The US Coast Guard has revised its Maritime Security (MARSEC) Directive 104-6 on Guidelines for US Vessels Operating in High Risk Waters by putting out Revision 3.  It’s a Sensitive Security Information (SSI) document, of course, available only to those with a need to know from their local Captain of the Port (CoTP).  For the rest of us, and for this discussion, the non-SSI version, published as Revision 1 to Port Security Advisory (PSA)(2-09), which is available on the non-secure side of the Coast Guard’s Homeport website,¹ will have to do.  (Revision 1 to PSA 11-09, U.S. Coast Guard Counter Piracy Information, has also been posted to Homeport.  That document no longer has substantive content as the provisions of the original PSA have been incorporated in the MARSEC Directive.)  The previous version of the MARSEC Directive, published last May,  said that it would be reviewed at least annually.  Now we have the (sanitized) results of the first such review.

The alterations to the MARSEC Directive, to the extent revealed in PSA (2-09)(Rev 1), are a mélange of a few substantive additions, some curious deletions, technical corrections/supplementations, and not a few “happy-to-glad” changes.  Examples of these follow:

• Substantive additions include: expanded communications requirements and cautions as to the adverse effect of heavy wheel movements on vessel speed, previously found in PSA 11-09; requirements for certain potential access points to be secured “with locking mechanisms which cannot be disengaged by automatic fire” and for members of security teams to have training compliant with 33 CFR 104.220; and beefed up discussion of post-incident US Government investigations, including a possible USCG safety inspection to determine adequacy of vessel and/or crew for continuation of intended operations
• Technical changes include addition of the correct website for the Office of Naval Intelligence, adjustment of verb form for parallel structure in lists, use of “Company Security Officers” or “CSO,” and sometimes “Vessel Security Officer,” in lieu of “Security Officer(s),” and the citation of various Coast Guard legal authorities.
• On the happy-to glad front, “counter-piracy” is now in and “anti-piracy” is out; “vulnerability assessments” have become “risk assessments,” “plans” and “sections” of plans to deal with piracy are now usually, but not always, “protocols,” and the “safe haven” for the crew is now referred to as “refuge area(s),” while the wording of some sentences has been reordered, as has the sentence order of some paragraphs.

A number of the deletions beg for lengthier discussion.  The examples of equipment that would make scaling the ship more difficult “(soaps, foams, netting, barbed wire, electric fencing, etc.)” have been removed.  Was this to avoid limiting creativity, because this information is now thought of as SSI, because the USCG doesn’t want to be seen as endorsing publicly any particular approach, or for some other reason?  The same questions apply to the elimination of the examples of “non-lethal means to disrupt, disorient, and deter boarders, e.g. loud acoustic devices, high energy light beams or other equipment to repulse attackers,” as well as the deletion of examples of “enhanced detection equipment (night vision devices, high beam searchlights, camera, etc.).”  It’s also unclear why comments on specific water pressures for fire hoses has been deleted or why the revised discussion of heavy wheel movements omits the following:

When performing these maneuvers, the ship should set a course into the prevailing seas and avoid creating a lee on the side of the vessel.  Evasive maneuvers will reduce vessel speed giving an attacker an advantage, so the use of this tactic is recommended only when the small vessel is in close proximity (less than 10 meters).  If the small vessel veers off beyond 10 meters, maintain a steady course to regain speed.

It seems like this information would be significant when considering whether to employ heavy wheel movements.  Finally, it’s unclear why reference to provisions of IMO Circular MSC/Circ. 623/Rev.3 dealing with contacting relevant Rescue Coordination Centers has been struck.  The heavy military presence in the Gulf of Aden and off the Horn of Africa may have rendered these provisions nugatory there, but they would seem appropriate to areas elsewhere in the world that lack the dedicated military effort being expended against the Somali pirates.

As a final note, unlike last year,² the revision to the MARSEC Directive and the two PSAs was, as usual for Coast Guard headquarters, accomplished with extreme stealth.  The PSAs simply appeared on Homeport.  Supposedly, if you have a “need to know” you would have gotten the word, but one wonders.  The same “process” is used for promulgating memoranda of policy from the MTSA Policy Advisory Council and the TWIC/MTSA Policy Advisory Council.  To stay up to date, you need to check Homeport frequently, or rely on blogs like this one.  IMHO, not a best management practice for an organization that claims to be big on transparency and information sharing.

^l On the Homeport website, http://homeport.uscg.mil/mycg/portal/ep/home.do, click on “Counter Piracy” under “Featured Homeport Links”  at the top right of the page.  Then scroll down to the listing of PSAs and click on PSA (2-09) or (11-09).

² Last May, as a result of the M/V MAERSK ALABAMA incident, the Coast Guard was under heavy Congressional pressure to “do something” about Somali piracy.  Accordingly, the 2009 revision of MARSEC Directive 104-6 was announced with great fanfare.