Commercial Vessel Compliance

6/7/2018: Summary of National Alternative Security Program sponsoring organizations workshop

The National Alternative Security Program (ASP) Sponsoring Organizations held a workshop in Washington, D.C., May 30, 2018, to discuss ongoing and emerging issues related to meeting regulatory requirements of the Maritime Transportation Security Act (MTSA) of 2002. MTSA was enacted to keep U.S. shores and vital waterways open, safe and secure for commerce.

The semi-annual workshop was hosted at the offices of the American Chemistry Council. Attendees came from as far away as Seattle and New Orleans and represented 11 industry organizations that oversee thousands of MTSA-regulated vessels and over two hundred MTSA-regulated facilities that share common business models. Industries represented include passenger, ferry and gaming vessels, offshore service and towing vessels, chemical and barge fleeting facilities, and grain terminals.

Coast Guard Director of Inspections and Compliance, Capt. Jennifer Williams, opened the workshop by welcoming attendees and thanking them for their ongoing work to ensure a safe and secure Marine Transportation System. Williams discussed the Coast Guard’s focus on improving its Third Party Oversight program in light of the recommendations in the El Faro Final Action Memo, as well as working toward a smooth implementation of the first major phase-in period for towing vessels regulated under Subchapter M. In addition, Williams provided an update on the TWIC Reader Final Rule, which is currently under review with the Office of Management and Budget, and the Coast Guard’s draft cyber NVIC, which is in the final stages of internal review following adjudication of over 200 public comments. Williams encouraged attendees not to wait for the Coast Guard’s cyber NVIC, but to begin thinking about their cyber risk management strategy now.

“Whether you’re a vessel or a facility, cyber should be a critical piece of your safety and security strategy going forward,” Williams said. “If you’re not already thinking about it, you need to start now because it should be a part of all your risk management plans, including your day-to-day operational plans.”

Representatives from the Transportation Security Administration gave a presentation on upcoming enhancements to the TWIC’s design and embedded security features. Those who currently hold a valid TWIC will not be required to obtain the new card until their normal renewal cycle, or if their current card is damaged or lost. TSA will begin issuing the newly designed card to first-time and renewal applicants in the near future. Editor’s note: For the convenience of our readers, FAQs from TSA about the new TWIC are included at the end of this post. For more information contact TSA.

Mr. Casey Johnson, a program analyst with the Office of Port and Facility Compliance, gave a brief on the Coast Guard’s work with the Federal Aviation Administration to identify potential impacts unmanned aerial systems – drones – could have on the safety and security of maritime critical infrastructures. Johnson said the Coast Guard’s primary goals are to establish a conduit for maritime industry to report unauthorized drones operating near vessels or port facilities, while ensuring legitimate drone use remains unimpeded.

“Many industry partners use drones for inspections, so we have to find the right balance,” Johnson said.

Ms. Betty McMenemy briefed attendees on implementing five year renewals of their ASPs, including the renewal timeline, sponsoring organization and member responsibilities, and the importance of conducting security assessments.

“Security programs are designed to address vulnerabilities, so if you don’t do an assessment of the facility or vessel type, how do you know what vulnerabilities need to be addressed?” McMenemy said.

Additionally, McMenemy emphasized the need for users to identify, by name or by title, the facility/vessel security officer and the company security officer, as well as identifying any secure or restricted areas, and employee and public access points.

Other items on the workshop agenda included:

• Status of current regulations, including the as-yet-unpublished Seafarer’s Access rule and the Consolidated Cruise Ship rule, which went into effect April 18, 2018
• Overview of the Homeport 2.0, which launched September 2017
Area Maritime Security Committees roles and responsibilities

“The Coast Guard conducted over 5,300 security-related inspections at MTSA-regulated facilities last year,” said Capt. Ryan Manning, chief of the Office of Port and Facility Compliance. “Every opportunity we have to meet with large industry groups that are dedicated to keeping their members in compliance with federal regulations not only keeps the Coast Guard relevant and in step with fast-paced technology, but also reinforces our ability to maintain secure and safe ports.”

The next National Alternate Security Plan Workshop is tentatively scheduled for June 2019. For more information, contact Ms. Betty McMenemy at

Graphic showing FAQs on new TWIC

For more details on the new TWIC, contact TSA.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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