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The Challenge

The Facility Security Officer must be reachable 24 hours a day, 365 days a year. When MARSEC levels change, the facility must implement its plan immediately — not after locating it.

MTSA-regulated facilities operate under a Facility Security Plan approved by the Captain of the Port. The FSO is a designated position with specific accountability — and when that person leaves, the obligation does not leave with them. The succession chain must be current, documented, and exercisable without a phone tree.

MARSEC level changes are not scheduled. When the COTP issues a MARSEC change, the facility has a defined window to implement its FSP requirements for that level. The organization that has to locate its FSP and verify its contacts during that window is the organization that falls behind.

Multi-agency coordination during a maritime security incident — USCG, CBP, local law enforcement, port authority — requires pre-designated roles and pre-established notification chains. Improvised coordination is the failure mode the CSB documents in its reports. The maritime version is documented in after-action reviews that most facilities never share.

How CROS Helps

The Living Model knows what your organization is obligated to do — and whether it is doing it.

The COTP does not call to schedule the inspection. The Facility Security Plan must be current, the FSO must be reachable, and the succession chain must be exercisable — before the vessel arrives, not after.
Regulatory Framework

Obligations CROS encodes at onboarding.

MTSA 33 CFR Part 105
Maritime Transportation Security Act — Facility Security Plan, FSO designation, MARSEC level implementation, drill and exercise requirements.
USCG Captain of the Port
COTP authority to direct facility security operations, suspend transfer operations, and issue MARSEC level changes within the Marine Inspection Zone.
33 CFR Part 127
Waterfront transfer of liquefied natural gas and liquefied hazardous gas — intersects MTSA obligations for applicable facilities.
CBP 19 CFR Part 4
Customs and Border Protection vessel arrival reporting and cargo security requirements — coordination obligation during multi-agency maritime security incidents.
EPA EPCRA
Reporting obligations for facilities handling extremely hazardous substances — applicable at terminals handling covered chemicals.
OSHA 29 CFR 1910.38
Emergency action plan requirements — applies to waterfront operations with covered hazard profiles.

See how CROS handles the MTSA compliance and maritime security stack.

We load your facility type, encode your FSP requirements by MARSEC level, and run a scenario against your COTP notification sequence.

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