Posted by: towmasters | October 17, 2009

ALCOAST: Seafarers Shore Access On Maritime Transportation Security Act (MTSA) Facilities

Here’s some more potentially good news on the sometimes serious mariner access problems that we’ve all experienced at various terminals and facilities when trying to change out crews, go grub shopping or just take a simple walk for exercise. Coast Guard Rear Admiral Kevin Cook, Director of Prevention Policy, released this ALCOAST (CG-wide) message on October 2nd that clearly states that the Coast Guard recognizes that there is still a problem and that it needs fixing. We’re into the thick of the 5-year renewal period for the original versions of the Facility Security Plans  (FSP’s) that were mandated in the Maritime Transportation Security Act, and this is where the big opening exists to rectify some of the abuses that have occurred. Paragraph 2 of the ALCOAST reads:

"THERE ARE STEPS THAT COTPS SHOULD CONSIDER IMMEDIATELY TO
FACILITATE SEAFARER ACCESS BEYOND WHAT IS CURRENTLY BEING DONE AND
PREVIOUSLY RECOMMENDED IN REFERENCE E. SPECIFICALLY, WITH THE FIVE-
YEAR REVIEW PROCESS FOR FACILITY SECURITY PLANS (FSP) UNDERWAY,
THERE IS AN OPPORTUNITY WITH THE APPROVAL PROCESS TO ENSURE THE
REQUIREMENT OUTLINED IN REGULATION FOR COORDINATION OF SEAFARER
ACCESS IS CLEARLY DEFINED WITHIN THE FSP. COTPS SHOULD CONFIRM
THAT EVERY FSP SUBMITTED FOR REVIEW SPECIFICALLY DESCRIBES HOW
COORDINATION OF CREW CHANGE OUTS, SHORE LEAVE AND VISITS TO THE
VESSELS BY UNION AND WELFARE ORGANIZATION REPRESENTATIVES WILL BE
ACCOMPLISHED BY THE FACILITY IN ACCORDANCE WITH 33 CFR 105.200(B)"

It is imperative that any and all mariners who have experienced problems at particular terminals convey this information directly to the Coast Guard Captain of the Port (COTP) or Officer in Charge Marine Inspection (OCMI) , who are often one and the same, that has jurisdiction over the facility. It is they who will ultimately approve or disapprove the individual FSP’s. If you’re not sure what office has jurisdiction you can look up the geographic boundaries of all of the different COTP zones in 33 CFR – Part 3, and click here for a phone directory of each office. If you’re a member of a labor union you might want to check with them first to see if they’re coordinating a larger group effort to report access problems. Either way, it will carry much more weight if you carefully document your particular access problems with the dates, times and locations where they occurred, and what exactly happened. Then provide that detailed information to the Coast Guard. Generalized complaints of the “this shit sucks” variety are not likely to be taken very seriously by anyone. You either have all your ducks lined up or you don’t, and the Coast Guard is kinda’ busy, so get on with it.

Coast Guard Commandant Adm. Thad Allen followed up the ALCOAST with this post nine days later on his iCommandant blog, which also includes a guest post by RADML Cook. Check it out…..and remember, don’t wait for someone else to do this for you. It is incumbent on each individual mariner to report these problems now and in the immediate future, while the opportunity exists to fix the problem. So speak up now or stop with the pissing, moaning and bitching.

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