Tuesday, May 25, 2010

Reader Comment 05-25-10 CG Inspectors II

Earlier today I received a very interesting and important comment on an earlier blog about the Coast Guard MTSA inspections from an anonymous Coast Guard Inspector (and I certainly appreciate the reasons for that anonymity having spent 15 years in the Army). While the entire response is well worth reading (see the end of that earlier blog) I would like to address two important portions of that comment. Training First our Coast Guard Inspector (CGI) doesn’t think that my comment on the one-day training in A School tells the entire story. CGI writes:
“My point is, as a CG Facility Inspector I want to make sure everyone who reads that story understands there was more than 1 day of training during MST "A" school. There is in-field training that is required prior to receiving that qualification that takes months and requires a lot of shadowing of someone qualified.”
As a former military instructor I am well aware of the differences between formal instruction and on-the-job training. Both are an important part of producing a professional in any field. OJT, particularly when supervised by an intelligent and experienced mentor, is an invaluable part of the development of a security professional. The details of day-to-day operations; what to look for in a wide variety of facility settings, and, more importantly, how to deal with a variety of facility personnel; can only effectively be taught in a real world setting. There is, however, an inherent weakness in OJT; the lack of control of subject matter exposure. A daily work environment frequently limits the number and types of encounters that will be experienced in an OJT period. One of a kind facilities with unique requirements and characteristics are frequently missed in such programs. Types of facilities not found in a particular area will obviously be glossed over or ignored. A CGI trained at a West Coast port will have no exposure to the security concerns associated with loading bulk ammonium nitrate on river barges, for example. Now a classroom period of instruction on bulk loading of river barges will never completely substitute for working along side someone who has done hundreds of inspections of such facilities. But that classroom instruction will provide much more information than what someone would pick-up on the job in Long Beach. This is one of the reasons that when DHS set up the Chemical Inspector Academy that they include both the classroom instruction and visits to a variety of chemical facilities. And I certainly agree with our commentor that an experience CGI would almost certainly have an easier transition to become a chemical facility inspector than, for example, someone from the Federal Protective Service with more experience at office building security. But, we probably need all of the CGI that we have to continue to keep our MTSA facilities properly secured. Working-out Program Bugs Our anonymous commentor makes a point about the MTSA implementation that certainly applies to some extent to the CFATS program as well, writing that:
“I think it is worthy to note that the Coast Guard Facility Inspectors were handed a set of regulations a few years back and told to enforce them with little to no guidance. While we can all rant and rave about the injustice's done to the "mom and pop" facilities who had stringent (and arguably unnecessary) regulations enforced on them I think you have to remember that there should be a grace period for the CG to figure out how to do their job the best and safest way. In this instance I would consider the Coast Guard's approach to 33 CFR 105 facility security was "better too much then too little". Again, that can be argued either way.”
CFATS inspectors are getting more formal training than the original MTSA inspectors did, but they are still the first ones on the ground, learning as they enforce. While it will be hard for facility personnel to accept this, they are going to have to deal with it. Even the ‘senior’ inspectors will only have a couple of facilities worth of experience under their belt when they show up at the front gate. There is a very good chance that they have never been in that particular type of chemical facility ever before in their life. There are no checklists and the inspectors are working off the same ‘vague’ guidance document that industry has been complaining about for a year now. This is another reason that these initial inspections are so time consuming. The inspectors are having to work with facilities to understand each facility’s unique situation. With the lack of CFATS inspection experience achieving that understanding will be that much more difficult. Both sides of the inspection process are going to have to work together to make this program effective.

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