A Isps Questions and Answers
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1. What happens if the ship history indicates that ports visited are ones where port security does not really exist? IMO will publish a list of ports with an approved port facility security plans (PFSP). If the ship comes from a port which is not on the IMO "white list" then the government responsible for a "white list" port may take this as "clear grounds" that the ship may not be in compliance with the ISPS Code (see ISPS Code B 4.33). In such cases the ship may be subject to the control and compliance measures in SOLAS XI-2/9. In extreme cases this may even lead to the ship being denied entry into port. 2. If a port does not provide adequate security, and despite best endeavours by ship crew, suspect personnel get onboard. How will IMO help? How can the shipping company apportion blame to the port authorities? The security of the ship is at all times the responsibility of the company. Appropriate measures, identified during the risk assessment and implemented through the ship security plan, must be taken. 3. Will there be "black lists"? As stated above, there will be a "white list "of ports published by IMO. IACS will also publish a "white list" of ships issued with an International Ship Security Certificate (ISSC) by member societies. A ship not having a valid ISSC will, by definition, be outside international requirements. 4. Who will pay for port delays if these occur because of security clearance of the crew? Undue delays may be compensated under the provisions of SOLAS XI-2/9. 5. Will Lloyd's Register issue standard ship security plans that could be tailored to individual ships? As with the ISM Code, the ISPS Code is not prescriptive. Each SSP must be individual to suit the company, the ship and the conditions under which it is trading. Lloyd's Register provides training for all levels of company staff and the ISPS Ship Practical Pack to provide a framework to assist clients. Lloyd's Register Mariner, the software for assessing risk, may be used to aid the development of SSP’s. 6. Will Lloyd's Register co-operate with consultants and validate their work? Lloyd's Register will not be involved with any form of consultancy where we will be involved in the approval and certification process. Lloyd's Register will consider consultancy where we can not offer certification services because the administration will not be delegating responsibilities to RSO and Lloyd's Register will not be providing certification services to the ISM Code. Advisory services will be provided through training and the ISPS Ship Practical Pack. Validation of other consultants’ work will be through the certification audit process. 7. The industry does not understand the requirements of ISPS but yet is told to prepare for the next voyage to the US. What do we have to do? At this time the US has imposed some pre-arrival requirements additional to those agreed by IMO. Be aware of NAVIC 10-02 (www.uscg.mil/hq/g-m/nvic/). Information on cargo security requirements is found at (www.customs.ustreas.gov/). The USA has published a consultation document on their proposed maritime security regulations. Lloyd's Register will be attending all of the public meetings being held in the USA to discuss these proposals. 8. What about guns and how is the industry supposed to defend itself without them. It is felt that passengers will not feel comfortable seeing officers with guns? The ISPS Code itself mandates no security hardware other than the Ship Security Alert. The decision to carry guns (if allowed) is that of the company and not a requirement of the code. The carrying of such weapons however may generate other problems with port authorities. Lloyd's Register does not advocate merchant shipping carrying firearms in ANY circumstances. 9. Who will be the security officer on board the ship and will there be one in the company ashore? The ISPS Code does not specify who shall be nominated the ship security officer (SSO) or
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Transcript of A Isps Questions and Answers
1. What happens if the ship history indicates that ports visited are ones where port security does not really exist?IMO will publish a list of ports with an approved portfacility security plans(PFSP). If the ship comes from a port which is not on the IMO "white list" then the government responsible for a "white list" port may take this as "clear grounds" that the ship may not be in compliance with the ISPS Code (see ISPS Code B 4.33). In such cases the ship may be subject to the control and compliance measures in SOLAS XI-2/9. In extreme cases this may even lead to the ship being denied entry into port.
2. If a port does not provide adequate security, and despite best endeavours by ship crew, suspect personnel get onboard. How will IMO help? How can theshipping companyapportion blame to the port authorities?The security of the ship is at all times the responsibility of the company. Appropriate measures, identified during the risk assessment and implemented through the ship security plan, must be taken.
3. Will there be "black lists"?As stated above, there will be a "white list "of ports published by IMO. IACS will also publish a "white list" of ships issued with an International Ship Security Certificate (ISSC) by member societies. A ship not having a valid ISSC will, by definition, be outside international requirements.
4. Who will pay for port delays if these occur because of security clearance of the crew?Undue delays may be compensated under the provisions of SOLAS XI-2/9.
5. Will Lloyd's Register issue standard ship security plans that could be tailored to individual ships?As with the ISM Code, theISPS Codeis not prescriptive. Each SSP must be individual to suit the company, the ship and the conditions under which it is trading. Lloyd's Register provides training for all levels of company staff and the ISPS Ship Practical Pack to provide a framework to assist clients. Lloyd's Register Mariner, the software for assessing risk, may be used to aid the development of SSPs.
6. Will Lloyd's Register co-operate with consultants and validate their work?Lloyd's Register will not be involved with any form of consultancy where we will be involved in the approval and certification process. Lloyd's Register will consider consultancy where we can not offer certification services because the administration will not be delegating responsibilities to RSO and Lloyd's Register will not be providing certification services to the ISM Code.Advisory serviceswill be provided through training and the ISPS Ship Practical Pack. Validation of other consultants work will be through the certification audit process.
7. The industry does not understand the requirements of ISPS but yet is told to prepare for the next voyage to the US. What do we have to do?At this time the US has imposed some pre-arrival requirements additional to those agreed by IMO. Be aware of NAVIC 10-02 (www.uscg.mil/hq/g-m/nvic/). Information on cargo security requirements is found at (www.customs.ustreas.gov/). The USA has published a consultation document on their proposed maritime security regulations. Lloyd's Register will be attending all of the public meetings being held in the USA to discuss these proposals.
8. What about guns and how is the industry supposed to defend itself without them. It is felt that passengers will not feel comfortable seeing officers with guns?The ISPS Code itself mandates no security hardware other than the Ship Security Alert. The decision to carry guns (if allowed) is that of the company and not a requirement of the code. The carrying of such weapons however may generate other problems with port authorities. Lloyd's Register does not advocate merchant shipping carrying firearms in ANY circumstances.
9. Who will be the security officer on board the ship and will there be one in the company ashore?The ISPS Code does not specify who shall be nominated the ship security officer (SSO) or the company security officer (CSO). As with the ISM Code, such nominations should take into consideration existing
11. It is said that the Lloyd's Register are working with the USCG, but the same has been said of other major classification societies.Lloyd's Register is closely involved in IMO, with the many flag administrations and other influential groups, both inside and outside of government.
12. Does Lloyd's Register have the resourceslocally and globallyto offer security certification services and what will be the costs?The Lloyd's Register intention is to mirror the ISM resource with that of ISPS. The associated costs of auditing will be similar to those of ISM.
13. Lloyd's Register regularly holds ISM seminars. Will these be expanded to include security?Yes, as and when the local need is identified.
14. Will local ISM staff assist clients withsecurity issuesas they do with ISM issues?See Question 6, above. Lloyd's Register will not provide consultancy services on procedure development to companies where it also provides certification services. This is a contravention of IMO requirements. Lloyd's Register will provide assistance through training and "add value" through the certification audit process.
15. ISPS sounds like another certification scheme similar to ISM. However, are there any physical issues that will need to be checked. Are there any defined exercises required?The ISPS audit regime is similar to that of the ISM Code. The Code does require the fitting of the ship Security Alert system and the implementation of various drills and exercises identified in the SSP.
16. Will port state control be involved in anyway?Yes, port state control is already defined within SOLAS. To avoid confusion with existing safety related measures, SOLAS XI-2/9 talks of "officers duly authorised by contracting governments". To all practical purposes, this is port state control for maritime security measures.
17. It is feared that some countries may take unilateral action. How can Lloyd's Register help us in that respect?Lloyd's Register is constantly lobbying through the IMO and IACS to ensure standardisation of standards and is in discussion with flag administrations such as the US to ensure practical solutions.
18. Lloyd's Register and other classification societies appear to be diverting from their usualclass business. It is believed that they are linking safety with security. Companies cannot train seafarers as anti-terrorist experts?There is no requirement for this. Threats must be mitigated primarily through the management system not through the use of arms.
19. What happens if the crew is of a nationality that is not "welcomed" at the port of arrival? How will IMO protect against race discrimination?Contracting governments cannot discriminate on race alone. There must be compelling need for such action and this will be decided on a case by case basis. However, the requirements of the immigration departments of individual governments are beyond the influence off IMO.
20. What additional equipment, alarms, monitors,video recorders, locks, etc. need to be included in the specification for new construction?SOLAS Chapter V has amended the requirement for the fitting of AIS, Chapter XI-2 requires the fitting of a ship security alert. Other "hardware" may well be required to meet the requirements of the ISPS Code. The need for any such equipment will be identified when the Ship Security Assessment is carried out. Security hardware is supplied to provide an effective control against an identified risk.
workloads, aptitude and suitability for the job and be provided with the appropriate training. Many companies are appointing the current ISM DPA as the CSO and the chief officer onboard to act as the SSO.10. Will the company shore based operations need any preparation or training?Yes. Both the CSO and the SSO are required to be adequately trained and have the knowledge required to discharge their duties.
