All Maritime Transportation Security Act (MTSA) Regulated
Outer Continental Shelf (OCS) Facility Owners & Operators
In our previous blog, we introduced you to Seebald & Associates International and how we can help you achieve and maintain compliance with your MTSA regulated OCS facility security responsibilities as prescribed in 33 CFR Part 106. Next let’s emphasize what you need to do to improve security, reduce your operational and compliance risk, and make your U.S. Coast Guard inspection and plan submission worry-free.
Seebald & Associates is extremely proud to announce our new affiliation with J. Connor Consulting, Houston, Texas. J. Connor Consulting is an industry and government recognized leader with decades of safety, environmental management and drill permitting experience in the offshore oil and gas industry. Seebald & Associates relationship with J. Connor Consulting will ensure the highest degree of safety and security compliance success. This association of companies allows the bundling of some safety and security management functions and less disruption to your facility’s critical daily operations.
An ounce of preparedness can prevent a ton of response!
While responding to a safety or security incident requires activating contingency plans and resources, it may shutdown production or interrupt operations! Keeping you in compliance and fully operational is our main purpose and focus and we recommend starting the OCS facility plan renewal process at least six months before its renewal deadline. If you answer NO or MAYBE to any of the following statements, then you need to take swift action to avoid costly risks and expenses that can easily be prevented:
- Have my OCS facility company security officers, facility security officers, company personnel with specific security duties and all other OCS personnel been properly trained and the training documented in accordance with 33 CFR Part 106?
- Has my OCS facility security plan been audited in the last 12 months by a competent third-party organization outside of our own?
- Has my currently U.S. Coast Guard approved OCS facility security plan been updated as reflected by any vulnerabilities and non-conformities found during our annual audits?
- Has our MTSA required OCS facility security assessment to include the required vulnerability and risk-based analysis been conducted?
- Has our MTSA required OCS facility security plan been updated with the data from the OCS facility security assessment?
- Are we prepared to meet our five-year renewal deadline for the submission of our updated OCS facility security plan including the required facility security assessment?
- Have we already submitted our OCS facility security plan or plans for all our MTSA regulated facilities? (Early submission does not get penalized by the U.S. Coast Guard and helps them manage the evaluation and approval of MTSA required plans).
- Have we conducted drills every three months that test one part of our OCS facility security plan?
- Have we conducted an exercise in the last eighteen months that tests our OCS facility security plan?
- Have we maintained records and documents as required by 33 CFR Part 106?
- Do we utilize and maintain Declarations of Security with all vessels providing services to our OCS facilities?
- Do we have defensible justification for not meeting the deadline for our OCS facility security plan renewal submission to the U.S. Coast Guard?
If you answered NO or MAYBE to any of the listed statements you should act as soon as possible to prevent a serious disruption to your facility operations in the Gulf of Mexico. Any violation or non-compliance with required MTSA 33 CFR Part 106 security activities is permanently recorded by the U.S. Coast Guard and may result in a disruption. Noting that most OCS facility plan renewals may be due in in the middle of hurricane season in the Gulf, spending time and resources trying to get into compliance after your renewal deadline may be interrupted by storm preparation, evacuation and recovery.
Reminder: Seebald & Associates will be offering the first US Coast Guard approved Company Security Officer/OCS Facility Security Officer training soon with locations along the Gulf Coast.
Seebald & Associates, along with J. Connor Consulting, have a strong reputation and record in meeting and exceeding established U.S. Coast Guard safety and security compliance standards, and we always stand by our clients. We look forward to hearing from and working with you.