MMC 125 22 11 2022
MMC 125 22 11 2022
(DCCM)
V.04
1. The purpose of this Merchant Marine Circular is to provide information and guidance to
the owners, operators and master of Panamanian flagged ships concerning the
Administration’s requirements for compliance with the International Ship & Port Facility
Security Code (ISPS Code).
2. According to the ISPS Code, Part A 9, each ship shall carry on board a Ship Security
Plan approved (SSP) by the Administration. Additionally, this Administration has
delegated the review and approval of the ship security plan, or of amendments to a
previously approved plan, to the recognized security organizations, for all those who for
some reason want a different option than direct approval by the Administration.
3. This Administration states all Ship Security Plans (SSP) have to make provision for the
three, internationally adopted, Security Levels:
3.1. Security Level 1, normal; the level at which ships and port facilities will
normally operate;
3.2. Security Level 2, heightened; the level applying for as long as there is a
heightened risk of a security incident;
3.3. Security Level 3, exceptional; the level applying for the period of time
when there is a probable or imminent risk of a security incident.
4.1. The Plan must address, at least, the following (Part A 9.4 ISPS Code);
measures designed to prevent weapons, dangerous substances and
devices intended for use against people, ships or ports, and the carriage of
which is not authorized on board the ship;
4.2. Identification of the restricted areas and measures for the prevention of
unauthorized access;
4.3. Measures for the prevention of unauthorized access to the ship;
4.4. Procedures for responding to security threats or breaches of security,
including provisions for maintaining critical operations of the ship or
ship/port interface;
4.5. Procedures for responding to any security instructions Contracting
Governments may give at Security Level 3;
4.6. Procedures for evacuation in case of security threats or breaches of
security;
4.7. Duties of shipboard personnel assigned security responsibilities and of
other shipboard personnel on security aspects;
4.8. Procedures for auditing the security activities;
4.9. Procedures for training, drills and exercises associated with the Plan;
4.10. Procedures for interfacing with port facility security activities;
4.11. Procedures for the periodic review and updating of the Plan;
4.12. Procedures for reporting security incidents;
4.13. Identification of the Ship Security Officer (SSO);
4.14. Identification of the CSO including 24-hour contact details;
4.15. Procedures to ensure the inspection, testing, calibration, and maintenance
of security equipment provided on board, if any;
4.16. Frequency of testing or calibration of security equipment provided on board,
if any;
4.17. Identification of the locations where the ship security alert system activation
points are provided (this information should be kept elsewhere on board in
a document know to the master, the SSO and other shipboard personnel as
decided by the Company);
4.18. Procedures, instructions and guidance on the use of the ship security alert
system, including testing, activation, deactivation, resetting, and procedures
to limit false alerts.
5. According to Part B 9.2 of the ISPS Code, the Ship Security Plan (SSP) must:
6. In addition, the SSP should establish the following, which relate to all Security
Levels (Part B 9.7 ISPS Code);
6.1. Duties and responsibilities of all shipboard personnel with a security role;
6.2. Procedures of safeguards necessary to allow continuous communications
to be maintained at all times;
6.3. Procedures needed to assess the continuing effectiveness of security
procedures and any security and surveillance equipment and systems,
including procedures for identifying and responding to equipment systems
failure or malfunction;
6.4. Procedures and practices to protect security sensitive information held in
paper or electronic format;
6.5. The type and maintenance requirements of security and surveillance
equipment and systems, if any;
6.6. Procedures to ensure the timely submission, and assessment, of reports
relating to possible breaches of security or security concerns;
6.7. Procedures to establish maintain and update an inventory of any dangerous
goods or hazardous substances carried on board, including their location.
7. According to ISPS Code Part A 9.6, this Administration establishes the Plan can be
kept in an electronic format. In such case, it must be protected by measures aimed
at preventing unauthorized access, disclosure, deletion, destruction or amendment
(Part A 9.6 ISPS Code).
8. The Ship Security Plan should address the security measures to be taken at each
Security Level covering:
9. Fleet Plans and Sister Ships: Each vessel shall have an individual Ship Security
Plan tailored to its Security Assessment. However, there will be information in each
ship’s plan that will be the same for all of the ships in the company’s fleet, for
vessels on the same trade route and for sister ships operating in the same trade.
The Security Assessment for the first ship can be used as a model for each of the
other ships engaged in the same trade on the same routes. In such a case, only the
ship’s specific variations need be addressed during the on-scene Security
Assessment.
12. Shipboard personnel without designated security duties should receive security-
related familiarization training to be able to:
13. Security drills must test the proficiency of vessel personnel in assigned security
duties at all maritime security levels and the effective implementation of the Ship
Security Plan (SSP). They must enable the Ship Security Officer (SSO) to identify
any related security deficiencies that need to be addressed.
14. The SSO must ensure that at least one security drill is conducted once every three
months to promote the effective implementation of the Ship Security Plan, except:
15. Security drills may be held in conjunction with non-security drills where appropriate.
The PMA accepts that a Safety Drill, which has a security component within it, can
be credited as a Security Drill.
16. Security drills must test individual elements of the SSP, including response to
security threats and incidents. Drills should take into account the types of
operations of the vessel, vessel personnel changes, and other relevant
circumstances.
17.1. Exercises should be carried out at least once each calendar year with no
more than 18 months between the exercises.
17.2. Exercises should test communications, coordination, resource availability,
and response. Exercises may be and not limited:
19. In this regard, a copy of the radio technician’s report, demonstrating compliance
with SOLAS 74’, as amended Chapter XI-2 Regulation 6 paragraphs #2 to #4
inclusive and MSC.1/Circ.1190, shall be kept on board for use by the RSO at the
next scheduled ISPS audit.
20. At subsequent ISPS verification, the RSO shall examine the records of activities on
the SSAS equipment, as specified in the ISPS Code A/10.1.10, witness a complete
security alert test and verifying the operational requirements and in the case of a
SSAS.
21. This Administration recommends all Panamanian flagged vessels to keep the
records of the drills conducted in the vessel for a period of time indicated in their
Ship Security Plan. Otherwise, the records must be kept as per stated in the
procedures of the company. If this is not indicated in neither of the previous
documents, this Administration recommends the records of the drills conducted to
the vessel must remain onboard for a period of time equivalent to the duration of
the International Ship Security Certificate.
22. For Maritime Security contact points, please refer to the following addresses:
Inquiries concerning the subject of this Merchant Marine Circular or any other request
should be directed to: