Guidelines for Maritime Security Training Course Providers

I. BACKGROUND

Section 109 of the Maritime Transportation Security Act of 2002 (MTSA) (P.L. 107-295) charged the Secretary of Transportation with developing “standards and curriculum to allow for the training and certification of maritime security professionals.” The Secretary of Transportation delegated the MTSA mandate to the Maritime Administration (MARAD) and the United States Merchant Marine Academy, which developed the required standards and curriculum and prepared a report to Congress. The standards, curriculum, and recommendations contained in that report were developed through a deliberative and collaborative process, through which MARAD proactively sought comment from all public and private stakeholders and initiated interagency cooperation with the United States Coast Guard and Transportation Security Administration.

During development of the training guidelines, MARAD received many comments from training providers seeking a means through which to have their courses “approved,” or otherwise designated as courses that incorporate the standards and curriculum developed under MTSA. Similar requests were received from facility and vessel operators wishing to enroll their security personnel in courses employing MARAD’s training standards and model curriculum.

In response to these comments, and in order to assist parties charged with implementing the education and training provisions of the MTSA, the Maritime Administration and the U.S. Coast Guard have developed an optional program for maritime security training course certification. This voluntary system is designed to align with any potential future regulatory requirements.

II. PROGRAM ELEMENTS

The voluntary program consists of the following elements:

(1) Application procedures for approval of maritime security training courses;

(2) Administrative procedures and record keeping for training providers;

(3) Oversight procedures to ensure that courses are taught in accordance with the established guidelines;

(4) Renewal procedures; and

(5) Procedures for suspension or withdrawal of approval.

A training provider may seek approval of maritime security training courses by electronically submitting the information described in Appendix A via the MARAD Virtual Office of Acquisitions website. The MARAD coordinator is presently Sheila Brown and her email address is: Sheila.Brown@dot.gov. A MARAD contractor, approved by the Coast Guard as a Quality Standard System (QSS) organization with experience in maritime education and training, will assess requests and may conduct on-site verification, which will then be reviewed by the appropriate government agency. The Coast Guard will be responsible for vessel personnel training; MARAD will be responsible for other course approvals. An approval letter and course approval certificate will then be issued electronically by the Contractor.

Course approvals are evidence that the course meets all of the guidelines contained in this notice.

III. IMPLEMENTATION.

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 United States flag vessel to be eligible for this program.

Training providers seeking course approval should submit a request containing the “ ELEMENTS OF REQUEST FOR A MARITIME SECURITY TRAINING COURSE APPROVAL” specified in APPENDIX A, which is based on the IMO model course format, to the MARAD coordinator. The request will be reviewed to ensure that the course meets the standards for the type of training intended.

A. Course Administration Elements

(1) Curriculum. The content of approved courses should conform to the syllabi of the relevant IMO model courses. Courses should be conducted as submitted and in accordance with the conditions of the approval as stated in the course approval letter. Any changes to the initial curriculum should be submitted electronically to the MARAD coordinator for evaluation and written approval.

(2) Instructor(s). Information regarding instructors should be submitted as part of the initial request for course approval. Any subsequent instructor changes should be submitted electronically to the MARAD coordinator for evaluation and written approval.

(3) Records. A training provider offering an approved course should maintain a file at the training facility, for at least 10 years after the end of each student's enrollment, containing the student's examinations, a report of practical tests administered, and a record of classroom attendance. If approved courses are taught in more than one location, the records may be maintained at one central location identified in the course approval package.

(4) Course Completion Certificates. Course completion certificates should be in the training provider’s standard format and contain: (1) the name of the course as stated in the course certification letter; (2) the name of the school or training provider; (3) the date the training began and was completed ; (4) the signatures of the course instructor and director or department head; (5) the student’s full name; and (6) the student’s date of birth. Training providers will issue a certificate to candidates who successfully complete maritime security training courses. Training providers should verify the identification of all students attending certified security training courses and issue consecutively numbered certificates to students who successfully complete the approved course. Blank course completion certificates should be kept secure at all times. The paper stock of course completion certificates should contain microprinting, watermarks and/or other effective measures to help prevent production of fraudulent certificates. Training providers should consult International Maritime Organization MSC/Circ. 1089 “Guidance on Recommended Anti-Fraud Measures and Forgery Prevention Features for Seafarers’ Certificates” available via the IMO website at www.imo.org.

B. Oversight.

(1) Purpose. Oversight audits may be conducted to verify that the terms of the course approval letter are followed.

(2) Types of Audits. There are three types of audits that may be conducted: announced, unannounced and customer survey. An announced audit is conducted when representatives from the certifying agency inform training course providers that they will attend the course or review administrative course records prior to doing so. An unannounced audit is conducted when representatives from the approving agency attend the course anonymously or when representatives review administrative course records. A customer survey audit is conducted when representatives of the oversight agency send letters to students to verify that courses are conducted in accordance with the terms of the course approval.

(3) Results. All audits, except customer surveys, are followed-up by a letter discussing the results of the audit. Preliminary results will be discussed with training provider personnel prior to the auditors’ departure from the training site.

C. Renewal.

(1) Period of Approval. Course approvals are effective for a period of two years; or until the controlling interest in an approved course is surrendered, sold or otherwise transferred or conveyed; or until the approval is suspended or withdrawn. Subsequent renewals will be valid for five years, and may be granted subject to a written request to the approving agency via the MARAD coordinator.

(2) Renewal Requests. A request for the renewal of a course approval should be submitted at least 90 days before the current approval expires. Courses submitted for renewal shall be in the same format as the original submission. To facilitate the renewal process, all changes should be highlighted. If there have been no changes since the last approval, a statement to the effect that the curriculum, instructors and facilities are the same should accompany the submittal. Renewals are effective for five years.

D. Suspension or Withdrawal of Approval.

(1) Suspension. If it is determined that a specific course no longer complies with the standards and terms of course approval, or substantially deviates from the course curriculum that was approved, or if the course is being presented in a manner that is insufficient to achieve the course learning objectives, the responsible agency may suspend the approval, require the approval holder to surrender the approval, if any, and may direct the holder to cease claiming the course is approved. The responsible agency will notify the approval holder in writing of its intention to suspend the approval and the reasons for suspension and provide a time period for corrective action. If the approval holder fails to correct the reasons for suspension, approval will be withdrawn.

(2) Withdrawal. The responsible agency may withdraw the approval for any or all courses by an approval holder upon a determination that the approval holder has demonstrated a pattern or history of:

• failing to comply with the applicable regulations or the requirements of course approvals;
• substantial deviations from their approved course curricula; or
• presenting courses in a manner that is insufficient to achieve course learning objectives.

(3) Appeal. Anyone directly affected by a decision to suspend or withdraw an approval may appeal the decision to the responsible agency via the MARAD coordinator.

E. Voluntary Cessation of Course Offering

Course providers who cease offering their courses shall immediately notify the MARAD coordinator so the course can be removed from the publicized course approval lists on the Internet.

APPENDIX A

ELEMENTS OF REQUEST FOR MARITIME SECURITY

TRAINING COURSE APPROVAL

The elements listed below comprise a request for course approval. The request and supporting material shall be submitted electronically via the MARAD Virtual Office of Acquisitions website. The MARAD coordinator is Sheila.Brown; Sheila.Brown@dot.gov. (Items specified below that can not reasonably be transmitted electronically via the MARAD Virtual Office of Acquisitions website, such as text books, posters and illustrative mock-ups, shall be catalogued in the request for subsequent verification at the discretion of the MARAD Contractor.) Definitions unique to maritime security training are provided in ATTACHMENT 4.

I. REQUEST FOR APPROVAL: The formal statement of request for course approval will be in the form of a cover letter from the training course provider to the MARAD coordinator by email. The letter should include: (1) the name of the course; (2) the location where it will be held; (3) a general description of the course; and (4) and the specific category(s) of maritime security training (e.g., Vessel Security Officer, Company Security Officer, Facility Security Officer) that the course is intended to address.

II. COURSE FRAMEWORK : This section provides an overview of the purpose, nature, and individual components of the course, and should contain each of the following:

A. Scope . A brief description of the course.

B. Objective . A statement of the goal(s) and learning outcomes of the course.

C. Student Identity. A statement that, prior to enrolling students in a security course, the training provider verifies the identity of students through one of the following forms of photo identification listed below. The training provider should keep a copy of the identification document in their files. All documents presented for verification of identity must be unexpired. Training providers should report suspicious identity documents and/or circumstances to appropriate law enforcement authorities. Acceptable forms of identification are:

• U.S. Merchant Mariner Document issued after February 3, 2003
• STCW 95 Certificate (with embedded photograph),
• U.S. Passport,
• Foreign passport,
• U.S. Armed Forces identification card,
• Photo Identification cards issued by U.S. federal, state, or local government agencies, and
• Driver’s license with photo of the driver issued by a U.S. possession or commonwealth.

D. Class limitations .

• Class size : State the maximum class size for classroom lessons and, if appropriate, for practical demonstrations or simulation exercises and assessments, include the number of the students per simulator.
• Student/teacher ratio : State the student/teacher ratio and discuss the organization's policy for circumstances when more than one instructor will be present during any of the lessons.
• Instructors: Include a list of instructors with a description of their experience, background and qualifications to demonstrate that they have the subject matter expertise to interact with students and to answer student questions, as well as the instructional capability to impart the required information to students. It is preferred that instructors have attended a course in instructional systems design and techniques. Any instructor changes should be reported immediately to the MARAD coordinator for evaluation and written approval.

E. Teaching facilities and equipment .

• Facility : Include the address and a description of the facility at which the training will be held. A statement that the site is as represented in the request should be included and signed by the president or director of the course provider. The request should include electronic photographs, diagrams or plans of the training site. Any changes to training site should be submitted to the MARAD coordinator for evaluation and written approval.
• Course equipment : Include a description of the equipment that will be used during the course. This includes all equipment to be used during hands-on training and/or testing, and any simulators or simulation programs to be used. If a simulator or simulation program is to be used, include technical specifications and brochures provided by the manufacturer. Any changes to course equipment should be submitted to the MARAD coordinator for evaluation.

F. Teaching aids .

• Visual aids : Include copies of all visual aids and a discussion of how audiovisual and other aids will be used during the training course, and which performance objectives they will impact. This information may be a part of the curriculum documentation that discusses the make up of the lesson plans.
• Textbooks : Include copies of all student handouts, homework assignments, workbooks, and a bibliography of textbooks to be used. The MARAD Contractor may ask for copies of textbooks it does not have access to, and will return the texts after the course has been evaluated.

III. DETAILED TEACHING SYLLABUS : Include a detailed teaching syllabus consisting of lesson plans for each instructional unit written in learning objectives format in which the objective describes what the student must do to demonstrate that the specific knowledge or skill has been learned. The format of any standard educational lesson plan is acceptable. The lesson plan should include the major teaching points and all required subskills and knowledge. References should be made against the learning objectives to indicate which publications and teaching aids the instructor may use when preparing and presenting the lesson. See ATTACHMENT 1 for a sample of learning objectives.

IV. COURSE SCHEDULE : Include a course schedule in a format similar to ATTACHMENT 2. The course schedule should include the length of each lesson and indicate whether the lesson is a classroom lecture, practical demonstration, simulator exercise or examination. Each subject matter in the course schedule should be prefaced by a number that corresponds to the subject area listed in the detailed teaching syllabus and course outline.

V. COURSE OUTLINE: Include a course outline, containing a summary of the syllabus by subject area with the number of hours for each lecture, practical demonstrations, or simulation program. This shows the focus of the course while highlighting how the course meets IMO and Coast Guard time requirements. See ATTACHMENT 3 for a sample course outline.

VI. INSTRUCTOR MANUAL : Include an instructor's manual, providing specific guidance on instructional strategies and techniques appropriate for the educational domain of each learning objective of each lesson. The manual should address the major components of each instructional strategy for each lesson identified in the course schedule.

VII. EXAMINATION AND ASSESSMENT :

A. Method of examination : Include an explanation of how the students' performance will be evaluated throughout the course. Include whichever is applicable:

• Written examinations : Copies of all written examinations, the grading procedure to be used, frequency of revision, and what will be considered a passing score.
• Practical demonstrations : Detailed descriptions of all practical or simulator examinations, tests, or exercises that describe the situation presented to the student; what the students must do to successfully complete each test; and how each student's performance will be evaluated and recorded. Provide a separate checklist to evaluate each practical examination and what is considered a passing score. This checklist should include the condition under which the practical demonstration will occur, the behavior to be observed, and the criteria for successful completion of the demonstration.
• Note: Instructors should not assist or coach students in any way during the evaluation process.

B. Determination of final grade . Include a discussion of how the instructor(s) will determine final grades by proportioning written and practical examination scores as appropriate.

C. Re-test procedures : Include a description of the training provider’s policy on re-tests of failed examinations.

D. Course Critique : Include a sample student course evaluation form(s) or the training provider’s procedures for obtaining student feedback to the school on the effectiveness of the instruction and instructors.

VIII. SUBMISSION Checklist

The following details shall be included in the curriculum submission. Any missing details shall be explained in the cover letter.