Maritime Cybersecurity White Papers

The Cybersecurity Officer Problem: Subpart F’s Hardest Requirement for Small Maritime Operators

The compliance conversation around Subpart F is organized around documents, and documents can be bought. One requirement does not fit the pattern: each covered owner or operator must designate a Cybersecurity Officer, in writing, by name and title, accessible to the Coast Guard 24 hours a day, 7 days a week, carrying duties that amount to the standing management of the entire cybersecurity program, including the single most consequential judgment in the rule, the Critical IT and OT determination. The Coast Guard estimated the covered population at 3,447 owners and operators, roughly 91 percent of them small entities, and for that majority the person the requirement describes does not currently exist inside the organization. This paper reviews the requirement as written, converts the duties into calendar terms to show why the role is smaller than a full-time position and much larger than a collateral duty, examines why the burden falls on the smallest operators, and evaluates the three available staffing structures, internal designation with external support, one CySO shared across multiple vessels or facilities, and an outside designee under contract, with the price of each stated plainly. It closes with the questions a management team should answer before putting anyone’s name in the plan.