The IMO issued a Circular providing guidance relating to the implementation of SOLAS Chapter XI-2 and the ISPS Code. It was pointed out that a written Declaration of Security is generally unnecessary in routine situations and that port
state control officials at subsequent port calls should not expect such documents to be in the ship’s records.
Port facility security plans should specifically include provisions relating to access to visiting ships by owners’ representatives, safety inspectors or auditors, maintenance and repair personnel, and representatives of seafarers’ welfare and labor organizations. Shipboard personnel should be allowed ashore to read draft marks and perform other safety-related duties. Port state control officials should not expect the Company Security Officer to be available on a 24-hour basis, so long as an appropriate company duty officer can be contacted. Control measures should not be instituted based on information from anonymous or non-official sources, unless every effort is made to confirm the authenticity of the information. MSC Circ. 1132 (HK Law).