ISM & ISPS Codes

ISM & ISPS Codes Introduction ISM Code: Safety Management System Safety management objectives are to offer safer practices in ship or rig operations and a safe working environment, assess all related risks to ships or rigs, personnel and the environment, establish proper safeguard mechanisms, and continuously improve personnel safety management skills, including preparation for emergencies concerning both safety and environmental protection. ISPS Code: Ship Security Management System Security management objectives are to establish an internationally approved framework to eliminate security threats and take precautionary measures against security incidents which directly or indirectly affect port facilities, ships and rigs. Also, to ensure the early collection and effective flow of security-related information, to provide a method for assessing security like having in place ship security plans and process instructions for changing security levels, and as well as to ensure the placement of adequate and clearly defined maritime security measures. By integrating applying both codes, the risk to the fleet can be minimized and fines and Port State Control detentions can be avoided.

To help reduce the risks, the following are to be included as part of the final checks prior to port entry and voyage to ensure conformity to the international convention requirements. In addition, the implementation of ISM and ISPS will protect the fleet’s reputation and will help to get most out of the company’s human resources. All items in this policy review are to be checked on an ongoing basis to supplement the company’s operational and maintenance procedures as well as the  State’s requirements. ISPS Code Compliance Requirements Every ship or rig to which the security code applies must have:

• A Company Security Officer (CSO);
• Implemented and approved Ship Security Plan (SSP) ;
• A Ship Security Officer (SSO);
• IMO Number marked on certain locations on the vessel;
• Installed AIS, (see Equipment, paragraph 1)
• A Continuous Synopsis Record – CSR; and
• Installed Security Alert System (see Equipment, paragraph 2).

Ship Security Plan Ship security plan is the plan developed to ensure the application of the vessel’s or rig’s measures and designed to protect the crew on board, cargo, cargo gear units, and stores or overall the ship from risks related to security incidents. The submitted SSP shall be reviewed and approved when it is verified to be in compliance with the ISPS Code. (Handbook for Ship Security System Audit, 2012) Continuous Synopsis Record The CSR is intended to provide an on board record of the history of the vessel or rig with respect to the information recorded therein. Manpower

• Port Facility Security Officer (PFSO)

The person responsible for the development, revision, maintenance and implementation of the port facility security plan and operate as liaison with company security officer and ship security officer.

• Company Security Officer (CSO)

The designated person of the company for ensuring that the vessel security planning is carried out; responsible for the development of the security plan, approval submission, maintenance and implementation as well as for liaison with the ship security officer, port facility security officer, and the flag. The auditor is to verify that the vessel has provided essential information of the individuals in their company who have been designated as a CSO. This information shall be in the SSP.

• Ship Security Officer (SSO)

A person on board the vessel, most commonly the Master, designated as responsible for the security aspects of the ship, including maintenance and implementation of the ship security plan and to perform activities as liaison with the CSO, PFSO and the flag administration. The auditor is to verify that the company has designated and trained at least one of the senior officers onboard to perform the SSO duties. Equipment Automated Identification System (AIS)

• For all vessels performing activities and engaged in international voyages is required the installation of an Automatic Identification System installed according to SOLAS Chapter V Regulation 19.2 or a valid exemption certificate issued by the flag administration.
• The AIS installation has to be approved by the ship’s or rig’s classification society.

Ship Security Alarm System (SSAS)

• The installation and operation of SSA shall be verified upon installation by the RSO that issued the ISSC. The SSAS equipment and its operation are to remain confidential. The verification of the SSAS shall be conducted by the same RSO that issued the initial certification. The number of individuals, who were part of the verification and review process and have knowledge of the location of SSA, is to be kept to a minimum.

• 4.16.3The message programmed into the SSAS shall include, but is not limited to:

• Vessel name;
• IMO number;
• Call sign;
• Maritime Mobile Service Identity (MMSI)/DSC number;
• Position, course and speed; and
• Date and time (UTC) of the message.

• The ship security alerts shall be sent to the company and the administration.

Training

• The auditor shall verify that the CSO and SSO have received the appropriate training as referenced in STCW VI/5&6 and that documentary evidence is available. Refer to the corresponding flag administration website for list of approved training institutes.
• For all seafarers, a certificate of proficiency issued by CSO or SSO is to be available. The CoP will be granted upon the successful completion of the audit which examines the personnel in the following:
  • Is the crew familiar with the content of the company security policy and the related procedures, as described in the SSP?
  • Is there evidence about the crew’s awareness in security related issues (e.g., access control of people, cargo control, restricted areas onboard, responsibilities in case of security threats, etc.)?
  • Does the crew know how to respond to an attack or threat situation?

Sustainability

• All records presented to the auditor shall be recorded in English.
• All records listed under the ISPS Code shall be kept for at least 3 years. This is to ensure that they will be available for review during the verification audits.
• Each vessel shall have an individual SSP tailored to its SSA. However, there will be information in each ship's plan that will be the same for all of the ship's in the company's fleet, for vessels on the same trade route and for sister ships operating in the same trade. The SSA for the first ship can be used as a model for each of the other ships engaged in the same trade on the same routes.
• The auditor is to verify any changes made in the CSR and that the flag administration has been informed accordingly. Failure to keep the Administration informed is cause for invalidating the ship security certificate.

• Company security exercise shall test communications, company coordination, resource availability and response in accordance with ISPS Code Part B/13.7.
• The CSO shall provide a summary of the vessels in exercise, that should include:

• Description of the scenario;
• Summary of the drill;
• List of all parties involved; and
• Description of any recommendations that could improve the SSP.

Overall Assessment Summary Even though, ISPS Code represents the culmination of just one year’s intense work by IMO, an international framework focusing on the assessment of security threats and preventive measures against incidents, involving shipping and port industries and government agencies is established. In drafting ISPS code, care has been taken to ensure compatibility with the provisions of International Safety Management Code and the harmonized system of survey and certification. ISM’s main sections (1-9) are addressed efficiently in the ISPS code as follows.

1. Safety and environmental protection policy------------>ISPS
2. Company responsibilities and Authority------------>ISPS Part A-6 (pp.11)
3. Designated persons------------>ISPS Part A-12 (pp.16&17)
4. Master’s responsibility and authorities------------>SOLAS Reg.8 (pp.118)
5. Resources and personnel------------>ISPS Part B-15.5 (pp.77)
6. Shipboard operations------------>ISPS Part A-8 (under ship security assessment)
7. Emergency preparedness------------>ISPS Part A-13 (pp.18)
8. Reports and analysis of non-conformities, accidents and hazardous occurrences-->ISPS Part A-10 (pp.15&55-59)

However, ISPS Code requires further assessment to enhance its objectives, implement its paragraphs and allow for sustainability in the maritime industry. In order to, establish a more effective ISPS Code and manage more efficiently potential security threats recommendations have to be made. The following paragraphs are dedicated to the synthesis of a complete action plan for the implementation of the Code. Undoubtedly, many of them have been addressed as specific requirements from flag administrations, however if they get incorporated in the original document they are able add value to the present code. - During SSP review and approval, the following shall be defined within the SSP, in addition to those listed in Part A of the ISPS Code.

• Ship’s security organizational structure;
• The vessel’s relationships with the company, port facilities, other vessels and relevant authorities with security responsibilities and duties;
• The ship communication systems within the effective communication between the ship and port facilities or CSO;
• The basic security measures for security level 1, both operational and physical, that will always be in place;
• The additional security measures that will allow for the ship’s to change to security level 2 and, if necessary, to security level 3;
• The provision for regular review and audit of the Ship Security Plan and for its alterations in response to experience or changing circumstances; and
• Detailed reporting procedures to the Contracting Government's contact points.

During the ISPS verification, the following sections of Part B of the ISPS Code shall be treated as mandatory requirements for issuance of the corresponding certificates.

• Revision of SSP;
• Protection of the confidentiality of security plans and assessments;
• Recognized security organization;
• Minimum competencies of RSO;
• Setting the security level;
• Contact points and information on PFSPs;
• Identification documents;
• Ship's application of the security practices as recommended by the administration depending on the waters they are sailing;
• Manning awareness level;
• Accurate and rapid flow of information when a vessel is denied or expelled from a port;
• Ships from a State which is not a party to the Convention;
• Company's obligation to provide information about the ship's operators;
• Minimum standards for the SSA;
• Independence of RSO; and
• Frequency of drills and exercises regarding security for crew and security officers.

According to the Liberian Flag (ISPS Code Special Requirements, 2012, pp.5) although it is not a requirement, the company should contemplate incorporating the relevant shipboard security requirements into the company’s Safety Management System (SMS). The Safety Management system should:

• Define the security duties and responsibilities for the Company Security;
• Officer, the Ship Security Officers and the crew;
• Discuss who will be responsible for organizing security drills and exercises;
• Contain procedures for immediately reporting any noncompliance with the;
• ISPS Code, threats and breach of security to the Administration;
• Defined maintenance requirement for the security equipment;
• Provide for the logging of actions or measures taken to rectify deficiencies and non-conformities noted during Security Assessments and notification of the Administration and the RSO of any corrective actions taken;
• Provide the list of records to retain on board and retention period;
• Define the procedures for the harmonized internal ISM and ISPS Code audits
• State the company will provide the support necessary to assist the CSO and SSO to deliver their duties and responsibilities in accordance with chapter XI-2 of SOLAS and the ISPS Code.

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