The maritime security regulations call for the use of a Declaration of Security (DOS) during certain times and situations when there a heightened security threat. The International Ship and Port Security (ISPS) Code takes a more general approach to the DOS than do the very specific U.S. Coast Guard regulations on the topic, which spell out which types of interfaces require a DOS at which MARSEC levels.
However, the intent of the regulations is clear in both, which is for the two interfacing parties to get together and make a deal regarding who will take responsibility for what security measures during a particular interface. This contract, which is usually limited to a single page, is signed by both parties. (Source: Maritime Compliance)
Unfortunately, as the years have passed since the publication of the Code and regulations, some of the intent and perceived value of such a document has been lost. It is not unusual to find that a DOS has been filled out and signed, but that the facility and the vessel personnel are unaware of its contents. It is also not unusual to find initials down both columns, including the vessel signing that it is taking responsibility for controlling access to the facility. Clearly, individuals responsible for fulfilling the obligations of the DOS should be aware of the contents.
According to the U.S. regulations, a DOS can be filled out and signed by a Facility or Vessel security Officer or their “designated representative.” This should not necessarily be a third party tankerman or stevedore who has no control over the processes prescribed in either security plan. The designated representative should be properly trained as a “vessel and facility personnel with security duties.” However, a designated representative does not have to be an alternate facility or vessel security officer who would be required to be trained to the level of an FSO or VSO under the regulations.
A Declaration of Security is a useful tool if used correctly. It continues to raise eyebrows each time we role-play filling one out during training sessions. Make good use of a DOS. The regulations have not gone away, and neither have the threats.