Know Your Revised Alternate Security Program (ASP) Jen Wilk Passenger Vessel Association
Tips to Assist - Implementation ALTERNATE SECURITY PROGRAM Tips to Assist - Implementation Why Revised Changes Made Steps for Implementation Tools Guidance Materials
Applicability: Who Has to Have One SECURITY PROGRAM Applicability: Who Has to Have One Required of Vessels Carrying 150 or More Passengers and the Facilities at Which these Vessels Dock Must be Approved by Coast Guard A Security Program Includes Provisions for: Assessing Vulnerabilities and Developing Countermeasures Measures at Different Maritime Security (MARSEC) Levels Training, Drills & Exercises Screening, Access Control Required Recordkeeping and Documentation Acting under the authority of the Maritime Transportation Security Act of 2002, the United States Coast Guard issued a Final Rule on October 22, 2003, requiring certain vessel operators to develop and implement security measures. The majority of the maritime security rules are to be found in Title 33, Code of Federal Regulations, Subchapter H. Vessel operators have two choices to meet these requirements. One option is for a company to write and implement an individual security program that must be approved by the Coast Guard. The other is to use an already developed and approved industry-wide alternative. The Alternate Security Program (ASP), developed by the Passenger Vessel Association and approved by the Coast Guard provides a comprehensive and well established means of compliance for those domestic passenger vessels, small passenger vessels and facilities subject to maritime security requirements. Compliance with the PVA Program meets all the security requirements as an Approved Alternative under 33 CFR 101, 104 and 105 PVA members with a vessel with a passenger capacity of 150 or more may elect to satisfy the requirement to implement a Vessel and/or Facility Security Plan using the PVA Program
Why Revise the ASP? Required Update and Renew ASP Every 5 Years ALTERNATE SECURITY PROGRAM Why Revise the ASP? Required Update and Renew ASP Every 5 Years September 12, 2017, Coast Guard Approved 4th Revision of ASP Updates Include New Coast Guard Requirements and Policy Guidance Improve User Experience – Provides Clarification Based on Feedback Framework and Solutions are both Reasonable and Achievable for PVA Operators
ALTERNATE SECURITY PROGRAM Timeline The latest revision will be in effect until September 12, 2022 90 day phase in period for implementation Do not wait until December 11 to fully implement Member have until December 12 to fully implement the revised ASP.
Changes Updated Coast Guard Requirements and Policy Guidance ALTERNATE SECURITY PROGRAM Changes Updated Coast Guard Requirements and Policy Guidance PVA Tools and Resources Formatting Changes
Cyber Security Definitions of Cyber Security and Cyber Security Breach ALTERNATE SECURITY PROGRAM Cyber Security Definitions of Cyber Security and Cyber Security Breach Assess Vulnerabilities (New Form) Encourage Best Practices Report Cyber Activity that Could Result in Transportation Security Incident (TSI) National Response Center National Cyber Security and Communications Integration Center (NCCIC) - Part of Department of Homeland Security (DHS) National Cybersecurity and Communications Integration Center (NCCIC)
TWIC Readers Only Applicable to certain regulated facilities ALTERNATE SECURITY PROGRAM TWIC Readers Only Applicable to certain regulated facilities Receive Vessels that Carry >1,000 passengers Installation completed by mandated deadline (Aug 2018) Records maintained as required Possibility of Delayed Implementation Date
Breach of Security Applies New Policy Letter Guidance ALTERNATE SECURITY PROGRAM Breach of Security Applies New Policy Letter Guidance Updated Breach of Security Form Reporting National Response Center NCCIC National Cybersecurity and Communications Integration Center (NCCIC)
Screening Updated Definition ALTERNATE SECURITY PROGRAM Screening Updated Definition Added MARSEC Directives to Provide Clarification on Applicable Screening Rates for Domestic Passenger Vessels: 104-2 - Passenger Vessel/Ferry Vessel 105-1 - Cruise Ship Terminal (For reference if cruise ships dock at a facility that uses the PVA ASP) 105-2 - Passenger Vessel/Ferry Vessel Terminal
ALTERNATE SECURITY PROGRAM Screening A reasonable examination of persons, baggage, vehicles, carry-on items, etc. for the protection of the vessel, its passengers and crew. The goal of screening is to preclude the introduction of an unauthorized dangerous substance or device that may cause significant loss of life, environmental damage, transportation system disruption or economic disruption in a particular area.
PVA Resources and Tools ALTERNATE SECURITY PROGRAM PVA Resources and Tools New Cyber Guidance – Best Practices New Cyber Assessment Form Revised Vessel and Dock Assessment Form Drill and Exercise Templates TSA Training Videos (Online Training Portal) TSA Cyber Security Resources
ALTERNATE SECURITY PROGRAM Formatting Changes Appendices and Guidance Modified to Improve Ease of Use Appendices Better Mirror Elements of ASP Some New Appendices Added So Company-Specific Information Can be Better Catalogued
Steps for Implementation ALTERNATE SECURITY PROGRAM Steps for Implementation Review All Changes So You Are Familiar with Revisions Conduct Assessment of Vessel(s) and/or Facilities (Using Revised ASP) Transfer and Update, as appropriate, all Vessel and Facility Company Specific Information Note Appendices Changed Include Vessel/Facility Schematic (Secure, Restricted, Employee, Passenger Areas) Retain Records – Drills, Exercises, Declaration of Security etc.
Steps for Implementation ALTERNATE SECURITY PROGRAM Steps for Implementation Advise Your Company’s Personnel with Security Responsibilities on Applicable Revisions to the ASP Review Changes to Actions at Different MARSEC Levels Document This as a Drill – You Get Credit For It! Towards Your 3 Required Drills Annually
Steps for Implementation ALTERNATE SECURITY PROGRAM Steps for Implementation Inform the Coast Guard only if: Vessel Additions/Deletions are not up to date Any Changes to Facility Vulnerabilities and Countermeasures. Notify Coast Guard Captain of the Port of Using Template Letter and CG Form 6025 in Appendix J & K Remove and Destroy All Outdated Info Associated with Previous Versions of the ASP If there is no record in the company ASP that a letter was sent to the CG Marine Safety Center identifying which vessels are enrolled in the ASP, then a separate letter needs to be submitted with all vessels currently using the ASP. Members do not need to notify the CG if there are no changes to the vulnerabilities and countermeasures.
ALTERNATE SECURITY PROGRAM Updating Contact Info with PVA PVA is Updating Records for Contact Information of Company Security Officers (CSO) Email Jen Wilk jwilk@passengervessel.com Email Eric Christensen echristensen@passengervessel.com Fill Out Online Form: (PVA ASP Update form)
Thank You! Jen Wilk Director, Security Program, Public Affairs & Development 800-807-8360 ext. 24 jwilk@passengervessel.com Passenger Vessel Association 103 Oronoco Street Suite 200 Alexandria, VA 22314