b'Photo by Ekrulila from PexelsFOGHORN FOCUSKeeping Watch of MTSA Compliance Exam De cienciesBY BETTY McMENEMYU.S. HEADQUARTERS, OFFICE OF PORT AND FACILITY COMPLIANCET he Maritime Transportation Security Act (MTSA) came intorequired your attention. The CG-Form 835 is not a warning nor does it existence as a direct result of the events of September 11, 2001.involve a fi ne. Based on the severity of the defi ciency, actions taken by The primary goal of MTSA is the prevention of a transportationCoast Guard inspectors may also increase in intensity. If the defi ciencysecurity incident (TSI). A TSI is defi ned as a signifi cant loss of life,is more severe or a previously discussed item has not been remedied, a environmentaldamage,transportationdisruption,oreconomicLetter of Warning (LOW) may be issued. A LOW is a more formal notice disruption in a particular area. At the heart of MTSA is the securitythat a defi ciency exists and must be addressed by the owner/operator of plan. Vessels and facilities subject to the regulatory requirements ofthe vessel or facility. If a defi ciency continues to exist after an LOW is MTSA must submit to and operate under a U.S. Coast Guard-approvedissued, the vessel or facility may incur potential fi nes. An unaddressed Vessel Security Plan (VSP), Facility Security Plan (FSP), or Alternativevulnerability may leave a vessel or facility open to malicious acts that Security Program (ASP). putitsinfrastructure,personnel,and/orassets The U.S. Coastin jeopardy.A mandate of the U.S. Coast Guard is to assure thatvesselsandfacilitiesfullyimplementGuard is requiredBecausedefi cienciesarerecordedintheCoast their security plan. This is confi rmed throughto examine eachGuards Marine Information for Safety and Law MTSAcomplianceexaminations.TheU.S.Enforcement (MISLE) system, a history of eachCoastGuardisrequiredtoexamineeachregulated facilitysvessel/facility is readily available to Coast Guard regulated facilitys operations at least once perinspectors and this information should be reviewed year. Required vessel inspections are arrangedoperations at leastbeforeeachcomplianceexam.Usingthedata by the Company Security Officer under 49once per year. stored in the MISLE system, the following are the CFR part 2. top fi discrepancies found during complianceve examsforvesselandfacilitiesoperatingunder However, based on the vessel/facility history, these inspections mayall ASPs approved by the U.S. Coast Guard. This information covers a occur as often as necessary for maintaining full compliance. Everyonetwelve-month period ending on October 31, 2021.has experienced a compliance exam, whether it was a spot check or a full-scale inspection process. The compliance exam program aims toVESSEL DEFICIENCIES: prevent maritime transportation security incidents and marine casualtiesDrills remain the number one defi ciency found during vessel inspections. resulting from malicious acts, accidents, or from events of natural causes:Drills are required to be conducted every three months (not once a protecting your personnel, critical infrastructure, and assets. The intentquarter). Sometimes a vessel doesnt get credit for drills because they and purpose of compliance exams is to ensure the security measures inhave not been included in the vessels records.place adequately address vulnerabilities identifi ed and documented as required by the vessel and/or facility security assessment. Restricted area requirements are high on the list of defi ciencies primarily due to lack of proper signage.During compliance exams, it is not uncommon for the vessel or facility inspector to discover defi ciencies. Generally, these defi ciencies are notAccess control signage is another area of concern that could easily be life threatening and can be fi xed on the spot, such as missing signage.fi this means signage must be conspicuously posted showing thexed: A CG-Form 835 will be fi out as documentation that somethingMARSEC Level and describing security measures in eff ect, including alled FOGHORN FOCUS 14 FOGHORN'