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Forward to Compliance. Communication PFSO RSO Training. John Twiss, Lead RSO Consultant. Who am I to talk to you about ISPS Compliance? 24 years Maritime Military Service 15 years Commercial Marsec experience 11 years Nigeria/W Africa consultancy
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Forward to Compliance Communication PFSO RSO Training
John Twiss, Lead RSO Consultant • Who am I to talk to you about ISPS Compliance? • 24 years Maritime Military Service • 15 years Commercial Marsec experience • 11 years Nigeria/W Africa consultancy • 10 years ISPS experience across the full range of ISPS compliance in Nigeria/Worldwide • 2 years Local Project Coordinator for the lead RSO with PICOMSS 1 in Abuja • Unparalleled expat experience of the Nigerian Govt role in delivering ISPS compliance
The Ship/Port Interface • Whilst this conference is ostensibly about PF Security we must remember that the essence of the ISPS code is the ship/port interface or the ship/ship interface!
The Ship/Port Interface • The dynamic of the PFs you operate are very different in their operations • From Bonny terminal to Apapa to the Offshore sector • One thing you all have in common is when vessels berth at your PF they increase your security workload
COMPLIANCE? Compliance comes in many forms • Compliant Personnel inc! DA, Lead RSO/RSO and all Stakeholders inc Govt Agencies • Trained, versed in, understand their obligations to achieving and maintaining compliance - Top down process SECURITY IS EVERYONE’S RESPONSIBILITY
Compliance comes in many forms • Compliance in meeting International obligations • Compliance in meeting DA Directives • Compliant Plans PFSP/SSP - Achieved by compliant personnel • Maintaining Compliance • Effective Communication • A two way street!
COMMUNICATION?The bedrock of the ISPS Compliance Process Designated Authority Preparatory Phase Lead RSO/RSO Client NIMASA Timely Notification of Visit Identification of Potential ISPS Assets Ports/Ships Asset Categorisation (Review Existing) PFSA-SSA ISPS Compliance required? OSS Survey Amend PFSP/SSP if required PFSP/SSP Operation Implementation Programme Training
The Key to CommunicationPFSO The responsibility of developing and implementing the PFSP to ensure the security of lives and property in the port facility lays with the PFSO whose duties and responsibilities are well documented in the ISPS code and specifically in the NIMASA ISPS Code Implementation & Governance Handbook There are specific Nigerian requirements for the PFSO
The Key to CommunicationPFSO NIMASA ISPS Code Implementation & Governance Handbook 6.2. Every PFSO shall be duly trained and certified by NIMASA to be eligible to operate as a PFSO in the Nigerian maritime domain. 6.3. Upon certification as a PFSO, every PFSO automatically becomes a member of the PFSO forum, which shall hold monthly across the 4 MSZ. 6.4. PFSOs shall be required to undergo periodic refresher/re-currency courses in order to update their knowledge of global maritime developments and trends. 6.5. All the continuous trainings that shall be provided by the Agency.
The Key to CommunicationPFSO • PFSO responsibilities One of the main responsibilities of the PFSO is, and as per ISPS Code part A 17.2.2 “the development and maintenance of the PFSP” That statement literally encompasses the other 12 duties and responsibilities of the PFSO mentioned in the code
PFSO responsibilities • To enable PFSOs to discharge their duties and responsibilities they must, and as per Part A 17.3 of the code be given the necessary support to fulfil those duties imposed upon them by the code • The PFSO is the interface between the PF operator and the DA • PFSOs must be made to feel inclusive within their operating environment • As well as management and financial support, they must be given time to undertake familiarisation training for your workforce • Attend PFSO forums and meeting etc enabling them to keep up to speed with the latest intelligence, trends and BMP!
RECOGNISED SECURITY ORGANISATION(RSO) What is an RSO ? • Contracting Governments may authorize a Recognized Security Organization (RSO) to undertake certain security related activities, including: • Conducting Port Facility Security Assessments required by the Contracting Government • Approval of Ship Security Plans, or amendments thereto, on behalf of the Administration; • Verification and certification of compliance of ships with the requirements of chapter XI-2 and part A of this Code on behalf of the Administration;
What is an RSO? • An RSO may also advise or provide assistance to companies or port facilities on security matters, including SSA, SSP, PFSA and PFSP • This can include completion of an SSA or Plan or PFSA or Plan Existing Nigerian RSOs have applied for re-accreditation to continue to operate in the Federal Republic of Nigeria and within the auspice of the new DA for ISPS compliance
What is an RSO? • When authorizing an RSO, Contracting Governments should give consideration to the competency of such an organization An RSO should be able to demonstrate: • Expertise in relevant aspects of security • Appropriate knowledge of ship and port operations • Capability to assess the likely security risks at the ship/port interface and how to minimise such risks
What is an RSO? • Maintain and improve their expertise • Avoid unauthorized disclosure of, or access to, security sensitive material • Knowledge of the requirements of the ISPS code • Knowledge of current security threats relevant to the sector
What is an RSO? • Knowledge of security and surveillance equipment and systems and their operational limitations • Provide support in identifying relevant security equipment that meets the Nigerian National Baseline Security Equipment Standard
Assured Service • When delegating specific duties to an RSO, Contracting Governments, including Administrations, should ensure that the RSO has the competencies needed to undertake the task NIMASA demands that the highest professional standards be maintained by the nominated RSOs Stakeholders amongst you requiring the services of an RSO can be confident that the RSO you choose will have been assessed by NIMASA as being up to the task
NIMASA approved RSOs will also be capable of providing the following services • Development of Port Facility Procedures & Security Management System • Provide Security Training (I will elaborate) PFSO courses are the responsibility of NIMASA. PFSOs must meet the criteria laid down by NIMASA to be allowed to operate as a PFSO at a Nigerian Port Facility
TRAININGThe Key to Transition • If communication is the bedrock of the compliance process, training is the key to understanding what needs to be communicated throughout the compliance process • Training is a top down process and for many people here today - this is where the training by way of familiarisation begins • MANY LEVELS OF TRAINING REQUIRED - not all are ISPS code mandatory courses
TRAINING • Enhanced Management-Level Maritime Security • Many have attended • many will need to! • The PFSO, appropriate port facility security personnel • The CSO/SSO, appropriate shore-based personnel SHALL have knowledge and have received training, taking into account the guidance given in part B of the ISPS Code
TRAINING • Flag State/Ship Management • Under the ISPS code and born out of the Manila amendments to the STCW convention 2010 there are 2 new levels of mandatory security training for all seafarers: • PDSD (Proficiency in Designated Security Duties) • PSA (Proficiency in Security Awareness) Compliant by 01 January 2014
TRAINING Miscellaneous • Port State Security Control Officers (PSSCO) Course • Maritime Guard Force Security Officers Course • Offshore Security Officers (OSO) Course
TRAINING Non mandatory (but essential) ISPS Training for all staff involved at ship/port interface • Port Facility Security Awareness Training • Govt Agencies ISPS Awareness Training • Shipping Company ISPS Awareness training
TRAINING • RSOs, equipment/vendors, guard force companies will be required to train their personnel engaged in operations in the maritime sector as required by the DA
TRAINING! The future • Piracy is leading to more standardised training for PMSC’s • Many companies operating in the Oil & Gas sector are being forced to adopt more Internationally approved training standards for their security personnel • More and more clients are now requiring more stringent vetting of their security providers • Although ostensibly aimed at the armed commercial security sector new International standards WILL have an impact in the shipping and offshore sector in Nigeria
TRAINING! The future • Nigerian security companies operating in the maritime domain need to be aware of the new trends and adapt accordingly • NIMASA will strive to implement international standards on any security company providing services within the ISPS code umbrella in NIGERIA ISO/PAS 28007 • New standard for the assessment of PMSCs
Full Compliance is achievable • We mustn't forget though the size of the task in front of us • Double the amount of Port Facilities with their incumbent infrastructure and manpower than the task started by PICOMSS 1, 10 or so years ago! • Infrastructure and manpower that will need assessing and training respectively • The commitment to compliance demonstrated by the general stakeholders over the last 2 days is to be commended and this continued commitment will be critical as we go forward to COMPLIANCE