Calendar year 2019 is almost halfway over and after conducting numerous Facility Security Plan annual mandated audits, we note many Facility Security Officers (FSO), Company Security Officers (CSO), Alternate FSOs, Personnel with Security Duties (PSD) and All Others (AO) are not current on their required Maritime Transportation Security Act (MTSA) training.
This non-conformity is a compliance risk and will draw warnings and citations from a U.S. Coast Guard facility security inspection. It is generally recommended that facility security staff attend a U.S. Coast Guard approved 33 CFR, Part 105 or Part 106 training course at a minimum initially, then every 3-5 years with a refresher course. Depending on when security personnel have been trained, even within the past 5 years, many new MTSA regulation, guidance and policy updates and changes have taken place. Recent topics of significant interest are cyber-security threats, seafarer access, active shooter threats, TWIC card access procedures and cruise terminal screening requirements.