Facility Security Documentation Requirements

1. Facility Security Documentation Requirements

2. Requirement • All of the documents in the next slide are SSI and should be treated as such. • If kept in electronic format ensure all of the following are recorded and protected accordingly.

3. Main Documents • ASP or FSP • FSA • CG-6025A

4. All of the documents in the next slide are required to be kept for two years except for DOS which is to be kept for at least 90 days after the end of its effective period

5. Documents • (1) Training records for facility personnel with security duties ONLY (those personnel covered in 33 CFR 105.210) • (2) Drills and Exercises • (3) Incidents and Breaches of Security • (4) Change in MARSEC Levels • (5) Maintenance, calibration, and testing of security equipment • (6) Security Threats • (7) Declaration of Security (DoS) • (8) Annual audit of the FSP/ASP

6. Documentation • The Coast Guard cannot monitor every facility 24 hours a day. • Facilities must maintain records as proof of implementation of security measures. • Records should also be viewed as a source of information for planning audits and exercises.

7. Training Records • For each training you will record: • the date of each session • duration of session • a description of the training • a list of attendees

8. 105.210Employees with Security Duties Training • The FSO will ensure that facility personnel with security duties are trained in accordance with 33 CFR 105.210. • Ensure that “appropriate” subjects match the reason the facility is MTSA compliant.

9. For each drill or exercise record: the date held, description of drill or exercise, list of participants, and any best practices or lessons learned which may improve the Facility Security Plan (FSP); 105.220Drills and Exercises

10. Incidents and breaches of security For each incident or breach of security record: • the date and time of occurrence • location within the facility • description of incident or breaches • to whom it was reported • description of the response

11. Change in MARSEC level For each change in MARSEC record: • the date and time of notification received • time of compliance with additional requirements

12. 105.250Security Systems and Maintenance • These records serve the following purposes: • It forces the FSO to take a look at ALL the security systems and equipment on hand and mandates that the equipment receive adequate maintenance. • Ensures faulty equipment will be identified. • Ensures the use of manufacturer’s recommended maintenance procedures.

13. 105.250Security Systems and Maintenance • You must have records on: • Lighting. • Intrusion detection devices. • Cameras and monitors. • Access control systems such as card readers. • Fences, gates, and barriers. • all security equipment is to be tested and maintained IAW the manufacturer’s recommendations.

14. Security Threats For each security threat record: • the date and time of occurrence • how the threat was communicated • who received or identified the threat • description of threat • to whom it was reported • description of the response

15. 105.245Declaration of Security • The point where two security programs meet pose an ideal place for a threat to succeed. • The Declaration of Security (DoS) identifies the required security specific tasks, as well as who is responsible for them.

16. 105.245Declaration of Security • The time frames for a continuing DoS at MARSEC Level 1 is 90 days and 30 days for MARSEC level 2. • Continuing DoS are only good for a specific MARSEC Level. • The plan will have procedures for changing the DoS based on a change in MARSEC Level? • The FSP will ensure a copy of all current, continuing DoS are kept with the FSP?

17. 105.305(d)(1)The FSA Requirements • This section of the plan ensures that the owner / operator: • Conducted a physical survey of the facility. • Identified all the resources. • Identified which resources require protection. • Identified the security measures currently in place to protect those resources. • Determined the adequacy of their existing security posture. • Upgraded the shortfalls (mitigated the vulnerabilities).

18. CG-6025 • Form must have all facility and COTP administrative information: • Name • Address • LAT / LONG coordinates • Vulnerabilities. • Mitigation strategies for vulnerabilities. • Must match the FSA.

19. Vulnerabilities Poorly Secured Chemical Storage

20. Vulnerabilities • Poorly Maintained Equipment

21. Vulnerabilities Poorly Designed Equipment

22. Facility Security Plan (FSP) • (1) Security administration and organization of the facility • (2) Personnel training • (3) Drills and exercises • (4) Records and documentation • (5) Response to change in MARSEC Level • (6) Procedures for interfacing with vessels

23. Facility Security Plan (FSP) • (7) Declaration of Security (DoS) • (8) Communications • (9) Security systems and equipment maintenance • (10) Security measures for access control, including designated public access areas • (11) Security measures for restricted areas • (12) Security measures for handling cargo

24. Facility Security Plan (FSP) • (13) Security measures for delivery of vessel stores and bunkers • (14) Security measures for monitoring • (15) Security incident procedures • (16) Audits and security plan amendments • (17) Facility Security Assessment (FSA) report • (18) Facility Vulnerability and Security Measures Summary (Form CG-6025)

25. Alternate Security Plans • Will be covered later

26. 105.415Audits and Amendments • The FSO will ensure the FSP is audited and all amendments are completed in accordance with 33 CFR 105.415. • For each annual audit, a letter certified by the FSO stating the date the audit was completed

27. Questions?