Did you ever wonder how the Coast Guard manages to track activities and enforcement actions across thousands of regulated maritime activities?  Does your Coast Guard Inspector seem to know more of your facility’s regulatory history than your own corporate recall?  If those questions and more make you ponder the reach of your regulators’ data mining capabilities, join us this month as we explore the Marine Information for Safety and Law Enforcement (MISLE) database.

Seebald & Associates International works hard to deliver a thorough, high level Audit for our clients.  Our Audits include:

-               -   A complete review of the Facility Security Plan;

                 -   A tour, review and critique of the entire physical facility and physical security systems;

                 -   Review and testing of the implementation of all security procedures and protocols;

                 -   A review of all Records and Documents, cleaning and updating of records and documents, and implementation of the Seebald Records & Documents Kit;

                 -   Security Awareness training as needed;

                 -   The conduct of at least one security drill;

-               -   The conduct of an annual exercise;

-               -    A comprehensive Audit Report for the FSO (not to be shared with the USCG);

-               -    Preparation of minor amendments;

-               -    One year of telephone support;

-               -    One year of support through our Platinum Membership service.

When you’re looking for an expert to conduct your Annual Audit, consider the team at Seebald & Associates!  We’re here to help ensure that your facility is secure and that you remain in compliance with 33 CFR105!

After doing hundreds of Audits, we see some frightening errors and problems.  The problems run the gamut from physical security problems to not following processes and protocols.  On the physical security side, some of the typical issues include: damaged fences, overgrown vegetation adjacent to fences, and fence areas used as a junkyard.  We also find open gates, damaged or missing signage, and lights that are out.

In the protocols and procedures area, we see a lack of TWIC checks, a lack of random screening, and a general lack of understanding of FSP security protocols.  We also find a lack of proper maintenance of records and documents.

All of these items are fairly obvious and should be observed in routine reviews conducted by the FSO.  They are easily corrected and should be repaired, corrected and maintained on a regular basis.

The answer to the question, "What constitutes an expert?" is fairly simple.  You want a person who thoroughly understands 33 CFR 105, is well-versed in all facility security-related issues, and is not part of your facility's security organization.  Our general guidance is that, “If you know more than your auditor, you need a new auditor.”  The auditor should be your “critical best friend” who will tell you the good, the bad and the ugly regarding your security.  The guy next door is probably not your best pick!  And if you've had the same person serving as your auditor for several years, then it's time to bring in a fresh set of eyes.  

The Audit is a critically important tool to test your FSP and your people, and to keep your facility safe and secure.  The Audit is more than just another regulatory requirement!  Your Audit must include a thorough review of your Facility Security Plan (FSP).  Additionally, it must include a complete site review of your physical security and security systems, and a test of your security screening and monitoring protocols.  At the conclusion of the Audit, you should receive a report of all findings and discrepancies.  Remember, Coast Guard Compliance Inspectors conduct inspections, not audits!!!

The recent Executive Order imposing an immigration order could affect your maritime regulated facility - if a vessel arrives with a crew member from a banned country, there may be:

1) increased CBP presence at your facility;

2) COTP orders* affecting the vessel and your facility;

3) increased USCG presence at your facility.  

* The COTP order may include directed security enhancements short of setting an increased MARSEC level, such as a dedicated security guard at the berth to ensure no unauthorized personnel depart the vessel.  

Have a conversation with your Coast Guard Inspector.  Stay aware - be secure and safe today!