The recent American Association of Port Authorities (AAPA) Port Operations, Safety and Technology Seminar included a Panel on “Regulatory Updates Roundtable: Safety and Security.” This Panel included a presentation on “Coast Guard Regulated Waterfront Facilitiesâ€”Port Safety Requirements” that also covered maritime transportation security and one on “Regulatory Updates,” (to be discussed in a future post, in addition to the exposition on the TWIC Pilot discussed in a previous post. The AAPA Seminar took place on June 7th in Long Beach, California. I wasn’t there, so the following is based on the PowerPoint® slides that the AAPA has kindly posted on its website.
Facility Security Inspection Results
The “Port Safety Requirements” briefing, which was delivered by LT Michael Collet, Chief, Facilities Inspection Branch, USCG Sector Los Angeles-Long Beach, had a two-fold “agenda:”
Scope of Facility Safety Inspection/Pollution Prevention Program
Common Discrepancies identified within each safety related category.
One slide provides the breakdown, by annual facility inspection category, of 8963 “deficiencies” uncovered at 3671 waterfront facilities (an average of 2.44 deficiencies per facility). The slide does not indicate a time frame for these inspections. A different slide, entitled “Discrepancy Overview” displays a graph indicating that total discrepancies” peaked in 2007 at about 8,500 and then dropped to about 5,500 in 2010, leaving at least me wondering whether “discrepancies” and “deficiencies” are the same or different.
Whatever the time-period, 42% of the deficiencies fell under the category of “Documentation,” with a specific mention of the need to log safety and security drills and exercises and with “Honorable Mention” for warning signs, such as for restricted areas. The next largest category of deficiencies, at 26%, was “Ops Management,” where “Almost All Deficiencies were Security Related.” Specific issues included access control procedures, Facility Security Officer responsibilities, failure to conduct drills and exercises, and the need to follow MARSEC directives at all Maritime Security Levels. A third inspection category, “Personnel” accounted for 5% of the deficiencies and “had Mostly Security Related Deficiencies.” The major problem was lack of FSO understanding of the Maritime Transportation Security Act and other maritime security requirements, leading to the conclusion that there’s a “Big need for FSO Training!” [Shameless Plug: The next MPS Maritime Security Officer Course will convene on August 2nd. Get information here and request enrollment here. End Shameless Plug] The “Ripple Effect of Poor FSO Trainings” leads to facility personnel with security duties also having a poor grasp of the Maritime Transportation Security Act and other maritime security mandates. And again, LT Collet’s suggested remedy is “Training!” [Another Shameless Plug: MPS can help with this kind of training too. End Shameless Plug]
It’s nice to see some information on facility security inspection results for the first time in a long while. The Coast Guard releases yearly breakdowns of the types of security deficiencies that led to “Major Control Actions” against foreign-flag vessels in US ports, as part of annual Port State Control Reports. But the only other statistics on facility security deficiencies that I know of are in a 2008 Government Accountability Office Report and date from 2006. The problem LT Collet’s briefing from the standpoint of maritime transportation security practitioners is that his security data is commingled with safety and oil pollution issues. If the category Ops Management is almost entirely composed of security deficiencies, this type of deficiency would loom larger in a security-only than it does when these deficiencies are comingled with fire fighting and pollution control equipment problems. The GAO focus on security alone produced a much clearer picture, as may been seen in the following pie chart.
If the Coast Guard were to publish such a pie chart or a bar graph showing the proportions and absolute numbers of security violations annually, the maritime transportation industry would have a better idea of what to concentrate additional security efforts. Trainers would know the areas to which to add emphasis while training FSOs. In short, publication of this kind of data could result in actual improvements in maritime transportation security. It would not need to be a glossy report like those issued on Port State Controlâ€”a quick and dirty “just the facts, Ma’am” would do the trick. But give LT Collet credit for making a start.NOTE: This post, or any portion of it, may be copied, distributed, and displayed and derivative works may be based on it, provided it is attributed to Maritime Transportation Security News and Views by John C. W. Bennett, www.mpsint.com.