Ship security and the ISPS Code

In short

The International Ship and Port Facility Security (ISPS) Code is the mandatory security regime adopted after the 11 September 2001 attacks, brought in through SOLAS Chapter XI-2 and in force from 1 July 2004. It makes security a managed, audited function on board: every ship carries an approved Ship Security Plan, a designated Ship Security Officer, a company-level Company Security Officer, an International Ship Security Certificate and a Ship Security Alert System. Deck cadets and officers are examined on it in Maritime Law/Security papers of the Indian Maritime University B.Sc Nautical Science course, in the DG of Maritime Administration (formerly DG Shipping) competency orals for Second Mate and Mate, and in STCW security training courses. Shipping companies (SCI, Great Eastern, Synergy, Anglo-Eastern, Fleet, V.Ships, Executive Ship Management) ask ISPS questions in cadet and officer interviews because a security lapse means detention by port State control. In India it is administered by the DG of Maritime Administration under the Merchant Shipping Act, 2025, with ports and terminals covered as port facilities.

Explained

Origin, legal framework and scope

• Trigger: the attacks of 11 September 2001 and the bombing of the tanker *Limburg* (2002) showed that shipping was a target and a possible weapon; IMO's Diplomatic Conference of December 2002 adopted the measures.
• Instruments: SOLAS Chapter XI-1 (special measures to enhance maritime safety - CSR, ship identification number, IMO number marking) and the new SOLAS Chapter XI-2 (special measures to enhance maritime security), which makes the ISPS Code mandatory. In force 1 July 2004.
• Code structure: Part A is mandatory requirements (19 sections plus appendices with the ISSC forms); Part B is recommendatory guidance on how to meet Part A. Many flag States, India included, make specified parts of Part B mandatory through national instruction - so quote Part B as guidance unless the flag has made it binding.
• Applies to ships on international voyages: all passenger ships including high-speed craft; cargo ships of 500 GT and above including high-speed craft; mobile offshore drilling units; and the port facilities serving them.
• Does not apply to warships, naval auxiliaries, other State-owned ships on non-commercial service, and (under SOLAS) fishing vessels; purely domestic/coastal trade is outside the Code, though India applies comparable security measures to major ports and coastal vessels through separate national orders.
• Objectives: detect security threats and take preventive measures; define roles and responsibilities of Governments, administrations, shipping companies and port facilities; ensure collection and exchange of security information; provide a methodology for security assessments; and ensure confidence that adequate and proportionate security measures are in place.
• Key assumption: the Code is threat-based and procedural, not prescriptive hardware - it does not tell a master what fence to build; it requires an assessed plan and the discipline to run it.

Security levels and the Declaration of Security

• Security Level 1 (normal): minimum appropriate protective measures maintained at all times.
• Security Level 2 (heightened): additional protective measures for a period of time because of a heightened risk of a security incident.
• Security Level 3 (exceptional): further specific measures for a limited period when a security incident is probable or imminent, even though the specific target may not be identified.
• Levels are set by the Contracting Government (in India, the DG of Maritime Administration / designated authority) for ships flying its flag and for port facilities in its territory - not by the master or the company. A port State can require a visiting ship to raise to the port's level.
• The ship must always operate at the higher of its own level and the port facility's level. If the ship's level is higher than the port's, the ship informs the port facility and the two agree measures.
• Changes must be acknowledged by the ship, recorded, and the corresponding SSP measures implemented without delay; Level 3 instructions may be specific and must be followed.
• Declaration of Security (DoS): a written agreement between a ship and a port facility (or ship-to-ship) stating the security measures each will take, the responsibilities of each and the period of validity. Required when the port facility or the Contracting Government requires it - typically at Level 2 and 3, for a ship of a higher level than the port, or where a ship/port facility has no approved plan. Retained for the minimum period set by the Administration (commonly the last 10 port calls; check flag instruction).
• Ship-to-ship activity (STS transfer, bunkering, crew transfer at sea) needs its own measures and, where required, a DoS.

Company and shipboard organisation

• Company Security Officer (CSO): appointed ashore by the company; may cover more than one ship if the ships are identified. Duties - arrange the Ship Security Assessment, ensure the SSP is prepared, submitted, approved, implemented and maintained; arrange internal audits and reviews; ensure training of the SSO and crew; ensure adequate security equipment; liaise with PFSOs and the Administration; advise the level of threat.
• Ship Security Officer (SSO): designated on board, accountable to the master, responsible for implementing and maintaining the SSP - regular security inspections, proposing modifications, reporting deficiencies, enhancing security awareness and vigilance, training/drills/exercises, reporting incidents, co-ordinating with the CSO and PFSO, and ensuring security equipment is operated, tested, calibrated and maintained. Holds an STCW security training certificate for designated security duties plus the SSO course.
• Port Facility Security Officer (PFSO): the counterpart ashore for the port facility, responsible for the Port Facility Security Plan and liaison with ships, SSOs and CSOs.
• All seafarers with designated security duties need STCW Regulation VI/6 training; all other personnel need security-awareness training. Since 1 January 2014 every seafarer must hold at least the security-awareness certificate.
• The master's overriding authority is preserved (SOLAS XI-2 Reg. 8): the master may take or require any decision necessary to maintain the safety and security of the ship; if there is a conflict between safety and security requirements, safety prevails. Neither the company, the charterer nor any other person may constrain this.
• Reporting line: SSO → master → CSO → Administration / Designated Authority; the CSO and master must not be hindered from performing their duties.

Ship Security Assessment and Ship Security Plan

• Ship Security Assessment (SSA) is the risk analysis that must precede the plan. Steps:
  1. Identify existing security measures, procedures and operations on board.
  2. Identify key shipboard operations important to protect - bridge, machinery spaces, steering gear, cargo and cargo spaces, stores, crew accommodation, access points.
  3. Identify possible threats to those operations and their likelihood - damage/destruction of ship or port facility by explosives or arson, hijacking or seizure of the ship or persons on board, tampering with cargo, essential equipment/systems or stores, unauthorised access or use including stowaways, smuggling weapons or equipment, use of the ship to carry those intending to cause an incident or their equipment, use of the ship itself as a weapon, attack from seaward while at berth or at anchor, attack while at sea.
  4. Identify weaknesses including human factors, infrastructure, policies and procedures.
  5. Prioritise countermeasures and record the assessment; it must be documented, reviewed, accepted and retained by the company, and protected from unauthorised access.
• Ship Security Plan (SSP): ship-specific, written in the working language of the crew (with translation where required), approved by the Administration or a Recognised Security Organisation (RSO) acting on its behalf. It must address at least: measures to prevent weapons and dangerous substances coming aboard; identification of restricted areas and measures to prevent unauthorised access; measures to prevent unauthorised access to the ship; procedures for responding to security threats or breaches, including maintaining critical operations; responding to Level 3 instructions from Governments; evacuation on a security threat; duties of personnel with security responsibilities; auditing security activities; training, drills and exercises; interfacing with port facility security activities; periodic review and updating; reporting security incidents; identification of the SSO and CSO with 24-hour contact details; ensuring inspection, testing, calibration and maintenance of security equipment; frequency of testing; location of SSAS activation points; and procedures/instructions for use of the SSAS including testing, activation, deactivation, resetting and limiting false alerts.
• Confidentiality: the SSP is protected from unauthorised access or disclosure. Port State control officers may not inspect the plan except the limited sections listed in Part A (those covering restricted areas, access control, security duties, drills, port interface, review, incident reporting, SSO/CSO identification) and then only with the flag State's consent; the master may refuse general inspection.
• Amendments to sections specified in Part A/9.5 require Administration approval; the SSP may be kept in electronic form if protected from deletion, destruction or amendment.

Certification, records and onboard documentation

• International Ship Security Certificate (ISSC): issued after an initial verification that the ship's security system and equipment comply with the approved SSP. Valid not more than 5 years.
  • Intermediate verification between the second and third anniversary dates.
  • Additional verifications as determined by the Administration (e.g. after a major change or after an incident).
  • Renewal verification before expiry; endorsement rules and short-extension provisions mirror the SOLAS certificate regime.
  • Interim ISSC (validity not more than 6 months, not consecutively extendable in normal circumstances) for a new ship on delivery, on transfer of flag, on a company taking over operation of a ship new to that company, or on change from a non-Contracting Government flag.
• Continuous Synopsis Record (CSR): required by SOLAS XI-1/5 - a continuous history of the ship's name, flag, port of registry, registered owner, registered bareboat charterer, ISM Company, classification society, issuer of the DOC/SMC/ISSC, and date of deletion from register. Issued by the Administration in English, French or Spanish; must be kept on board, available for inspection, amended/updated with each change, and must never be altered on board - continuity is the point.
• Other security documentation on board: approved SSP; SSA records; ISSC; records of training, drills and exercises; records of security threats and incidents; changes in security level; internal audits and reviews; periodic SSP review; maintenance, calibration and testing of security equipment including the SSAS; and the last 10 port calls with DoS copies, ship-to-ship activities and security level at each. Records kept for the period set by the Administration (commonly minimum 2 years for drills/records; verify the flag circular), in the ship's working language, protected from unauthorised disclosure.
• Ship identification: the IMO number permanently marked (XI-1/3) on a visible external place and internally; AIS carriage under SOLAS V/19; LRIT (long-range identification and tracking) under SOLAS V/19-1 for ships on international voyages.

Ship Security Alert System, access control and restricted areas

• Ship Security Alert System (SSAS) - SOLAS XI-2 Reg. 6. Requirements:
  • It transmits a covert, ship-to-shore security alert identifying the ship and its position and indicating that security is under threat or has been compromised.
  • The alert goes not to other ships and not as a general alarm - it raises no alarm on board, and is sent to a competent authority designated by the flag State (which may be the company/CSO under flag arrangements), who then informs the coastal State.
  • Activation points: at least two - one on the navigation bridge and at least one other location, protected against inadvertent operation.
  • The alert continues until deactivated or reset. It must meet IMO performance standards and may use the GMDSS radio installation.
  • Carriage dates were phased from the first radio survey after 1 July 2004 (passenger ships including high-speed craft, and oil/chemical/gas tankers, bulk carriers and cargo high-speed craft ≥500 GT) and after 1 July 2006 for other cargo ships ≥500 GT and MODUs - so all ships in scope now carry it.
  • False alerts must be avoided and cancelled immediately through the designated authority; unexplained alerts bring a security response.
• Access control (measures scale with security level): single controlled access point with a gangway watch; identity checks of all persons seeking to board and recording of name, ID, purpose, time in/out; visitor escorting; search of persons, baggage, stores, vehicles and cargo at stated percentages; lighting of decks and overside; deck and overside patrols; securing unused access points; unused ladders/side ports secured; deterring waterborne approach; preparing for a full/partial search of the ship.
• Restricted areas typically include the navigation bridge, machinery spaces of category A and other control stations, spaces containing security and surveillance equipment and their controls and lighting controls, ventilation and air-conditioning systems, spaces with access to potable water tanks, pumps or manifolds, spaces containing dangerous goods or harmful substances, cargo pump rooms, cargo spaces and ballast spaces, crew accommodation, and any other space to which access must be restricted.
• Security equipment typically carried: CCTV, additional lighting, searchlights, intruder alarms, alarmed access doors, metal detectors, mirrors, locks and seals, two-way radios, public address, AIS, SSAS. It must be tested, calibrated and maintained to the SSP schedule.
• Drills and exercises: a security drill at least once every 3 months, and additionally within 1 week whenever more than 25% of the crew has changed and has not previously participated in a drill on that ship within the last 3 months. Exercises (full-scale or tabletop, with the company, port facilities, authorities, other ships) at least once each calendar year with not more than 18 months between them. Scenarios should cover damage/destruction, unauthorised access, restricted-area breach, smuggling, bomb threat, stowaways, cargo tampering and ship misuse.

Control, compliance, piracy and Indian practice

• Control and compliance measures (SOLAS XI-2 Reg. 9): a ship in port is subject to control to verify a valid ISSC. Where there are clear grounds to believe non-compliance, a duly authorised officer may require inspection, delay, detention, restriction of operations including movement within the port, or expulsion from port. All measures must be proportionate, and the master and company informed of the grounds.
• Pre-arrival information: ships may be required to provide, before entry, the ISSC details, current security level, security level at the last 10 port facilities, special or additional measures taken, ship-to-ship activities and their security procedures, DoS records, and crew/passenger/cargo information. Usually 24 hours notice (or before leaving the previous port if the passage is shorter) - the exact notice period and format are set by the port State.
• Ports or facilities without an approved PFSP mean the ship must put its own compensating measures in place and record them; the SSP must cover such calls.
• Piracy and armed robbery are addressed not by the ISPS Code itself but by IMO guidance (MSC circulars) and the industry Best Management Practices (BMP5, 2018): register with MSCHOA/UKMTO, follow the voluntary reporting scheme, harden the ship (razor wire, water spray, locked access, citadel), maintain a vigilant lookout and radar watch, increase speed and manoeuvre, muster and report. High-risk area boundaries and threat advisories change - verify current advisories (UKMTO, IMB, Indian Navy NAVAREA VIII warnings) rather than quoting a fixed box. The Indian Navy and Coast Guard conduct anti-piracy escort in the Gulf of Aden and the Arabian Sea.
• Privately contracted armed security personnel (PCASP): allowed only subject to flag State, coastal and port State law; India restricts carriage and transfer of arms in Indian waters, and DG of Maritime Administration circulars govern Indian-flag use - treat the detail as changeable and verify the current circular.
• Stowaways: prevented by access control and pre-departure searches; handled under the FAL Convention and IMO guidelines, reported to flag, port and the P&I club; a stowaway found at sea is a security incident and a humanitarian obligation.
• India: security is administered by the DG of Maritime Administration (the renamed DG Shipping) under the Merchant Shipping Act, 2025, which replaced the 1958 Act from 15 March 2026; RSOs (classification societies - IRS, DNV, LR, ABS, BV, NK) do SSP approval and ISSC verification on the Administration's behalf. Major ports under the Major Port Authorities Act, 2021 and non-major ports under the maritime boards, with the Ministry of Ports, Shipping and Waterways, operate PFSPs; the Indian Coast Guard co-ordinates coastal security and the Directorate General of Lighthouses and Lightships runs the national coastal AIS chain, while the coastal surveillance radar network is operated by the Indian Coast Guard. Seafarer security training is delivered at DG-approved institutes (IMU campuses, MASSA, Samundra, TMI, LBS College) and recorded on the CDC/INDoS record.
• Advantages of the regime: a common language of security levels for ships and ports worldwide; auditable plans rather than ad hoc vigilance; clear accountability (CSO, SSO, PFSO); a covert alerting path; and reduced detention and insurance risk.
• Limitations: compliance can become paperwork-driven; the Code was written for terrorism, not piracy on the high seas; small vessels, fishing craft and domestic trade fall outside it; costs of guards, searches and equipment fall on the operator; and confidentiality of plans limits independent verification.

Key points

• ISPS Code - mandatory security code given force by SOLAS Chapter XI-2, in force 1 July 2004; Part A mandatory, Part B guidance.
• Applicability - passenger ships, cargo ships ≥500 GT and MODUs on international voyages, and the port facilities serving them; not warships or State non-commercial ships.
• Security Level 1/2/3 - normal / heightened / exceptional; set by the Contracting Government, never by the master; the ship complies with the higher of ship and port level.
• Declaration of Security - written ship-port (or ship-ship) agreement on who does what, for how long; typically at Level 2 and 3 or where a plan is absent.
• CSO - shore appointee who gets the SSA done, the SSP approved and the crew trained, and who liaises with the Administration and PFSOs.
• SSO - onboard officer accountable to the master for implementing the SSP, inspections, drills, records and equipment.
• PFSO - the port facility counterpart responsible for the Port Facility Security Plan.
• Ship Security Assessment - documented risk analysis (measures, key operations, threats, weaknesses, countermeasures) that must precede the SSP.
• Ship Security Plan - ship-specific, in the crew's working language, approved by the Administration or an RSO, confidential and only partly inspectable.
• ISSC - certificate valid up to 5 years with an intermediate verification between the 2nd and 3rd anniversaries; interim ISSC valid up to 6 months.
• Continuous Synopsis Record - SOLAS XI-1/5 onboard history of flag, owner, ISM company, class and certificate issuers; never altered on board.
• SSAS - covert alert to a shore authority with ship identity and position; no alarm on board, not sent to other ships; at least two activation points, one on the bridge.
• Master's overriding authority - SOLAS XI-2/8; where safety and security conflict, safety prevails.
• Restricted areas - bridge, machinery spaces, control stations, cargo spaces and pump rooms, security equipment spaces, accommodation, among others.
• Drills and exercises - drill at least every 3 months (and within 1 week if over 25% of the crew is new), exercise at least once a year with not more than 18 months between.
• Records - last 10 port calls, security levels, DoS copies, drills, incidents, audits, equipment maintenance, kept for the period the Administration sets.
• Control measures - inspection, delay, detention, restriction of movement or expulsion from port on clear grounds, and they must be proportionate.
• Piracy - outside the Code's core; handled by BMP5 hardening, UKMTO/MSCHOA reporting and naval escort; India uses the Merchant Shipping Act, 2025 and the DG of Maritime Administration.

Formulas and examples

This topic is procedural; the only numerical content is certificate windows, percentages of crew and search quotas.

Examples

• Which security level governs. An Indian-flag bulk carrier at Level 1 arrives at a port facility that has gone to Level 2 after a local threat. *Steps:* the ship must operate at the higher level, so Level 2; the SSO implements the Level 2 measures in the SSP (second gangway watch, 100% ID check, increased search percentage, deck patrols, lighting, locked unused accesses); the master and PFSO complete a Declaration of Security; the change of level and the measures taken are logged and the CSO informed. The ship does not raise the SSAS - there is no specific threat to this ship.
• Drill trigger arithmetic. A ship has a crew of 22. At a crew change, 7 join who have not taken part in a security drill on that ship in the last three months. 7 ÷ 22 = 31.8% > 25%, so a security drill is required within one week of the change, in addition to the quarterly drill. If only 5 had joined, 5 ÷ 22 = 22.7% < 25% - no extra drill, the next quarterly drill suffices.
• ISSC validity dates. An initial verification is completed and the ISSC is issued on 10 March 2026, expiring 9 March 2031 (5 years). The anniversary date is 10 March. The intermediate verification must fall between 10 March 2028 and 10 March 2029 (between the 2nd and 3rd anniversary dates). Renewal verification must be completed before 9 March 2031. If the ship changes to another company's operation on 1 August 2029, an interim ISSC (up to 6 months) may be issued while the new SSP is approved.
• Search quota. The SSP requires 100% ID verification and 25% baggage search at Level 1, rising to 50% at Level 2. A shore gang of 34 persons boards at Level 2: baggage searches required = 0.50 × 34 = 17 persons. All 34 identities are checked and recorded; the count, names and times are entered in the security log and the stevedore supervisor is told the search is a condition of access.
• Clear grounds and control measures. A port State control officer boards and finds the ISSC expired, no record of the last 10 port calls, and the gangway unattended with no log of visitors. *Steps:* these are clear grounds of non-compliance under SOLAS XI-2/9; the officer may require rectification, inspect the limited SSP sections with flag consent, delay or detain the ship, restrict its movement in port or order it out of port. The master records the grounds given, informs the company and flag, and the CSO arranges an additional verification by the RSO.

Where it is used

• Shipboard deck ranks: the Third/Second Mate commonly holds the SSO function on Indian-manned ships; gangway watch, visitor logs, restricted-area checks and security rounds are daily deck duties in port.
• Ship management offices: CSO and deputy CSO roles at SCI, Great Eastern Shipping, Synergy Marine, Anglo-Eastern, Fleet Management, V.Ships and Executive Ship Management - SSP drafting, security audits, SSAS test logs, security-level advisories.
• Ports and terminals: PFSO and port security teams at JNPA, Deendayal (Kandla), Paradip, Chennai, Visakhapatnam, Cochin, Mundra and Hazira run Port Facility Security Plans, access control and container scanning.
• Regulators, class and audit: DG of Maritime Administration security section and Mercantile Marine Departments do port State control and flag inspection; the Indian Register of Shipping and other RSOs approve plans and issue the ISSC.
• Offshore and naval support: MODUs, offshore supply vessels and ONGC field support craft work to ISPS and additional offshore security instructions; Indian Coast Guard and Navy handle coastal security and anti-piracy escort.
• Training and vetting: DG-approved institutes deliver security-awareness, designated-security-duties and SSO courses; tanker vetting (SIRE 2.0, CDI) and charterer audits examine security records, which is why security logs are commercially significant.

Interview questions

• Q: What legal instrument makes the ISPS Code mandatory, and from when? A: SOLAS Chapter XI-2, adopted in December 2002 and in force from 1 July 2004; Part A of the Code is mandatory and Part B is guidance.
• Q: Who sets the security level, and what does a ship do if the port is at a higher level? A: The Contracting Government sets it - never the master. The ship must operate at the higher of the two levels and apply the corresponding SSP measures.
• Q: What is a Declaration of Security and when is it needed? A: A written ship-port or ship-ship agreement on the security measures and responsibilities of each party and its period of validity, required at heightened levels, where levels differ or where a party has no approved plan.
• Q: What happens on board when the SSAS is activated? A: Nothing visible - the alert is covert, raises no alarm on board and is not sent to other ships; it goes to the shore authority designated by the flag State with the ship's identity and position.
• Q: How long is the ISSC valid and what verifications does it need? A: Up to five years, with an intermediate verification between the second and third anniversary dates, plus any additional verification the Administration requires; an interim certificate is valid up to six months.
• Q: Can a port State control officer read your Ship Security Plan? A: Only the limited sections listed in Part A, and only with the flag State's consent on clear grounds; the master may refuse general inspection because the plan is confidential.
• Q: How often are security drills and exercises held? A: A drill at least every three months, and within one week if more than 25% of the crew has changed and has not drilled on that ship in the last three months; an exercise at least once a calendar year with not more than 18 months between exercises.
• Q: What is the difference between the ISM and ISPS Codes? A: ISM (SOLAS Chapter IX) manages safety and pollution prevention through the SMS, DOC, SMC and a DPA; ISPS (SOLAS Chapter XI-2) manages security against deliberate unlawful acts through the SSP, ISSC, CSO and SSO.
• Q: What is the Continuous Synopsis Record and why can it not be amended on board? A: A SOLAS XI-1/5 document giving the ship's continuous history of flag, owner, ISM company, class and certificate issuers; only the Administration issues or amends it, because its value is an unbroken, unalterable trail.
• Q: As SSO, what would you do if a port facility had no approved security plan? A: Apply the compensating measures in our SSP, agree and sign a Declaration of Security if required, record the arrangement, and inform the master and CSO.
• Q: Does the ISPS Code cover piracy? A: Not directly - it targets security of the ship-port interface; piracy at sea is handled through IMO guidance, BMP5 hardening and reporting to UKMTO/MSCHOA, with naval escort in high-risk areas.
• Q: If a security measure conflicts with a safety requirement, which wins? A: Safety - under SOLAS XI-2 Regulation 8 the master's overriding authority stands and safety takes precedence; the master records the decision and informs the company and the port facility.
• Q: Name five restricted areas on a bulk carrier. A: Navigation bridge, category A machinery spaces and control stations, cargo pump room or cargo control room, spaces holding security and surveillance equipment and lighting controls, and crew accommodation.

Common mistakes

• Saying the master or the company sets the security level - it is set by the Contracting Government; the ship only complies with the higher level in force.
• Treating the SSAS as a general alarm or a distress alert - it is covert, goes ashore only, and is distinct from GMDSS distress and from the general emergency alarm.
• Confusing ISM with ISPS documents: SMS/DOC/SMC/DPA belong to ISM; SSP/ISSC/CSO/SSO/PFSO belong to ISPS.
• Quoting the ISSC as valid "5 years with annual surveys" - there is one intermediate verification between the second and third anniversaries, not annual endorsements.
• Forgetting the 25%-crew-change drill within one week, or confusing the quarterly drill with the annual exercise.
• Claiming a port State officer may read the whole Ship Security Plan, or conversely that the plan can never be inspected - only the specified sections, with flag consent.
• Applying the Code to fishing vessels, warships or purely domestic voyages, and assuming cargo ships below 500 GT are covered.
• Quoting a fixed piracy high-risk area or a PCASP rule as settled - boundaries and national rules change and must be checked against the current advisory or DG circular.

Related topics

SOLAS and the ISM Code · MARPOL and marine pollution · Maritime law and commercial shipping: charter parties and bills of lading · STCW and watchkeeping · Flag State, port State control and classification societies · Emergency procedures, search and rescue and distress communications.