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Much has been discussed about Piracy since last years Safety4Sea Forum. Those who were present will remember that we have been still discussing about the pros and cons of using armed or unarmed guards. I do believe that what is often necessary has already been established. So I am not going to talk to you about pirates or why you should play PCASP on your vessel. The topic of my presentation will assist you get insight of the inner workings of a PMSC. I will go through the challenges that we have to face as a PMSC. Some are easy and are dealt by simple management systems but others are more complex with many factors, out of our immediate control.
You know first hand that ever changing regulations are difficult to deal with and even in the current bad market you have to face a storm of new regulations. What we have to face isn’t similar to the reality of a ship owner. Within the last year we have seen changes of regulations in Qatar, UAE, Egypt, Sri Lanka, Mozambique, Kenya, Tanzania, Comoros, Oman, Mauritius, Maldives, multiple times. So pretty much in all countries surrounding the high risk area. Don’t let me even start with the regulations of Flag States. Most Flag States have also changed the requirements to obtain flag authorization for deployment of PCASPs on board a vessel.
So it’s not sufficient to have a network of agents and local offices and a static set of procedures. We need to be continuously flexible and often go to great lengths to be compliant in an ever changing landscape. Especially since such changes occur while a vessel is in transit. A prime recent example of this is Mauritius, where it seems that on almost a weekly basis there is some modification to the paperwork required. At that some point they requested for documentation that had never before existed. It required intervention at Government level and the creation of brand new set of unique paper work authorized by the UK Government on every individual occasion. It is fortunate indeed that some Governments – and lobbying did help – have been proactive and assisting PMSCs to legally carry out their work instead of placing layer upon layer of new bureaucracy often without notice.
But don’t get me wrong. Those of us that strive to operate completely legally, we welcome new regulations. When ASPIDA entered the market a couple of years ago it was still a pretty much completely unregulated industry. We were looking for laws and standards to comply with but most areas of law were a very grey area and no standards existed. And this brings us to a second challenge we face.
There are no standards or better there is lack of a universally accepted standard. There are now many voluntary standards and vetting processes conducted both by external organizations and numerous in house vetting processes loosely based on IMO Guidance that many ship owners carry out however few entities accept someone else’s vetting process. This creates a huge administrative burden on the PMSC and consequently increasing the requirements for office personnel and costs. But in our business increased office costs is not the biggest challenge.
Apart from regulatory issues in individual countries, a PMSC in order to provide reliable capability across all occasions they service they have to maintain a large inventory of both firearms, communication and protective equipment and be able to provide that capability in house without exposing their customers potentially without their knowledge to the risk of utilizing an unknown un-vetted subcontractor or worse yet bringing illegally borrowed firearms to the vessel. As an example, ourselves , in order to maintain undisrupted service to our customers regardless of time and location we need to maintain an inventory of a 150 rifles, 200 sets of body armor, helmets, radios, 50 satellite phones, 50 sets of night vision goggles, 50 binoculars and many other small accessory items. Whilst clearly the acquisition of the inventory presents financial and licensing obstacle, which once overcome, doesn’t present itself often again, the real challenge here comes from the poor access to equipment once deployed. It is not possible to physically access equipment ashore in all storage locations in order to maintain service and in some cases repair or replace them. This means that qualified personnel must often be deployed to maintain the equipment when it is used during transits. Resupply of ammunition, replacement of broken items is also extremely difficult. As only certain locations allow the directly import by air of such spares. As you can understand without the ability to central maintain equipment managing such an inventory is an expensive and administratively intensive exercise.
Without substantial volume of transits throughout all the parts of the high risk area it is impossible for individual PMSC to produce a complete intelligence picture without reliance on external sources. Open source information, of which the same is available to PMSCs and ship owners alike, is frequently incomplete and the incidents that are important are not always distributed in a timely fashion, if at all. Although statistically the chances of an individual vessel and encountering an act of piracy remain low, security teams alone have provided at least three detailed incident reports with clear photos sawing proof of firearms and boarding equipment and one instance a mother ship but none of these reports made it to the publically available intelligence updates provided by local and state agencies. This underreporting by itself presents a challenge as our customers are less aware of the actual Risk. In order to be able to overcome this challenge we partner up with a leading maritime security intelligence provider. Intelligence provides our operations department and all the vessels we protect, with a far more accurate intelligence picture that could not achieve with open source information and the information from our teams alone.
Figure: High Risk area
A substantial challenge of any PMSC is the selection and the recruitment of correct personnel. While the pool of candidates should be finite, the number of CV’s received with mostly at suitable candidates seems endless. The role of the individual consultants applied as part of a team by a PMSC is not simply limited by their understanding of which end of the gun goes bang and which goes against their shoulder. From our perspective the service a PMSC is not providing is guns for hire but a team of consultants who also legally and safely carry firearms which is not a matter of complacency. Our job is to mitigate the risk, not to steer the ship into the path of it and shoot pirates or allegedly in the case of some providers fishermen in the face.
So what is this should be looking for in these individuals? First of all they should be security minded. They do not have worked as a delivery driver, pizza boy or a gymnast for the last five or more years. They should have no gaps in their fire arms competency. It’s no use if someone used an M-16 15 years ago and hasn’t touched one since then. But equally importantly they need to have the intellectual capacity to learn about ship systems, adapting to a new environment as inevitably a large majority of them will come from land based security and even those who are from army backgrounds may never have worked on a bridge or even served on a boarding ship. Even navy seals or any national equivalent are doubtless highly competent with firearm and dispatching the bodies, are unlikely to be familiar with working on the bridge of a ship. As you can see the role of the individual consultant requires more than the ability to use a weapon. There becomes a price point at which below the PMSC will have to compromise. Ultimately it is the end user that will suffer as it must not be forgotten that their reputation is tight to that of the PMSC.
I continue to be amazed by the number of companies in Greece that they claim to offer solely ex special forces personnel when we ourselves paying the best rates in the Greek market and after two years of recruiting we have selected only 45 Greek operators. It is worth noting that uniquely to Greek Nationals, it is possible to have served your one year of national service in the Special Forces. This from our perspective does not compare to the experiences of former professional military personnel that have served and trained for many years. So what do some of these ex Special Forces guys do? They set up new PMSCs.
Another challenge is competition. Still in 2012 new PMSCs pop up like mushrooms in the forest. But you know what? When you walk in the forest to pick up some mushrooms to eat you may get some white truffles but you may pick up some that maybe poisonous as well. All of these factors contribute to creating an uneven playing field where frequently contract renders simply count down to number of guys number of guns, cost. This brings us to our biggest challenge. The ship owners, charterers and other entities that contract security services are sustaining the uneven playing field and users want to hire high calibre PCSPs at the price of cowboys. During a paperwork inspection all may appear the same. However just as our consultants can rapidly put in place processes on paper, PMSCs that may lack genuine internal capability can easily do the same. Without deeper inspection of companies, this makes it difficult for you all of our customers to properly assess the quality of a PMSC. When few of you will have the time or resources available to conduct an in depth vetting, looking under the surface of the paperwork presented. We face even more challenges with some of you. We have been called to provide two man teams, one man teams, armed security to unhardened vessels or on vessels whose crews continue to work on deck in extremely high risk areas with confirmed pirate attack activity.
Owners want to take the shortest route through the high risk area on the basis of having guns on board, when a small deviation can greatly mitigate the risk. As an industry we need to change the misconception and we need to educate our customers that we are not guns for hire or commandos as this continues to promote the cowboy operators. Whenever a PMSC has to compromise you have to compromise. This simply can be arranged to the lowest price. Armed security should not be commoditized. Weapons bring with them internal risk as well as mitigating external risk. But as such they require a high standard of competent personnel and procedures from a well run PMSC. But I don’t blame you. Most of you wear most hats apart from that of the CSO and at the same time get bombarded by an endless stream of emails, phone calls, web advertising. So it is difficult and in some cases impossible to make the right choice. Missing universally accepted standards and relying on paperwork exercises.
Above article is an edited version of Panos G. Moraitis presentation during 2012 Safety4Sea Annual Forum
You may view relevant video by clicking here.