The ISPS Code becomes mandatory for all internationally trading passenger ships and cargo vessels above 500gt on 1 July 2004. Are shipowners and operators ready?
What is emerging is an impression that some shipowners and ship management companies are lagging behind in critical essential groundwork. Ship security assessments and plans are not only complex ship-specific operational documents, uniquely tailored to each ship's individual security needs and trading profile, but moreover, the Ship Security Plans (SSP's) require careful implementation onboard on a ratio of unique plan per ship.
Although many flag state administrations have appointed IACS member classification societies as a Recognised Security Organisation, or RSO, other flag states have either not yet finalised their delegations or not yet issued their own security interpretations and guidelines.
Therefore, even though most administrations, shipowners and management companies demonstrate awareness of the ISPS Code and the need for nearly 40,000 ships worldwide to be ISPS-certified by 1 July, the time and distance remaining for many appears a daunting task, and edge-cutting attempts are occurring.
Some shipowners and management companies are compressing their ISPS plan preparation time; 'cookie-cutting' their plans by over-simplifying their ship uniqueness; or alternatively, sequence-switching the steps in the approval process. Accordingly there are ISPS plans being presented to the RSO approving surveyor that are in an incomplete, disorganised, or otherwise inadequate form, resulting in rework and waste of time and money both for the company and the RSO. Obviously, as this trend was emerging already in February 2004, there is potential for increased tensions in the next few months.
At least one flag state has introduced a 60-day onboard implementation period for security plans, allowing for the two-month clock to begin ticking upon delivery of the company pre-approved plan to the Ship Security Officer (SSO) onboard for implementation. Thus, if the final plan approval by the RSO surveyor reveals shortfalls or deficiencies that require resolution before the SSP is approved, inconvenience may be caused the company and ship if substantive changes become necessary - not only administrative, but potentially also procedural and operational. Training and drills already completed can likewise become subject to question, if in conflict with the ultimately approved security plan. Sequence switching of the implementation and approval processes then compounds the difficulties facing all parties involved.
However, mostly there is proactive, sound planning and execution of the security system by the company - from the Company Security Officer (CSO) ashore to the most junior crew member onboard - can and will ensure success. Many companies, large and small, have already successfully met the intentions and objectives of the ISPS Code. To succeed with the ISPS Code implementation, all parties, masters, crews, RSOs, flag state administrations, and other authorities, must actively recognise and support the necessity to preserve quality and effectiveness within the ISPS security equation. Any temptation to shortcut, undermine, or ignore the intention and requirements of the ISPS Code, in the hot pursuit of a trading certificate by 1 July, is not only foolhardy and risky, but simply bad business.
At this point in time, the ultimate success of the ISPS Code and its impact on security at-sea and in-port can only be judged based on a combination of identified or estimated security risks and incidents that have been successfully forestalled or avoided. The counter-argument of bureaucracy and added administrative burden may at first appear valid in the face of non-events, but conversely prove to be good insurance in the aftermath of a deflected or reduced threat. The debates on these and other related security worthiness issues would linger long after the mandatory compliance deadline that rapidly approaches.