Implementation of the International Ship & Port Facility Security Code

Although CISR is not delegating any responsibilities under the ISPS Code to Classification Societies or other Recognized Security Organizations, most of these organizations have help and advice on their websites. The websites of the major Classification Societies can be found at www.iacs.org.uk . Advice from CISR can be obtained from Survey , please ensure you include details of you Cayman Islands registered ships with your enquiry so we can offer the most relevant advice.

AIS is to be provided on all yachts which have been issued with a Certificate of Compliance for a Large Charter Yacht, regardless of whether the operate in a purely private capacity. Further, the CISR recommends the fitting of AIS to all yachts engaged on international voyages.

The CISR will accept marking of the external Ship Identification Number in line with the requirements for passenger ships. That is, the external marking may be on a horizontal surface visible from the air, providing the marking is clear of awnings and other obstructions. For yachts, transfers will be considered an acceptable method for externally marking the Ship Identification Number; provided these are clearly visible, clear of any other markings on the hull and of a contrasting colour to the hull.

When marking the Ship Identification Number internally in the machinery space, the following methods are considered acceptable:




 
Steel Hull Aluminium Alloy Hull GRP / FRP Hull
Raised lettering by welding or centre punching. Raised lettering by welding or centre punching. Raise lettering mechanically fastened to the ships structure by means of bolts, screws etc or laminated.

The size of the markings shall be in accordance with SOLAS XI-1/3.

The ship identification number must include the prefix “IMO”. That is, the number should be in the form “IMO 1234567” and not just “1234567”. This was decided by IMO at MSC 77 in June 2003. The reasoning lies in IMO Assembly Resolution A.600(15) which covered the adoption of Ship Identification Numbers by IMO. The number “1234567” is legally a “Lloyd’s Register Number”, while “IMO 1234567” is the Ship Identification Number as adopted by IMO.

Application forms for the CSR can be obtained from www.cishipping.com.

The simple answer is “as soon as possible”. Regardless of the Administration your ships are registered with, or if your Administration has delegated to a RSO, the number of ships to be verified is far in excess of the number of qualified auditors to conduct the verifications. If every ship requires verification in the last few weeks before 1 July 2004, the demand for verifications will outstrip the global capacity to supply the qualified auditors. As well as being a SOLAS requirement, recent reports suggest that failure to obtain an ISSC by the due date will invalidate P&I cover.

No! You already conduct internal audits, perform management reviews and prepare for emergencies related safety; it makes sense to employ this knowledge and experience in complying with the ISPS Code. A word of warning though; your existing procedures and practices may need revising to fully meet the requirements of the ISPS Code. One important difference between the ISM and ISPS Codes is that the SSP requires formal approval. When you submit your SSP for approval it must be complete. Common ISM / ISPS procedures and contingency plans must be included if full. The SSP can not state “internal audits will be conducted in accordance with ISM Procedure XXX” unless the full procedure s included in the SSP.

A procedure is not a simple restatement of the requirements of the Code; rather it describes how you will meet these requirements. What is to be done? Who does it? How is it done? What controls do you have in place to ensure it is done? Draw on the experience you have gained in complying with the ISM Code. A simple statement that “internal audits will be carried out annually by persons independent of the area being audited” would not be accepted as an internal audit procedure for ISM, and similarly it would not be considered acceptable as an internal audit procedure for the ISPS Code.

If the operation of any equipment is necessary to fulfill a requirement of the SSP or the ISPS Code it will be classed as “security equipment” for the purposes of the ISPS Code. This will include “dual use” equipment, even when the equipment’s primary function is not related to security. As an example, deck lighting will probably be classed as security equipment as it is required to effectively monitor deck areas during the hours of darkness. Similarly, communications equipment will be classed as security equipment if it is used for security related communications. Conversely, an internal door lock would not normally be classed as security equipment unless, say, it was also used to control access to a restricted area.

Because of the short time scale ships have to comply with the ISPS Code, the CISR is not requiring a minimum implementation period before an ISSC can be issued. Up until 1 July 2004, the CISR will issue an ISSC if there is satisfactory objective evidence that:

  1. All onboard have received appropriate instruction and training and are fully conversant with their roles and responsibilities related to ship security.
  2. Both the master and the SSO are fully conversant with all aspects of the Ship Security Plan (SSP).
  3. The SSP is onboard and has been approved by the CISR.
  4. There are plans to conduct an internal audit within 3 months of the SSP being implemented onboard (if an internal audit has not already been carried out).
  5. At least one security drill specified in the SSP has been carried out and any identified corrective action implemented.
  6. Security equipment has been included in the ships maintenance system and has been maintained in accordance with the requirements of that system.
  7. All security equipment is operational and is fit for its intended service.
  8. All security measures indicated for the current security level are being implemented and that the ship is able to implement the security measures for all security levels.

After 1 July 2004, minimum implementation requirements will be harmonized with those for the ISM Code.

Although the CISR will not be approving individual training courses, we will accept security officer training that is approved, accepted or recognized by any Administration on the STCW “White List” as meeting the requirements of the relevant IMO Model Course. It should be noted that the CISR auditors will verify the effectiveness of this training during the onboard verifications.

Current security levels will not be available via www.cishipping.com, as the UK Government considers this information as “Sensitive” or “Restricted”. When the Security Level changes the company security officer (CSO) will be informed by email of the change.

The CISR requires records to be retained onboard for three years. This is to ensure that all records that have been made since the last verification are available at the next verification.

The Ship Security Plan, and the Ship Security Assessment (SSA) on which it is based, should be submitted to the Cayman Islands Shipping Registry (CISR) in George Town. The SSP and SSA can be submitted either as a hard and electronic copy or purely as an electronic submission. If a hard copy is submitted it will be stamped after approval and returned to the company. If only electronic copies are submitted, the title, index and revision status pages will be printed and stamped and returned to the company for inclusion in the copy of the SSP that is to be forwarded to the vessel. The CISR will only retain an electronic copy of the approved SSP and the SSA. Any additional hard copies that have been submitted will be destroyed by secure shredding after the approval process is complete.