MTSA Compliance Checklist

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

United States Coast Guard

MTSA FACILITY COMPLAINCE


GUIDE

Name of Facility/Location Facility Type

Facility ID Number MISLE Activity Number

Date(s) Conducted

Facility Inspectors

1. 5.

2. 6.

3. 7.

4. 8.

Guidance for completing the MTSA Facility Compliance Guide (checklist) –


Coast Guard facility inspectors and facility security officers (FSOs) shall complete the checklist by addressing each
item contained therein. Completion of the check boxes is mandatory for all items. Each item contained in the guide
(checklist) must be notated as one of the following:

Sat – Item satisfactorily meets requirements contained in the guide and referenced regulations.
N/O – Item was Not Observed during this inspection.
N/A - Item is Not Applicable to this facility or inspection.
Fail - Item was found to be unsatisfactory and therefore failed inspection.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Compliance documentation

FAIL
SAT

N/O

N/A
33 CFR 105.120

1. Approved Facility Security Plan (FSP) or

1.1. Review the FSP


1.2. Review the Facility Security Assessment and CG-6025

2. Letter of Authorization to Operate (LOA) or

2.1. Review the submitted FSP


2.2. Review the submitted Facility Security Assessment and CG-6025

3. Alternative Security Program, with letter signed by facility owner/operator

3.1. Review ASP


3.2. Review the Facility Security Assessment and CG-6025

Non-Compliance

FAIL
SAT

N/O

N/A
33 CFR 105.125

4. Conditions existing (if any):

4.1. 1) __________________________________________________

4.2. 2) __________________________________________________

5. Conditions met.

6. COTP notified of non-compliance?

Waivers & Equivalents


FAIL
SAT

N/O

N/A

33 CFR 105.130 & 105.135

7. Approval letter for waiver from Commandant G-MP.

8. Approval letter for equivalent from Commandant G-MP.

Maritime Security (MARSEC) Directives


FAIL
SAT

N/O

N/A

33 CFR 105.145

9. Incorporated in to security plan.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Facility Security Officer Knowledge & Training

FAIL
SAT

N/O

N/A
33 CFR 105.205

10. Name of FSO: __________________________________________

11. FSO Contact Information:

11.1. Primary phone number ( ) _____ - _________

11.2. Secondary number ( ) _____ - _________

12. Is FSO familiar with FSP and relevant portions of the regulations? FSO must have
general knowledge through training or equivalent job experience in the following:

12.1. Facility security organization

12.2. Vessel and facility security measures to be implemented at the different


MARSEC Levels

12.3. Familiarity with security equipment and systems, and their operational
limitations

12.4. Familiarity with methods of conducting audits, inspections, control, and


monitoring techniques

FSO must have knowledge and receive training in the following, as appropriate:

12.5. Risk assessment methodology

12.6. Methods of facility security surveys and inspections

12.7. Instruction techniques for security training and education, including


security measures and procedures

12.8. Handling (as well as access to and distribution of) sensitive security
information and security related communications

12.9. Current security threats and patterns

12.10. Recognizing and detecting dangerous substances and devices

12.11. Recognizing characteristics and behavioral patterns of persons who are


likely to threaten security

12.12. Techniques used to circumvent security measures

12.13. Conducting physical searches and non-intrusive inspections

12.14. Conducting security drills and exercises, including exercises with vessels

12.15. Assessing security drills and exercises

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Facility Personnel With Security Duties

FAIL
SAT

N/O

N/A
33 CFR 105.210

13. Verify that personnel with security duties are familiar with FSP and relevant
portions of the regulations? These personnel must have general knowledge through
training or equivalent job experience in the following:

13.1. Current security threats and patterns

13.2. Testing, calibration, operation, and maintenance of security


equipment and systems

13.3. Security related communications (including the handling of SSI)

13.4. Methods of physical screening of persons

13.5. Knowledge of emergency procedures and contingency plans

13.6. Techniques used to circumvent security systems

13.7. Recognition of characteristics and behavioral patterns of persons who


are likely to threaten security

13.8. Recognition and detection of dangerous substances and devices

13.9. Inspection, control, and monitoring techniques.

13.10. The meaning and the consequential requirements of the different


MARSEC levels

Facility Personnel Without Security Duties

FAIL
SAT

N/O

33 CFR 105.210 & 105.215 N/A


14. Verify that all other personnel are familiar with FSP and relevant portions of the
regulations. These personnel must have general knowledge through training or
equivalent job experience in the following:

14.1. Relevant provisions of the FSP & meaning of different MARSEC


levels.

14.2. Recognition & detection of dangerous substances and devices.

14.3. Recognition of characteristics and behavioral patterns of persons who


are likely to threaten security.

14.4. Techniques used to circumvent security measures.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Drill & Exercise Requirements

FAIL
SAT

N/O

N/A
33 CFR 105.220

15. Review Drill Log to ensure drills are conducted at least every 3 months.

15.1. Date/Type of Last Drill:

________________________________________________

16. Review Exercise Log to ensure exercises are conducted each calendar year, no
more than 18 months between exercises.

16.1 Date/Type of Last Exercise:

_______________________________________________

Facility record keeping requirements

FAIL
SAT

N/O

N/A
33 CFR 105.225

17. Review records to ensure all of the following are recorded -

17.1. Breaches of security

17.2. Changes in Maritime Security (MARSEC) Levels

17.3. Maintenance, calibration, and testing of security equipment

17.4. Security threats

17.5. Training records for facility personnel with security duties ONLY. (Those
personnel covered under 33 CFR 105.210)

17.5.1 Date of each training session

17.5.2. Duration

17.5.3. Description of training

17.5.4. List of attendees

17.6. Verify that all records are maintained for at least (2) years.

17.7. Verify that the FSP/ASP undergoes an annual audit.

17.7.1. Check the document(s) signed by FSO certifying the annual audit.

17.7.2. Verify that past audit findings are addressed.

18. Verify the FSP is being protected from unauthorized disclosure in accordance with
SSI procedures.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

MARSEC Level Coordination & Implementation

FAIL
SAT

N/O

N/A
33 CFR 105.230

19. Ensure facility is operating at proper MARSEC level in effect for the Port.

19.1. Review procedures outlined in FSP for current MARSEC level

20. Review the procedures for changes in MARSEC levels.

20.1. MARSEC Level I to 2

20.2. MARSEC Level 2 to 3

21. 12 Hour implementation timeframe & reporting to COTP.

Communications

FAIL
SAT

N/O

N/A
33 CFR 105.235

22. Verify that primary and backup communications systems and procedures allow
effective and continuous communications between the facility security personnel,
vessels interfacing w/facility, the COTP and authorities w/security responsibilities.

23. Verify that each active facility access point provides a means of contacting police,
security control, or an emergency operations center.

Declaration of Security

FAIL
SAT

N/O

N/A
33 CFR 105.225 & 105.245

24. Verify that DoS’s are maintained for 90 days.

25. When a continuing DoS is used, the FSP/ASP must ensure that:

25.1. The DoS is valid for a specific MARSEC Level.

25.2. The effective period at MARSEC Level 1 does not exceed 90 days.

25.3. The effective period at MARSEC Level 2 does not exceed 30 days.

Security systems and equipment maintenance


FAIL
SAT

N/O

N/A

33 CFR 105.250

26. Verify security systems and equipment are in good working order and inspected,
tested, calibrated, and maintained according to Manufacturers’ recommendations.

27. Verify procedures for identifying and responding to security and equipment
failures or malfunctions.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Security measures for access control

FAIL
SAT

N/O

N/A
33 CFR 105.255

28. VERIFY procedures at MARSEC Level 1 to ensure that security measures


relating to access control are implemented AS OUTLINED IN THE FSP, these
procedures include those that:

28.1. Screen persons, baggage, personal effects, and vehicles, for dangerous
substances and devices at the rate specified in the approved FSP.

28.2. Conspicuously post signs that describe security measures currently in


effect and clearly state the entering the facility is deemed valid
consent to screening or inspection, and that failure to consent or
submit to screening or inspection will result in denial or revocation of
authorization to enter.

28.3. Check the identification of any person seeking to enter the facility,
including vessel passengers and crew, facility employees, vendors,
visitors.

28.4. Identify access points that must be secured or attended to deter


unauthorized access.

28.5. Screen by hand or device, such as x-ray, all unaccompanied baggage


prior to loading onto a vessel.

28.6. Secure unaccompanied baggage after screening in a designated


restricted area and maintain security control during transfers between
facility and vessel.

29. REVIEW procedures for MARSEC Level 2 to ensure that security measures
relating to access control can be implemented AS OUTLINED IN THE FSP.

30. REVEIW procedures for MARSEC Level 3 to ensure that security measures
relating to access control can be implemented AS OUTLINED IN THE FSP.

Security measures for restricted areas


FAIL
SAT

N/O

N/A

33 CFR 105.260

31. VERIFY procedures to ensure that security measures relating to restricted area
access control are implemented AS OUTLINED IN THE FSP. These procedures
include those that:

31.1. Identify which facility members are authorized access.

31.2. Identify when other personnel are authorized access.

31.3. Define the extent of any restricted area.

31.4. Define the times when access restrictions apply.

- Section continued on next page -

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Security measures for restricted areas

FAIL
SAT

N/O

N/A
33 CFR 105.260

31.5. Clearly mark all restricted areas.

31.6. Control entry, parking, loading and unloading of vehicles.

31.7. Control the movement and storage of cargo and vessel stores.

31.8. Control unaccompanied baggage or personnel effects.

32. VERIFY procedures at MARSEC Level 1 to ensure that security measures


relating to restricted areas are implemented AS OUTLINED IN THE FSP.

33. REVIEW procedures for MARSEC Level 2 to ensure that security measures
relating to restricted areas can be implemented AS OUTLINED IN THE FSP.

34. REVIEW procedures for MARSEC Level 3 to ensure that security measures
relating to restricted areas can be implemented AS OUTLINED IN THE FSP.

Security measures for handling cargo

FAIL
SAT

N/O

N/A
33 CFR 105.265

35. VERIFY procedures at MARSEC Level 1 to ensure that security measures


relating to handling cargo are implemented AS OUTLINED IN THE FSP. These
procedures include those that:

35.1. Routinely check cargo, cargo transport units, and cargo storage areas
within the facility prior to, and during, cargo handling ops to deter
tampering.

35.2. Check that cargo, containers, or other cargo transport units entering
the facility match the delivery note or equivalent cargo
documentation.

35.3. Screen vehicles.

35.4. Check seals and other methods used to prevent tampering upon
entering the facility and upon storage within the facility.

36. REVIEW procedures for MARSEC Level 2 to ensure that security measures
relating to handling of cargo can be implemented AS OUTLINED IN THE FSP.

37. REVIEW procedures for MARSEC Level 3 to ensure that security measures
relating to handling of cargo can be implemented AS OUTLINED IN THE FSP.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Security measures for delivery of vessel stores and

FAIL
SAT

N/O

N/A
bunkers 33 CFR 105.270

38. VERIFY procedures at MARSEC Level 1 to ensure that security measures


relating to delivery of vessel stores and bunkers are implemented AS OUTLINED
IN THE FSP, these procedures must include those that:

38.1. Screen stores at rate specified in FSP.

38.2. Require advance notice of deliveries.

38.3. Screening delivery vehicles at rate specified in FSP.

39. REVIEW procedures for MARSEC Level 2 to ensure that security measures
relating to delivery of vessel stores and bunkers can be implemented AS
OUTLINED IN THE FSP.

40. REVIEW procedures for MARSEC Level 3 to ensure that security measures
relating to delivery of vessel stores and bunkers can be implemented AS
OUTLINED IN THE FSP.

Security measures for monitoring

FAIL
SAT

N/O

N/A
33 CFR 105.275

41. VERIFY procedures at MARSEC Level 1 to ensure that security measures


relating to monitoring are implemented AS OUTLINED IN THE FSP. These
procedures include those that:

41.1. Monitor the facility area, including shore and waterside access.

41.2. Are capable to monitoring access points, barriers and restricted areas.

41.3. Are capable of monitoring access and movement adjacent to vessels


using the facility, including augmentation of lighting utilized by
vessels.

42. REVIEW procedures for MARSEC Level 2 to ensure that security measures
relating to monitoring can be implemented AS OUTLINED IN THE FSP.

43. REVIEW procedures for MARSEC Level 3 to ensure that security measures
relating to monitoring can be implemented AS OUTLINED IN THE FSP.

Security incident procedures


FAIL
SAT

N/O

N/A

33 CFR 105.280

44. Verify procedures for responding to security threats or breaches of security and
maintaining critical facility and vessel-to-facility interface.

45. Review procedures for reporting security incidents.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Passenger and Ferry Facilities Only

FAIL
SAT

N/O

N/A
33 CFR 105.285

46. Verify areas are established to segregate unchecked persons and effects from
checked persons and effects.

47. Verify vehicles are being screened IAW the FSP/ASP.

48. Verify security personnel control access to restricted areas.

49. Verify sufficient security personnel to monitor all persons within the area.

Cruise Ship Terminals Only

FAIL
SAT

N/O

N/A
33 CFR 105.290

50. Verify procedures to screen all persons, baggage, and all personal effects for
dangerous substances and devices.

51. Verify procedures for checking personnel identification.

52. Inspect designated holding, waiting, or embarkation areas to segregate screened


persons and their effects.

53. Verify procedures to provide additional security personnel to designated holding


areas and deny passengers access to the restricted areas.

Certain Dangerous Cargo (CDC) Facilities Only

FAIL
SAT

N/O

33 CFR 105.295 N/A

54. Verify procedures to escort all visitors, contractors, vendors, and other non-facility
employees.

55. Verify procedures for controlling parking, loading and unloading of vehicles.

56. Verify procedures for security personnel to record or report their presence at key
points during security patrols.

57. Verify procedures to search key areas prior to vessel arrivals.

58. Inspect alternate or independent power source.

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Barge Fleeting Facilities Only

FAIL
SAT

N/O

N/A
33 CFR 105.296

59. Verify designated restricted areas within the barge fleeting facility.

60. Inspect current list of vessels and cargoes in the designated restricted area.

61. Verify that there is at least one tug available to service the facility for every 100
barges.

*Barge Fleeting Facilities are exempt from Security Measures for Handling Cargo and
Security measures for delivery of vessel stores and bunkers.

--- Notes on deficiencies ---

Two distinct types of deficiencies may be identified utilizing this compliance checklist -

Facility is not operating in accordance with their approved/submitted FSP or ASP – This type of deficiency is
addressed utilizing a range of enforcement and compliance measures, from Lesser Administrative actions (worklists,
etc.), up to and including more significant measures such as Notice of Violations, Civil Penalties, and Operational
Controls which may restrict facility operations.

Facility is operating in accordance with their approved/submitted FSP or ASP, but plan does not meet the specific
performance criteria outlined in the regulations – These types of deficiencies must be addressed through the plan
amendment guidance as set forth in 33 CFR 105.415 (excerpt provided below).

“(a) Amendments to a Facility Security Plan (FSP) that is approved by the cognizant COTP may
be initiated by” “(ii) the cognizant COTP upon a determination that an amendment is needed to
maintain the facility’s security. The cognizant COTP will give the facility owner or operator
written notice and request that the facility owner or operator propose amendments addressing any
matters specified in the notice. The facility owner or operator will have at least 60 days to submit
its proposed amendments. Until amendments are approved, the facility owner or operator shall
ensure temporary security measures are implemented to the satisfaction of the COTP”.

Generally, items in the checklist beginning with “Verify procedures” indicate issues requiring plan amendments.
These sections include, but are not limited to:

Communications, 22 – 23
Security measures for access control, 28
Security measures for restricted areas, 31
Security measures for handling cargo, 35
Security measures for delivery of vessel stores and bunkers, 38
Security measures for monitoring, 41
Security incident procedures, 44 – 45
Passenger and Ferry facilities only, 46
Cruise Ship Terminals only, 50 – 51, 53
CDC facilities only, 54 – 57
Barge fleeting facilities only, 59

--- Inspection Summary included on next page ---

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Enclosure (10) to NAVIGATION AND VESSEL INSPECTION CIRCULAR No: 03-03, CH-1

Inspection Summary

Comments:
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