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ISPS Code – Elements
After the world trade center attacks on 9/11, a strategy was developed to monitor and
track vessels, to ensure the security of vessels and ports, to verify the identity of seafarers
and to secure containerized cargo. The strategy was adopted at the IMO Maritime Safety
Committee meeting in December 2002.
A series of amendments to the 1974 SOLAS Convention was adopted including changes in
existing SOLAS Chapter XI (Special measures to enhance maritime safety). Chapter XI-2
enshrines the International Ship and Port Facilities Security Code (ISPS Code) consisting of
part A and part B. Part A of the Code is mandatory and Part B contains guidance as to how
best to comply with the mandatory requirements.
Apart from IMO’s initiative a number of other mandatory national initiatives such as the
Marine Transportation Security Act 2002 and 33 Code of federal regulations sub-chapter H
were undertaken by the United States and are mandatory for vessels leaving, arriving and
passing through the United States. The United States also interprets part B of ISPS code as
a mandatory requirement for US bound-vessels.
The ISPS code applies to passenger ships and cargo ships of 500 gross tonnages and
upwards, including high speed craft, mobile offshore drilling units and port facilities serving
such ships engaged on international voyages.
The principal responsibility of the company under the ISPS code is to ensure that each
vessel it operates obtains an International Ship Security Certiicate (ISSC). This certiicate
is issued by the lag state administration of the vessel or by a recognized security
organization (RSO)such as the classiication society on the lag state’s behalf.
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Regulation XI-1/3 require ship’s identiication numbers to be permanently marked in a
visible place either on the ship’s hull or superstructure at the irst scheduled dry docking of
the ship after July 2004.
Regulation XI-1/5 requires ships to be issued with a Continuous Synopsis Record (CSR)
which is intended to provide an on-board record of the history of the ship. The CSR shall be
issued by the Administration and shall contain information such as the name of the ship and
of the state whose lag the ship is entitled to ly, the date on which the ship was registered
with that state, the ship’s identiication number, the port at which the ship is registered
and the name of the registered owner(s) and their registered address. Any changes shall
be recorded in the CSR so as to provide updated and current information together with the
history of the changes.
• requiring ship and port security plans based upon security assessments
• providing means for raising the alarm in reaction to security threats or incidents
• requiring training and drills to ensure familiarity with security plans and procedures
The ISPS Code outlines the following steps required for the issue of a ship
security certiicate:
• undertaking a ship security assessment (SSA), including an on-site survey for every
vessel
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• developing a lag state approved ship security plan (SSP) that references the ship’s
SSA and containing all the elements required by the code
• providing adequate training for the CSO, SSO and crew who are engaged in security
duties
• ensuring that all record keeping requirements are met as per the code
The matrix shown below will help comparison of the requirements under ISPS/SOLAS and
the US code of federal regulation 33 CFR 101-1-6
CONTRACTING GOVERNMENTS/
SOLAS ISPS-A ISPS–B
ADMINISTRATIONS
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Ch XI-2,
Pre-Arrival Notice Ch XI Sec 4.37 160.203
Reg 4, 9
Ch XI-1,
Ship ID
Reg 3
Ch XI-1,
Continuous Synopsis Record
Reg 5
Signs Charter
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• approving the Ship Security Plan and relevant amendments to a previously approved
plan
• verifying the compliance of ships with the provisions of SOLAS chapter XI-2 and part
A of the ISPS Code and issuing the International Ship Security Certiicate
• determining the security requirements of the port facilities, designating a Port Facility
Security Oficer (PFSO) and implementing measures as per the Port Facility Security
Plan
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Security level 1: normal, the level at which the ship or port facility normally operates. This
level is when there is a possibility of a threat against shipping (in general) and this security
level should always be maintained during normal working conditions.
Security level 2: heightened, the level applying for as long as there is a heightened risk
of a security incident. This is where ‘intelligence’ from a reliable source has been received
indicating that a threat against shipping or ports / terminals has been given to a respective
operating area or type of ship although no speciic target has been identiied.
Security level 3: exceptional, the level applying for the period of time when there is the
probable or imminent risk of a security incident. This security level indicates that a speciic
ship or port / terminal have been identiied and that the threat is highly probable. Security
levels may change from security level 1, through security level 2 to security level 3; it is also
possible that the security levels will change directly from security level 1 to security level 3.
Security levels may change from security level 1, through security level 2 to security level 3;
it is also possible that the security levels will change directly from security level 1 to security
level 3.
Some administrations have already advised their procedure for informing security level,
which should be incorporated into SSP accordingly. So far, many lag administrations have
decided to require record-keeping for the last ten port calls, or three or ive years, however,
there is an administration which requires seven years.
Company Responsibilities
• designating a company security oficer (CSO) and providing all support and resources
to fulill duties and responsibilities as CSO
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• ensuring that the SSP contains a statement emphasizing the master’s authority with
respect to ship security and ensuring that appropriate resources are provided for all
personnel concerned
• ensuring that the SSP together with the documented SSA is submitted to lag
administration for review and approval
• ensuring the implementation and maintenance of the SSP onboard by the CSO and
SSO
• ensuring that the training drills and exercises on ship security are carried out for all
relevant personnel
• ensuring that records of the activities addressed in the SSP are kept onboard
• ensuring that the declarations of security are completed, if required according to ISPS
• ensuring that the ship always acts on the security levels set and ensuring the
implementation of the security measures appropriate for these security levels
• ensuring that there is onboard veriication of the security system by lag state
• ensuring that a valid ISSC is issued and maintained onboard the ship after successful
completion of the veriication
• establishing a reporting and recording system for incidents and passing that
information to the authorities
• supporting the master in his authority to make independent security decisions and
asking for assistance where necessary.
Ship requirements
• conducting a Ship Security Assessment - SSA
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• developing a Ship Security Plan - SSP
Since each ship (or class of ship) presents different risks, the method in which they will
meet the speciic requirements of this Code will be determined and eventually be approved
by the lag state administration.
Implementation process
For a new vessel, the initial implementation involves the following process.
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breach and suggests options to eliminate or mitigate the risks identiied. The assessment
forms an essential and integral part of the process of developing and updating a ship
security plan.
The ship security assessment ensures that the key ship board operations are assessed
for possible threat scenarios. The on-scene survey is conducted to examine and evaluate
existing vessel protective measures, procedures, and operations related to security.
Third parties may be used in any aspect of the SSA if they have the appropriate skills and if
the Company Security Oficer (CSO) reviews and accepts their work.
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The following background information is to be provided to the person carrying out the
assessment:
• general lay-out of the ship – potential point of access, cargo spaces, stores, spaces
which require restricted access
• emergency equipment
• any agreement with private security companies and exiting security measures and
procedures on board such as identiication system, alarms, lighting, communication
systems etc.
First Stage: Identify possible threat motives and potential security risks for the
ship
Likelihood comments
Security risks Example
Unlikely Probable Likely
1. Political motives
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2. Symbolic motives
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(eg military
supplies),
represent
wealth
(eg cruising).
3. Economical damages
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installations,
etc.), or for
industry
production
(gold, silver,
silicates, etc.)
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Second Stage: Identiication & evaluation of key shipboard operations that it is important
to protect
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2.5 Galley/pantry
3. Cargo Handling
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5. Security Monitoring
5.1 Lighting
Third Stage & Fifth Stage: Identify possible threat scenario to key shipboard operations
and assess likelihood of those occurrences
Possible 5th
Relevant Likelihood 3rd stage
consequences stage
Yes No Mod High Extre Unlik Like Vul measu new
Possible threat
erate 2 me 3 ely 1 ly 2 ner res for vulne
scenarios
1 ability mitiga rabili
score tion ty
score
1. Damage to, or destruction of, the ship (bombing, arson, sabotage, vandalism)
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5rd 5rd
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On-scene security survey examines and evaluates the existing shipboard protective
measures, procedures and operations for:
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The report of the assessment identiies the remedial action that is needed to be
implemented based on the conclusion of the vulnerability assessment and on-scene security
survey and recommends the security measures that are to be included in the Ship Security
Plan (SSP). The completed SSA and SSA report are submitted together with the SSP for
approval by the lag state administration.
The SSA is reviewed and revalidated and the SSA report is updated each time the SSP is
submitted for approval.
The SSP is developed to ensure the application of measures on board the ship that are
designed to protect persons on board, ship, cargo and ship’s stores from the risks of a
security incident.
• identiication of the restricted areas and measures for the prevention of unauthorized
access
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• procedures for responding to security threats or breaches of security, including
provisions for maintaining critical operations of the ship or ship/port interface,
evacuating persons on board, and reporting on incidents
• procedures for auditing the security activities, and for ensuring the inspection,
testing, calibration, and maintenance of any security equipment provided on board
• procedures for training, drills and exercises associated with the plan
• procedures for the periodic review of the plan and for updating
• procedures, instructions and guidance on the use of the ship security alert system,
including the testing, activation, deactivation and resetting and to limit false alerts
• instructions indicating that the master has overriding authority and responsibility
to make decisions with respect to the safety and security of the ship and to request
assistance as may be necessary
• annually, beginning no later than one year from the initial date of approval
• when there have been modiications to the vessel, including physical structure,
emergency response procedures, security measures, or operations. This audit can be
limited to those sections of the SSP affected by the vessel modiications.
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• not have regularly assigned security duties
If the results of an audit require amendment to the SSP, the SSP should be submitted to
the lag state for review and approval along with the SSA.
The lag state administration or RSO will verify that all measures as per SSP are
implemented, ship staff are able to demonstrate that they are able to carry out the security
related duties as per the plan. On successful veriication an International Ship Security
Certiicate (ISSC) is issued.
This certiicate is valid for a maximum of ive years, however, extensions can be granted in
the case where:
• renewal veriication has been completed but a new certiicate cannot be issued
or placed on board the ship before the expiry date of the existing certiicate. The
existing certiicate could then be extended for a maximum of ive months beyond
the expiry date
A certiicate issued to a ship engaged on short voyages that has not been previously
extended may be granted a period of grace of up to one month.
• if the relevant veriications are not completed within the period speciied
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• when a ship owner assumes the responsibility for the operation of a ship not
previously operated by that ship owner
• a ship without a certiicate, on delivery or prior to its entry or re-entry into service
• the transfer of a ship from the lag of a Contracting Government to the lag of
another Contracting Government
• the transfer of a ship to the lag of a Contracting Government from a State which is
not a Contracting Government
• when a ship owner assumes the responsibility for the operation of a ship not
previously operated by that ship owner
This certiicate will only be valid for a maximum of six months and cannot be extended.
Control measures like boarding may be implemented prior to the ship entering port, by
contracting governments to better ensure security or based on clear grounds for believing
that the ship does not comply with the Code.
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Examples of Clear Grounds
The following are examples of clear grounds for a detailed inspection by a port state oficer:
• a report or complaint containing reliable information indicating that the ship does not
comply with the requirements of chapter XI-2 or part A of the ISPS Code
• evidence or information that the ship has embarked persons, stores or goods at
a port or from another ship where either the port or the other ship is in violation
of chapter XI-2 or part A of the ISPS Code, and the ship has not completed a
Declaration of Security, nor taken appropriate, special or additional security
measures or has not maintained appropriate ship security procedures
• the security system and security equipment of the ship does not correspond with the
requirements of the code.
The SSP is a security sensitive document and is not subjected to inspection by Port
State Control (PSC) oficers. However, if there are clear grounds that the ship is not in
compliance, limited access to the speciic sections of the plan can be carried out with the
agreement of the ship’s master or of the administration.
The following table shows the provisions of plan which may be inspected by the port state
Provisions of Plan which may be inspected with consent of the lag state or of
the master of the ship
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Provisions of plan which may be inspected only with the consent of the lag
state.
According to the US coast guard NAVIC -06-2003, the initial threat assessment is itself not
suficient to maintain the ship in compliance with ISPS. The US Coast Guard has clearly
interpreted that the ISPS code assumes that an ongoing and dynamic threat assessment
component is well maintained and continuously updated. It will serve as the foundation for
the establishment of security levels onboard. The SSP is to be a “living” document and be
maintained accordingly.
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The vessel is subject to boarding and inspection by the port state if the ship security
assessment is not updated to relect the current voyage and threats. Initial security
assessment only allows for the initial assessment before implementation of the code and
the SSP is prepared on that basis.
Threat situation can change based on recent civil/political activity, national threat
levels, security and safety issues - in particular ports, terminals, facilities etc. - and also
changes in sensitivities of cargoes, crews, types of ships, routings etc. Threat assessment
has to be updated every voyage and especially before entering US ports. The initial
threat assessment performed to obtain the ship ISPS certiicate is the foundation—new
information must be added continuously.
The CSO and the superintendent should provide the threat assessment information to the
ships, and responsible for seeing that the results of the threat assessment are appropriately
implemented.
The Administration or the RSO may approve the alternative security measures being
taken and the action plan, require amendments to such measures, require additional or
alternative measures, speedier repair or replacement or take other appropriate action.
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As the superintendent, you should be aware of the possible cumulative effect of individual
failures or suspensions which could impair the ship’s ability to operate at different security
levels as required by the lag state administration or the port facility.
During the security veriication, the technical system speciied in the ship security plan will
be veriied 100% every time and the operational security measures will be veriied by a
sample audit.
Record Keeping
Records of the following activities addressed in the Ship Security Plan are to be maintained
on board:
• declaration of security
• breaches of security
• any special or additional security measures taken by the vessel in any previous port
where it has concluded a ship/port interface
• communications relating to the direct security of the ship such as speciic threats to
the ship or to port facilities
• periodic reviews of the Ship Security Assessment and the Ship Security Plan
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So far, many lag administrations have decided to require record-keeping for three or ive
years, however, there is an administration which requires seven years.
Security drills should be conducted at least once every three months. In a case where more
than 25% of the ship’s personnel has been changed, at any one time, with personnel that
have not previously participated in any drill on the ship within the last three months, a drill
should be conducted within one week of the change.
In case of the vessel out of service due to repairs or other reasons, then a drill must be
conducted within one week of reactivation. Security drills may be conducted in conjunction
with other non security drills.
Drills are to be conducted to test the individual elements of the security plan such as :
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Exercises should be conducted at least once each calendar year, with no more than 18
months between exercises. Exercises are full test of the security program including the
active participation of relevant company and vessel security personnel. It may also include
the facility security personnel and government authorities depending upon the scope and
natures of the exercises.
It may be full scale or live exercise or tabletop simulation or seminar. It can be also
combined with other appropriate exercises or can be a combination of a live exercise and
simulation exercise. Each exercise should test communication and notiication procedures,
and element of coordination, resource availability and response.
Vessels are required to maintain records of the date, list of participants and description
of the on-board training, drill or exercise conducted. Records will be reviewed by the port
state control oficer to ensure drills and exercises are taking place as required by the code.
During the inspection, the port state control oficer can ask for a security drill if there is
evidence or reliable information that the vessel has failed to meet drill requirements.
Where a vessel is not complying with the requirements of the ISPS code, or cannot comply
with the requirements of the security level set by the lag state or the port state then the
superintendent should notify the appropriate competent authority prior to entering a port.
A port state may require the following information from a ship intending to enter the port
(regulation XI-2/9.2.1, chapter XI-2 of SOLAS):
• the vessel possesses a valid ISSC or a valid Interim ISSC. the name of its issuing
authority
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• the security level at which the ship is currently operating
• the security level at which the ship operated in the previous ten calls at ports
• any special or additional security measures that were taken by the ship in any
previous port eg declaration of security
• conirmation that appropriate ship security procedures were maintained during any
ship-to-ship activity during the vessel’s previous ten calls at ports eg ship to ship
transfer, rescue operation
• crew list
• passenger list
• information regarding who is responsible for deciding the employment of the ship in
cases where the ship is employed under the terms of charter party(ies), who are the
parties to such charter party(ies)
Declaration of Security
Declaration of security means an agreement reached between a ship and either a port
facility or another ship with which it interfaces, specifying the security measures each will
implement. This declaration is to be completed by the master or the ship security oficer
and the port facility security oficer or by a shore–side security oficer on behalf of the port
facility
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• the ship is operating at a higher security level than the port facility or other ship
• there has been a security threat or security incident involving the ship or port facility
• the ship is conducting ship- to- ship transfer with a ship without approved security
plan
U.S. Code of Federal regulations requires cruise ships and cargo vessels carrying certain
dangerous cargo as speciied under the regulation, to complete declaration of security at
security level – 1.
• does not send the ship security alert to any other ships
• other cargo ships of 500 gross tonnage and upward and mobile offshore drilling
units, not later than the irst survey of the radio installation after 1 July 2006.
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The system should be capable of being activated from the navigation bridge and in at least
one other location (master’s cabin). The existing radio installation on board may be used
for the alert system.
When the administration receives a ship security alert from the ship, the administration will
immediately notify the coastal states in the vicinity of which the ship is presently operating
to initiate measures.
Since the ship security alert is a covert alert, unlike a distress message which is an
overt alert, no attempt should be made to contact the ship originating the alert and no
communication to be made with the ships within the vicinity of the vessel under threat.
The CSO and the superintendent should liaise with the lag state administration and other
authorities (law enforcement agencies) to facilitate response measures.
In the view of the fact that a security incident may lead to a distress situation or a distress
situation may be followed by a security incident, the situation should be assessed to
determine and prioritize the response to be provided.
List of recipients of ship security alerts and other security related contact points in each lag
administration can be obtained from IMO’s global integrated security information system
(GISIS).
• developing and maintaining the Ship Security Plan for each ship, based on the ship
security assessment and to accurately relect the ship speciic information
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• modifying the SSP to correct deiciencies and satisfy the security requirements of the
individual ship
• ensuring adequate security training for personnel responsible for the security of the
ship
• co-ordination and implementation of Security Plans with the SSO and relevant Port
Facility Security Oficers
• liaison with all the relevant external agencies in the industry, port authorities and
law enforcement
• implementation of all aspects of the Security Plan where deiciencies have been
identiied
• developing the Security Manual and acting as the sole authority for changes and
updates to develop the manual
• implementing his authority to set security level, but not less than that set by the
Contracting Government
The CSO should have in his possession suficient documentation of the ship such as general
lay out, access points, restricted areas, emergency equipments, security devices etc to
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There is no stipulation within the code as to who should be the SSO and, it is up to the
Company and the CSO to decide. However it should be noted that the responsibilities
detailed in the Code are such that only a senior oficer will have the experience and
authority on board to satisfactorily carry out the SSO’s duties. The Master has the
overriding authority under the Code and any SSO is answerable to the Master and the CSO.
• undertake regular security inspections of the ship to ensure that appropriate security
measures are maintained
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• maintaining and supervising the implementation of the ship security plan, including
any amendments to the ship
• coordinating the security aspects of the handling of cargo and ship’s stores with
other shipboard personnel and with the relevant port facility security oficers
• coordinating implementation of the ship security plan with the company security
oficer and the relevant port facility security oficer
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