Recently, several experienced U.S. Coast Guard facilities inspectors reported finding these issues at numerous facilities:
- Documented drills focused on portions of the facility not regulated by the Maritime Transportation Security Act (MTSA); often these drills were dictated by corporate headquarters. Although inappropriately filed with MTSA-required documentation, these drills do not fulfill MTSA’s monthly requirement.
- The same drills completed month after month.
- Safety drills filed as security drills, although the drill was stopped before actually exercising any potential security nexus. (for example, a fire at the plant could result in the fire department being summoned, but drill stopped before Personnel with Security Duties (PSD) are tested for their ability to receive and appropriately direct arriving emergency personnel).
What does Seebald & Associates recommend? Your documentation is critical to making a good impression on a Coast Guard inspector. We recommend:
- Minimize documents given to the U.S Coast Guard Remove drill data older than 2 years. Do NOT include drills that fail to exercise your Facility Security Plan (FSP) or that do not relate to your MTSA-regulated footprint.
- If necessary, educate your corporate headquarters regarding the U.S. Coast Guard’s exclusive focus on your FSP and the MTSA-regulated footprint; if your HQ still requires drills outside this limited purview, file those drills separately from your MTSA-required FSO documents. (When police stop a motorist and ask for license and registration, is it wise to also volunteer your tax returns? No!)
- Vary your drill material to eventually test every element of your FSP. Vary shifts and weekend/weekdays, keeping everyone more alert. Conducting the same drill every month breeds complacency.
- Collaborate closely with your safety staff. Allowing a safety drills to progress the point where security is also tested will maximize your facility’s drill effectiveness (“killing two birds with one stone”), enhance collaboration between facility personnel, and minimize lost operational time. The same is true for those frequent safety briefs - ask to have a couple minutes to review security information, such as the requirements for “all other” personnel to know - especially before the U.S. Coast Guard comes to inspect!
... and remember vessels at the facility during your drills! The regulations stipulate that the facility can't force a vessel to participate in a drill, but Seebald & Associates recommend inviting them to participate as a best practice. At a minimum, the FSO should notify the vessel that the facility is (or will be) conducting a security drill. Drills that involve suspicious activity/packages, breach of security/possible intruder, MARSEC increase, etc. - all of these and more should involve notifying the vessel, even if the vessel doesn't want to participate (or simulated vessel notification if no vessel is actually present).