Coming soon to a yacht near you - bonanza time for Flag and Port State Control.
There will be easy pickings for them to levy fines for bringing an unseaworthy vessel into one of their ports.
Their inspection can be over and the Captain can be damned in less than two minutes. Why?
Legislation covering security training for ALL crew serving in ISPS compliant vessels has been effective since 1 January 2012. As a courtesy to allow ship owners more time to become compliant, most Port State Control (PCS) authorities have been requested to postpone enforcement until 1st July 2015, provided that a vessel is otherwise ISPS compliant. That window is about to close with a bang.
The new requirements are:
Inclusion within the ship’s induction procedure of familiarisation with the onboard security system
Certification in Proficiency in Security Awareness (PSA) for all crew members (except those holding a higher level of security certification)
Certification in Proficiency in Designated Security Duties (PDSD) for any crew member with specific security related duties.(except for those holding a recognised certificate as Shipboard Security Officer (SSO)
(i) if not already included in the ship’s SMS manual, it will need to be changed to include, or have appended to it, the appropriate procedure for security familiarisation for joining crew
(ii) security certification is required for ALL crew members serving in an ISPS compliant vessel, such certification being appropriate to their role in the onboard security system
(iii) any crew member giving instruction in security, or with a specific security duty such as gangway watch, anchor watch, harbour watch, etc., will need to have PDSD certification as a minimum
(iv) although any vessel not yet meeting these requirements is already technically non-compliant, as from 1st. June such non-compliance may be regarded Flag State Control (FSC) or PSC as a detonable non-conformity, in that the non-compliance would be a breach of safe manning, thereby impinging on the vessel’s seaworthiness.
(v) Up until 1st July 2015 Shipping Companies holding UK ISM Document of Compliance may apply for "grandfathering" to the Seafarers Training & Certification Branch of the MCA to issue PSA and PDSD certificates as follows: PSA for Security for seafarers who have at least six months sea service in any capacity in the 5 years prior to 1st January 2014; and PDSD for seafarers who have at least six months sea service which has included designated security duties in the 5 years prior to 1st January 2014. Appropriate supporting documentation is required.
Start shopping around for the best deal in appropriate certification for your role. If you are looking for a job, check the offers at various training establishments. If you are in a job, make sure that your certification will allow you to retain your position after 1st July. If you are a Captain or Manager, negotiate a lump-sum classroom or onboard training and certification for the entire crew or entire fleet. No owner or charterer will be happy to find that in mid-season the yacht he/she is on became unseaworthy overnight because somebody forgot to check the rules.
Get compliant now, and keep smiling until the real Christmas comes. Don’t let FSC or PSC give governments an early Christmas by filling their coffers with unnecessary fines.