ISPS Code - Maritime Security

1. ISPS Code
Mohammud Hanif Dewan,
Maritime Lecturer & Trainer

2. 11 September 2001
2
In the wake of the tragic events of 11 September 2001 in the United
States of America, IMO Secretary-General William A. O’Neil,
consulted Member Governments on the need to review the measures
already adopted by IMO to combat acts of violence and crime at sea.

3. Resolution A.924(22)
(20 November 2001)
• A call for a review of measures and procedures to
prevent acts of terrorism which threaten the security
of passenger and crews and the safety of ships;
• A boost to the Organization’s technical co-operation
programme of £1.5 million to help developing
countries to address maritime securing issues.
3

4. Limburg – October 2002
4
Further impetus was added by the attack on the tanker
LIMBURG off Yemen in October 2002

5. What is the ISPS Code?
• The International Ship and Port Facility Security Code
(ISPS Code) is a comprehensive set of measures to
enhance the security of ships and port facilities,
developed in response to the perceived threats to ships
and port facilities in the wake of the 9/11 attacks in the
United States.
• The ISPS Code is implemented through chapter XI-2
Special measures to enhance maritime security in the
International Convention for the Safety of Life at Sea
(SOLAS).
• The Code has two parts: Part A - mandatory and Part B
– recommendatory.
5

6. Purpose of ISPS Code
The purpose of the Code are:
 to provide a standardised, consistent framework for
evaluating risk,
 enabling Governments to offset changes in threat with
changes in vulnerability for ships and port facilities
through determination of appropriate security levels and
corresponding security measures.
6

7. History of ISPS Code
Diplomatic Conference in
December 2002:
Conference resolution 1
Amendments to SOLAS
• Chapter V
• Chapter XI-1
• Chapter XI-2
7

8. Diplomatic Conference
December 2002 (1)
Other Conference resolutions:
• Resolution 3 .- Further work by the International
Maritime Organization pertaining to the enhancement of
maritime security;
• Resolution 4 .- Future amendments to Chapters XI-1
and XI-2 of the 1974 SOLAS Convention on special
measures to enhance maritime safety and security;
• Resolution 5 .- Promotion of technical co-operation
and assistance;
• Resolution 6 .- Early implementation of the special
measures to enhance maritime security;
8

9. Diplomatic Conference
December 2002 (2)
• Resolution 7 .- Establishment of appropriate measures to
enhance the security of ships, port facilities, mobile
offshore drilling units on location and fixed and floating
platforms not covered by chapter XI-2 of the 1974 SOLAS
Convention;
• Resolution 8 .- Enhancement of security in co-operation
with the International Labour Organization;
• Resolution 9 .- Enhancement of security in co-operation
with the World Customs Organization;
• Resolution 10 .- Early implementation of long-range
ship’s identification and tracking; and
• Resolution 11 .- Human element-related aspects and
shore leave for seafarers.
9

10. ISPS Code (1)
Preamble
Part A and Part B
1 General (introduction, objectives and
functional requirements) / Introduction
2 Definitions
3 Application
4 Responsibilities of Contracting
Governments
5 Declaration of security
10

11. ISPS Code (2)
6 Obligations of the Company
7 Ship security
8 Ship security assessment
9 Ship security plan
10 Records
11 Company security officer
12 Ship security officer
13 Training, drills and exercises on ship
security
11

12. ISPS Code (3)
14 Port facility security
15 Port facility security assessment
16 Port facility security plan
17 Port facility security officer
18 Training, drills and exercises on port
facility security
19 Verification and certification for ships
12

13. Rationale
-- Risk management activity
- Appropriate security measures
- Risk assessment
- ISPS Code standard framework
– evaluating risk
– change threat level
– change vulnerability of ships/port facility
- Functional security requirements for
ships and port facilities
13

14. ISPS CODE
Implementation

15. ISPS Code: International Ship and
Port Facility Security Code
• Part A
Mandatory requirements:
– Ships / Companies
– Port facilities
– Administration
• Part B
Guidance:
– Background
– Compliance
– Assistance
No. 15

16. ISPS Code - Objectives
• To establish An international framework
involving co-operation between CGs,
Govt agencies, local administrations and
shipping & port industries to detect
security threats and take preventive
measures.
• To establish respective roles and
responsibilities of CGs, Govt agencies,
local administrations and shipping & port
industries.
16

17. ISPS Code – Functional requirements
• Gathering & assessing information on security
threats & exchanging it with appropriate CGs.
• Requiring maintenance of communication
protocols for ships & PFs
• Preventing unauthorized access to ships, PFs
& their restricted areas.
• Preventing introduction of unauthorized
weapons, incindiary devices or explosives to
ships or PFs.
17

18. ISPS Code – Functional requirements
• Providing means for raising alarm in
reaction to security incidents.
• Requiring ship & PF security plans based
upon security assessments.
• Requiring training, drills and exercises to
ensure familiarity with security plans and
procedures.
18

19. ISPS Code – Declaration of security
• Declaration of security :
– CGs shall determine when it is required by
assessing the risk the ship/port interface or
ship to ship activity poses to people,
property or the environment
– A ship may request completion of DOS
– To be completed by the master or the SSO
on behalf of ship AND PFSO or any other
body identified by CG on behalf of port
facility
19

20. 20

21. 21

22. ISPS Code-
Ship Security Assessment
• CSO to ensure that SSA is carried out by
persons with appropriate skills to evaluate
the security of a ship
• RSO may carry out SSA
• SSA shall be documented, reviewed &
retained by the Company
• SSA shall include an on-scene security
survey
22

23. ISPS Code
Ship Security Assessment (cont’d)
• SSA shall include at least the
identification of :
– existing security measures, procedures and
operations
– and evaluation of key shipboard operations
– possible threats to such operations and the
likelihood of their occurrence, in order to
establish and prioritise security measures
– identification of weaknesses, including
human factors in the infrastructure, policies &
procedures
23

24. Ship Security Plan (SSP)
The CSO has the responsibility of ensuring that a Ship Security Plan (SSP) is
prepared and submitted for approval. The Ship Security Assessment (SSA) will have
identified the particular features of the ship and the potential threats and
vulnerabilities. The preparation of the SSP will require these features to be addressed
in detail.
All SSPs should contain:
1. Detail the organizational structure of security for the ship;
2. Detail the ship’s relationships with the Company, port facilities, other ships and
relevant authorities with security responsibility;
3. Detail the communication systems to allow effective continuous communication
within the ship and between the ship and others, including port facilities;
4. Detail the basic security measures for security level 1, both operational and
physical, that will always be in place;
5. Detail the additional security measures that will allow the ship to progress without
delay to security level 2 and, when necessary, to security level 3;
6. Provide for regular review, or audit, of the SSP and for its amendment in response
to experience or changing circumstances; and
7. Reporting procedures to the appropriate Contracting Governments contact points.
24

25. Restricted areas on the ship
The SSP should identify the restricted areas to be established in ships. The purpose of
restricted areas are to:
 prevent unauthorized access;
 protect passengers, ship's personnel, and personnel from port facilities or other
agencies authorized to be on board the ship;
 protect sensitive security areas within the ship; and
 protect cargo and ship's stores from tampering.
Restricted areas may include:
1. navigation bridge, machinery spaces of category A and other control stations as per
SOLAS chapter II-2;
2. spaces containing security and surveillance equipment and systems and their controls
and lighting system controls;
3. ventilation and air-conditioning systems and other similar spaces;
4. spaces with access to potable water tanks, pumps, or manifolds;
5. spaces containing dangerous goods or hazardous substances;
6. spaces containing cargo pumps and their controls;
7. cargo spaces and spaces containing ship’s stores;
8. crew accommodation; and
9. any other areas as determined by the CSO, through the SSA to which access must be
restricted to maintain the security of the ship.
25

26. ISPS Code - Records
• Records of following activities addressed
in SSP shall be maintained on board :
–Training, drills & exercises
–Security threats, security incidents &
breaches of security
–Changes in security level
–Communications relating to the direct
security of the ship such as specific
threats to the ship or to port facilities
the ship is at or has been
……continued……
26

27. ISPS Code - Records
(cont’d)
• Internal audits & reviews of security
activities
• Periodic review of the SSA
• Periodic review of the SSP
• Implementation of any amendments to
the plan
• Maintenance, calibration and testing of
security equipment, if any including
testing of the ship security alert system
27

28. ISPS Code – Training, drills & exercises
on ship security
• Drills shall be carried out at appropriate intervals to
ensure effective implementation of the SSP, taking
into account :
– Ship personnel changes
– PFs to be visited
– Other relevant circumstances
• CSO shall ensure effective coordination &
implementation of SSP by participating in the
exercises at appropriate intervals.
28

29. Port Facility Security Plan (PFSP)
Preparation of the Port Facility Security Plan (PFSP) is the responsibility
of the Port Facility Security Officer (PFSO).
All PFSPs should:
1. detail the security organization of the port facility,
2. the organizationís links with other relevant authorities and the
necessary communication systems to allow the effective continuous
operation of the organization and its links with others, including ships
in port;
3. detail the basic security level 1 measures, both operational and
physical, that will be in place;
4. detail the additional security measures that will allow the port facility
to progress without delay to security level 2 and, when necessary, to
security level 3;
5. provide for regular review, or audit, of the PFSP and for its
amendments in response to experience or changing circumstances;
6. reporting procedures to the appropriate Contracting Governments
contact points.
29

30. SCOPE OF APPLICATION
Chapter XI-2 of SOLAS and the ISPS Code apply to
following types of ships engaged on international voyages :
 Passenger ships, including HS passenger craft
 Cargo ships, including HS craft, of 500 GT and upwards
 Mobile offshore drilling units
 Port facilities serving such ships engaged on
international voyages
Do not apply to :
Warships & naval auxiliaries, other ships owned/operated
by a CG and used only on Govt. non-commercial service.

31. International Ship Security Certificate
• An International Ship Security Certificate shall
be issued after the initial or renewal verification
in accordance with the provisions of section 19.1
of ISPS code.
• Validity of the certificate is 5 years.
31

32. DEFINITIONS
Company :
• a company as defined in regulation IX/I.
Ship/port interface :
• The interactions that occur when a ship is directly and
immediately affected by actions involving the movement
of persons, goods or the provisions of port services to or
from the ship.
Ship to ship activity :
• any activity not related to a port facility that involves
transfer of goods or persons from one ship to another.
32

33. DEFINITIONS
Port facility :
• A location, as determined by the Contracting
Government or by the Designated authority, where the
ship/port interface takes place. This includes areas such
as anchorages, waiting berths and approaches from
seaward, as appropriate.
Designated authority:
• The organization (s) or the administration (s) identified,
within the Contracting Government, as responsible for
ensuring the implementation of the provisions of Chapter
XI-2 pertaining to port facility security and ship/port
interface, from point of view of the port facility.
33

34. DEFINITIONS
Recognized security organization (RSO):
An organization with appropriate expertise in security
matters and appropriate knowledge of ship and port
operations; authorized to carry out an assessment, or a
verification, or an approval or a certification activity,
required by Chapter XI-2 or by Part A of the ISPS Code.
Security incident :
An suspicious act or circumstances threatening the security
of a ship, including a mobile offshore drilling unit and a
high speed craft, or of a port facility or of any ship/port
interface or any ship to ship activity.
34

35. DEFINITIONS
• Ship security officer ( SSO) :
“ The person on board the ship, accountable to the Master,
designated by the Company as responsible for the
security of the ship, including implementation and
maintenance of the SSP and for liaison with the
company security officer and port facility security
officers.”
• Company security officer (CSO) :
“The person designated by the Company for ensuring that
a ship security assessment is carried out; that a ship
security plan is developed, submitted for approval, and
thereafter implemented and maintained and for liaison
with port facility security officer and the SSO.”
35

36. DEFINITIONS
• Port facility security officer (PFSO) :
“ The person designated as responsible for the
development, implementation, revision and maintenance
of the port facility security plan and for liaison with the
ship security officers and company security officers.”
36

37. Security Levels in ISPS Code
In setting the security level Contracting Governments should
take account of general and specific threat information.
Contracting Governments should set the security level
applying to ships or port facilities at one of three levels:
Security level 1:
 normal, the level at which the ship or port facility normally
operates. Security level 1 means the level for which
minimum appropriate protective security measures shall be
maintained at all times.
37

38. Security Levels in ISPS Code
Security level 2:
 heightened, the level applying for as long as there is a
heightened risk of a security incident.
 Security level 2 means the level for which appropriate additional
protective security measures shall be maintained for a period of
time as a result of heightened risk of a security incident.
Security level 3:
 exceptional, the level applying for the period of time when there
is the probable or imminent risk of a security incident.
 Security level 3 means the level for which further specific
protective security measures shall be maintained for a limited
period of time when a security incident is probable or imminent,
although it may not be possible to identify the specific target.
38

39. ISPS Code-
Security Responsibilities

40. Security Responsibilities
I. Contracting governments
II. RSO’s
III. The Company
IV. The Ship
V. The Port Facility
VI. SSO
VII. CSO
VIII. PFSO
IX. Vessel Personnel with specific security duties
X. Facility Personnel with specific security duties
XI. Other Personnel
XII. CSI Example
3.40

41. I. Contracting Governments
• CG shall set the Security levels: 1 – 2 – 3
and provide guidence for protection from
security incidents.
• Higher security levels indicate greater
likelihood of occurrence of a security
incident. Governments consider different
factors in setting the appropriate security
level:
3.41

42. I. Contracting Governments
• An administration requiring his ships to set SL 2
or 3 in a port of another Contracting Government
shall inform that Contracting Government
without delay.
• Contracting Governments, when they set
security level 3, shall issue appropriate
instructions and shall provide security-related
information to the ships and port facilities that
may be affected.
3.42

43. I. Contracting Governments
Other responsibilities as:
• Approving the SSP and subsequent amendments ;
• Verifying compliance of ships with ISPS Code and issuing the
ISSC ;
• Determining which port facilities needs a PFSO ;
• Ensuring compliance and approval of PFSA and subsequent
amendments ;
• Approving PFSP and subsequent amendments ;
• Exercising control and compliance measures ;
• Testing the approved plans (PFSP & SSP) ;
• Communicating information to IMO, shipping & port industries.
3.43

44. II. RSO’s
• Contracting Governments may authorize a “Recognized
Security Organisation” to undertake certain security-
related activities.
• An RSO may advise / provide assistance to companies
or port facilities on security matters.
• This can include completion of an SSA or SSP or PFSA
or PFSP
• A recognized security organisation who completed an
SSA or SSP is NOT authorized to approve that SSP.
3.44

45. II. RSO’s
What an RSO can do :
• Approval of a SSP or amendments thereto on behalf of
the Administration ;
• Verification and certification of compliance of ships with
ISPS Code on behalf of the Administration; and
• Conducting PFSA required by Contracting Government
3.45

46. II. RSO’s
What an RSO can’t do :
• Setting of security level ;
• Determining which of the PF are required to designate a PFSO and
to prepare a FFSP;
• Approving a PFSA or any subsequent amendments;
• Approving a PFSP or any subsequent amendments;
• Exercising control and compliance measures and
• Establishing requirements for a DoS.
3.46

47. III. The Company
• The Company must designate a CSO and one SSO
per ship.
• The Company shall insure that the Master has
documents on board relating to :
- the crewing of the vessel and
- the employment of the vessel.
• Ship security assessment (SSA) are being
maintained by the SSO in each ship.
• Ship security plan (SSP) are provided to each ship
and continuous updated and monitored by CSO.
3.47

48. III. The Company
3.48

49. IV. The Ship
• The ship must have:
- International Ship Security Certificate
(ISSC)
- Automatic identification system (AIS)
- Ship security alert system (SSAS)
- Declaration of Security (DoS)
- Training and documentation of all crew
and record of drill & security excercises.
49

50. The ship must comply with the requirements of the SSP as per
the security level set !
3.50

51. 51

52. 52

53. V. The Port Facility
• Port facilities shall comply with the requirements of
Chapter XI-2 of SOLAS and the ISPS Code
• The port facility shall act upon the security levels set by
the Administration within whose territory it is located.
• Security measures & procedures shall be applied as to
cause a minimum of interference with, or delay to,
passengers, ship, ship’s personnel and visitors, goods
and services (Part A, 14)
3.53

54. V. The Port Facility
At Security level 1
• Ensuring the performances of all port facility security
duties;
• Controlling access to the port facility;
• Monitoring of the port facility, including anchoring &
berthing areas;
• Monitoring restricted areas to ensure that only
authorized persons have access;
• Supervising the handling of cargo;
• Supervising the handling of ship’s stores, and
• Ensuring that security communication is readily
available.
3.54

55. V. The Port Facility
At security level 2
Additional protective measures, specified in the PFSP shall be
implemented for each activity detailed in the previous slide.
At security level 3
Further specific protective measures, specified in the
PFSP shall be implemented for each activity detailed in the previous
slide.
Part B of the Code contains a guidance re the
additional and protective measures.
3.55

56. VI. SSO
• The Company shall designate a SSO for each ship
• He is responsible for the SECURITY of the ship. This
includes the implementation and maintenance of the
SSP, the liaison with the CSO and PFSO
3.56

57. VI. SSO
Duties & responsibilities of the SSO (but not limited to):
 Undertaking regular security inspections of the ship ;
 Maintaining & supervising the implementation of SSP;
 Co-ordinating security aspects of the handling of cargo & ship’s
stores with other crewmembers and relevant PFSO;
 Proposing modifications to SSP ;
 Reporting to CSO any deficiencies/non-conformities ;
 Reporting all security incidents;
 Ensuring adequate training to shipboard personnel;
 Enhancing security awareness and vigilance on board
 Co-ordinating implementation of SSP with CSO and PFSO;
 Ensuring that security equipment is properly operated, tested,
calibrated and maintained
3.57

58. VII. CSO
The Company shall designate one CSO or several CSO’s depending
on the number or types of ships ;
Duties & responsibilities of the CSO (but not limited to):
• Advising the level of threats to ships ;
• Ensuring that SSA is carried out;
• Ensuring development/submission/approval/implementation &
maintenance of SSP;
• Ensuring modification of SSP as appropriate;
• Arranging for internal audits/reviews of security activities;
• Arranging initial/subsequent verifications by Administration or
RSO;
3.58

59. VII. CSO
Duties & responsibilities of the CSO (but not limited to):
• Ensuring identification of deficiencies & non-conformities;
• Enhancing security awareness & vigilance;
• Ensure security training for ship’s personnel;
• Ensure effective communication & co-operation between SSO and
relevant PFSO;
• Ensuring consistency between security requirements and safety
requirements;
• Ensure that each plan reflects the ship-specific information
accurately;
3.59

60. VIII. PFSO
 A PFSO shall be designated for each port facility ;
 He shall be given the necessary support to fulfil his duties and
responsibilities;
 His tasks may include :
- Conducting an initial security survey of the port facility;
- The development and maintenance of PFSP;
- The implementation and test of the PFSP;
- The regular inspection of the port facility;
- The recommendation & incorporation of modifications to the
PFSP;
- Enhancing security awareness & vigilance of personnel
3.60

61. VIII. PFSO
 His tasks may include (next) :
- The training of security personnel of the port facility;
- The reporting of security threats & maintaining records of
occurrences;
- Co-ordinating implementation of PFSP with appropriate
Company & SSO’s;
- Co-ordinating with security services, as appropriate;
- Setting standards for security personnel;
- Ensuring that security equipment is properly operated, tested,
calibrated & maintained;
- Assisting SSO in confirming identity of those seeking to board
the ship (when requested, not a routine).
3.61

62. VIII. PFSO
If the PFSO is advised that
 A ship is at a higher security level than the port :
the PFSO shall report the matter to the competent
authority and shall contact the SSO to co-ordinate
appropriate action if necessary.
 A ship encounters difficulties in complying/implementing
the procedures detailed in the SSP (especially in case of
security level 3), PFSO & SSO shall liaise and co-
ordinate appropriate actions.
3.62

63. IX. Vessel Personnel with specific
security duties
Shipboard Personnel with Specific Security duties…
…and responsibilities shall understand their responsibilities for ship
security as described in the SSP and shall have sufficient
knowledge and ability to perform their assigned duties.
3.63

64. IX. Vessel Personnel with specific
security duties
Their knowledge & ability should include, as appropriate :
• Knowledge of security threats & patterns;
• Recognition & detection of weapons, dangerous substances and
devices
• Recognition of characteristics & behavioural patterns of persons who
are likely to threaten security;
• Techniques used to circumvent security measures;-
• Crowd management & control techniques;
• Security-related communications;
• Knowledge of the emergency procedures & contingency plans;
• Operations of security equipment & systems;
• Testing, calibration & at-sea maintenance of security equipment &
systems
• Inspection, control and monitoring techniques;
• Methods of physical searches of persons, personal effects, baggage,
cargo and ship’s stores
3.64

65. 65

66. 66

67. 67

68. X. Facility Personnel with specific
security duties
Port Facility Personnel having Specific Security duties…
…shall understand their duties and responsibilities for port facility
security, as described in the SSP and shall have sufficient
knowledge and ability to perform their assigned duties.
3.68

69. XI. Other Personnel
Shipboard personnel and port facility personnel OTHER than
personnel having specific security duties …
… may have a role in the enhancement of maritime security
… should have sufficient knowledge of and be familiar with relevant
provisions of the SSP.
3.69

70. XI. Other Personnel
This includes :
• The meaning and requirements of the different security levels;
• Knowledge of the emergency procedures and contingency plans;
• Recognition and detection of weapons, dangerous substances and
devices;
• Recognition of characteristics & behaviour patterns of persons who
are likely to threaten security;
• Techniques used to circumvent security measures
3.70

71. ISPS Code
71
Set Security Level
Manage Different
Security Level
Request Declaration
of Security
PFSA
Contracting
Government
Port Facility
Security Officer
Company
Security Officer
Ship Security
Officer
Local
Administrator
SSA
PFSP
SSP

72. Ship Identification Number
In December 2002, the Diplomatic Conference on Maritime
Security adopted a number of measures aimed at
enhancing security of ships and port facilities. This included
a modification to SOLAS Regulation XI-1/3 to require ships'
identification numbers to be permanently marked in a
visible place either on the ship's hull or superstructure.
Passenger ships should carry the marking on a horizontal
surface visible from the air. Ships should also be marked
with their ID numbers internally.
The IMO ship identification number is made of the three
letters "IMO" followed by the seven-digit number assigned
to all ships by IHS Fairplay (formerly known as Lloyd's
Register-Fairplay) when constructed.
72

73. Ship Identification Number (cont’d)
This is a unique seven digit number that is assigned to propelled,
sea-going merchant ships of 100 GT and above upon keel laying
with the exception of the following:
- Vessels solely engaged in fishing
- Ships without mechanical means of propulsion
- Pleasure yachts
- Ships engaged on special service (e.g. lightships, SAR vessels)
- Hopper barges
- Hydrofoils, air cushion vehicles
- Floating docks and structures classified in a similar manner
- Ships of war and troopships
- Wooden ships
This number is assigned to the total portion of the hull enclosing the
machinery space and is the determining factor should additional
sections be added.
The IMO number is never reassigned to another vessel and is
shown on the ship’s certificates.
73

74. Ship Identification Number (cont’d)
- Permanently marked
- Visible on:
* stern or side of hull or superstructure
* horizontal surface for passenger
vessels
- Contrasting color
- NLT 200 mm; width proportionate to
height
- raised lettering or by cutting it into
or center punching (or other
equivalent)
74

75. CONTINUOUS SYNOPSIS RECORD (CSR)
 To be issued by the Administration to each ship under its flag
 In case of changes, Administration to issue amended record
 To be kept on board and available for inspection at all times
 Basic diary of ship or historical record of ship
 Issued by Administration, but must be maintained and updated
onboard
 Information includes:
 name of flag state
 date of registry
 ship’s ID number
 name of owner
 name of registered demise charterers
 name of shipping company
 name of classification society(ies)
 name of authorities or associations issuing certifications
75

76. Ship Security Alert System (SSAS)
• Required to be provided on
– All ships constructed on or after 1 July 2004
– Ships constructed before 1 July 2004 :
• Oil & chemical tankers, gas & bulk carriers, and cargo
HS craft, of  500 GT; Passenger ships including HS
passenger craft; not later than the 1st survey of
radio installation after 1 July 2004
• other cargo ships of  500 GT and mobile offshore
drilling units; not later than the 1st survey of radio
installation after 1 July 2006
76

77. Ship Security Alert System (SSAS)
- The ship security alert system, when activated, shall:
1. initiate and transmit a ship-to-shore security alert to a competent
authority designated by the Administration, the Company,
identifying the ship, its location and indicating that the security of
the ship is under threat or it has been compromised;
2. not send the ship security alert to any other ships;
3. not raise any alarm on-board the ship; and
4. continue the ship security alert until deactivated and/or reset.
- The ship security alert system shall:
1. be capable of being activated from the navigation bridge and in at
least one other location; and
2. conform to performance standards not inferior to those adopted by
the Organization.
- Protected from inadvertent initiation
- Administration or coastal state notification requirements
77

78. ANY QUESTION?
78
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