FACILITY SECURITY PLANS (FSP’s)

1. FACILITY SECURITY PLANS(FSP’s) MSD STURGEON BAY MST2 JEROMY COWELL

2. FORMAT & CONTENT • Security Administration & Organization • Personnel Training • Drills & Exercises • Records & Documentation • Changes is MARSEC Levels • Interfacing with vessels • Declaration of Security • Communication

3. FORMAT & CONTENT • Security systems/equipment • Access Control • Restricted Areas • Handling cargo • Delivery of vessel stores & bunkers • Monitoring • Audits & Amendments • Facility Security Assessments • Facility Vulnerability (CG-6025)

4. Submission & Approval • 1 copy of the facility FSP must be submitted to the local COTP for review and approval • USCG reviewers can either approve it, return it for revisions, or disapprove it • One FSP may be submitted to cover more than one facility with similarities of design & operations • Once approved, the FSP is valid for 5 years from the date of approval

5. Amendments • Initiated by either the facility or the COTP if deficiencies are found • For amendments initiated by the COTP, facility has at least 60 days to submit proposed amendments • Amendments by the facility must be submitted at least 30 days prior to it taking effect for COTP review • Facility change in ownership requires a amendment(s)

6. Audits • Performed Annually • Conducted for FSP(s) if: • A change in facility ownership • Facility modifications • Auditors must have knowledge of security techniques & methods

7. USCG Enforcement Actions • CG-835 Facility Inspection Requirements • Letter of Warnings • Notice of Violations • Class I Civil Penalties

8. CG-835 Facility Inspection Requirements • For minor first-time infractions where on-the-spot training can correct the deficiencies • Given a specific date to correct the deficiencies • Issued at the discretion of USCG facility inspectors • Lowest level of enforcement

10. Letter of Warning (LOW) • It’s like a written warning issued by a police officer for a traffic violation with no monetary penalty, but will stay on a facility’s record for 1 year. • Facilities can either “Accept” or “Decline” the warning • Declining a LOW will progress the violation to a Notice of Violation.

12. Notice of Violation (NOV) • It is similar to a traffic citation given by a police officer for a traffic violation resulting in a monetary penalty • For penalties less than $10,000 • Can either “Accept” or “Decline” the NOV • Can “Decline” the NOV within 45 days, afterwards it goes to USCG collections department. • “Declining” a NOV will send the violation to a USCG Hearing Officer for a determination • Final assessment may be equal or greater than the proposed penalty

14. QUESTIONS ?