Declaration of Security

Maritime security regulations call for a Declaration of Security (DOS) to be used during certain times when there is a heightened security threat.

The International Ship and Port Security (ISPS) Code takes a more general approach to the DOS than the U.S. Coast Guard. Coast Guard regulations spell out which types of interfaces require a DOS at which MARSEC levels.

However, the intent of the regulations is clear in both. The two interfacing parties must get together and make a deal regarding who will take responsibility for what security measures during a particular interface. Both parties sign the contract.

Unfortunately, as the years passed since the publication of the ISPS Code and regulations, some of the intent and perceived value of such a document has been lost. It is not unusual to find that a DOS has been filled out and signed, but that the facility and the vessel personnel are unaware of its contents. It is also common to find initials down both columns, including the vessel that took responsibility for controlling access to the facility. Clearly, individuals responsible for fulfilling the obligations of the DOS should be aware of the contents.

According to U.S. regulations, a DOS can be filled out and signed by a facility or vessel security officer or their “designated representative.” This should not necessarily be a third-party tankerman or stevedore who has no control over the processes laid out in either security plan. The designated representative should be properly trained as a “vessel and facility personnel with security duties.” However, a designated representative does not have to be an alternate facility or vessel security officer who would be required to be trained to the level of an FSO or VSO under the regulations.

If used correctly, a DOS is a useful tool. It continues to raise eyebrows each time we fill one out during a training session. Make good use of a DOS. The regulations have not gone away. Neither have the threats.

 

About the author

Kevin Gilheany

Kevin Gilheany is a marine consultant and owner of Maritime Compliance International in New Orleans. He works with companies to help increase profitability through improved compliance and management systems. Gilheany is a retired U.S. Coast Guard marine inspector, certified marine surveyor and auditor, and crew endurance management expert. He has also provided contract training to the U.S. Coast Guard, was an adjunct instructor of maritime security at Tulane University’s Homeland Security Studies Program, and has contributed to marine industry publications. He can be reached at kgilheany@marcomint.com or www.maritimecomplianceinternational.com.

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