DESIGNATED OR NOT DESIGNATED? – THAT IS THE QUESTION
To designate is a fairly straightforward word and is defined in the Oxford English Dictionary as: to specify, to particularise, to appoint to office. Straightforward that is, until it is used to describe the level of security training required for seafarers. Such a simple and easily defined word appears to be causing immense confusion and misunderstanding by seafarers themselves, training establishments, management companies and indeed Administrations.
The Answer to the Question
What is a designated security duty?
- Controlling access to the ship;
- Controlling the embarkation of persons and their effects;
- Monitoring restricted areas to ensure that only authorised persons have access;
- Monitoring of deck areas and areas surrounding the ship;
- Supervising the handling of ship’s stores;
- Any other specific duty as determined by the SSO
Which crew members have designated security duties?
Anyone who performs any of the above, e.g. in port day/night watch, anchor watch.
Which crew members need PDSD?
Anyone who performs any of the above, e.g. in port day/night watch, anchor watch.
It is the global understanding (misunderstanding) of ‘who needs what’? that is required to be addressed so that there is no confusion or embarrassment when the Port State Control (PSC) official comes on board to inspect seafarers certification.
To clarify beyond dispute it is merely a question of understanding the regulatory requirements:
The STCW Code 2011 Edition, Section A-VI/6 lays down Mandatory minimum requirements for security-related training and instruction for all seafarers engaged on board a ship which is required to comply with the provisions of the ISPS Code; this includes commercially operated yachts >500gt.
Section A-VI/6 is sub-divided into three sections covering (i) [paragraph 1] competence for security-related familiarisation training, (ii) [paragraph 4] competence for security-awareness training and (iii) [paragraph 6] competence for seafarers with designated security duties.
In essence, every seafarer requires being able to evidence competence in STCW Section A-VI/6, paragraphs (1) and (4) that is, for security-related familiarisation training and for security-awareness training; while those seafarers with designated security duties, in addition to the familiarisation training also require to achieve competence to the standard laid down in paragraph (6). This applies to every seafarer who is designated to perform security duties as stated in the Ship Security Plan and also includes anti-piracy and anti-armed robbery related activities.
If a person, in this case, a crew member, is ‘designated’ to perform a task, such as a security duty, then he/she is ‘appointed’ to that specific task. It therefore follows that such crew member has by definition ‘designated security duties.’
Section 12 of the ISPS Code (the Code) at 12.1 states “A ship security officer shall be designated on each ship” Since the implementation of the Code, there has been no confusion or dispute as to the meaning of ‘designated’ in regard to the Ship Security Officer (SSO). This individual has been ‘appointed to office’ by the Company.
Section 12 of the Code then goes on to list duties and responsibilities of the SSO. In line with the Code, the SSO, under the ultimate sanction of the Master, has responsibility for designating security duties to other crew members, viz: Section 7.2.1 of the Code “Ensuring the performance of all ship security duties”
Section 2 of the ISPS Code clearly defines Ship security officer as “the person on board the ship, accountable to the master, designated by the Company as responsible for the security of the ship ….” but as the Code was in existence prior to the STCW 2010 amendments, there is no listed definition for Seafarer with designated security duties. Rather the body of the Code refers to “specific security duties”
By first looking at the various security duties that are required under Section 7 of the ISPS Code – Ship security, it is clear that the SSO could not possibly carry out all of these duties, all of the time and therefore he/she will have to delegate to other crew members, such that these crew members are assigned designated security duties.
In the case of a commercial yacht, the items listed under Section 7.2 of the Code are ALWAYS delegated to other crew members on a rotational basis:-
7.2.2 Controlling access to the ship;
7.2.3 Controlling the embarkation of persons and their effects;
7.2.4 Monitoring restricted areas to ensure that only authorised persons have access;
7.2.5 Monitoring of deck areas and areas surrounding the ship;
7.2.6 Supervising the handling of (cargo) and ship’s stores
So, by default and definition, EVERY crew member on a commercial yacht has designated security duties.
Section 9 of the Code – Ship security plan (SSP) at 9.4.7 addresses “duties of shipboard personnel assigned security responsibilities and of other shipboard personnel on security aspects” In the SSP’s formulated by the author, these duties are contained in the Security Watch Orders annex of the SSP which are compiled by the master and SSO to instruct and guide those personnel who have security responsibilities, i.e. all crew members. It is also commonplace for all crew members to be assigned search duties in the event of a security search in both drill and real incident scenarios.
Section 13 of the Code – Training, drills and exercises on ship security at 13.3 “Shipboard personnel having specific security duties and responsibilities shall understand their responsibilities for ship security as described in the ship security plan and shall have sufficient knowledge and ability to perform their assigned duties”
Prior to the implementation of the requirements of STCW 2010 amendments, Section A-V1/6 and the associated Tables of Competence, the guidance given in ISPS Code Part B 13.3 and 13.4 was used as a framework to ensure sufficient knowledge, ability and familiarity with assigned security duties. However there was no requirement to formally evidence this training and it was left entirely to the Company and SSO to decide the level of competence as required under ISPS Code Section 13.3 and 13.4. This is no longer the case and the SSP should detail the training requirements for all crew members as per STCW 2010 amendments.
By comparison it can be seen that the STCW Tables of competence for Section A-VI/6 competence for security-awareness training Table A-VI/6-1 and competence for seafarers with designated security duties Table A-VI/6.2 are very closely related to the aforementioned ISPS Code Part B 13.3 and 13.4 with some expansion on the latter. The significant difference being that the seafarer is now required to provide evidence of having achieved the required standard of competence and that the instruction and/or training programme must be approved.
The vast majority of commercial yachts are manned on a ‘heads on beds’ basis with little or no slack in the system to accommodate any additional workload imposed by enforcement of enhanced security measures. Again, with reference to the ISPS Code Part B 4.28, Administrations have an obligation under the Code “to ensure that the yacht is adequately manned to take account of any additional workload which may result from the implementation of the ship’s security plan and ensure that the ship is sufficiently and effectively manned. In doing so the Administration should verify that ships are able to implement the hours of rest and other measures to address fatigue which have been promulgated by national law, in the context of all shipboard duties assigned to the various shipboard personnel.”
It would therefore be impractical and unreasonable to expect any less than the full complement of a commercial yacht’s crew to be trained to the level of Proficiency in Designated Security Duties (PDSD).
Whilst not against the regulations to employ a seafarer holding only Proficiency in Security Awareness (PSA), the captain / SSO would have to ensure that sufficient additional crew holding the higher PDSD were available to carry out all designated (specific) security duties as listed in Section 7.2 of the Code above.
In writing this article, it is hoped that the situation regarding ‘who needs what?’ is now clear and that the references used will leave the reader in no doubt as to the crew certification requirements in relation to security-related duties on commercial yachts.
The author is a Master Mariner currently serving as Master on a passenger / Ro-Ro vessel with experience on High Speed Craft. Since 2004 has also been employed as safety and training consultant and ISM Co-ordinator for Pelagos Yachts Ltd in the Isle of Man and undertakes the role of Deputy Company Security Officer. Having written several ship security plans, he is a career marine professional and holder of a Diploma in Superyacht Operations.
Any crew member or operator seeking further clarification or wishing to partake in the PDSD approved course should contact Pelagos Yachts Ltd via their website. The course can be done on board and so minimise costs for Owners and crew.
Captain Allan Albiston AFNI