b'notifi cation that access to the vessel is deemedcited defi ciencies were: correct signage wasFurther,thisinformationmaybe valid consent to screen. Anyone refusing to bemissing; TWICs or proper ID of all whoconsideredwhenimplementingyourASP, screened will be denied access to the vessel.were seeking access to the facility were notperforminganannualaudit,conducting Additionally,ensuringtheTransportationverifi ed; and screening was not conductedsecurityassessmentsorpreparingfora WorkerIdentifi cationCredential(TWIC)according to the requirements of MARSECcompliance exam. orproperIDofeachpersonrequestingtoDirectives 105.1 or 105.2.board the vessel is checked and deemed valid.Overall, industry has achieved a high rate Persons without a TWIC must be escorted ifRecordkeepingrequirementsareclearlyof compliance with MTSA regulations. The accessing secure areas on the vessel or facility. describedintheMTSAregulations.MostU.S. Coast Guard appreciates this vigilance often, the FSO did not have records of drills,inmaintainingthesecuritystandards Fully implementing the ASP is a requirementannual audits, and/or training.required by MTSA. Protecting our ports and ofoperatingunderanyoftheU.S.Coastvital waterways is a shared responsibility. The Guard approved security programs. ASPs areIt can be a benefi cial exercise to look at theseU.S. Coast Guard thanks facility and vessel anindustry-createdsecuritystandardbasedcommondefi cienciesanddeterminewhatsecurityofficerswhoremainvigilanton onabusinessmodel;chemicalfacilities,couldhappenifanyofthosedefi cienciesthe waterfront every daynothing is more grainfacilities,tugs&towingvessels,andwere used to advantage by someone wishingimportant in eff orts to secure and protect the passenger vessels, to name a few. Regardlesstodoharmtoyourvesselorfacility.shores and waterways of our country.ofsizeorgeographiclocation,membersin good standing of the sponsoring organization may implement its approved ASP. It is notAbout the Author: uncommonforavesseltoaddasecurity measuretothoseintheapprovedASP.BETTY McMENEMYHowever, a vessel that wishes to modify the U.S. HEADQUARTERS, OFFICE OF PORT contents of the ASP, should submit a vessel- AND FACILITY COMPLIANCEspecifi csecurityplan(VSP)totheMarine Safety Center.Betty McMenemy is a Marine Transportation Specialist at the U.S. Coast Guard Headquarters. She has been Recordkeeping and documentation are areasworking with MTSA regulations since January 2004, thatcontinuetocauseissuesduringfi attheMarineSafetyCenterreviewingVesselrst compliance exams. Records of security drills,Security Plans and working with industry to assure annual audits, and training are the most oftenfull compliance with the regulatory requirements of 33 missing items required by this rule. The latestCFR part 104. In November 2006, Betty transferred to approved version of the ASP under which thethe Office of Port and Facility Compliance where her vessel is operating must also be kept onboardfocus was on facility security. Throughout that time, she as well as a vessel-specifi c security assessment. worked with both Coast Guard fi eld units and industry in interpretation and application of the regulations to vessels and facilities. She manages all aspects of the FACILITY DEFICIENCIES:Alternative Security Program and is pleased to be a Drills and exercises are also the number onepartner with PVA.defi ciency found during compliance exams for facilities. As with vessels, it is often difficult to determine if drills were not conducted or were not recorded as required. A drill must be conducted once every three months.Restricted areas defi ciencies were the second mostcommondefi ciencywithinspectors noting that these designated areas were not marked with proper signage. Training was the third most commonly found defi ciencyforfacilities.MTSAlistsspecifi c areasinwhichtheFacilitySecurityOfficer (FSO)andpersonnelwithsecurityduties must have knowledge. This knowledge may be gained through training or experience. It was specifi cally indicated that in some cases facility personnel were not aware of how to respond during a security incident.Accesscontrolremainsamongthetopfi ve areas of inspection concerns. The most often DECEMBER 2021 15 FOGHORN FOCUS'