# Keep public-access facility exemptions conditional and reachable > Use 33 CFR 105.110 - Exemptions to review this narrow operational decision without extending the source beyond its stated scope. - Canonical URL: https://update.dsesecurity.com/updates/keep-public-access-facility-exemptions-conditional-and-reachable/ - Publisher: Detection Systems & Engineering (DSE Security) - Author: DSE Security Editorial Team - Published: 2026-08-27T12:09:58+00:00 - Modified: 2026-08-27T13:12:22+00:00 - Last reviewed by DSE: 2026-08-26 - Resource type: Explainer - DSE priority: Advisory - Topics: Access Control, Cybersecurity - Reading time: 3 minutes ## What you need to know Use 33 CFR 105.110 - Exemptions to review this narrow operational decision without extending the source beyond its stated scope. ## Potentially affected Teams, systems, services, or facilities within the stated scope of 33 CFR 105.110 - Exemptions ## DSE recommendation Compare the observed state with the cited official source, document applicability and exceptions, and test any approved change with rollback safeguards. ## Article Frame this document as a source-led configuration and assurance check: Keep public-access facility exemptions conditional and reachable. Only the official source and traced locations below supply facts. Confirm applicability before acting. ## Source fact: The official [33 CFR 105.110 – Exemptions](https://www.ecfr.gov/current/title-33/section-105.110) from U.S. Coast Guard via eCFR supports the following bounded statements: - Under 33 CFR 105, a designated public-access area is exempt from the specified screening and identification requirements in sections 105.255 and 105.285(a)(1). The research record locates this support at 33 CFR 105.110(a) (eCFR anchor p-105.110(a)). - An exempted public-access facility must comply with every COTP condition and keep the COTP supplied with current contact information for the person responsible for facility security. The research record locates this support at 33 CFR 105.110(c)(2)(i) and 105.110(c)(2)(ii), read with 33 CFR 105.110(c)(2) (eCFR anchors p-105.110(c)(2)(i) and p-105.110(c)(2)(ii)). Keep the evidence boundary at these traced claims. They support a review of credentials, readers, controllers, panels, door hardware, access decisions, monitoring, and life-safety interfaces; they do not support conclusions outside the source’s stated conditions. ## What the source does not establish This applies only to exemptions within 33 CFR 105.110. It does not create an exemption, displace COTP conditions, or excuse security measures imposed under other authority. A correct source interpretation can still be inapplicable to a particular design. Confirm identity sources, DNS where used, time, networks, power, fire systems, monitoring, and authorized operators, ownership, and change authority instead of treating documented behavior as a deployment guarantee. ## Applicability questions - For source statement 1 at 33 CFR 105.110(a) (eCFR anchor p-105.110(a)), which observable configuration, record, or test can confirm applicability here? - For source statement 2 at 33 CFR 105.110(c)(2)(i) and 105.110(c)(2)(ii), read with 33 CFR 105.110(c)(2) (eCFR anchors p-105.110(c)(2)(i) and p-105.110(c)(2)(ii)), which observable configuration, record, or test can confirm applicability here? - Which owner can attest to the recorded state of credentials, readers, controllers, panels, door hardware, access decisions, monitoring, and life-safety interfaces, including exceptions? - What baseline for identity sources, DNS where used, time, networks, power, fire systems, monitoring, and authorized operators must accompany the source-specific observation? - Which success, stop, and escalation criteria are written before testing begins? ## DSE recommendation: DSE recommends using the cited source as the evidence anchor for this decision. Anchor the review in the cited section and keep observation separate from interpretation. Record the source location, examined part of credentials, readers, controllers, panels, door hardware, access decisions, monitoring, and life-safety interfaces, observed and expected states, owner, and reason for deviation. If the review warrants change, use a bounded implementation with prerequisites, test population, monitoring, abort criteria, and a rehearsed reversal. Sequence checks for identity sources, DNS where used, time, networks, power, fire systems, monitoring, and authorized operators and sanitize protected material before retention. ## Verification and evidence Evidence should let another reviewer reproduce this decision. Retain observations beside the traced locations 33 CFR 105.110(a) (eCFR anchor p-105.110(a)); 33 CFR 105.110(c)(2)(i) and 105.110(c)(2)(ii), read with 33 CFR 105.110(c)(2) (eCFR anchors p-105.110(c)(2)(i) and p-105.110(c)(2)(ii)). Favor approved configuration exports, access-event tests, controller state, door inspections, alarm handling, and exception records, linked to stable identifiers, time, and operator. Retain the starting state, authorization, execution record, outcome, deviation, and final state as one review package. Move disruptive checks to an approved test path. Reopen the decision when versions, design, dependencies, ownership, or official guidance changes. ## Official references - [33 CFR 105.110 – Exemptions](https://www.ecfr.gov/current/title-33/section-105.110) — U.S. Coast Guard via eCFR ## Primary reference - Name: 33 CFR 105.110 - Exemptions - Authority: www.ecfr.gov - URL: https://www.ecfr.gov/current/title-33/section-105.110 - Source publication date: Not stated by the source ## Citation and use Preferred citation: “Keep public-access facility exemptions conditional and reachable,” DSE Security, https://update.dsesecurity.com/updates/keep-public-access-facility-exemptions-conditional-and-reachable/ Publishing principles: https://update.dsesecurity.com/updates/dse-updates-editorial-methodology/ Usage and citation policy: https://update.dsesecurity.com/usage/ Copyright © 2026 Detection Systems & Engineering. All rights reserved.