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FACILITY SECURITY PLANS (FSP’s)
MSD STURGEON BAY MST2 JEROMY COWELL
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FORMAT & CONTENT Security Administration & Organization
Personnel Training Drills & Exercises Records & Documentation Changes is MARSEC Levels Interfacing with vessels Declaration of Security Communication
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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)
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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
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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)
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Audits Performed Annually Conducted for FSP(s) if:
A change in facility ownership Facility modifications Auditors must have knowledge of security techniques & methods
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USCG Enforcement Actions
CG-835 Facility Inspection Requirements Letter of Warnings Notice of Violations Class I Civil Penalties
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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
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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.
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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
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QUESTIONS ?
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