The Coast Guard has proposed amendments to 33 CFR PART 105 to conform to Congressional action in the 2010 Coast Guard Authorization Act. The Act said, in part, "each facility security plan approved under section 70103(c) of title 46, United States Code, shall provide a system for seamen assigned to a vessel at that facility, pilots, and representatives of seamen's welfare and labor organizations to board and depart the vessel through the facility in a timely manner at no cost to the individual."
NAWE believes the proposed amendments go beyond Congressional intent in certain respects. As proposed, the amendments would cover additional individuals beyond seafarers and give the Captain of the Port (COTP) discretion to determine whether a system was timely. The Coast Guard should maintain the legislated definition of covered individuals and not legislate the coverage of any additional individuals who may require access to a vessel through a facility. The Coast Guard should also provide balanced criteria for the facility operator to devise a system which best meets the given circumstances of the facility operation rather than require a plans submission that is left to the judgment of the COTP.