b'SAFETY MATTERSSAFETYUnderstanding PVAsAlternative Security ProgramERIC CHRISTENSEN // PVA DIRECTOR OF REGULATORY AFFAIRS & RISK MANAGEMENTS ince2003,PVAsAlternativeSecurityWhen implementing the program, Company Protecting the ASP: The contents ofProgram (ASP) has been a valuable toolSecurity Officers (CSO) are required to addressthe ASP once completed are considered in the compliance toolbox for hundredsthe following within the ASP: sensitive security information (SSI) and of PVA member passenger vessels and facilitiescannot be shared outside the company. requiredtomeetvesselandfacilitysecurity Identify personnel and areas to be coveredCoast Guard inspectors have access to therequirements. As personnel come and go, it isby the ASP. plan during inspections.important for those with security duties to be familiar with the ASP and their responsibilities Conduct security assessments of vesselsunder the program. and facilities as applicable. Compliance with BACKGROUNDIdentify the type of operation (ferry,the PVA ProgramActing under the authority of the Maritimeexcursion, overnight, facility, etc.) withinmeets all the security TransportationSecurityAct(MTSA)ofAppendix B of the ASP and note the type 2002,theU.S.CoastGuardissuedaFinalof security measures that need to be putrequirements as an Rule on Oct. 22, 2003, requiring certain vesselin place at different Maritime Security operators to develop and implement security(MARSEC) levels.Approved Alternative.measures. The majority of the maritime secu-rity rules are to be found in Title 33, Code of Personnel Training: Company personnelFederal Regulations, Subchapter H. with security duties must be trainedASP APPENDICESto the level needed to carry out theirThecompanyspecificelementsoftheASP TheMTSAsecurityrequirementsapplytoresponsibilities. The company, vessel, andare contained in the appendices, and it is the small passenger vessels which are less than 100facility security officers need not haveappendices that make the document useful as gross registered tons with a capacity of moreCoast Guard-approved training or anwell as SSI. All documentation resides in the than 150 passengers and passenger vessels ofendorsement on their merchant marinerappendices from assessments and schematics 100 gross registered tons or more regardless ofcredential to assume the duties of thosetocorrespondenceandreports.Theappen-passenger capacity. Facilities that receive thesepositions. The PVA ASP allows fordices also contain sample documents that are vessels must also meet certain security require- company specific familiarity and training. referred to in the ASP.ments under the MTSA.Drills and Exercises: Three drills and oneCurrently, the fourth revision contains appen- Vessel operators have two choices to meet theseexercise are required annually. Drills candices A though O. The upcoming revision, dis-requirements. One option is for a company totest a portion of the security programcussed below, will have two more appendices writeandimplementanindividualsecuritysuch as suspicious person or bag onboard.for Seafarer Access and Cyber Security. Addi-program that must be approved by their localExercises test broader areas of the programtional company appendices are not permitted Coast Guard. The other is to use an alreadyand include external response or lawintheASP.Allrequireddocumentationto developed and approved industry-wide alter- enforcement resources such as local policeimplement the PVA ASP should be able to fit native. The ASP developed by PVA and ap- and fire departments. in one of the appendices.proved by Coast Guard Headquarters provides acomprehensiveandwell-establishedmeans Communication: How security threatsCOAST GUARD INSPECTIONS ofcomplianceforthosedomesticpassengerare communicated within the companyTheCoastGuardwillvisiteachfacilityand vessels,smallpassengervessels,andfacilitiesand externally to local response resources. vessel(s) throughout the year. The vessel and the subjecttomaritimesecurityrequirements.facility must be prepared to demonstrate com-CompliancewiththePVAProgrammeets Use and verification of transportationpliance with this program at all times throughall the security requirements as an Approvedworker identification cards (TWIC). drills, demonstrations, or on the job observation Alternative under 33 CFR 101, 104 and 105.byCoastGuardpersonnel.Itiscriticallyim-Suspicious activity reporting and awareness. portant that company personnel with security ASP STRUCTURE responsibilitiessuchasthecompanysecurity AND IMPLEMENTATIONRecordkeeping, documentation, andofficer (CSO), vessel security officer (VSO), andThePVAASPisbrokendownintosec- auditing: All records and documentationfacility security officer (FSO) have a solid working tions with the first few sections focusing onhave a place within the ASP. Auditing ofknowledgeoftheASPandcompanysecurity introducingtheprogramandestablishingthe program allows for validation of theprocedures. Proper succession training should be definitions, references, required elements, andASP and areas to improve. Auditing of thein place to manage personnel transitions. If the instructions for implementing the program. ASP is required every year. Coast Guard inspectors sense there is not a work-FOGHORN 34'