Ports, Marine Terminals & Offshore

The stake: MTSA facility security plans and the TWIC required for unescorted access to a secure area, alongside federal interest in pests arriving with vessels and cargo.

What is actually at stake at a marine terminal?

Cargo that cannot move, a security posture that cannot be relaxed to accommodate a contractor, and a set of federal interests that treat a pest as a border question rather than a housekeeping one.

That combination is what makes this vertical unlike any other on this site. In a restaurant a pest problem threatens a grade. In a food plant it threatens an audit. At a marine terminal it threatens the thing the terminal exists to do, which is turn vessels around, and it does so through agencies that have no commercial relationship with the terminal at all.

Four exposures sit on top of each other.

The first is cargo. A hold, a container or a consignment found with a regulated pest becomes an inspection matter, and the possible outcomes run from a hold, to a directed treatment, to re-export at somebody’s cost. None of those are pest control problems in the ordinary sense. They are logistics problems with an insect in them.

The second is the vessel. Time alongside is the most expensive commodity in the industry, and anything that extends it — an inspection, a finding, a treatment, a dispute about whose responsibility a condition is — is charged somewhere.

The third is the facility itself. A terminal is a working industrial site with warehouses, sheds, offices, a canteen, a yard, a quay, a fence line and usually a great deal of rock and water, and it has an ordinary rodent and insect problem underneath the exotic one. That problem is generally larger than the exotic one and gets far less attention.

The fourth is access, and it is the one that decides whether any of the other three can be worked on properly. A regulated maritime facility is a controlled environment under federal security regulation. Most pest contractors cannot get to the work without a member of the terminal’s own staff standing beside them, which changes what the work costs and, more importantly, changes what gets done. A technician who needs an escort does not spend forty minutes tracing a run of rub marks along the back of a shed. He does what he came to do and leaves, because somebody is waiting.

Graduate Pest Control has worked on buildings across New York City and Long Island since 1983, and the argument this firm makes everywhere — that a pest problem is a building problem — is nowhere more literally true than on a quay. The building here includes the rock armor, the apron, the sheds, the fence line and the interface where a vessel touches all of it.

Why can most pest control firms not lawfully reach the work?

Because a regulated facility has secure areas, and reaching a secure area without a credential means somebody has to walk with you.

The framework is the Maritime Transportation Security Act and the Coast Guard regulations under it. 33 CFR Part 105 covers facilities: which ones are regulated, the Facility Security Assessment and the written Facility Security Plan submitted for Coast Guard approval, the designated Facility Security Officer, the requirement to designate secure areas and control access to them, and the escalating measures at MARSEC Levels 1, 2 and 3. Part 104 does the equivalent for vessels, with a Vessel Security Plan, a Vessel Security Officer and designated restricted areas.

The access rule is where a contractor meets it. Under the facility access-control provisions, an individual seeking unescorted access to a secure area must hold a valid Transportation Worker Identification Credential and pass inspection of it, electronic or visual according to the facility’s risk group. An individual without one may be in a secure area only when accompanied.

It is worth reading the definition of accompanied, because it is more demanding than people assume. 33 CFR 101.105 defines escorting as ensuring that the escorted individual is continuously accompanied while within a secure area in a manner sufficient to observe whether the escorted individual is engaged in activities other than those for which escorted access was granted, accomplished by side-by-side companion or by monitoring depending on where access is granted. The same section defines a secure area as the area over which the owner or operator has implemented access control measures under a Coast Guard approved security plan, and restricted areas as those identified in a security assessment as requiring a higher degree of protection.

Translate that into a working day. A terminal that engages an uncredentialed pest contractor is committing one of its own people, for the duration of every visit, to standing next to a technician. That person has a job already. What happens in practice is entirely predictable: visits get shorter, the parts of the facility that are inconvenient to reach stop being visited, the yard and the fence line and the far end of the apron are inspected from a distance if at all, and the service becomes a series of station checks near the gate. The record shows a serviced facility. The rodent population lives at the other end.

A credentialed contractor removes that constraint. It is not a marketing distinction. It is the difference between a program that can go where the problem is and one that cannot.

What is TWIC, and what does it not tell you?

It is a vetted access credential, and it is worth being precise about both halves of that.

The Transportation Security Administration issues the TWIC after a security threat assessment — a background check against defined disqualifying criteria — to applicants in eligible immigration categories. It is required by the Maritime Transportation Security Act for workers who need access to secure areas of the nation’s maritime facilities and vessels, and for most mariners credentialed by the Coast Guard. It is valid for five years. The Coast Guard is the enforcement authority at the facility, and the facility’s own security plan governs how the card is used on site.

Ryan Katz holds it. What that means operationally is that he can be badged in and go to work.

Now the honest half. A TWIC is not a pest credential and nobody should present it as one. It says a person has been vetted for access to a secure environment. It says nothing about whether they can identify a stored-product beetle, read a rub mark, specify a seal at a masonry penetration or write a corrective register a facility security officer can use. A terminal evaluating contractors should treat the credential as a gate condition — the thing that determines whether a firm can perform the contract at all — and then evaluate technical competence entirely separately.

On that second question, the person who does the identification is the thing to look at. Graduate’s entomologist is Arnold Katz, who founded the firm in 1983 and holds the B.S. in Entomology from the University of Georgia; he still works accounts and provides the species determination where it changes the plan — which on a quay, with stored-product pests arriving in cargo rather than walking in, is more often than on a building. Ryan Katz does not hold a degree in entomology and does not hold an entomological certification. He is a New York certified applicator, C1822141 in categories 7A, 7F and 8, and holds PCQI and HACCP certification. Graduate is also a member of the National Pest Management Association and the New York State Pest Management Association, and those are memberships rather than certifications — a distinction this trade blurs constantly.

Beyond the cards, the licensing floor is the same as everywhere: New York business registration 03298, and Ryan Katz certified as an applicator under identification C1822141 in categories 7A, 7F and 8. Numbers a facility can check are worth more than logos.

What changes when the structure is offshore?

The transport does, and the transport is the gate. Everything after that is rodent and insect work in a very unusual building.

Getting a person to a structure at sea is a safety-qualification question before it is anything else. Helicopter underwater escape training is the recognized requirement for personnel routinely transported by helicopter over water: theory covering the phases of a ditching and the equipment involved, then practical work in a submersible simulator that inverts and floods, drilled until brace position, exit identification and egress without a life jacket inflated too early are automatic. Drowning is the dominant cause of death in a ditching, which is why the training is structured the way it is. Ryan holds HUET, together with Tier 1 offshore, and those records are verifiable through the RelyOn platform on which offshore and industrial compliance credentials are held.

The reason any of that matters commercially is that the offshore energy build-out in this market is now a shoreside and offshore facilities problem with a pest dimension. The South Brooklyn Marine Terminal in Sunset Park is being converted into the largest dedicated offshore wind port in the country across a seventy-three-acre site — staging and assembly for Empire Wind 1, a fifty-four-turbine, eight-hundred-and-ten-megawatt project, plus the long-term operations and maintenance base with a control room monitoring the array around the clock, and an onshore substation connection. That is not a construction story from a pest point of view. It is a permanent, staffed, food-serving industrial building on a waterfront with a container yard next to it, and it will have a rodent problem like every other one.

The offshore structures themselves have a narrower and stranger version of the problem. A substation platform or an operations facility at sea is a sealed steel building with a galley, stores, waste handling and periodic crew transfer. Insects arrive in stores and in personal effects. Rodents arrive in freight and on lifted containers, and once aboard they have nowhere to disperse to, which produces population densities on a small footprint that surprise people. Nothing about the biology is exotic; what is exotic is the logistics. There is no returning next Tuesday. Whatever needs doing has to be planned, carried, and completed in the window the transport allows, which puts an unusual premium on getting the diagnosis right the first time and on writing a specification precise enough that the facility’s own technicians can act on it between visits.

What arrives on a ship, and who is watching for it?

Several distinct things, watched by several distinct agencies, and a terminal that treats them as one subject gets surprised regularly.

Wood packaging material. The largest steady interception category at United States seaports. Pallets, crates and dunnage carry wood-boring insects, which is why treatment and marking regimes exist and why Customs and Border Protection agriculture specialists concentrate on them. The enforcement outcomes are real: cargo held pending treatment, directed fumigation or heat treatment, or re-export of a consignment. A terminal that handles a lot of machinery and heavy imports is handling a lot of wood.

Vessel-borne egg masses. The flighted spongy moth complex — the group formerly discussed as Asian gypsy moth — lays egg masses on ship structures in regulated Asian ports. APHIS and the Canadian Food Inspection Agency run a program covering pre-departure inspection and certification, and operators are expected to inspect their vessels while under way and remove what they find, notifying Customs and Border Protection if they do. On arrival, vessels are subject to inspection, and a find triggers a coordinated federal and state response. For a terminal this is a seasonal and origin-driven risk rather than a background one, and it is the clearest example of why vessel and shore pest management are not separable subjects.

Foreign garbage. 7 CFR 330.400 regulates garbage derived from fruit, vegetable, meat or other plant or animal material arriving from foreign countries, and the regime is built around preventing the introduction of exotic pests and diseases through it, with prescribed handling including incineration or sterilisation at defined conditions. In practical terms, the waste stream coming off a vessel is a regulated commodity, not refuse, and how it is staged on the quay is a matter with federal interest attached.

Stored-product insects in the commodity. Break-bulk and bagged cargo — cocoa, coffee, grain products, oilseed, dried commodities — carries its own insect complex, and a shed that has handled such cargo for decades has a resident population in the fabric of the building rather than in the consignment. This is the one that most often turns out to be the terminal’s own problem rather than the shipper’s.

Rodents. These do not usually arrive by sea. They board from the quay, which is the subject of the next section.

One further point belongs here because contractors misrepresent it. Ship Sanitation Control Certificates and their exemption equivalents, which replaced the older deratting certificates under the International Health Regulations, are issued in the United States only by the CDC as competent authority, with limited delegated authority to the Navy and Coast Guard for their own and certain government vessels. CDC’s own guidance is explicit that no port authority, public agency or private organization is authorised to issue them here and that a certificate issued by a private company in the United States is not valid. Graduate does not issue them and cannot. Any firm suggesting otherwise is telling a vessel operator something that will not survive contact with a port health officer.

Why is a terminal’s rodent problem not a warehouse’s rodent problem?

Because a warehouse has a perimeter and a terminal has an interface, and the interface moves.

Take the physical environment first. A marine terminal typically presents rock armor or riprap along a bulkhead, which is among the best rat harborage in existence — deep, dry, unreachable voids with water and food adjacent and no possibility of exclusion. It presents a quay apron with fendering, bollards, cable trenches and expansion joints. It presents cargo sheds with roll doors that are open through every working shift and were never specified to seal. It presents container stacks and, at any terminal with refrigerated boxes, a reefer rack area that is warm, sheltered, continuously powered and generates condensate. It presents a canteen and offices with ordinary domestic pressures. And it presents a boundary that in this harbor is frequently adjacent to residential streets, vacant lots, rail, or other terminals with their own conditions.

Then take the interface. When a vessel comes alongside, two rodent populations are connected by mooring lines, a gangway and a cargo operation. The standard mitigations are old and they work: rat guards on mooring lines, gangway lighting through the night, a watch that notices, and stores and freight checked before they go aboard. Guidance from harbor and vessel authorities has said the same things for decades — young rats disperse actively and will board a clean vessel from a dirty quay regardless of how well the vessel is kept. The direction of travel runs both ways, which is why a terminal that regards vessel rodent control as the ship’s own business is only managing half of its problem.

This is the part of the work that is closest to Graduate’s core trade, and it is worth saying where that expertise comes from rather than asserting it. Rodent exclusion is the center of this business rather than one service among several, and Ryan Katz teaches it: for the Mexican pest management association ACPUB in Querétaro, where he also ran a field rodent safari taking more than a hundred members out to work, for the PestInsight Initiative in Nigeria, and as an invited speaker in the United States. Very few firms in this market are teaching rodent work to professional bodies abroad, and none of that is relevant to a terminal except in one respect — the diagnosis on a quay is a reading problem, and the reading is what separates sealing forty openings from sealing the four that matter.

The practical consequence for a terminal is that the durable interventions are structural and sanitary rather than chemical. Roll door seals and thresholds on the sheds. Closing the cable trench penetrations into buildings. Screening intakes. Dealing with the canteen waste stream and its staging point. Managing the vegetation and the debris behind the sheds. Getting the reefer condensate away instead of letting it pond. Removing the pallet stacks that have not moved in two years. What holds when you seal on a marine structure is the same short list that holds anywhere: custom-fabricated 26-gauge galvanised sheet metal cut to the opening, copper and stainless mesh where an annulus has to be packed, hardware cloth where something must keep venting, mortar and hydraulic cement at masonry, Xcluder door sweeps and fill fabric at thresholds and services, Xcluder GEO where a barrier has to sit below grade against burrowing, and mechanical fasteners throughout. Expanding foam appears nowhere in it, in any role. On a salt-exposed structure the material choices matter more than usual, which is why stainless and copper rather than anything that will bleed rust down an elevation.

What can actually be applied at the water’s edge?

Less than at an inland site, and the limits are worth stating before a proposal rather than after one.

Three constraints narrow the options. The label is the first and it is law, and labels for products used near water carry specific restrictions; a quay is by definition near water. The facility’s own policy is the second, and terminals handling food commodities or working to a cargo owner’s standard frequently narrow things further. And the operating reality is the third: a windy, wet, salt-laden apron is a poor environment for anything that depends on a residue staying where it was put.

Rodenticide use at a terminal deserves particular care for reasons that have nothing to do with efficacy. A waterfront supports gulls, cormorants, waterfowl and raptors, and a working port is a foraging environment for all of them. Placement, containment and documentation matter more here than at an inland warehouse, and the honest answer in many locations is that the durable work is exclusion and harborage removal rather than a larger bait program. The reasoning is on rodent control and Norway rat control.

Mosquito work on a terminal is a drainage exercise. The production sites are tires, drums, containers holding water, catch basins, tarpaulins and covered equipment, ponded areas on an apron that no longer drains, and the low corners of a yard, and finding and removing them outperforms anything applied afterwards. Where material is used at all it is FIFRA 25(b) minimum-risk exempt product under category 8, and one limit belongs in writing: New York does not permit aquatic use of minimum-risk products, so any standing water that is genuinely aquatic habitat is outside this program and belongs with the authority responsible for it. The scope is set out under mosquito management. Ornamental and turf work — the landscaped frontage, the grassed buffer — sits in a category Graduate does not have and does not bid.

Where an entrenched stored-product population in a cargo shed genuinely requires fumigation, that is a major planned undertaking carried out by licensed fumigation specialists rather than something a general contractor should propose casually. It is also, in almost every case we have seen, the symptom of years of accumulated structural and sanitation failure in the building rather than a routine tool. The same applies to directed treatments ordered by a federal agency on a consignment: those are performed by the firms authorised for that work, and Graduate’s contribution is the building, the program and the record.

How is a terminal program actually laid out?

Outside in, in four layers, with the vessel interface treated as a fifth thing that has its own protocol.

The boundary and the ground. Fence line, rock armor, vegetation, debris, the yard corners nobody drives to, and the neighboring conditions that feed the site. This layer is a harborage survey before it is a device layout, and where a bank or dense groundcover makes visual inspection useless, canine rodent detection locates burrows that would otherwise be found by accident a year later.

The envelope of every building. Sheds, warehouses, offices, canteen, workshops, gatehouse, substations and equipment enclosures. Roll doors and their thresholds, personnel doors, cable and pipe penetrations, vents and intakes, roof curbs and flashing, and the wall-to-slab junction. What is caught immediately inside an opening is diagnostic rather than curative: repeat captures inside one roll door is a door result and the answer is a seal, not another device.

The interior. Non-toxic monitoring on the interior perimeter and at transitions, flying insect monitoring positioned to intercept rather than to attract and never over an exposed commodity, and pheromone monitoring with species-specific lures wherever susceptible cargo is handled or stored. In a shed that handles bagged commodity, this layer is the early warning system for the resident population in the fabric.

The people-occupied spaces. Canteen, mess, offices, locker rooms and welfare facilities, which behave like any commercial premises and generate a disproportionate share of the complaints.

The vessel interface protocol. Agreed in advance rather than improvised: rat guards deployed and checked, gangway lighting, where waste is staged and for how long, what happens with dunnage and packaging, who inspects stores going aboard, and how a sighting on either side gets reported to the other. This is the layer that most terminals do not have written down, and writing it down is nearly free.

Frequency should come out of the survey and be defensible in a sentence. A terminal handling food commodities with live receiving and a canteen is a different account from a lay-by berth used twice a month, and a frequency assigned before anyone has walked the fence line was copied from a template.

What does the documentation have to satisfy?

Two readers who do not normally read the same document: the facility security officer and whoever audits the cargo.

The security side is the one contractors forget. Work inside a regulated facility is an authorised activity inside an approved plan, and the sensible arrangement is agreed with the facility security officer before the first visit: which named individuals attend and what they hold, which secure and restricted areas the work reaches, how devices are identified and recorded so that a numbered box in a restricted area is never an unexplained object, how findings that touch security — a hole in a fence line, a door that no longer latches, a gate gap — get reported into the facility’s own process rather than only into a pest report, and how access and escorting, where any is needed, is logged. A pest contractor who produces findings that improve the facility’s physical security posture is doing the facility a second favor, and the same failed door hardware usually appears in both files.

The commercial side is ordinary but has to be portable. A dated device map matching the site as it currently stands. Service records that state findings rather than attendance. Trend by area rather than a site-wide total, because a total at a terminal is dominated by the fence line and hides the shed. A corrective register with a named owner and a date against each item, most of which will belong to the terminal’s own maintenance, engineering or operations functions rather than to us. Material records where anything is applied. And photographs, before and after, which are worth more than any paragraph when a cargo owner’s auditor asks what was done about the roll door.

Where a terminal handles food commodities and sits inside a customer’s audit scheme, the expectations converge with those described under food manufacturing and processing and food safety and SQF programs, and Ryan holds PCQI, HACCP and SQF credentialing on that side of the work, which means the conversation happens in the language the customer’s own food safety plan already uses.

What goes wrong at ports and terminals?

The patterns are specific to the environment and they repeat.

Service that stops at the gate. The consequence of an escort requirement nobody planned around. The stations near the office are immaculate and the fence line has not been walked in a year.

Treating the vessel and the shore as separate problems. They are connected by a gangway for as long as the ship is alongside, and a program that addresses only one side is managing half a population.

Rock armor treated as untouchable, therefore ignored. It cannot be excluded, which is true, and it is therefore left out of the survey entirely, which does not follow. It can be monitored, understood, and used to explain why pressure concentrates where it does.

Sheds that never close. A roll door open for a working shift is not a defect, it is an operation. The answer is what happens at the interior line and at the thresholds, not an instruction to keep the door shut that nobody will follow.

Waste staging without a clock. The interval between waste leaving a galley or a canteen and leaving the site is the number that matters, and at a terminal it is frequently nobody’s stated responsibility.

Findings with no owner. Doors, fencing, drainage, paving, roofing and vegetation belong to the terminal. An item without a named owner and a date does not close, and at a facility with an approved security plan an unclosed physical finding has a second life in a different file.

Assuming the neighbor is irrelevant. In this harbor, terminals sit against streets, lots, rail and other operators. Unexplained recurring exterior pressure reads as program failure; explained recurring pressure with the evidence attached reads as a managed risk, and the difference is a paragraph.

Where does a terminal start?

With a survey walked end to end by somebody who can get to the end of it.

Bring the operational picture rather than the pest history: what the facility handles, which berths and sheds are in use, where the food commodity goes, how waste moves, what the security arrangement requires of a visiting contractor, and which parts of the site people already know are bad. If there is an open finding from a customer audit or a Coast Guard inspection that touches condition, say so — it changes the order in which things get done.

Terminals with a food commodity operation should read food manufacturing and processing alongside this page; those under a customer’s certification scheme, food safety and SQF programs. Publicly owned port and waterfront property sits under municipal, county and public facilities, and terminal operators with warehousing or office portfolios elsewhere will want property management. The wider framework is on the commercial pest management hub, the physical discipline behind all of it is on structural exclusion, and where a facility is being built or converted — which describes a good deal of this waterfront right now — the cheapest version of the conversation happens before the walls close, under exclusion consulting. Coverage is listed under locations, and Ryan Katz sets out the credentials and the numbers behind them.

To begin, get in touch with the facility, what it handles, and what the access arrangement is. An initial consultation costs nothing and is usually a phone call, because most of what shapes a terminal program can be established that way. The written proposal and plan is billed as the deliverable it is, and where the facility proceeds, that fee comes off the cost of the project.