Lloyd Werft's Werner Lüken may not be too sure as to whether ship repair yards constitute "port facilities" under the ISPS Code but others do not share his doubts. Speaking at the Shiprepair Conference and Exhibition in London last month, he said he really didn't think that repair yards should be included under the Code's requirements and that newbuilding yards certainly shouldn't be. However, he admitted to being in ongoing discussions with the German authorities on the point and, as perhaps the world's most prominent cruiseship yard, there is a lot at stake. The arguments are complex and will keep lawyers busy for months. However, as Peter Rowat of the London Shipping Consultancy pointed out, whether or not repair facilities are covered by the Code's requirements is not really the issue.