The United States Coast Guard (USCG) Federal Maritime Security Coordinator (FMSC) for Los Angeles / Long Beach, who is also the Captain of the Port (COTP), issued Policy Letter 01-06 on 20 February 2006 concerning ship access control for shore-based workers. This policy memo serves to clarify the requirements for ships, facilities and persons subject to the security requirements of the International Ship and Port Facility Security (ISPS) Code and the Maritime Transport Security Act (MTSA) of 2002 for the COTP of Los Angeles and Long Beach zone.
It is important to note that failure to ensure that persons on board a ship are properly identified and authorised may result in the ship incurring criminal or civil penalties and there is also the possibility of an order that the ship cease operations. The policy letter includes the following requirements:
· Domestic and International Laws require facility owners and ship operators to control access.
· Access control is the cornerstone of a security regime and the most sensitive part of any security arrangement is the facility-to-ship interface. The identification and control of access of ship vendors, longshoremen, and other shore-based workers is essential to determine who is authorised to be on board ships.
· Permission to be in a facility does not automatically guarantee permission to be on board a ship. Sighting of identification cards must be demanded when a non-crewmember goes on board a ship.
· Any personal identification credential accepted under the access control provisions must, at a minimum, meet 33 CFR 101.515. The ID issuing authority must be a government authority or the individual’s employer, union or trade association. An example would be a valid photo driver’s license or a Pacific Maritime Association photo ID.
· Alternative access control measures may be proposed but must be approved by the FMSC and documented as a temporary security measure in an amended Facility or Ship Security Plan per 33 CFR Subpart H. At a minimum, these alternatives must contain:
- Disciplinary measures to discourage abuse
- Identification of every person visiting a ship
- Documentation of this alternative procedure on the Declaration of Security.
According to C&H Patriot Security, transportation security specialists, the policy letter should not impose any requirement additional to what is stated in a standard ISPS shipboard security plan. Such plans should require the gangway watch to check the identity of all persons seeking to board the ship and confirm their reasons for doing so by checking Agent’s instructions, boarding passes, work orders, etc. No unauthorised persons should be allowed to board the ship.
Please be aware the USCG takes all breaches of security at regulated ships and facilities very seriously. To avoid a potential Coast Guard enforcement action, all ships and facilities should take immediate action to prevent such incidents.
For additional information, questions or to report a breach of security, please contact the 24-hour Los Angeles-Long Beach Sector Command Duty Officer at +1 310-732-2045 or the National Response Centre at +1 800-424-8802.
Source of information:
C&H Patriot Security
Security Advisory 1-06