Annex D - Table of directive requirments and measures already in place or under development
| Directive | UK ISPS implementation | Notes |
|---|---|---|
| Art. 2.3: Definition of Port Boundaries. | PFSI Ch. 5 Pt. 4: Schematics showing security relevant areas of port. | Scale drawings, minimum 1:12500; Designation Orders with descriptions or graphics. UN port descriptors. |
| Art. 5.1: Designation of a “Port Security Authority” responsible for security planning & implementation. | PFSI Ch. 3 Pt. 1: “Port Security Committees” to implement plans, co-ordinate and communicate. | Normally a number of facilities share a common committee. |
| Art. 6: Port Security Assessment for each port, to specified minimum standard and approved by Government. | No equivalent under ISPS, but Multi-Agency Treat & Risk Assessment methodology developed jointly with Home Office and piloted in several ports. | As result of pilot, adapted for more suitability to maritime sector. |
| Art. 7: “Port Security Plan” addressing “specificities” of different port sections, integrating all port facilities, and (crucially) integrating with all other response and preventative plans. | No direct equivalent, but larger Ports have comprehensive plans with each separate port facility having an Annex to it. PFSIs also cover some aspects of port wide application, not just ship/port interface. | Operations categorised according to Threat as COG, CRR, PAX and OBC. Also “controlled buildings”. |
| Art. 7.3: In the case of international maritime transport service, the Member States concerned shall cooperate in the security assessment (for each port) | No arrangements. | The implication is that where a UK port links to another EC State, representatives of that other State must be involved in the port security assessment process. |
| Art.8: “3 Security Level” preparedness system, with option of different measures for different parts of the port at each level. | PFSI Ch. 2,3 & 5: Gradated measures at each Security Level for each category of facility were introduced as part of ISPS implementation. | Does not yet apply to AMSA facilities or non-operational areas of ports. |
| Art. 9: approval of a “Port Security Officer” to act as prime point of contact, and ideally a PFSO already. |
PFSI Ch. 3 Pt. 3: A senior PFSO can be representative for a Company with several facilities, or a single PFSO represent a number of facilities within a port. |
In most large ports a Principal PFSO has emerged, and is the lead point of contact for several facilities. |
| Art. 10: Review of Port Security Plans and Port Security Assessments at least every 5 years. | PFSI Ch.3 Pt. 8: 6 monthly reviews of plans and procedures by PFSO, as well as after incidents or inspections. Also annual audit of plans. Currently no adequate (in terms of Directive) review of Assessments. | All PFSOs asked to complete a risk assessment update in Feb 07. |
| Art. 12: Appointment of a “Focal Point for port security” at National level. | Ship & Port Facility (Security) regulations 2004, Regulation 5(a); Secretary of State for Transport. | In practice, TRANSEC for the EC Reg. and likewise for EC Dir. |
| Art.13: system for ensuring…supervision of…plans and their implementation. | TRANSEC and MCA inspectors undertaking announced and unannounced inspections, and covert tests, on ships and in ports. Stepped approach to enforcement, Legal sanctions and offences. | Needs adaptation as no operational need for MCA resource in relation to ports. |
| Art.16: document security and personnel vetting requirements. | Application of the HM Government protective marking system for documents, baseline security measures based on HMG Manual of Protective Security, and CTC Security clearance for key staff. | Annex I to Directive calls for other port personnel with access to “high risk” areas to be considered for vetting. |
| Art.17: effective, proportionate and dissuasive penalties for infringements. | Ship and Port (Facility) Security Regulations 2004 in relation to ISPS facilities, and AMSA 1990 in relation to non-ISPS facilities that are assessed as needing regulation. | Capability gaps at present are in relation to non-Harbour operations in ports, and non-ISPS facilities. |
| Art. 18: implementation; bringing into force laws, regulations and administrative procedures by 15th June 2007. | The above represents the administrative procedures, when taken into account with AMSA Directions, however a formalising Statutory Instrument has not yet been introduced but is subject to this consultation. |
Certain measures have been drafted to reinforce the 2004 ISPS regime, as well as introduce new categories for protection such as Port Related Areas and Controlled Buildings. |
