Recall the 3 P’s of access control –

  • Physical – security infrastructure and systems
  • Presence – bearing and attitude of security force personnel
  • Performance – security training, experience and application

Last week we touch on Physical security.  This week we address two more of access control’s 3 P’s, Presence and Performance.

Presence of a security force is necessary, and the Presence of the security guard is informative to Coast Guard Inspectors, Auditors, and would-be attackers.  In our line of work, we use terms like ‘Officer Presence,” “Bearing,” and “Attitude” to describe this.  Do your security personnel make you proud and feel secure?  Are they professionals in their appearance and demeanor?  If not, what are you – the FSO – doing about that?

Performance is how equipped the security force is and how well they carry out their duties.  Are security personnel properly trained, to include facility-specific training and awareness?  Do they have the requisite experience you require to guard your facility?  Are they confident in applying the security protocols required by the FSP?  How well do you sleep at night, knowing that your security personnel are standing the watch at your facility?

Ensuring the 3 P’s is the FSO’s job in conjunction with the security force.  Don’t rely solely on your security supervisor, doing so may eventually scare the P out of you!

As the FSO, you get this!  After all, your job depends on it.  The company is depending on you.  The local community and beyond is depending on the company.  Trade secrets, competitive advantage, threats, vulnerabilities… the list goes on.  Oh, and Coast Guard Inspectors do make unannounced visits to ensure you’re in compliance with MTSA, 33 CFR 105, NVIC 03-03 Change 2, and NVIC 03-07 along with other applicable regulations.

Remember the 3 P’s of access control –

  • Physical – security infrastructure and systems
  • Presence – bearing and attitude of security force personnel
  • Performance – security training, experience and application

The first of the 3 P’s, Physical security, forms the first impression – for compliance with the regulations, as well as target desirability for the would-be attacker.  Is the physical security well maintained, shiny and new looking, or not so much?

We’re talking about things like fencing, vehicle/rail/pedestrian gates, emergency egress points, sensor detection systems, lighting, and operational and/or security camera systems.  Much of this is not specifically spelled out in the CFR.  Look to security Best Practices and Industry Standards; and/or look to Seebald & Associates for their expertise by giving us a call.

The more sensitive the facility/product/location, the more formidable the physical infrastructure should be.  Ask yourself, is your facility a hard or soft target?

S&A Blog Title:  It's National Cyber Security Awareness Month!

Fellow Maritime Security Professionals - 

In case you missed it, the latest Coast Guard's Maritime Commons blog notes that October is National Cyber Security Awareness Month.  The Coast Guard's weekly blogs this month will contain important information on cybersecurity risk management.  And for a refresher, visit our web site, where we offer cyber security presentations from our Facility Security Symposium and webinars:

Cyber Security and the Maritime Transportation System


Building a Winning Cyber Security Program


Stay sharp - be secure & safe - train, drill, and exercise your facility personnel!

We’ve listened to your feedback!  The blogs this month are designed to you assist you in controlling facility access points and remaining compliant with random screening requirements.  Topics include:

3 P’s of access control

  • Physical – security infrastructure and systems
  • Presence – bearing and attitude of security force personnel
  • Performance – security training, experience and application

Just what does random screening mean?

Random screening is just that – screening that occurs without definite aim, reason, or pattern.  Random is NOT every 10th person or vehicle.  You are required to develop a protocol for randomizing your screening.  A best practice in random selection is the “Marble Method,” which is recognized and approved by the Coast Guard.  Other randomizing techniques may include a software program that randomly selects a person or vehicle to screen.  DO NOT rely on individuals determining off the top of their head when to screen – their choices are NOT random.

Randomizing your screening makes your access control effective by eliminating predictability, and will deter folks entering your facility from trying to bring on prohibited items.  A random screening protocol will increase your facility’s security reliability!

Join us this month while we review the regulatory requirements for the sake of building your security awareness.  Suggested Reading - 33 CFR 105.255.

An FSP is required to be resubmitted every five years to include a new FSA.  You are required to submit one copy of the FSP for review and approval to the cognizant COTP and a letter certifying that the FSP meets applicable requirements of Subpart D - Facility Security Plan.  The FSP must be submitted 60 days prior to allow the COTP enough time to review, and if your FSP consists of new operations, then you cannot start operations until your FSP is approved.  The COTP will examine each submission for compliance and either:

  • Approve it and specify any conditions of approval, returning to the submitter a letter stating its acceptance and any conditions;
  • Return it for revision, returning a copy to the submitter with brief description of the required revisions
  • Disapprove it, returning a copy to the submitter with a brief statement of the reasons for disapproval

Remember, completing a thorough and proper FSP, which is based on your FSA, is a lengthy process and you should not wait until the last minute.  When Seebald & Associates conducts an FSA, and writes an FSP we start the process at least 6 months before your FSP is due for submission.