Maritime Transportation Security Act (MTSA) Course Certification

Background

Section 109 of the Maritime Transportation Security Act of 2002 (MTSA), P.L. 107-295, required the Secretary of Transportation to “develop standards and curriculum to allow for the training and certification of maritime security professionals.” The Secretary of Transportation delegated this responsibility to the Maritime Administration; the Maritime Administrator charged the U.S. Merchant Marine Academy (USMMA) with its execution.

The document entitled "Maritime Security Act of 2002: Section 109 Implementation, A Report to Congress," containing draft standards and curricula for U.S. maritime security training, was prepared by a working group at the USMMA and was forwarded to the Congress in July 2003. The standards and curricula were developed through a collaborative and interactive approach that involved multiple government agencies, training institutions, and industry representatives. The full report is available online in the “resources” section below.

The Academy’s work on the MTSA Section 109 project led to USMMA responsibility for the development of IMO model courses for Ship Security Officer, Company Security Officer, and Port Facility Security Officer under the provisions of the ISPS Code. This project, undertaken jointly with the Government of India's Directorate General of Shipping under the coordination of the U.S. Coast Guard, was completed in September 2003. The model courses are now the international benchmarks for maritime security training, having been published by the IMO for use by training providers, carriers, and others worldwide.

In September 2003, the joint “Maritime Administration/Coast Guard MTSA Section 109 Committee” was established to develop a national system of certification and course approval as proposed in the Maritime Administration Report to Congress. The goal of this voluntary certification program is to promote high quality, uniform training of maritime security professionals.

Since early 2005, this program has provided maritime security training organizations with course review and potential government approval at no cost to providers. The Maritime Administration, until the recent exhaustion of available funds, has borne the full burden of expenses associated with the program.

A recent preliminary assessment found that the joint Maritime Administration/Coast Guard MTSA 109 voluntary approval program has, since its inception, resulted in the training by approved providers of more than 17,000 maritime security personnel.

Current Status

The voluntary program continues to function, but on a fee-for-service basis. Training providers are required to pay 75% of the application and processing fees and the United States government pays the balance.

The Maritime Administration has contracted with Det Norske Veritas (DNV), a U.S. Coast Guard (USCG)-accepted Quality Standards System (QSS) organization, to evaluate and certify maritime security training courses submitted for approval under the joint MTSA 109 program. DNV reviews applications and issues approvals on behalf of the Maritime Administration, the Coast Guard, or both, depending on the specific course(s) involved.

In order to be eligible, training providers--profit or non-profit--must be organized and authorized to conduct business under the federal laws of the United States, or under the laws of any state of the United States, and they must conduct the training in the United States or aboard a U.S.-flag vessel.

The approval of VSO courses is no longer an element of the joint program, as explained below.

USCG VSO Regulations

In May 2008, the U.S. Coast Guard issued a rulemaking intended to implement amendments to the IMO STCW Convention concerned with Ship Security Officer/Vessel Security Officer (SSO/VSO) training and certification requirements. The regulations can be viewed here.

When Coast Guard enforcement of these new regulations commences on 1 July 2009, designated ship security officers aboard all vessels subject to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), 1978, as amended, will be required to have completed VSO training that meets the requirements of the convention. When enforcement begins, VSOs will be required to carry and present upon demand a certificate verifying they have completed such training.

In support of these regulations, the Maritime Administration VSO model course was recently reviewed and amended to include the competences listed in the STCW convention, those subjects listed in MTSA Sec. 109 (b)(2); 33 CFR Chapter I, Subchapter H; the SAFE Port Act of 2006 Sec. 113 (b)(4)(A)-(J), and the requirements of the TWIC program. This course meets the mandatory training requirements in 33 CFR Chapter I, Subchapter H.

The USMMA also developed a VSO refresher model course to facilitate the transition to the USCG mandatory training requirements in 33 CFR Chapter I, Subchapter H and to meet the transitional requirements of the STCW convention. This refresher course also includes the latest requirements of the SAFE Port Act of 2006, the TWIC program, and other recent developments.

New approval of VSO courses is being handled by U.S. Coast Guard approved Quality Standards System (QSS) organizations. The Maritime Administration will no longer accept applications for approval of VSO courses. However, VSO courses that were previously approved under the Maritime Administration/Coast Guard MTSA 109 course approval program are “grandfathered” under the regulations and are considered to meet all requirements thereof.

Additional information concerning VSO training requirements and related certification is available on the Coast Guard National Maritime Center web site.

Course Submission

Requests for course approval shall be submitted in accordance with the Maritime Administration’s “Guidelines for Maritime Security Training Course Providers” and its “Appendix A - Elements of Request for Maritime Security Training Course Approval” contained in the electronic file below.

All request for approval and supporting material will be submitted electronically via the Virtual Office of Acquisitions (VOA) web site for processing. If there are technical issues or questions concerned with uploading course submissions, training providers may contact the Maritime Administration Help Desk at voasupport.marad@dot.gov.

Applications will be automatically receipted and numbered in order of receipt. Courses that will be accepted for consideration via the Maritime Administration VOA web site are the following:

  1. Company Security Officer (CSO)
  2. Facility Security Officer (FSO)
  3. Maritime Security for Vessel Personnel with Specific Security Duties (VPSSD)
  4. Maritime Security for Facility Personnel with Specific Security Duties (FPSSD)
  5. Maritime Security Awareness (MSA)
  6. Maritime Security for Military, First Responder, and Law Enforcement Personnel (MSLEP)

At the present time, all submitted courses will be evaluated based on the applicable model courses as per the "Guidelines" below. The competence tables referenced below are provided for informational purposes only, and they may be helpful to training providers.

Where CSO and FSO courses are concerned, International Maritime Organization (IMO) model courses for Company Security Officer (Model Course 3.20), and Port Facility Security Officer (Model Course 3.21), respectively, will be used for evaluation until such time as domestic versions of these model courses have been prepared. These model courses were developed by USMMA staff in collaboration with counterparts in India, in coordination with the U.S. Coast Guard, and are available for purchase in the U.S. through IMO designated distributors listed on the IMO web site.

A competence table for CSO, published by the IMO in a non-mandatory circular on May 25, 2005, is available electronically in the resource material below. A similar competence table for FSO (referred to by the IMO as Port Facility Security Officer) is also provided below.

Where VPSSD, FPSSD, MSA and MSLEP courses are concerned, MTSA model courses 04-01, 04-02, 04-03 and 05-01, developed by the U.S. Merchant Marine Academy (USMMA), will be used for evaluation purposes. These model courses, and relevant competence tables also developed by USMMA, are available in the electronic resource files below.

Maritime Security Awareness (MSA) courses that are conducted via electronic learning methods of instruction (“E-Learning”) may be submitted for approval. E-Learning guidance is provided in the “Guidelines” below. All other courses must be instructor led to be submitted for approval.

While the MSLEP model course was developed in response to the Congressional mandate contained in Section 109 of the MTSA, this class of personnel is not referenced in 33 CFR Subchapter H and there is currently no requirement for any military, first responder or law enforcement personnel to complete this training. The MSLEP model course is provided as a training tool, principally designed for personnel without prior maritime background.

The Maritime Administration coordinator will conduct a preliminary review of the application package to determine if the package contains the necessary documents to process the request for course approval. After the Maritime Administration processing, the proposals will be forwarded to DNV. DNV will determine the adequacy of the submitted course(s) against the guidelines and reference model course(s).

The need for on-site verification of training providers that do not currently offer USCG-approved maritime training courses will be determined on a case-by-case basis.

Conforming courses will be issued an approval letter and a course approval certificate as follows:

  • CSO, FSO, FPSSD and MSLEP courses will be issued an approval letter and a course approval certificate on behalf of the Maritime Administration.
  • MSA courses will be issued an approval letter and a course approval certificate jointly on behalf of the Maritime Administration and the Coast Guard.
  • A single course covering multiple categories (such as VSO, CSO and FSO) will be issued an approval letter and a course approval certificate jointly on behalf of the Maritime Administration and the Coast Guard.
  • The original approval of these training courses will be valid for two years unless sooner surrendered, suspended or withdrawn. Renewals will be valid for five years.

A current list of certificated courses is maintained electronically below. The Maritime Administration Coordinator is Brandon Cummo, (202) 366-2277, Brandon.Cummo@dot.gov.

Maritime Security Training Course Approval Resources

Guidelines

Guidelines for Maritime Security Training Course Providers
Appendix A - Elements Request for Maritime Security Training Course Approval

Model Courses

MTSA 08-01 Vessel Security Officer (VSO) (New)
MTSA 08-01R Refresher Course for Vessel Security Officer (New)
MTSA 04-01 Maritime Security for Vessel Personnel with Specific Security Duties
MTSA 04-02 Maritime Security for Facility Personnel with Specific Security Duties
MTSA 04-03 Maritime Security Awareness
MTSA 05-01 Maritime Security for Military, First Responder, and Law Enforcement Personnel

Competence Tables

Guidelines on Training and Certification for Company Security Officers (IMO MSC Circ.1154)
Guidelines on Training and Certification for Port Facility Security Officers (IMO MSC Circ.1188)
Maritime Security for Vessel Personnel with Specific Security Duties Competencies
Maritime Security for Facility Personnel with Specific Security Duties Competencies
Maritime Security Awareness Competencies

The Maritime Administration Report to Congress

The Maritime Administration MTSA Section 109 Report to Congress

List of Certificated Courses

MTSA 109 Certificated Courses