Last week we addressed the regulatory requirement for Drills and Exercises, but there are more important reasons for conducting these.  At a truly secure facility, the FSO must know the security strengths, weaknesses and vulnerabilities.  In order to accomplish this, drills and exercises are used to test your FSP and test your personnel.  A powerful way to uncover potential weaknesses is to conduct meaningful drills.  Are there confusing or ineffective parts of your FSP? Are there post orders that are confusing to your security guards (PSDs)?  Are there particular guards that need re-training or does the entire guard force need a training refresher?  Frequent drills improve your FSP, strengthen the skills of your people, and make your facility more secure!

Next week we’ll address some tips & tricks for conducting drills.

...It's the law! Let's start by reviewing the regulatory requirements for Drills and Exercises.  33 CFR 105.220 requires that all facilities conduct at least one drill every three months and must test one element of the Facility Security Plan (FSP), including response to security threats and incidents.  Drills should take into account the types of operations of the facility, facility personnel changes, the type of

vessel the facility is serving, and other relevant circumstances.

Exercises must be conducted at least once each calendar year, with no more that 18 months between exercises.  Exercises are a full test of the security program and must include substantial and active participation of FSOs, and may include government authorities and vessels visiting the facility.

We've confirmed with our Coast Guard contacts that there most likely will be a delay in implementing the TWIC Final Rule. Bottom line is Don't make any big decisions until the government provides further information. The Coast Guard is exploring all options and will issue guidance. We at Seebald & Associates expect that guidance in the coming months. 

We'll strive to be the first to keep you informed with maritime security news and perspective. Be well - Stay secure & safe!

Maritime Security Colleagues, 

You may have heard that the TWIC Final Rule implementation date may be delayed as the Coast Guard considers reopening the rule for further comment. This news comes from a report of a recent meeting between the Coast Guard, congressional representatives, and industry. We made inquires to clarify this report. The verdict is still out on its accuracy. We'll keep looking for an official Coast Guard statement on this and will pass it to you as soon as we receive it. 

In the meantime, how does this impact you? If you're a Risk Group A facility, you can continue your planning toward impleneting electronic TWIC readers. We still advise you to wait on purchasing any electronic TWIC readers or integrated Physical Access Control System pending more specific Coast Guard guidance. 

Physical Access Control System - PACS can satisfy the requirement for electronic TWIC inspection on Risk Group A facilities in one of two ways: 

     -     PACS (with facility access card) registered to an individual whose TWIC and biometric data is stored in the facility's access control system. The facility access card holder presents access card, submits biometric at entry point and the system validates the TWIC card has not been canceled or expired against the TSA Canceled Card List (CCL).

     -     PACS (with biometric only) registered individual whose TWIC and biometric data is stored in the facility's access control system. The indiviual submits biometric at entry point and the PACS validates the TWIC card has not been canceled or expired against the CCL. 

Remember - Everyone in a PACS authorized to access the secure or secure-restricted portion of a maritime facility is also subject to random screening.