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Maritime Security Training Requirements

Posted on Thu, Mar 07, 2013

Vulnerability assessments may reveal that certain waterfront facilities are considered “high-risk” to security breaches and associated threats. The main goal of security assessments is to identify and limit security risks to your facility, equipment, and personnel. Being able to identify and quantify risks at waterfront facilities allows companies to establish policies and procedures that can minimize the risk and consequences of security threats, and provide increased safety.

Marine Transportation Security Act  (MTSA) requires “any structure or facility of any kind located in, on, under, or adjacent to any waters subject to the jurisdiction of the United States to conduct a vulnerability assessment and prepare and submit a security plan to the Secretary of Homeland Security based on the assessment.” This law is the U.S. equivalent of the International Ship and Port Facility Security Code (ISPS), and was fully implemented on July 1, 2004. Security plans may include, but are not limited to:

  • Passenger, vehicle, and baggage screening procedures
  • Security patrols
  • Establishing restricted areas
  • Personnel identification procedures
  • Access control measures
  • Installation of surveillance equipment.

A facility that is deemed high risk must assign a Facility Security Officer (FSO) and conduct appropriate training. According to CFR 33 part 105, Maritime Security for Facilities, companies with multiple portside locations can assign a single employee as the FSO for all sites, as long as those facilities are in the same Captain Of The Port (COTP) zone and are within 50 miles of each other. The FSO may also perform other duties within the company, but they must be able to perform the duties and responsibilities required of the FSO.

A security plan is required to describe the training, drills, and security actions of persons at the waterfront facility. These actions should deter, to the maximum extent practicable, a transportation security incident, or a substantial security threat. As per §105.210, facility personnel with security duties should be trained in the following:

  • Knowledge of current security threats and patterns
  • Recognition and detection of dangerous substances and devices
  • Recognition of characteristics and behavioral patterns of persons who are likely to threaten security
  • Techniques used to circumvent security measures
  • Crowd management and control techniques
  • Security related communications
  • Knowledge of emergency procedures and contingency plans
  • Operation of security equipment and systems
  • Testing, calibration, and maintenance of security equipment and systems
  • Inspection, control, and monitoring techniques
  • Relevant provisions of the Facility Security Plan (FSP)
  • Methods of physical screening of persons, personal effects, baggage, cargo, and vessel stores
  • The meaning and the consequential requirements of the different Maritime Security (MARSEC) Levels
  • Familiar with all relevant aspects of the TWIC program and how to carry them out

All other facility personnel, including contractors, whether part-time, full-time, temporary, or permanent, must have knowledge of, through training or equivalent job experience, in the following, as appropriate:

  • Relevant provisions of the Facility Security Plan (FSP)
  • The meaning and the consequential requirements of the different MARSEC Levels as they apply to them, including emergency procedures and contingency plans
  • Recognition and detection of dangerous substances and devices
  • Recognition of characteristics and behavioral patterns of persons who are likely to threaten security
  • Techniques used to circumvent security measures
  • Familiar with all relevant aspects of the TWIC program and how to carry them out.

The MTSA requires that facilities with a higher risk of involvement in a transportation security incident perform certain tasks in order to continue operating in the United States. Facilities must be able to present a Facility Security Assessment (FSA) Report and Facility Vulnerability and Security Measures Summary (Form CG-6025).  If these items are not included in the Facility Security plan, Coast Guard Inspectors will not approve the plan.

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

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Tags: Dock Operations, MTSA, Training and Exercises, Security plans

The Common Regulatory Requirements between the EPA and USCG

Posted on Mon, Aug 27, 2012

Many U.S. facilities, such as marine transfer facilities with aboveground storage tanks, are regulated by both the Environmental Protection Agency and the U.S. Coast Guard (USCG). Certain EPA-regulated facilities that are located adjacent to U.S. waters, or on company property adjoining a marine-transportation-related facility, may be also held accountable by USCG regulations. The marine transportation security aspects regulated by the USCG covers the entire facility, not just the oil transfer or “dock” area. Although the USCG’s 33 CFR part 105 105 mandates the details of facility security planning and the EPA’s 40 CFR part 112  pertains to oil spill prevention and response planning, there are several overlapping provisions.

EPA’s 33 CFR part 112 requires Facility Response Plans (FRP) that describe the response procedures for oil discharges of all types, whether the cause is accidental, man-made, natural, or deliberate. EPA’s FRP requirements address responses to worst-case discharges, which can damage the facility, disrupt waterborne commerce, and cause substantial economic or environmental damage.  The USCG’s 40 CFR part 112 on maritime security aims to prevent the consequences of a worst-case discharge. Specific provisions that may overlap in the two sets of requirements include, but are not limited to the following:

Notification:

  • Part 112: The FRP must include an emergency response action plan, which summarizes key response information from the FRP, including emergency contact information for the Qualified Individual, facility response personnel, response organizations, and local responders. 
  • Part 105: The Facility Security Officer must have a means to effectively notify facility personnel of changes in security conditions at a facility. Transportation security incidents are reported to the National Response Center and to appropriate emergency responders. At each active facility access point, a system must be in place to allow communication with authorities with security responsibilities, including the police, security control, and the emergency operations center.
Fencing and monitoring:
  • Part 112: The FRP must describe facility security, as appropriate, including fencing, guards, and lighting. The SPCC Plan must also describe facility security measures to restrict access to the oil handling, processing, and storage areas. The SPCC also requires adequate lighting to prevent discharges caused by vandalism.
  • Part 105: The Facility Security Plan must describe security measures to prevent unauthorized access to cargo storage areas, including continuous monitoring through a combination of lighting, security guards, and other methods.

Evacuation:

  • Part 112: The FRP requires detailed evacuation plans, including primary and secondary evacuation routes, centralized check-in area, and references to community evacuation plans.
  • Part 105: The owner or operator must identify the location of escape and evacuation routes and assembly stations to ensure that personnel are able to evacuate during security threats.

Assessment:

  • Part 112:  The FRP required a detailed site plan diagram, hazard evaluation, and vulnerability assessment. The assessment in the FRP examines potential effects of an oil spill, such as the shutdown of downstream water intakes.
  • Part 105: The Facility Security Assessment requires description of the layout of the facility, and response procedures for emergency conditions, threat assessment, and vulnerabilities, with a focus on areas at the facility that may be vulnerable to a security threat, such as utility equipment and services vital to operations.

For information about SPCC Plans, download TRP Corp's free SPCC and FRP Inspections guide.

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Tags: USCG, Dock Operations, EPA, OPA 90, Oil Spill

The Basics of a USCG Dock Operations Manual

Posted on Thu, Jun 07, 2012

A leak or spill of a hazardous liquid bulk product directly into a waterway pollutes the water and could contaminate sediment and adversely affect marine life. As a result, U.S. Coast Guard Dock Operations Manuals are required by facilities involved in transferring oil or hazardous materials in bulk to or from a vessel that has a total capacity, from a combination of all bulk products carried, of 250 barrels or more. However, the regional Captain of the Port (COTP) may determine that a facility transferring less than 250 barrels must provide a dock operations manual if it is deemed that a discharge into or on navigable waters, adjoining shorelines, or exclusive economic zone may cause substantial harm to the environment.

Details of Dock Operations Manual

A dock operations manual should include, but is not limited to, the following details:

  • Plot plan and location maps.
  • Emergency contact numbers - Include qualified individual, contractors, agencies, emergency resources, and applicable company personnel.
  • Detailed facility information - Including latitude and longitude, hours, details of facility ownership, and dock specifications and capabilities.
  • Product Descriptions - Appearance, odor, hazards involved in handling, instructions for safe handling, procedures for spills, leaks or human exposure, and firefighting procedures (MSDS information).
  • Watchman duties.
  • Communication system specifications.Dock_Operations_Manual_TRP.jpg
  • Details of personnel shelter(s).
  • Monitoring devices and containment equipment.
  • Transfer procedures - Beginning with vessel arrival, pumping, and post transfer processes.
  • Emergency procedures for discharge/spill and equipment necessary.
  • Fire equipment.
  • Reporting and notification procedures.
  • Lighting details.
  • Identification of Person in Charge and qualifications.
  • Hose identification markings maximum allowable working pressure details).

Facility operators are required to submit two copies of the dock operations manual to the COTP of the zone in which the facility is located. If the COTP finds that the manual meets the minimum requirements, one copy will be returned to the operator marked “Examined by the Coast Guard”.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

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Tags: USCG, Dock Operations, Oil Spill, Facility Management