procedures necessary to comply with Department of Homeland Security/Coast Guard regulatory requirements for vessel security plans. The following list provides an example of the services and assistance that an ASP can provide to vessel owners and operators: � Security related assistance in training both vessel and office based personnel � The creation and implementation of security drills and exercises � The implementation of a system to comply with the recordkeeping requirements and the protection of sensitive security related information � Assistance in responding to changes in the MARSEC Level � The creation of procedures for vessel interaction with both port facilities and other vessels � Declaration of Security (DOS) requirements � The installation and design of vessel security systems and maintenance � The creation and implementation of security measures related to vessel access, restricted areas access, cargo handling, vessel stores and fuel, and vessels temporarily out of service Furthermore, some ASPs provide annual audits to ensure that member owners and operators continue to comply with the plan. Routine Coast Guard inspections ensure compliance with the vessel based security regulations. A Vessel/Facility Security Verification Report will be completed by the Coast Guard inspector prior to leaving the vessel after conducting an inspection. The verification report will be left with the vessel safety officer. Minor security related discrepancies will be expected to be corrected on the spot. Larger discrepancies will be noted in the report if further correction is needed. For major issues that materially affect the security posture of the vessel, the Coast Guard Port Captain will issue an order restricting the vessel from conducting any MTSA regulated operations and may opt to pursue further enforcement actions including a Letter of Warning, Notice of Violation or a civil penalty. Major discrepancies which will require correction include, but are not limited to: 1. The VSP or ASP is not on board the vessel, or is on board but not approved 2. The absence of an assigned VSO on board
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3. The VSO on board is not competent to serve as a VSO 4. The crew assigned security responsibilities are not familiar with the VSP/ASP or their responsibilities 5. A lack of vessel access control as required in the approved VSP/ASP Considering the complexity of the post September 11 security rules and regulations, these Coast Guard approved Alternative Security Programs provide a practical means for vessel owners and operators to ensure compliance with Coast Guard security regulations. As with all plans, a good plan does not do anything to protect the owner or operator if it is not implemented properly. Thus, once a plan is developed, all employees, whether vessel or office based, should be trained, drilled, and updated on an ongoing basis. Additionally, management should also develop a plan of monitoring the training and implementation of the plan with the hopes of identifying any gaps in the plan before a potentially unsafe situation develops.
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