If the commandant approves an ASP for a group of vessels, such as those that belong to an organization like the PVA, “Their members can use the ASP and fill in the necessary information so the security program becomes vessel specific,” McMenemy said.
The company doesn’t have to write the plan, and the COTP doesn’t have to go through a line-by-line review process. More vessels are covered by the various ASPs offered through their respective associations than those with individual security plans. There are about 3,300 vessels with individual security plans, and approximately 7,200 covered under an ASP.
PVA members include owners and operators of dinner cruise vessels, sightseeing and excursion vessels, car and passenger ferries, gaming vessels, private charter boats, whale watching and eco-tour vessels, day sailers, and windjammer sailing vessels, overnight cruise ships, and amphibious vessels. PVA members operate U.S. Coast Guard certificated, as well as Canadian Coast Guard or state-inspected vessels. The passenger vessel industry safely carries more than 200 million passengers each year, according to the PVA.
To be MTSA compliant, PVA members can write and implement an individual security plan and have it approved by the Coast Guard, or, said PVA’s Jen Wilk, director of public affairs, security, and development, they can use an already-developed and approved industry-wide alternative. “The Alternate Security Program, developed by the Passenger Vessel Association and approved by the Coast Guard, provides a comprehensive and well-established means of compliance for those domestic passenger vessels, small passenger vessels, and facilities subject to maritime security requirements.”
Compliance with the PVA program meets all the security requirements as an approved alternative under Title 33 Code of Federal Regulations parts 101, 104, and 105. “PVA members with a vessel with a passenger capacity of 151 or more may elect to satisfy the requirement to implement a vessel and/or facility security plan using the PVA program,” Wilk said.
PVA’s ASP is an important tool to help members meet their security requirements, and Wilk said PVA members in good standing can use this exclusive benefit as a formal security program that meets the functional requirements of the MTSA and its implementing regulations. This ASP addresses security for both vessels and facilities.
“Passenger vessel operators take security seriously, and ensure that there are robust security measures in place. PVA’s ASP provides a comprehensive framework for security procedures while at the same time allowing companies the flexibility to address the unique features of their operations and make the program their own,” she said.
“PVA’s ASP was developed by PVA member volunteers with years of operations experience. Our ASP is pre-approved by Coast Guard Headquarters, and members do not need to undergo the challenges of creating their own individual program and subsequently having it approved – especially when it’s time for revisions and renewal every five years,” she said.
Wilk said PVA works with the Coast Guard to update the ASP in advance of its regular five-year renewal to make appropriate revisions and federal security policy changes, such as the recent Transportation Worker Identification Credential (TWIC®) reader requirements.
“Most facilities include a fenced security perimeter surrounding the plant, which is considered the restricted area for regulatory purposes, with discrete access points that are effectively monitored and managed to safely control who and what can be allowed to enter and leave the facility. Personnel access is tightly controlled and restricted to only those who have been authorized for entry, possess a current Transportation Worker Identification Credential or who are escorted by security personnel.”
PVA communicates with Coast Guard leadership through quality partnership meetings and ASP sponsoring-organizations’ group meetings. PVA also meets regularly with the Transportation Security Administration (TSA). “PVA appreciates the open dialogue we have with the Coast Guard,” Wilk said.
Formula for Success
Transporting chemicals is a significant business for oceangoing carriers, inland barge operators, and other water freight transportation companies. “The chemical industry conducting port operations must comply with the MTSA, and implement rigorous security measures to prevent unauthorized access to restricted areas within covered facilities, such as the loading dock. Such security measures employed include access control, background checks, fencing, monitoring, and security guard patrols,” said Bill Erny of the ACC.
In addition to MTSA, the ACC has imposed its own Responsible Care® Security Code, which mandates an additional layer of security and third-party auditing for members. “Both programs together ensure an effective approach to protecting the maritime environment from [an] intentional act of terrorism and other types of criminal behavior to prevent the disruption in the flow of marine commerce,” said Erny.