Also refer to Article 2.9 of the Marine Shipping Safety Policy Rules (in NeRF).
Drills
Drills must be performed on-board, according to the requirements of ISPS, Part A, Paragraph 13.4 and Part B, paragraph 13.6. The SSO is the person who holds primary responsibility for its implementation.
Exercises:
'Exercises' are not the same as 'drills' and they must be held annually (each calendar year) with no more than 18 months between them, according to the requirements of ISPS Part A, paragraph 13.5 and Part B paragraph 13.7.
The organisation of these exercises is in principle the responsibility of the company (in this case the CSO). .
The purpose of these exercises is to test the security system of the company and assure effective coordination, communications, resources available and implementation of SSPs.
More than one company ship (if applicable), but not all ships of the same company have to be involved in a specific exercise.
The results of these exercises have to be shared with all other ships of the same company that sail under the Dutch flag. These results must be discussed on-board each ship, and a record of this must be logged in the ship's log. Moreover, any improvement identified during the exercises where applicable, shall be implemented
on all ships of the company sailing under the Dutch flag.
The reports on the exercises must be kept on-board all ships of the company that sail under the Dutch flag.
Relevant authorities may be involved in such exercises, but their participation is not mandatory. Authorities are certainly encouraged to perform their own exercises.
If a CSO participates in such an exercise, this counts as an annual mandatory exercise (see ISPS, Part B, paragraph 13.8). The report obligations are identical to those for the reports on exercises organised by the company itself.
If, when asked, a ship is unable to provide documentation regarding the mandatory exercises (for example during an intermediate verification) to the Inspectorate, or an RSO acting on its behalf, the ISSC may be revoked.
If a ship is unable to provide documentation regarding mandatory exercises (Exercises & Drills) during a Port State Control (PSC) inspection abroad, then this can be deemed by the PSC organisation as a security deficiency and it may result in detention. |