Because MTSA allows for regulated facilities to implement an alternative security program in lieu of submitting a facility security plan (FSP) to the local COTP, Erny said the ASP is a highly effective and efficient means to comply with Coast Guard security regulations using a sector approach. “In this case, ACC members can opt to comply with the chemical sector ASP that addresses security practices common to chemical plant operations. This approach focuses regulatory requirements that are common to the chemical sector, providing for an efficient process that minimizes duplication and enhances clarity during implementation.”
Port security begins with the people in the port.Transportation Worker Identification Credential cards are issued to personnel who work in or bring vehicles or vessels in and out of ports, based upon successfully completing a common vetting process. The TWIC card access control is required to be compliant with the Maritime Transportation Security Act of 2002 .
Since ASPs are developed by the private sector in cooperation with the Coast Guard, Erny said the requirements can be updated more frequently to keep pace with the changing security environment. “For example, ACC is finalizing the third edition of the chemical sector ASP. When approved, the new third edition will include a new section on cybersecurity.”
Across the industry, Erny said chemical facilities that operate at the port have numerous aspects in common. “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.”
Erny said the chemical industry has a very good relationship with the U.S. Coast Guard, starting at the local level with the COTP. “We take our security responsibilities under MTSA very seriously – it’s an integral part of safe marine commerce. Our ability to move chemical products in bulk through the inland waterways and along the coastal system is crucial to our nation’s economy, our standard of living, and to the well-being of our communities. To do this effectively, it takes a collaborative approach between the chemical industry and the U.S. Coast Guard. This can be evidenced through the development and effective implement of the ACC Alternative Security Program.”
Port security begins with the people in the port. TWIC cards are issued to personnel who work in or bring vehicles or vessels in and out of ports, based upon successfully completing a common vetting process. The TWIC card access control is required to be compliant with MTSA.
According to Lt. Cmdr. Brett Thompson, who is in charge of TWIC implementation, the TSA issues the card following a verification of an individual’s background. “The Coast Guard is responsible for enforcement of facilities and vessels to incorporate TWIC as part of their access control measures under MTSA.”
Security plans for vessels and facilities must be reviewed and approved every five years to ensure they are current and compliant. If a facility or vessel is subject to MTSA, then it’s subject to TWIC.
“We conduct random checks to make sure the correct processes are in place for access control,” Thompson said.
A recently promulgated rule requires owners and operators of certain vessels and facilities regulated by the Coast Guard to conduct electronic inspections of TWICs as an access control measure. The new rule requires electronic inspection of the TWIC credentials, to include biometrics, to verify people for access at designated high-risk MTSA-regulated vessels and facilities.
According to Cmdr. Frances Fazio, chief of the Cargo and Facility Division, “There are 525 facilities and one vessel designated as part of ‘Risk Group A,’ which come under the ruling. Risk Group A encompasses facilities that handle certain dangerous cargoes [CDCs] in bulk, receive vessels that carry CDC in bulk, or receive vessels that carry more than 1,000 passengers. Additionally, Risk Group A encompasses vessels that carry CDC in bulk, certificated to carry more than 1,000 passengers, or vessels engaged in towing either of the above.
“For those facilities with an existing physical access control system, they will need to incorporate certain requirements explained in the rule-making into their existing system to be compliant,” Fazio said.