The Ship Security Assessment (SSA) is an essential and integral part of the process of developing and updating Ship Security Plans (SSP).
Shipping companies are required to designate a Company Security Officer (CSO) to co-ordinate the security activities of the company and its ships on one hand and port facilities and Governments on the other. The CSO is also responsible for ensuring the security systems are fully maintained and internally audited. Each ship is to have a designated Ship Security Officer (SSO), who may be the ships master. The CSO and SSO are required to have knowledge of the security system and to have received appropriate training; this also applies to other personnel assigned security duties. In addition to maintaining the SSP they are to ensure its effective implementation by carrying out drills and exercises at appropriate intervals. The guidance gives a three month interval for drills, or within a week of changing more than 25% of the crew (if they have not participated in a drill on that ship within 3 months) and annual exercises.
This is being looked over by Seafarer Standards at the moment. The demand for a "conversion course" is not seen as high and has been given low priority. However the possibility of a combined course (duration 5 days) is being investigated.
MCA will recognise them if they have gone through the approval process.
Do not return the SSP as we could be inundated. It could be amended on board by the first available MCA Surveyor to visit the vessel for any survey as you would for class items, minor changes in certificates etc.
Please contact mcga.gov.uk for details.
A company can instruct the SSO to request a Declaration of Security.
CSOs and SSOs will not be vetted. It would be very difficult to vet SSOs in particular bearing in mind most would not be UK citizens. Regarding PFSOs, bearing in mind the limited numbers of PFSOs it is likely they will be vetted though the final decision remains to be made by TRANSEC.
When ships are intending to enter a foreign port they may be required to provide information by the port state including: - Confirmation the ship possesses a valid ISSC, - Security level at which the ship is operating, - Security level at which the ship operated in the last ten ports of call, - Special or additional security measures undertaken at the last ten ports of call, - Confirmation that appropriate procedures were maintained during any ship-to-ship activity between the last ten ports of call, - Other practical security related information.
An International Ship Security Certificate issued under the ISPS Code will be accepted as prima facie evidence that the ship is in compliance with the MTSA and its implementing regulations, with the exception of 33 CFR Parts 104.240, 104.255 and104.295 as appropriate. We will verify implementation of the ship security plan through our robust port state control regime.
If a MODU is mechanically propelled " ie able to make a voyage as opposed to being just able to move around a wellhead " it will need an ISSC, with no exceptions.
International Chamber of Commerce (International Maritime Bureau) run a website at http://www.iccwbo.org/ccs/menu_imb_bureau.asp IMO publish monthly, quarterly and annual reports of piracy and armed robbery against ships at MSC Circulars. The Latest annual report is MSC.4/Circ.32 which can be found at: http://www.imodocs.imo.org
The International Ship and Port facility Security Code was adopted at the IMO on 12 December 2002. The Code has two parts: Part A which contains mandatory requirements and Part B which contains detailed guidance. Contracting Governments must implement the mandatory requirements of the Code, taking into account the guidance, by 1st July 2004.
Transport Security Division (TRANSEC), part of the Department for Transport (DfT), has overall responsibility for implementing IMO requirements and will deal primarily with port facility and passenger ship security. The Maritime and Coastguard Agency (MCA) is responsible for cargo and freight ship security.
Responsibilities of Contracting Governments, e.g. setting security levels and providing guidance for protection from security incidents, establishing the requirements for a Declaration of Security, testing the effectiveness of ship security plans and or port facility security plans and exercising control and compliance measures in accordance with SOLAS X-1 2/9; - A Declaration of Security addressing the security requirements that could be shared between a port facility and a ship (or between ships) and stating the responsibility each shall take. - Obligations of the company to "ensure the ship security plan contains a clear statement emphasizing the master’s authority" and "ensure the company security officer, the master and the ship security officer are given the necessary support to fulfil their duties and responsibilities". - Ship security with activities defined as to how a ship is required to act upon security levels set by Contracting Governments. - Ship Security Assessments to be "carried out by persons with appropriate skills to evaluate the security of a ship" and to include an on-scene survey and a number of other elements. - Ship Security Plan approved by the Administration and carried on board ship. - Records of certain "activities addressed in the ship security plan shall be kept on board for at least the minimum period specified by the Administration" These records to be protected from unauthorised access or disclosure. - Provisions for designated company security officers and ship security officers. - Training, drills and exercises concerning ship security. - Verification and certification for ships. Other requirements under Amendments to SOLAS chapters V and XI include: - Carriage requirements for ship borne navigational systems and equipment. - Requirements as to where and how the ship’s identification number will be permanently marked. - Every ship to which chapter I of SOLAS applies must have a Continuous Synopsis Record containing specified information. - Provision of a ship security alert system as specified in SOLAS XI-6
The ISPS Code and the Amendments to SOLAS apply to the following types of ships engaged on international voyages: - Passenger ships, including high-speed passenger craft. - Cargo ships (including commercial yachts) also includes high-speed craft, of 500 gross tonnage and upwards, - Mobile offshore drilling units (MODUs). They also apply to port facilities serving such ships engaged on international voyages. The Code does not apply to Warships, naval auxiliaries or other ships owned or operated by a Contracting Government and used only on Government non-commercial service
No. If an administration recognises the old tonnage (as the MCA Does) then it is applicable to apply compliance requirements for the old tonnage. So in this case the ship need not comply. The proviso is that the administration should issue the ship with a letter or some other form of authority to continue using the old tonnage.
The ISPS Code will apply to commercial yachts over 500 GT. It will not apply to commercial yachts under 500GT or to private yachts. A yacht carrying over 12 fare paying passengers will be classed as a passenger vessel. If it is also over 500 gt and engaged on international voyages, then the ISPS Code will apply. The reference to this in the code is ISPS Code reference is A/3.1.1.
From International Maritime Organisation, details as follows: Product: International Ship and Port Facility Code Code: 1116E Price: €14.00 Tel: + 44 (020) 7735 7611 Email: [email protected] Website: www.imo.org
The following steps need to be taken: - Appoint and organise approved training for, the Company Security Officer and Ship Security Officers. - Ensure a Ship Security Assessment (ISPS Code A/8.2) is undertaken for each ship by people with appropriate skills. This will include as on-scene survey of the ship (ISPS Code A/8.4) and could involve the use of a consultant. - The Ship Security Assessment shall be documented, reviewed, accepted and retained by the Company. - Develop a Ship Security Plan (ISPS Code A/9.4) taking into account the findings of the Ship Security Assessment. This could involve the use of a consultant. - Submit SSP and Ship Security Assessment for approval to the Administration. - Arrange for an internal review of the ship security system prior to verification visit.
The SSP is to be developed from the SSA written in the working language of the ship. If that language is not English, French or Spanish a translation into one of these languages shall be included.
There is currently no requirement in either SOLAS XI-2 or the ISPS Code for this to take place. MCA have based their maritime security process on the basis of a single ship visit for the verification. However, for training purposes a limited number of ship visits will be made to liaise with CSO regarding SSA and SSP. ISPS Part A Section 9.1 Requires Administration to approve SSP Section 9.3 Requires SSPs submitted for approval to be accompanied by SSA along with the Security GA Plan with all security equipment identified. Section 9.5 Requires administrations to specify which changes to SSP require approval ISPS Part B Para 9.6 Requires SSP security measures to be in place before initial verification.
SOLAS Ch IX/2 - Reg 6 - 1 All ships shall be provided with a Ship Security Alert Systems as follows Point 4. Other Cargo ships (including Commercial Yachts) of 500 gross tonnage and upward ………… not later than the first survey of radio installation after 1 July 20067
The marking shall be plainly visible and painted in a contrasting colour in the form of "IMO XXXXXXX". On ships constructed of steel or metal the marking shall be made by: - raised lettering, or - cutting it in, or - centre-punching it, or - any equivalent method of marking which is not easily expunged. high (width proportionate to the height). The positioning of the external marking is subject to a range of options: - on the stern of the ship, or - either side of the hull, amidships port and starboard, above the deepest assigned load line, or - either side of the superstructure port and starboard, or - on the front of the superstructure, or - In the case of passenger ships, on a horizontal surface visible from the air. Internally the permanent marking shall be in an easily accessible place and shall be not less than 100 mm high (width proportionate to the height). The positioning of the internal marking is also subject to a range of options: - on either end of the transverse bulkheads of machinery spaces as defined in regulation II-2/3.30, or - one of the hatchways or - in the case of tankers in the pump room, or - In the case of ships with ro-ro spaces as defined in regulation II-2/3.41, on one of the end transverse bulkheads of the ro-ro space.
The ISPS Code requires a shore based CSO to be appointed, However a discussion with your flag administration will guide you.
The ISPS Code doesn’t specifically disallow this therefore it could be a runner. However the Code does impose some executive powers in the CSO such as ensuring the SSA’s are carried out (A?11.2.2) etc which would need addressing.
No, if the number of ships on another flag exceeds the number on the UK flag, then that Flag's CSO course would be required. You can always check with Seafarer Standards.
When a ship announces its intention to enter the port of a Member State, the competent authority for maritime security of that Member State shall require that the information referred to in SOLAS Ch XI/2 Reg 9 paragraph 2.1 of Regulation 9 be provided: - At least twenty-four hours in advance; or - At the latest, at the time the ship leaves the previous port, if the voyage time is less than twenty-four hours.
If, after receipt of this information, there are clear grounds for believing that the ship is in non-compliance with the ISPS code, port state officers are to attempt to establish communications with and between the ship and its Administration in order to rectify the situation. Should this fail they may take proportionate steps that include: - A requirement to rectify the non-compliance, - A requirement that the ship proceed to a location specified in the country's territorial seas or internal waters, - Inspection of the ship, if it is within their territorial sea, - Denial of entry into port.
Specifically with regard to the limitation of liability issue, the MTSA and our regulations do not address third party liability. We have concluded however, that the requirements of the MTSA are satisfied through participation in the international regime and that an owner’s ability to limit liability is not in jeopardy by complying with the MTSA regulations. In our view, compliance with a plan will not only prevent a TSI (Transport Security Incident) but also will allow an owner of a SOLAS vessel who has complied with the SOLAS amendments and the ISPS Code to limit liability. This can be accomplished by those responsible for security effectively implementing its plan so that the requirements of the ISPS Code are met. Of course we re-emphasise the point that this assumes the plan being implemented fully complies with the SOLAS amendments and the ISPS Code and takes into account the relevant provisions of Part B. We will be vigorously overseeing this implementation through a very active port state control regime and through our foreign country audit program.
A UK ship travelling from a UK port to an installation in the UK sector (of the North Sea) would not be travelling to a port, so this is not an international voyage. Even if the installation was in a foreign sector of the North Sea, it would still not be a port. The word port is not defined in SOLAS Chapter 1, however it is considered that it would be stretching the natural meaning too far to make it include an offshore installation.
The reference to MODU is shorthand for that contained in SOLAS XI-2/1. MODU means a Mechanically propelled Offshore Drilling Unit as defined in regulation 1X/1 not on location. Regulation IX/1 defines MODU as "a vessel capable of engaging in drilling operations for the exploration or exploitation of resources beneath the sea-bed such as liquid or gaseous hydrocarbons, sulphur or salt". IMO's Maritime Safety Committee at its 77th session, which met in May 2003 after the ISPS Code was ratified, agreed that Floating Production Storage and Offloading (FPSO) units and Floating Storage Units (FSU) were not subject to the ISPS Code. It was also agreed that Single Buoy Moorings (SBM) would be covered either by the security regime of the offshore facility or port facility as appropriate.
The MCA have been delegated the tasks of; - Approving ships' security assessments and security plans, the associated verification activities for cargo ships and the issuing of ISSCs. - Undertaking inspections of foreign flagged ships visiting UK ports MCA's through Port State Control Officers. - Issuing ships' Continuous Synopsis Records. This is a document that remains with the ship for its whole life detailing, the ships' identification number, name changes, ownership, operating company, ISM and ISPS issuing and maintaining authorities. - Communicating security levels set by TRANSEC to ships; both UK ships world-wide and foreign ships in UK waters. - Monitoring ships operating at higher security level than those set for UK Port Facilities. - Approving training courses for Company Security Officers and Ship security Officers.