INTERTANKO ISTEC Meeting 26 – 28 March 2004
ISPS CodeAreas of particular concern during Shipboard Verifications
No.2 Ship Organization & Communication No.1 SSP Restricted Distribution • Communication systems are in line with the SSP known to responsible personnel. • Communication within the ship, with the company, with other ships, with ports and with relevant authorities. Various levels of confidentiality assuring personnel access to SSP parts they are authorized to review. No.3 CSO • 24 hour contact details may be verified by contacting the CSO.
No.4 SSO Security incidents reporting. Master’s Role still vague – Security incident will mainly be handled by the authorities Training; Documented evidence that required qualifications are fulfilled. Documented evidence of a formal course diploma or a company statement issued by the CSO adequately trained.
No.5 Drills Drills are conducted at least once every three (3) months fully in line with the drill plan of the SSP At least one (1) drill should be performed prior to initial verification. On the scene drill may be also required during the verification process
No.6 Exercises (N/A during the initial audit) No.7 Reporting Various types of exercises may require the participation of CSOs, PSOs, FSAs, SSOs carried out at least once each calendar year with no more than 18 months intervals between exercises. • Procedures for handling of documents are followed and kept for the period required by the SSP, detailed in SSP.
No.8 Security Equipment • All security equipment listed in the SSP are verified by a functional check and test according to the SSP or device/ equipment manuals, calibration inclusive duly recorded. No.9 SSAS Such information is to be kept elsewhere on board in a document known to the Master and/or the SSO and other senior shipboard personnel as may be decided by the company The Master and/or the SSO are familiar with the plan of the SSA installation. Location(s) is not required to be stated in the SSP.
No.9 SSAS cont. • Authority/ Organization letterhead and/or logo • Specifying “SSAs” or Ship Security Alert System • Refers to ISPS Code and IMO MSC Res. 136(76) or 147(77) depending upon date of installation. • SSAs antenna is located and mounted in an unobstructed stable way Procedures, instructions and guidance reflecting the use of the device, testing inclusive activation and/or resetting and to limit false alerts are verified (live testing during the shipboard verification shall be in accordance with FSA policy) SSAs “approval” documentation:
No.9 SSAS cont. No.10 Records • No specific requirement to describe procedures for retaining records in the SSP. However, security records are required to be kept onboard. Such records are evaluated during shipboard verifications, also available to PSC inspections. SSAs components are securely positioned and interfaced away from general public view.
No.10 Records cont. Records of the following activities/ tasks shall be maintained onboard as found necessary by the FSA: Training drills and exercises Security threats and incidents Security breaches Changes of Status in Security Level at all times (at least 10 ports of call) Any special or additional security measures taken by the vessel in any previous port where, it has concluded a ship/port interface
No.10 Records cont. STS activities. Internal Audits and Reviews of Security Activities Periodic Review of SSA and SSP Implementation of any amendments to the SSP Maintenance, calibration and testing of any security equipment, including testing of the SSAs Records maintained in an electronic format should be substantiated be relevant procedures Records are readily available to PSC officers to verify the SSP implementation
No.11 ISPS Code Commercial Implications Safe Port Laytime provisions If called at a port with no approved PFSP, implications may arise (especially in the U.S.) DEVIATION: I.e., avoiding “customary route” for security reasons Implications may arise from the CSR especially in the sale & purchase of second hand tonnage
No.14 ISPS Code Commercial Implications Cont. NOR tendering and the case of “Johanna Oldendorff”. The vessel may be instructed to remain away from the “customary waiting area”. Will the NOR still be valid? There is a need for a new clause to be drafted and incorporated in the C/Ps (either voyage or time) The BIMCO Clause dated 26/11/03 is not adequate
Security related equipment/ devices Example List requiring maintenance/ regular testing • P/A SYSTEMS • MOBILE PHONES • SEARCH LIGHTS • ID-SYSTEM CARDS • METAL DETECTORS • CAMERAS SSAs RADARS GMDSS PORTABLE VHFs WALKIE TALKIES TORCH LIGHTS