Pre-Arrival Notification Procedure

In accordance with the EU Regulation on enhancing ship and port facility security, ships intending to enter a UK port must provide answers to a number of security questions before arrival and being granted entry.

Note:  Under the EU Regulation, member states are permitted to exempt scheduled services between ports from the requirement to supply pre-arrival notifications.  Where an exemption exists, ships must be able to provide evidence of this.  TRANSEC has generally granted exemptions for scheduled international ferry services.

The information provided by the ship must be collected and considered by the Port Facility Security Officer (PFSO) at the earliest opportunity prior to the ship seeking entry into the port.  These stages of the pre-arrival notification procedure are described below:

Stage 1: Pre-Arrival Notification Form

PFSOs must collect security data from an incoming ship prior to its arrival in a UK port.  In most cases the best way to meet this responsibility will be to ensure that the ship's agent requests the information.  The agent will collate the ship's response to the security questions and provide a completed to the PFSO.  Where the agent is unable to obtain the information, the ship must be contacted directly and the Ship Security Officer (SSO) requested to supply the necessary details.  A copy of this form can be accessed by clicking on the link in the column on the right.  Completion of this form should be carried out 24 hours before the ship is due to enter the port, or as soon as possible thereafter.  Ships that have not provided such information must not be allowed to enter the port and TRANSEC advice must be sought.  The PFSO must retain completed Stage 1 forms for a period of six months from the date of issue and these may be subject to TRANSEC inspection.  A list of the dangerous Goods referred to in the form can be accessed by clicking on the link in the column on the right.

Stage 2: PFSO Procedures

The PFSO must consider the answers provided by the ship against a decision flow chart provided by TRANSEC.  This decision flow chart can be accessed by clicking on the link in the column on the right.  Following this flow chart will allow the PFSO to decide whether a ship can be allowed entry into the port in the normal way, or whether TRANSEC or the local Coastguard Watchroom must be contacted for further advice.

When a ship makes radio contact with the VTS or the individual port facility, the ship and port Security Levels should be confirmed, and checked against the preliminary information.

If the incoming ship is of Convention size (500gt or over) and its Flag State is a signatory to the Safety of Life at Sea (SOLAS) Convention, but does not have an International Ship Security Certificate (ISSC), PFSOs must contact their local Coastguard Watchroom for further advice.

Ports will be familiar with the situation whereby some ships, well above the actual tonnage requirements, declare themselves to be exempt from ISPS requirements under Tonnage 69 arrangements.  This is detrimental to the spirit and intent of the ISPS Code and a significant loophole in the international maritime security regime.  The International Maritime Organisation has recognised this and has decided to close the loophole permanently from 1 July 2008.  In the meantime affected ships are required to comply with ISPS requirements in respect of pre-arrival information and Declarations of Security.  Guidance to UK ports and ships on how these transitional measures should be implemented has been issued by TRANSEC.

Declarations of Security

A Declaration of Security (DoS) is a written agreement between a ship and a port facility that confirms the security responsibilities of each party during the ship/port interface.  A copy of the DoS form is available by clicking on the link in the column on the right.

Who carries out the DoS?
The PFSO or the Deputy PFSO must carry out the DoS on behalf of the port.  The Master or the SSO (in many cases this may be the same person) will carry out the DoS on behalf of the ship.  Either party (PFSO or SSO) may request a DoS.

What Level of Information should be recorded in the DoS?
A DoS specifies the security measures that each party will implement during the ship/port interface.  These measures are drawn from the respective sections of both parties' security plans.

However, the DoS should not include specific reference to security standards, for example fence heights and types, search percentages and frequency of patrols.  Security standards are classified by the Department of Transport (DfT) as 'RESTRICTED' material and must not be communicated to persons not connected to the operation of the port.

If a ship does ask a port facility to provide such information, TRANSEC must be informed so that the issue can be raised with the relevant Flag Administration.

When Must a PFSO Initiate a DoS?

• When a ship that does not fall within the scope of the Code, for example a ship whose Flag State is not a signatory to SOLAS requires entry to a port facility.  A list of non-SOLAS states can be accessed by clicking on the link in the column on the right.
• If a ship is not compliant with the ISPS Code, i.e. it does not have an ISSC, but the UK Government decides after a risk assessment that it can enter the port facility (albeit subject to appropriate control measures) a DoS must be requested by the PFSO.
• In all cases where a port facility or a ship entering the port facility is operating at Security Level 3.
• Following a security incident or security threat to the port facility or ships operating within it.
• When requested to do so by a TRANSEC or MCA security inspector.

Please see the DoS Requirement Matrix below, for more information about when a DoS is required.

DoS Requirement Matrix

DoS requested by PFSO
Situation	Port at Level 1	Port at Level 2	Port at Level 3
Non SOLAS ship	Required	Required	Required
Non-compliant ship if allowed entry & subject to UK Govt. control measures	Required	Required	Required
Ship at Level 1	Not Required	Not Required as the ship is required to raise its Security Level to equal the Port Security Level	Required.  The ship is required to raise its Security Level to equal Port Security Level
Ship at Level 2	Not Required	Not Required	Required.  The ship is required to raise its Security Level to equal Port Security Level
Ship at Level 3	Required	Required	Required
Following a security incident	Required	Required	Required
Following threat to port facility or ship	Required	Required	Required
When requested by TRANSEC or MCA	Required	Required	Required

PFSOs must request a DoS where the above matrix states 'Required'.

In addition, PFSOs may use their discretion and request a DoS on occasions when a mandatory DoS is not required, for example if the ship is operating at a higher Security Level than the port facility.  The PFSO may want the additional assurance of agreeing a DoS with the incoming ship.

There are occasions when a SSO will initiate a DoS.  Two examples are as follows:

• When a ship is operating at a higher security level than the port facility; and
• When a ship enters a port that does not have a PFSO/PFSP.

What action should be undertaken if a ship does not co-operate with a DoS request?

Ultimately a Harbour Authority can deny a ship access to its port facilities.  In reality a ship is unlikely to refuse a request for a DoS because a refusal to enter into one would have an impact on the next port of call (under the ISPS Code a ship must maintain records of its last 10 ports of call).  Any refusals should be notified to TRANSEC.

Does a DoS need to be reported to TRANSEC?

A DoS does not need to be reported to TRANSEC.  However, TRANSEC must be informed a DoS is carried out with a ship operating at Security Level 3.

Records of any DoS must be retained, and kept on file for 3 years.  TRANSEC may inspect records of DoS agreements in the event of a security incident and during routine compliance inspections.