OAN 562
Registered Date:
21 February, 2007
Review Date:
21 February, 2008
Revision:
Rev 01
Operational Advice Note (OAN)
Maritime and Coastguard Agency
Operations Advice Note / Document Number:
OAN 562
Revision:01 / ISPS CODE COMPLIANCE PROGRAMME
Date:16Feb07 / Distribution A, B & D
Not to be distributed outside MCA
Summary
This OAN replaces OAN 531 and the following changes from that OAN are highlighted:
- security-only inspection targets for 2007/8;
- requirement for national inspection coverage;
- a change to the balance of targeting ships, grouping UK ships with those registered in Crown Dependencies and OverseasTerritories;
- removal of the requirement to target UK ships in the 2nd half of the five-year security verification cycle;
- liaison with shipping companies on security issues
- clarification on the ship security plan approval process;
- ship security file documentation; and
- flow of information to Security Liaison Officers (SLOs) and CSMs;
1.Introduction
1.1The Transport Security and Contingencies Directorate (TRANSEC), the policy leaders for cross-modal transport security, have refreshed the compliance programme for maritime security that includes:
- Verification and inspection of port facilities (TRANSEC activity);
- Periodic verification of UK ships required by the International Ship and Port Facility Security (ISPS) Code (see paragraphs 4-6);
- Security-only inspections of both UK and foreign-flagged ships in UK ports (see paragraph 2);
- Security-only inspections of UK ships abroad;
- Security element of MCA’s Port State Control Inspections
- Liaison meetings with port and shipping stakeholders (see paragraph 3).
2.Security-only Inspections
2.1The inspections in most cases will be conducted by one of the MCA’s six Security Liaison Officers (SLOs). The target will not include interim, initial, intermediate or renewal security verifications which will be conducted separately and continue to be harmonised with the ISM process. Port State Control inspections will also not be included in the security-only inspection target number.
2.2For the seven-month period from 1 September 2006 to 31 March 2007, a proportionate number of 90 inspections will be carried out by each Security Liaison Officer; the target number of security-only inspections is 540 (i.e. Eastern Region 270, Wales and Western Region 90 and Scotland and Northern Ireland Region 180).
2.3The annual target for the year 1 April 2007 to 31 March 2008 is for 900 inspections to be conducted all round the coast each year (i.e. Eastern Region 450, Wales and Western Region 150 and Scotland and Northern Ireland Region 300).
2.4The target number of inspections above is linked to Security Level 1. If there is a change to the Security Level set for UK ports additional ISPS inspections will be required to be carried out. ROMs and AOMs will be informed about additional inspections required.
2.5Security-only Inspections are to be carried out as follows:
- ROMs should break down their regional targets to ensure that national inspection coverage is achieved.
- As a guide, the ratio of inspections will be one-third British ships (including those registered in UK, Crown Dependencies and OverseasTerritories) to two-thirds foreign registered ships;
- The ships chosen for security-only inspection are to be randomly selected and are not to include ships already visited by MCA during that port visit.
- Unless deficiencies were identified at previous security-only inspections, verifications or port state control inspections ships inspected in the previous 12 months should not be re-inspected;
- UK ships with deficiencies identified by other Administrations should also be targeted as a priority;
- Receipt of specific security information about a ship, such as a report form another port State or a Harbour Master, will trigger an overriding priority under the Port State Control regime, in which case the Security Liaison Officer would attend the vessel with the PSC Officer. Under these circumstances the security inspection would be counted as a "targeted" inspection.
- Inspections will be based on the aide memoire MSF5517(SecurityControlandComplianceAidememoire);
- The findings should be entered on report forms MSF1602 and MSF1603. Guidance for completion of these forms can be found on the Inspection microsite under ‘AdviceforcompletionofUK/DTInspections'.
- For security-related deficiencies, additional advice for completion of form MSF1603 is given below
15a / Code / 0160 for ISSC deficiencies
0162 for CSR deficiencies
0995 for Ship Identification Number (IMO No.)
2705 for all other security deficiencies
15b / Description of (2705) Deficiencies /
- ‘Access control’ (at gangway): none or inadequate.
- ‘Restricted area’: not marked; access not controlled
- ‘Training’ (inc. drills & exercises): unable to perform security tasks (identify task)
- ‘Ship Security Officer’ (SSO): not appointed or has insufficient knowledge.
- ‘Ship Security Plan’ (SSP): not approved; not reviewed or audited.
- ‘Ship Security Alert System’: not working.
- ‘Interface’ either ship/port or ship/ship: current security level incorrect; unable to contact PFSO; no pre-arrival information given.
- ‘Communication’: consider separate recording if also recorded under ISM or if identified during security-only inspections.
- ‘Monitoring security of ship’: in co-operation with port facility measures not effective, to landward or seaward.
- ‘Other’: not covered above (identify)
- ‘Records’: lack of records to be recorded under appropriate category identified above
15c / Regulation reference / Article 3.1 and/or 3.5 of Regulation (EC) No. 725/2004(This is only needed if ship is detained)
16 / Action Codes / Please see Annex A for guidance on suggested codes
REPORT TO SURVEYOR / Outstanding deficiencies found at security-only inspections have to be “closed down” on the reports of inspection and the SIAS database. Please see the Inspection microsite under ‘‘AdviceforcompletionofUK/DTInspections'’.
2.7An example of a completed form MSF1603 is given at annex B.
2.8Security-only inspection Information from Forms MSF1602 and MSF1603 will be entered onto SIAS in the usual way so that deficiencies found can be analysed and monitored and subsequent targeting of security-only inspection activity identified.
2.9A review of forms used for security is currently being considered with a view to rationalisation.
3.Liaison with Shipping Companies
3.1Prior to the implementation of SOLAS XI-2 and the ISPS Code on 1 July 2004, concerted efforts were made to contact shipping companies and ensure ongoing dialogue regarding security matters. Since the ISPS implementation date the impetus for ensuring regular contact in respect of security may have declined and with this in mind Security Liaison Meetings are included in the compliance programme.
3.2The liaison is to encourage effective two-way communications between Government and Industry. It will provide an opportunity to examine compliance challenges and ensure that Government security information is being received by companies and that Government has up-to-date information from companies.
3.3MCA should have at least two liaison contacts with the Company Liaison Officer (CSO) annually. The primary means of achieving this is through tasking Security Liaison Officers. These biannual contacts may be by face-to-face meeting or by telephone/email discussion depending on the location of the shipping company’s CSO. At least one contact is to be by telephone/email.
3.4The target requirement is for 90% contact with each company annually and 80% for a second contact.
3.5Group meetings comprising CSOs from several shipping companies are encouraged. These meetings should provide an opportunity for exchange of information with particular companies.
3.6On one side of form MSF 5614 an aide-memoire has been compiled to provide guidance on areas for discussion. It is not a prescriptive document and may need to be updated from time to time depending on current circumstances. It may prove useful to tell CSOs in advance what information will be required from them.
3.7The reverse side of MSF 5614 comprises a format to report the outcome of the liaison and will be used to account liaison against targets. After each liaison, a copy of the completed form MSF 5614 should be sent to Maritime Security and Audit Branch in Headquarters.
4.Ship Security Plan (SSP) approval process
4.1SSP approval should only be carried out by those that have had the appropriate training. The current one-stage approval process will be enhanced by a peer review system (see paragraph 6).
4.2Table 1 below provides guidance on the relationship between Marine Offices and SLOs, who will usually approve SSPs.
5.Ship Security file documentation
5.1MSF 5613 – Security CM file documents checklist - describes the security plan approval and security verification documentation which is required to be held with a completed ship security file.
5.2The Surveyor or Security Inspector carrying out the security plan approval or security verification is responsible for ensuring all relevant records are complete and up-to-date.
5.3After security verification has been conducted and all documentation completed, the security CM file should be returned to the relevant SLO. The SLO is responsible for ensuring necessary documentation in the security file is complete, up-to-date and accurate.
6.Peer Review of Security Plan Approval and Security CM File Documentation
6.1To ensure the standard of plan approval is maintained HQ Maritime Security and Audit Branch (MSAB) will select a number of ships at random from the database for peer review of the SSP approval. The review will make certain that the SSP meets relevant quality standards and complies with the latest revision of the CSSI.
6.2Two plans approved by each SLO from two different companies per year will be sufficient sample for this peer review, as this compromises an approximate 10% quantity check.
6.3At the time SSP approvals are peer reviewed, the SLO conducting the peer review should also carry out a quality control check of the ship security file to ensure that all documentation has been completed in line with policy and requirements.
6.4A report of the findings of the reviewing SLO will be sent to the Head of Maritime Security and Audit in HQ and the file returned to the SLO who normally has custody of it.
7. ISSC and other Information Updates
7.1To facilitate awareness of future flag-ins, Maritime Security and Audit Branch will forward to SLOs copies of Flag-in Narratives identifying ship details, flag-in deadline, Customer Account Manager and Customer Service Manager.
7.2SLOs have been allocated shipping companies based on the SLOs’ proximity to the CSMs. Table 1 illustrates this.
CSMs located in MOs at: / Assigned SLO
Tyne, Stockton, Hull / Greg Albrighton
Yarmouth, Harwich, Dover, Orpington / Alex Scott
Southampton / Mark Towl
Wales & West / Richard Snape
Belfast, Glasgow / Bob Turkentine
Aberdeen, Leith, Shetland / Jim Dickson
7.3 CSMs and SLOs are expected to liaise with each other to ensure that there is adequate information flow when an ISSC requires updating or renewing for any reason, e.g. due to change of ship name, or for other relevant security activities.
8.Funding and Outcomes of Compliance Programme
8.1The cost of the compliance programme should be set against the cost centre of the Marine Office that undertakes the work.
8.2Within ten working days of the end of each quarter, Maritime Security and Audit Branch will compile a report for TRANSEC of the compliance programme. A copy will be posted on the branch’s microsite.
9.Cancellation
9.1OAN 531 is cancelled.
9.2This OAN will remain in force for one year from the date of issue or until it is included in the next revision of MSIS0025 - Instructions to Surveyors.
Author:
J Paglia / Maritime Security and Audit Branch
For a printable version of Annex A, click here Annex A (PDF, 53KB)
For a printable version of Annex B, click here Annex B (PDF, 110KB)
This page was last modified
Monday, 12 March, 2007 at 02:30pm by igurr
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