USCG to Hold Meeting on FSO Training Requirements
UPDATE: RSVP Link that works.
The RSVP link listed in the Federal Register Notice doesn’t work. The Coast Guard expects to publish a Notice of Correction next week. In the meantime, you can use the following to sign up to attend the meeting. https://einvitations.afit.edu/inv/index.cfm?i=123867&k=036341017D50
The Coast Guard will be holding a public meeting to obtain public comment on a draft model Facility Security Officer (FSO) training course and other aspects of developing “the FSO training program.” The meeting will be held November 9, 2012 from 8:30 AM to 12:30 PM (although it may end earlier, “if all business, concerns, and questions are addressed) at the Oklahoma Room in the Department of Transportation Headquarters, 1200 New Jersey Avenue SE, Washington DC 20590.
Meeting attendance: To sign up to attend the meeting, fill out the RSVP form at https://einvitations.afit.edu/inv/anim/cfm?i=123867&k=036341017D50 ASAP (and NLT November 2). To actually get into the building, you will need two government-issued photo IDs. As the capacity of the venue is limited, and not everyone can afford to travel to Washington for a four-hour meeting, it is fortunate that there will be a live video feed of the meeting, available at http://trial4.cdn.level3.net/USCGLivePlayer_040611.htm.
Submit comments: In addition to oral comments at the meeting, the USCG is accepting written comments before, during, and after the meeting. Outside of the meeting, comments, identified with docket number USCG-2012-0908, may be submitted through the Federal eRulemaking Portal, http://www.regulations.gov, or by fax, mail, or hand delivery, as outlined in the Meeting Notice to be published in the Federal Register on October 11. In the meantime, a pre-publication version of the Notice is available online. Comments MUST be submitted by November 23, 2012.
Background: Section 821 of the Coast Guard Authorization Action of 2010 requires the DHS Secretary to establish “comprehensive facility security officer training requirements designed to provide full security training that would lead to certification of [FSOs].” The USCG is considering a rulemaking to implement this requirement and the meeting is designed to obtain public comments to inform that process. The USCG expects to have a draft model FSO training course available for viewing in the online docket and on its Homeport website at https://homeport.uscg.mil/mtsa. They’ve also promised to post a written summary of the meeting in the online docket.
Meeting Agenda: Topics to be discussed at the meeting include:
(1) Draft model FSO training course;
(2) Computer-based training and distance learning;
(3) Provisional FSO certification;
(4) FSO continuing education;
(5) FSO refresher course;
(6) Interim policy to provide curriculum guidelines for potential FSO training course providers; and
(7) Any additional topics of concern with respect to the FSO training program, certification, and the development and provision of training.
Blogger’s Comments: I’m glad to see the USCG asking for public comment on this issue in general and on the draft model course in particular. They will have to seek comments on any proposed regulation, but they have properly recognized that getting the comments earlier is better. As for the draft model course, we’ll have to reserve judgment until we see it. But it’s hard to imagine that it will not be an improvement over the existing standard, the International Maritime Organization’s Port Facility Security Officer Model Course No. 3.21. Nonetheless, the work of whatever small group produced the USCG’s draft model course can only be improved further with input from knowledgeable industry stakeholders. As far as I know, the Maritime Administration’s Model Vessel Security Officer Course was simply sprung on the world. IMHO, it has a number of deficiencies that could have been mitigated with broader maritime industry participation in its development.
With respect to the other topics on the agenda, I’ve long been in favor of both FSO certification and required refresher training. In the absense of formal training or attendance at training courses that haven’t met the standards for Government approval is simply substandard. Refresher training or continuing education is necessary because both threats and regulations change over time. Of course, you might expect me to take that stand: I won’t have to pay for any newly required training—I get paid for providing it.
Bottom line: This is an opportunity to influence the course of future requirements that will affect many businesses in the maritime industry. If yours is one of them, at least look at the model course and, if you don’t attend the meeting or watch it online, the summary of the meeting and submit comments before the November 23 deadline.
NOTE: This post may be copied, distributed, and displayed and derivative works may be based on it, provided it is attributed to Maritime Transportation Security News and Views by John C. W. Bennett, http://mpsint.com.
Model VSO Course: http://www.marad.dot.gov/documents/MTSA_VSO_Course.pdf