Below are some suggestions for Facility Security Officers (FSOs)
who are thinking about COVID-19 (corona virus) response. These suggestions are
generated from conversations with other FSOs, with health care professionals, and
from the cited references.
1. Let’s pay attention to what every single solitary health
professional is telling us and wash our hands.
Make it both mandatory and easy for employees to wash their hands. Restaurants
have signs stating, “Employees must wash their hands before leaving restroom.”
Consider instituting this policy; it is one way to ensure periodic
hand-washing. Make sure that the soap dispensers in the restroom and breakroom are
full. Make this someone’s responsibility and put it in writing.
Make alcohol-based hand sanitizer (at least 60 – 95%
alcohol) available when it is not possible to use soap and water. Portable hand
sanitizer stands are available online but these stands are something that the
facility can craft itself.
2. Make expectations for workplace behavior clear. Don’t
assume that employees know that they should wash their hands, perform good
cough and sneeze etiquette, stay home when sick, etc. Posters concerning these
issues can be found on the Centers for Disease Control website at https://www.cdc.gov/nonpharmaceutical-interventions/tools-resources/educational-materials.html
. It’s really important for employers to make their expectations about
workplace behavior very clear and these posters are a good way to do it.
3. Perform routine environmental cleaning. From the CDC: “Routinely
clean all frequently touched surfaces in the workplace, such as workstations,
countertops, and doorknobs. Use the cleaning agents that are usually used in
these areas and follow the directions on the label. No additional disinfection
beyond routine cleaning is recommended at this time. Provide disposable wipes
so that commonly used surfaces (for example, doorknobs, keyboards, remote
controls, desks) can be wiped down by employees before each use.”
4. Distance is your friend. The health professionals are
telling us to stay 6’ from other persons when possible. For example: if you are
having a meeting, move the chairs further apart. If you are walking around the
terminal, space yourselves out.
5. If you get into a situation where you must be around persons
whose health status is not known to you (like aboard the vessel), you should take
all reasonable precautions. If possible wear latex gloves. Maintain a good space from the crew. Minimize
touching handrails, etc. with your bare hands. A reasonable precaution may be
to have one person along just to watch for and report on possible contamination.
This person’s duties and responsibilities will only consist of this monitoring.
Politely decline beverages and food. Although currently there is no evidence to
support transmission of COVID-19 associated with food, situations that might involve transmission of
respiratory droplets should be avoided. Use
hand sanitizer as soon as possible and thoroughly wash hands (for 20 seconds)
as soon as possible.
6. Be familiar with the latest policy on COVID-19. Coast
Guard Maritime Commons blog (https://mariners.coastguard.blog/)
informs the maritime community when these documents are issued.
- The Coast Guard has issued Marine Safety Information Bulletin 01-20 Novel Coronavirus Precautions at https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/MSIB/2020/MSIB-01-20-Novel-Coronavirus-Precautions-USCG.pdf?ver=2020-01-24-192641-323. The MSIB states that “Local industry stakeholders, in partnership with their Coast Guard Captain of the Port, should review and be familiar with section 5310 Procedures for Vessel Quarantine and Isolation, and Section 5320 - Procedures for Security Segregation of Vessels in their Area Maritime Security Plan (AMSP).” These plan sections detail the steps that the Captain of the Port will take to ensure that the vessel is quarantined or a security segregation is accomplished. (It has been my experience that many FSOs are not familiar with the details of their AMSP and do not have a copy. Many FSOs do not attend AMSC meetings.)
- The Maritime Administration (MARAD) has issued Maritime Security Communications with Industry (MSCI) Advisory 2020-004-Global-Novel Coronavirus Outbreak., at https://www.maritime.dot.gov/content/2020-004-global-novel-coronavirus-outbreak. This communication states, “Illness of a person onboard a vessel that may adversely affect the safety of a vessel or port facility is a hazardous condition per 33 CFR 160.216 and must be reported to the U.S. Coast Guard COTP under 33 CFR 160.206. Suspected cases of 2019-nCoV must be reported to the COTP.”
- The CDC’s main site for information on COVID-19 is https://www.cdc.gov/coronavirus/2019-ncov/index.html
- A good guide for COVID-19 and employers, Interim Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019 (COVID-19), February 2020, is found at https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/guidance-business-response.html
- The Centers for Disease Control (CDC) has a page concerning COVID-19 recommendations for ships, at https://www.cdc.gov/quarantine/maritime/recommendations-for-ships.html, Interim Guidance for Ships on Managing Suspected Coronavirus Disease 2019.
- 42 CFR 71.21 requires ships’ masters to report to the CDC or to nearest the port at which the ship will arrive, the occurrence, on board, of any death or any ill person among passengers or crew (including those who have disembarked or have been removed) during the 15-day period preceding the date of expected arrival or during the period since departure from a U.S. port (whichever period of time is shorter).
7. Find out what practical steps you should take if you discover
that multiple persons on the vessel are sick and guess what! no one has
reported it to anybody. CBP, the ships chandlers, the dock crew, have all been
aboard. Talk to your local health department; they may have an outbreak plan. Do
not assume that they know anything about your operations or the vessels that
come into your dock.
Granted, vessel representatives are required to report sick
or deceased crew/passengers within the last 15 days to the CDC under 42 CFR
71.21. However - I am concerned that the
flow of information CDC > U.S. Coast Guard > individual facility might somehow
stovepipe. Here is what is supposed to happen, from the MARAD advisory “The
Coast Guard will continue to review all “Notice of Arrivals” in accordance with
current policies and will communicate any concerns stemming from sick or
deceased crew or passengers to their Coast Guard chain of command and the CDC
quarantine station who will coordinate with local health authorities.”
8. Keep the Coast
Guard informed at once of any situation that might involve the maritime nexus
and COVID-19.
Just my opinion: I don't think we can make the distinction
that COVID-19 is a safety, not a security issue. Security activities such as
screening may bring employees into contact with other people in a manner that
was acceptable six months ago but may not be acceptable today, so this virus is
very much a security manager's concern.
