The purpose of this event was to allow potential certification bodies to share their experience of the pilot audit programme through a lessons-learned briefing hosted by the Security Association of the Maritime Industry (SAMI), and the Private Maritime Security Companies (PMSCs).
The briefing was attended by more than 100 delegates with the majority being PMSCs providing armed security for ships in high risk areas (HRA) and other stakeholders, plus professional maritime associations that have invested time and expertise in supporting the development of the standard, such as BIMCO, ISO, maritime law firms, P&I Clubs, and representation from the European Union.
Since the introduction of armed guards on board ship, no vessel carrying an armed security team on board has been successfully pirated thus far, despite a number of attempts.
However, the rapid development of companies offering armed guard services and their initially wide ranging standards has brought concerns from shipowners, insurers and flag states alike regarding the risks they might face in the event of an incident, or mistake. With the help of SAMI and all the stake holders involved, a series of standards included Best Management Practice (BMP), rules for the use of force (RUF), training needs and weapons licensing were developed.
These standards enabled a safe and graduated series of escalating responses in terms of the use of force to be developed to minimise the risk of accidents, protect everyone involved in terms of human rights issues and ensure that the process was within the legal high seas standard where self-defence is acceptable but engagement is not.
Within the existing framework of the supply chain standard ISO 28000, the new ISO PAS 28007 provided a risk- based quality management system to give ship operators and other stakeholders the confidence that those holding this new ISO accreditation will be able to uphold the security and safety of vessels and their crews in the HRAs to a recognised and trusted standard. This standard would also be supported by BIMCO, global shipowners associations and the EU, among others.
At the pilot audit briefing, each of the certification bodies - LRQA, MSS Global and RTI -outlined lessons learned during the pilot audit, thus far. RTI also suggested areas where the BIMCO standard security contract GUARDCON, developed for shipowners and PMSCs, might be enhanced to further clarify responsibilities between the two parties reduce risk and help protect security teams during the potentially risky transfers at sea between launch and the vessel.
RTI marine director Steve Cameron explained that the use of highly experienced Master Mariner auditors ensured the PMSCs procedures and their integration with ships’ ISM and SMS systems was carefully assessed and the auditors were able to add value from their knowledge of both security and maritime risk and safety requirements.
Assessments lacking
Cameron noted there were some concerns that the risk assessments of PMSCs were not always robust enough and the ISO 28007 pilot study had given everyone a chance for reflection and for remedial action to be taken.
There was insufficient focus, or reference to ISO 28000 and the assessment of the supply chain risks from end to end, he said.
He further explained that GUARDCON did not address operational safety requirements for the vessel’s Master (for example, during embarkation/disembarkation at sea) and as a result, there was still work to be done to drive PMSC’s maritime operational improvements.
He suggested that there should be clear written obligation on the Master to do all that is necessary to ensure a safe transfer. Sections should be added to GUARDCON on operational safety issues and armed guards’ welfare, he said.
For example, there could be a situation where instructions should be given to the launch skipper not to attempt a transfer if it is considered that the lee shelter is insufficient.
In addition, the transfer ladder should be given a simple risk assessment before use. He suggested that SAMI, or IMPA, could run training courses on risks when boarding vessels, such as the wearing of lifejackets, the use of pilot ladders and launches.
In addition, there were insufficient numbers of medical staff on board and he said that STCW was not sufficient, as no trauma training is mentioned. Legislation should also be clear on Export Control Order 2008 and BIS licensing for UK nationals working for non-UK domiciled companies.
Furthermore, owners often did not understand the legal issues of weapon transfers over national borders when vessels deviate. A list of ports either with, or without, disembarking restrictions should be published.
Cameron gave another example of guards who are required to stay on watch for four hours in 40 deg C plus heat without shade on a bridge wing without access to toilets, or drinks. He suggested that guidance to Masters should be issued allowing the guards free access around the bridge area.
One of the most popular embarkation/disembarkation points is Galle, Sri Lanka. Cameron said that a combination of unlit buoys and launches used without radar had resulted in Masters using searchlights to avoid collisions. Cameron suggested that SAMI could put pressure on the port authority to make the necessary improvements, as the PMSC sector has brought significant revenue to the area.
Cameron also explained that the discussions highlighted the difference in approach from that of West African operations, where within territorial waters; national security forces armed guards must be used. Ship operators can employ an unnamed security consultant on board for a transit of the area to brief the Master and seafarers on security and the current risks.
*This article was written with the help of RTI marine director Steve Cameron.