January 28, 2008

ISPSo Facto

(ipso facto: Latin for "by the very act", i.e. ‘automatically’)

Soon after the ISPS code was introduced (shoved would be a better word), we used to receive many emails from the CSO, usually forwarded. Wonderful thing, forwarding. Two clicks and the job is done.
One of them, when printed, was about eight pages long and was headlined “President Bush declares Code Orange- all ships to take appropriate measures”.
This was very interesting but useless, as we were on the SE Asia run and nowhere near the US, didn’t know what Code Orange was, didn’t have that code in the ISPS manual, didn’t know what appropriate measures to take, and, to be honest, didn’t much care.
There is no rest for the wicked. So we were told, in a subsequent email, that this involved more stringent checks on visitors, stevedores and stores without raising the Security Level. And no vehicles within 100 metres of the ship.

At which point I gave up, because we were a container ship with trailers and stackers coming alongside in all ports within a few metres of the shipside. However, I did think, briefly and just for fun, of enforcing the no-vehicle rule in Japan and stopping cargo operations as indirectly instructed. Better sense prevailed, as I didn’t feel like packing my bags just yet. Man does not live by ISPS alone.

But quite a few years have passed since then, surely we must have got our act together by now?

Well, consider this:

Ship Security Assessments are still being conducted hastily, at least when a ship is taken over second hand. I have seen these being conducted by one person sitting with a general arrangement plan and a laptop, modifying another vessel’s SSA as applicable.
Since this was an old ship, modifications were missed out, and since the vessel had not yet been taken over, input from crew was unavailable or unreliable.
The SSA was finished, nonetheless, in about three hours, approved, and the ship taken over. The new crew kept on finding new doors and access points to designated Unauthorised areas and others for a few days thereafter. The Ship Security Plan, based on this SSA, was quite useless, though it had a good lineage of required approvals. Nevertheless, it stayed in place awaiting embarrassing revisions during the remainder of my contract.

The Ship Security Plan is often generic, impractical and ill thought out. It almost never takes into account

· Peculiarities of the ship. On one ship, the navigating bridge doubled as a de-facto (de-facto is close to ipso facto, but more later!) ship’s office in port; it was the only place big enough to seat a dozen port officials at a time, besides the messroom, which was four flights down from the main deck. It did not help that the bridge was an unauthorised area, as it well should be. Another example... a ro-ro had shipchandlers driving up the ramp to a convenient point inside the ship for offloading stores. I authorised this in contravention of the ISPS procedures, which required all stores to be checked and tallied ashore. I did this because I did not have sufficient crew to lug provisions up six flights and across cargo compartments a hundred metres away from the accommodation- and since the provision crane was knackered, awaiting spares at a ‘convenient’ (read cheap) port.
· Other duties, planned and unplanned, of the crew in port.
· The number of crew available to monitor and enforce the Plan.
· The fact that some members of the crew may actually want to go ashore, reducing the numbers available on board.
· That different cargo ship’s have different levels of crew involvement in cargo. Companies put pressure on crew to lash and unlash cargo. A car carrier may require larger numbers of crew required for cargo operations versus a bulk carrier; a ro-ro with side and stern ramps and gangway all down has, suddenly, three access points with monitoring required at each. If somebody has to be escorted all the way up to the accommodation, you require six crew just to cover this. Often the suitability of the ship to the procedures being put in place is ignored. A gangway watch keeper cannot escort officials to the Master (as mandated by the Security Plan) and leave the gangway unattended. Do we then put two people per access point? Is there manpower for this?
· The number of stevedores which may be repeatedly boarding the vessel, in large numbers... as in a car carrier .. with drivers who return many times in each shift. (And the cargo superintendent requests gangway access for them, too, because for some reason turnaround is faster)
· The fact that cargo operations these days are often around the clock, with attendant pressures on short manned crews.
· STCW mandated rest periods. The Master, Officers and crew may be not rested before they even make the port. They certainly and often contravene the STCW regulations while departing most ports. (Ah, but it is the Master’s responsibility. He must stop the ship!)
· Commercial pressures. I have had pressure to remove cargo lashings while the ship is in the locks or in the river, or during the stevedore meal breaks. My refusal to handle lashings thereafter, on the grounds that the crew was being pushed so hard it was impacting safety (this, after I found helmsmen nodding at the wheel in congested waters), was not taken too well by all concerned, including the crew, who were making some pocket money. However, ISPS is not optional, but is similarly contributing to unrested Officers and crew navigating ships.
· Scheduled Surveys. With short port stays, a couple of scheduled statutory and non statutory surveys, inspections and the like can involve an entire crew just for these. With the explosion in regulations and their administration, it is common to see something scheduled here almost every port. The inspectors, surveyors et al get their rest at the end of the ship’s stay in port. The crew sail out – less than safely - unrested.
· The Ship Security Officer. I have seen Master’s or Chief Engineers or Chief Officer’s handling the SSO’s job. It doesn’t work. Too many other responsibilities in port.

And so on.

The ISPS Code was, as we all know, hastily brought out in an era of ‘if you are not with us, you are against us’ kind of thinking. The mandarins in various international bodies must have been worried about being marginalised and made redundant by fast moving events; Crews and Owners undoubtedly groaned, training institutes, classification societies, managers and such undoubtedly rubbed their hands in glee at another opportunity, another revenue stream.
But that does not mean that we cannot amend the Code to make it workable now. Or is it too much to ask?

In addition to all this, the crew are often unsuitable and ill trained to conduct ISPS checks and procedures. They are multitasking to an astonishing degree.. handling, simultaneously, stores, bunkers (where a large component of the engine and deck crew and officers are automatically involved these days), ballast, cargo, crew change, fresh water, garbage, surveyors, port officials, (where all Deck Officer’s tend to be involved), Managers and the like.. all of whom want everything now and show scant regard for the seaman as a human being... so, then, to add an onerous and time consuming responsibility like the vessel’s security to the list seems ridiculous.

On one ship, a 5% check of all visitors by metal detectors at access points was mandated. On another, a photograph had to be taken and clipped to a visitor’s ‘permit’ at the gangway. It was interesting to watch this in the rain, when a couple of shipchandlers, surveyors and such arrived at the same time, and the gangway amidships.

It is akin to asking the pilot of an aircraft to handle the aircrafts security on the ground , or a stewardess to frisk 5% of the passengers at the entrance to the aircraft. Much as some of us would love that idea, it is, simply, impractical, farcical and unworkable. And yet we ask the crew to do this, albeit with smaller numbers, all the time. It is laughable to the point of hysteria.

The industry needs to decide. Whether, (a) Ship security should remain the farce it often is. In which case nothing needs to change, and the only thing that has to be managed is the increasing pressure on crews. If we want to manage that at all, of course.

Or (b) Ship Security is a serious business. In which case amend the Code, make the Ship Security Plan with extreme care and with an eye on it’s practicality. Be prepared to have to outsource elements of this to shore personnel if required, or increase manning. Budget for this. Examine the possibility of passing on these special costs to customers... a run specific ISPS levy, similar to the surcharges airlines are so fond of?

Maybe, given the fractured nature of Shipping, we are not in a position to do that. Maybe the IMO or somebody will have to mandate that the logistics of the vessel’s security should be handled by suitably trained shore personnel, and not be loaded onto already overworked crews. (That’s a huge maybe).

In any event, and in my opinion, the ship’s crew are ill manned, ill equipped, ill trained and too busy to do a halfway decent job on Security.

And so and ergo and maybe, the ISPS Code as practiced, is, ipso facto, unworkable in it’s present form.

Maybe that is a possibility, too.

first published in http://www.marexbulletin.com/

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