February 5, 2008 Sector San Francisco Worker- Facility Access Final Report

February 5, 2008 WORKER-FACILITY ACCESS  PROJECT STATEMENT: Clear and reasonable access systems are required by Marine Transportation Security Act (MTSA) that facilitate personnel access. Persons entering a regulated facility must have both a valid identification and reason to be on the facility. The COTP has determined that any system, which provides a list of workers to a facility prior to the worker’s arrival fulfills this requirement. These access systems must fully comply with the provisions of Title 33, Code of Federal Regulations, Section 105, "Security measures for access control", and Navigation and Inspections Circular (NVIC) 3-07, dated July 2, 2007.

February 5, 2008 WORKER-FACILITY ACCESS  PROJECT GOAL:Develop a reasonable access management system (electronic, , telephone, fax, etc.) used by both labor and facility managers to control personnel access to facilities in accordance with Title 33, Code of Federal Regulations, Section 105, and Navigation and Inspections Circular (NVIC) 3-07, dated July 2, 2007.

February 5, 2008 Previous Regulatory Requirements 33 Code of Federal Regulations Part 105 (July 2004) Required the Facility Security Officer to verify a reason for each person to be on the facility  33 CFR Part (e)(3) Security Measures for Access Control- MARSEC Level 1: Check the identification of any person seeking to enter the facility… This check includes confirming the reason for entry by examining at least one of the following: (i) Joining instructions; (ii) Passenger tickets; (iii) Boarding passes; (iv) Work orders, pilot orders, or surveyor orders; (v) Government identification; or (vi) Visitor badges issued in accordance with an identification system required in paragraph (c) of this section;

February 5, 2008 Current Regulatory Requirements 33 Code of Federal Regulations Part 105 (July 2007) Requires the Facility Security Officer to verify a reason for each person to be on the facility  33 CFR Part (f)(4) Security Measures for Access Control- MARSEC Level 1: Check the identification of any person not holding a TWIC and seeking entry to the facility…This check shall include confirming the reason for boarding by examining at least one of the following: (i) Joining instructions; (ii) Passenger tickets; (iii) Boarding passes; (iv) Work orders, pilot orders, or surveyor orders; (v) Government identification; or (vi) Visitor badges issued in accordance with an identification system implemented under paragraph (d) of this section.

February 5, 2008 Current Regulatory Requirements, Continued… 33 Code of Federal Regulations Part 105 (July 2007) At MARSEC Level 2 requires the Facility Security Officer to verify a destination for each person to be permitted onto the facility  33 CFR Part (g)(5) Security Measures for Access Control- MARSEC Level 2: In addition to the security measures required for MARSEC Level 1 in this section, at MARSEC Level 2, the facility owner or operator must ensure the implementation of additional security measures, as specified for MARSEC Level 2 in their approved FSP. These additional security measures may include: (5) Denying access to visitors who do not have a verified destination