The Norwegian Maritime Authority (NMA) has issued a circular to provide guidance on how to conduct functional testing of the ship security alert systems onboard. According to SOLAS Regulation XI2/6, all vessels subject to Security Regulations, shall be provided with a ship security alert system.
The requirement for a ship security alert system was introduced in 2004 and has thus been in force for nearly 20 years. The Joint Rescue Coordination Centre (JRCC) has informed the NMA that they receive a large number of alerts from ship security alert systems as a result of on-board testing of the system. Moreover, the JRCC reports that SSAS tests are being performed increasingly frequently. The JRCC needs to spend a lot of time and resources on managing such alerts, even if they are not real alerts.
The NMA expects SSAS testing to be conducted on a regular basis, and that it would be sufficient to perform testing at 6-month intervals. Moreover, it is stated that the Joint Rescue Coordination Centre (JCCR) must be involved in at least one of the tests. A distinction is made between drills and exercises carried out in accordance with the ISPS Code Part A section 13 and functional testing of the ship security alert system. Functional testing is conducted to make sure that the system works and transmits an alert. Drills and exercises to be carried out pursuant to Part A section 13 of the Code are described in more detail in the binding sections 13.6 and 13.7 of part B. Both are more comprehensive than the functional testing of the ship security alert system, and it is important not to mix them. This means, among other things, that the frequencies of drills and exercises referred to in sections 13.6 and 13.7 do not apply to
testing of the functionality only.
Both the JRCC and the NMA believe it is a good thing that ship security and testing of the ship security alert systems are taken seriously by the companies. Nevertheless, it is our opinion that the purpose of functionality tests can be achieved even though the number of tests involving the JRCC is reduced.
…the NMA explains in the circular.
The purpose of functional testing of the ship security alert system is to determine how well the system works and transmits alerts. This can be done without involving the Joint Rescue Coordination Centre in every test run. During functional testing, the alert should be transmitted to the company security officer (CSO) and/or a defined point of contact in the company’s emergency response organisation. Such testing must be conducted at least every six months.
The NMA further mentions that the JRCC must only be involved in functional testing carried out in connection with interim, initial, intermediate and renewal surveys linked to the ship’s ISPS certificate, cf. the Security Regulations sections 10 and 11. This means that the Joint Rescue Coordination Centre will as a maximum be involved every 2.5 years after the issuance of a full-term certificate.
We are not introducing a requirement for the JRCC to be involved at all certificate surveys. The purpose of this circular is rather to limit the number of tests where the JRCC is involved.
…the Norwegian Maritime Authority highlights, concluding it is important that all parties involved are informed of functional testing in advance. If a sharp alert accidentally sets off during testing, it must be ensured that all parties involved are informed of this as soon as possible. Furthermore, it is important that these measures are followed in order to avoid the unnecessary use of JRCC
resources.
