Guidance on Master Key Control Requirements on Merchant Vessels published by USCG

The United States Coast Guard has published the Guidance on Master Key Control Requirements on Merchant Vessels.

This policy letter was published on 13 November 2023.

It provides comprehensive guidelines and policies for the control and management of master keys on merchant vessels. Issued by the United States Coast Guard, the policy letter outlines the requirements for a master key control system, access and use of master keys, and specific information handling protocols.

The key points of the document include the definition of a master key, the necessity for a master key control system, and the responsibilities of vessel owners and crew members.

The policy emphasizes the need for vessels to be equipped with a master key control system that provides controlled access to all copies of the vessel's master key.

It specifies that only crew members identified by position in the master key control system are allowed access and use of a master key.

Additionally, the document mandates the maintenance of a logbook to record all access and use of the vessel's master key, including dates, times, locations accessed, and the names and ranks of the crew members using the master key.

The list of persons with access to the master key and the logbook must be made available to authorized personnel upon request.

Furthermore, the document highlights the enforcement of compliance with the master key control requirements by Officer in Charge, Marine Inspection (OCMI) and Marine Inspectors.

It also outlines penalties for crew members who use the master key without proper authorization, including civil penalties and potential suspension or revocation.

The policy letter applies to a wide range of vessels subject to inspection under 46 U.S.C. § 3301, including freight vessels, passenger vessels, offshore supply vessels, and more.

However, certain exemptions are provided for specific types of vessels, as detailed in the document.

In addition to the specific requirements, the document includes information on environmental aspect and impact considerations, as well as a disclaimer stating that the guidance is not a substitute for legal requirements and does not impose legally binding requirements on any party.

For more information, please see the document below (available only to subscribers):

Guidance on Master Key Control Requirements on Merchant Vessels