A few weeks ago, USCG officers arrived at a regulated facility, and observed the main gate security officer not inspecting and validating TWIC cards, and not conducting vehicle inspections as required in the Facility Security Plan. For a moment, the USCG considered shutting down the facility. Recently the USCG also released a list on common MTSA Facility Violations.
The Facility Security Officer (FSO) should expect the USCG to conduct at least two inspections per year. Typically, one inspection will be scheduled with the facility and the other will be an unannounced inspection. These unannounced inspections typically occur at night. The FSO must ensure that their facility, FSP, and records are prepared for the USCG inspections.
Prior to the inspection, the FSO should review the FSP and confirm that all information is up to date and correct. The FSO should also verify that all pertinent documents and records are in order and have the required Sensitive Security Information (SSI) labeling. The FSO will need to ensure that all drills, exercises, audits, security equipment tests, etc. have been properly conducted and recorded.
The FSO will also want to ensure that facility personnel, including security guards, have been properly trained according to the regulation and are prepared to answer questions if asked by USCG officers.
Most deficiencies are typically discovered during the required Annual Audit of the FSP. The MTSA regulation requires facilities to conduct an annual audit and that the person(s) conducting the audit are independent of any security measures being implemented at the facility.
Don Greenwood & Associates, Inc. has provided security assessments, plans and training for hundreds of Facility Security Officers and security-related personnel as mandated in the Maritime Transportation Security Act (MTSA). We also have a full set of compliance tools including training PowerPoints, Assessment Templates, and have produced employee training videos for several petrochemical companies.