ISPS Code: What It Actually Requires of a Ship, Port Call by Port Call
A port state control inspector comes aboard. Before asking for a single certificate, he looks at the gangway: who is keeping the watch, how the visitor is logged, whether the pass is checked. Within minutes he has formed a view of the ship's security, and that view will colour the rest of the visit.
The ISPS Code is twenty years old. It entered into force on 1 July 2004, in the aftermath of the attacks of 11 September 2001, and it remains one of the least well understood instruments in maritime compliance: many operators reduce it to an approved binder sitting in the master's office. Yet what gets examined during a port call is almost never the binder. It is the evidence of what the crew actually did.
What the ISPS Code is, and who falls under it
The ISPS Code, or International Ship and Port Facility Security Code, is the international code for the security of ships and port facilities. It was adopted by the International Maritime Organization and made mandatory through chapter XI-2 of the SOLAS Convention. It does not deal with safety in the sense of accident prevention, which is the business of the ISM Code, but with security: protection against deliberate acts, whether intrusion, sabotage, piracy, trafficking or terrorism.
Its scope, set out in section 3 of part A, is narrower than most people assume. The Code applies to ships engaged on international voyages, namely:
Passenger ships, including high-speed passenger craft, with no tonnage threshold.
Cargo ships of 500 gross tonnage and above, high-speed cargo craft included.
Mobile offshore drilling units.
The port facilities that serve such ships.
For yachting the consequence is unambiguous. A commercial yacht of 500 GT or more trading internationally falls within the SOLAS definition of a cargo ship and is fully subject to the Code. A strictly private yacht is not. Many large-yacht owners nevertheless adopt a voluntary security plan modelled on ISPS, if only to govern access during marina calls and to reassure the owner and his guests.
Three security levels, and what each one triggers on board
The Code works in levels, set by the flag state or by the port state, and the ship security plan must describe the measures corresponding to each of them.
Level 1: the minimum appropriate security measures, maintained at all times. Access control, gangway watch, visitor log, random searches in accordance with the plan.
Level 2: additional protective measures maintained for a defined period because of a heightened risk of an incident. More frequent rounds, systematic searches, wider restricted areas.
Level 3: exceptional measures, where a security incident is probable or imminent. The ship then acts in direct coordination with the authorities.
What catches crews out is not the level itself but the transition from one to the next. A raise ordered by the port state must be acknowledged, implemented within the time frame set in the plan, and above all recorded. A call spent at level 2 without a single line in the log is a non-conformity that shows up immediately.
The ship security plan: central document, and a confidential one
Every ship covered by the Code must carry a ship security plan, the SSP, approved by the flag administration. Section 9 of part A sets out its content: prevention of weapons and dangerous substances being brought on board, identification of restricted areas, access control, responses to a security threat, evacuation, allocation of duties, internal audits, training, the interface with the port facility, incident reporting, and procedures governing the use of the ship security alert system, the SSAS.
The plan is confidential, and that is exactly what creates a misunderstanding in port. The inspector does not get to read it in full, but he is entitled to check that the ship security officer knows it. An SSO who has to hunt for the document, or who cannot name his company security officer, makes a disastrous impression regardless of how good the plan actually is.
On the certification side, a compliant ship holds an International Ship Security Certificate, the ISSC, valid for five years and subject to an intermediate verification between the second and third anniversary dates. An interim certificate, limited to six months, covers entry into service or a change of flag.
SSO, CSO, PFSO: three roles that should not be confused
The ship security officer (SSO) is on board. He implements the plan, carries out regular inspections, trains and briefs the crew, reports incidents and proposes amendments to the plan.
The company security officer (CSO) is ashore. He drives the ship security assessment, has the plan developed and approved, organises internal audits, ensures deficiencies are corrected and liaises with port facilities.
The port facility security officer (PFSO) is the counterpart on the quay, the person with whom the ship-port interface is settled.
The most common confusion concerns the CSO. In smaller organisations the role is frequently combined with that of the designated person ashore under the ISM Code, which nothing forbids, provided the appointment is formal, the name is current and the crew knows whom to call at night and at weekends. Our ISM Checker gives a quick read on where an operator stands on those appointments.
The declaration of security, the form that gets forgotten
A declaration of security, or DoS, formalises between ship and port facility, or between two ships, who takes responsibility for which measure during the interface. It is not required for every call: section 5 of part A provides for one where the ship operates at a higher security level than the port, where a threat or an incident has occurred, where the ship calls at a non-compliant port, or during ship-to-ship activities with a vessel not subject to the Code.
That said, a ship may always ask for one. It is a useful reflex in unfamiliar ports, or wherever the local security arrangements look vague, since the DoS allocates responsibilities explicitly and stands as written evidence should an incident follow.
Drills, training and records: what the inspector opens first
This is where most non-conformities are found. Part B of the Code recommends a precise rhythm, which administrations and inspectors treat in practice as the benchmark:
A drill at least once every three months, under paragraph 13.6.
A drill within one week of a crew change affecting more than 25 % of the complement, where the newcomers have not taken part in a drill in the previous three months.
A full exercise at least once each calendar year, with no more than eighteen months between two of them, under paragraph 13.7. It may be run full scale, as a tabletop, or combined with another emergency exercise.
The deficiency codes used in port state control tell the rest of the story: the ship security plan, the security officer, access control, security drills and the alert system form the core of the visit. And the findings raised against drills are strikingly mundane, flag registries report: intervals overrun, documentation too thin to demonstrate what was done, partial crew participation, unfamiliarity with the equipment and, at worst, signed drills that never took place.
Records follow the same logic. The Code requires the ship to keep on board a trail of training, threats and incidents, breaches of security, changes in security level, communications, internal audits, reviews of the assessment and the plan, and maintenance of security equipment, for the minimum period specified by the flag administration. It is the same traceability requirement that governs certificates and hours of rest, whose real timeline we set out earlier.
The real issue is not the plan, it is the evidence
An approved plan is written once. ISPS compliance, by contrast, has to be demonstrated at every port call, and it is demonstrated with dates, names and signatures. That is precisely where operators still running security off a gangway notebook and a ring binder lose time, and sometimes hours of detention. The same mechanism applies to preventive maintenance: it is not the procedure that gets inspected, it is its execution.
The BoatOn Book acts here as a single register, alongside maintenance and crew:
Document management centralises certificates, the ISSC included, with alerts ahead of expiry and ahead of the intermediate verification. The Documents module keeps every successive version.
The digital logbook records changes in security level, signed declarations of security and incidents, time-stamped and attached to the vessel.
The drill and training schedule raises the quarterly and annual deadlines and keeps the named list of participants.
Job tracking records maintenance of security equipment, SSAS included, within the same marine CMMS as the rest of the ship.
Offline access lets a record be completed at sea and synchronised on arrival.
For operators who need to redo a ship security assessment or refresh an ageing plan, BoatOn Consulting supports ISM and ISPS work; and where the question arises across a whole fleet, we have set out elsewhere what changes at ten ships.
The ISPS Code has never asked crews to become security guards. It asks them to know who came aboard, when and why, and to be able to prove it six months later. Operators who treat security as operational data, in the same way as maintenance or hours of rest, pass their inspections without thinking about them. The others rediscover the binder the night before the call.
Illustrative photographs: Pexels, free licence. They do not show any particular vessel or port call.
