 2018.

Click here for the Notice of Proposed Rulemaking.

Click here and here for additional information regarding the TWIC Reader Rule.

Five Quick Things You Can Do to Improve Guard Performance

Review this list with your contract Branch Manager or Supervisor and make these activities part of their everyday routine.

  • Conduct meaningful daily Post Checks. In his book, management guru Ken Blanchard counseled – “Catch them doing something right (a moment of praise); or catch them doing something wrong (counsel them or take corrective action); or have a training moment (briefly review TWIC procedures or emergency call out processes, for example).
  • Don’t deviate from your own rules. If homework is prohibited in the post orders, do not make exceptions.  Same with Internet surfing, digital games, etc.  When you deviate from your own rules, the whole operation can degrade and you are likely to be accused of favoritism.
  • Daily mini-drills keep them on their toes: Place a ladder against the perimeter fence and see how long it takes for patrol to find it.  Spend a moment in the guard building drilling them on proper truck inspections or baggage screening.  Then fill out a brief drill report and file it with your FSP.
  • Require detailed daily activity reports. Insist they are detailed, and follow up on entries often enough so the guards know you review them.
  • Be receptive to questions. Create an atmosphere that encourages security officers to ask questions, seek clarification, and report unusual circumstances.

Don Greenwood & Associates has comprehensive templates for guard contracts, post orders, and security officer training programs.  Give us a call if we can help develop procedures and tune up your guard force.

Complete Active Shooter and Workplace Violence Program

“I knew this was going to happen.” That is the statement given in more than 50% of workplace and school rage killings.

We have learned that employees are unlikely to report emerging situations to management unless they feel confident that management has a plan and an organized response to address the issue.

Don Greenwood & Associates has supported clients with workplace violence prevention and response programs since 1995 – companies in oil & gas, field services, manufacturing, business, chemicals and computing.

Our program is comprehensive, ready for rapid deployment throughout the workforce, and includes:

  • A template for establishing a Threat Management Team (consistent with ASIS and SHRM guidelines) that includes specific responsibilities for Security, HSE, HR, Legal, and Operations.
  • A Quick Action Guide addressing active shooter situations – ready for distribution to your employees immediately.
  • A PowerPoint training program for employees that encourages reporting, engagement, and concise standards of behavior.
  • A PowerPoint for managers and supervisors with guidelines and standards for intervening in and managing workplace disruption.
  • Training materials to help employees formulate their own plans for run, hide, and fight – based on their immediate workplace environment.
  • Guidelines on assessing the potential for violence in emerging situations and strategies for managing these threats.

The program is complete, cost effective, and ready to tailor to your company’s needs and culture.

Send me an email or give me a call for more information – Don Greenwood, don@greenwoodsecurity.com, 281-435-2339.

Check out our website – www.greenwoodsecurity.com

Don Greenwood & Associates, Inc. – Full Service Security Management Consultants since 2003

2018 Port Security Grant Program Posted

Yesterday, the Department of Homeland Security and FEMA posted the 2018 Port Security Grant Notice of Funding Opportunity (NOFO).  Federal allocation this year is $100 million, more than last year.  However, for private, for profit companies, the federal match is 50/50 vs the 25%/75% if last year.  Which means, that if a recipient applies for $100,000 in funding for an appropriate security project, DHS will award $50,000 and the company receiving the award will need to provide $50,000 in matching funds.

That may make the grants program less attractive for many companies; however, it is logical that fewer will apply, so the chances of winning an award may be better than last year.

The deadline for filing applications is June 20th – we have less than 30 days.

In the last few years, Don Greenwood & Associates Inc. has help clients write and submit ten grant applications and have won awards for eight of the ten, including the largest award given to a private company in 2016 – just under $1 million dollars.  Writing successful grant applications depends on the consultant’s ability to draft a persuasive argument that the facility in question needs the award to support the goals of the larger community, the Area Maritime Committee, as well as the submitting company and port facility.

Contact us at 281-435-2339 or don@greenwoodsecurity.com for more information.

Get Ready Now for 2018 Port Security Grants

It is not too soon to start the registration processes:

The Administration has budgeted $100 million for port security grant awards in 2018.

When:

  • Likely before the end of May
  • Like last year, there will be a short window to submit applications
    • Last year grants were announced on June 2 and applications due by June 22, only 20 days to prepare and submit applications.

Grant priorities will probably remain the same.

  • Enhancing Maritime Domain Awareness
  • TWIC Technology
  • Cybersecurity Capabilities
  • Training and Exercises

Let’s get started.  Before we can develop an application, we need to discuss your facilities, what is needed, and whether or not the needs meet the grant priorities.  Successful grant writing is more an art than a science.  Give us a call at 832-717-4404 or email don@greenwoodsecurity.com.

To read more on preparing a grant application, click here.

TWIC Reader Rule Delay

TWIC Reader Rule Delay

On April 18, 2018, the Office of Management and Budget’s Office of Information and Regulatory Affairs announced that they received a proposed rule to delay the implementation date for the USCG TWIC Reader Rule.

To read more about the TWIC Reader Rule click here, here and here.

To read more about the delay, click here.