Fairway
Working guide§101.650(d)

A training program that survives inspection

Training is the requirement most operators are already violating — the deadline was January 12, 2026 — and the cheapest one to fix. This is the whole program: who trains, on what, when, and what the record must show.


The tracks

Five clocks, one program

All hands, annually
Everyone with IT or OT access, including contractors: threat recognition, how to report, and the plan provisions relevant to their role. Due for the first time January 12, 2026 — a date that has already passed — and every year after.
New hires: 5 days from system access
The clock starts when the login is granted, not when the person is hired. A deckhand who boards Monday and gets a TMS login Tuesday must be trained by the following Sunday.
Key personnel
People with designated cyber responsibilities get deeper training. Designate them in writing — the designation itself is a record the job aid checks.
OT users
Anyone operating engine monitoring, cargo transfer, SCADA or similar systems gets OT-specific content, not just the office phishing module.
After plan approval: 60 days
Once your plan is approved, personnel must be trained on its provisions within 60 days.

The record

What inspectors actually verify

Coast Guard inspectors verify training against a job aid during regular vessel and facility inspections. It does not ask whether your crews are security-aware. It asks for specific record fields:

Date and duration
When the session ran and how long it lasted. "Completed" without a duration is a gap.
Topic outline, mapped to the rule
The topics covered, traceable to §101.650(d)'s content requirements — threat recognition, reporting, plan provisions.
Full attendee list
Every person, by name. The inspector's job aid checks the roster against the crew list, which is how missing contractors get found.
Key-personnel designations
Who holds designated cyber responsibilities, in writing.
Third-party content evaluation
If you bought the training, the record that you evaluated it against the rule's requirements.

Records are retained at least two years §101.650(c)and produced on demand. A gap draws a deficiency finding — and a deficiency history is what your insurer’s underwriter reads.


Running it

The program in practice

Run the annual cycle on a fixed anniversary so it survives crew change, and put the 5-day clock on whoever grants system access — IT or the office manager — not on the training calendar. The clock is an onboarding step, like a drug test: no training, no login.

Third-party e-learning is fine and usually right for a small fleet; a maritime-specific course beats a generic office module for the OT track. Evaluate it once against the rule's content list, write that evaluation down, and keep your own attendance records rather than relying on the vendor's dashboard.

If you are starting from zero today: train everyone now, document it properly, and set the anniversary. An operator with completed training and clean records is in a categorically better position at inspection than one still deciding — and it takes days, not months.

Printable

The NRC call-script card, the training-records template and the CySO chooser

Three documents for the duties in force and the designation ahead — built to what the Coast Guard checks. Free; we ask for a name.

Get them —

Want training handled as part of the whole program?

Seats, rosters, the 5-day clock and inspection-ready records are part of the compliance membership — along with everything else the rule puts on your calendar.

Or call 303-848-9352 or email aaron@fairway.systems — a person answers within one business day.