As announced on 24 June 2020 key elements of the European Barge Inspection Scheme (EBIS) will transition to OCIMF’s SIRE programme from 1 January 2021. This will create a single barge inspection scheme within Europe.

To oversee the smooth transfer of EBIS into SIRE, the OCIMF/EBIS Transition Taskforce has been established, which includes members of the EBIS Board of Directors, OCIMF Members and secretariat. The first meeting of the taskforce was hosted remotely on 13 August 2020. Representatives of the wider European inland barge industry will be invited to future meetings.

OCIMF/EBIS Transition Taskforce will coordinate all activity relating to the transition of key elements of EBIS, including the EBIS vessel questionnaire templates – technical information templates currently in development by EBIS, Version 9. The Taskforce will also provide oversight on all work relating to:

Integrating EBIS member applications to become SIRE programme recipients.
Supporting accredited EBIS Inspectors looking to attain SIRE Cat 3 accreditation for the European region following application and completion of a training course.
Assisting vessel Owners and Operators in transferring their fleet’s EBIS technical information into the SIRE database.

Over the course of the transition period, training courses and webinars will be hosted by the OCIMF/EBIS Transition Taskforce to support OCIMF member companies, existing EBIS member companies, accredited EBIS and SIRE Inspectors as well as vessel Owners and Operators. Details of the training courses and webinars will follow in due course.

Should you have any queries or require support, please contact Matthew Graham, Barge Advisor, matthew.graham@ocimf.org

What are the key elements of TMSA 3 (Tanker Management Self Assessment)?

On the 10th of April 2017, OCIMF (The Oil Companies International Marine Forum) released TMSA 3, the latest edition of the Tanker Management and Self-Assessment (TMSA) programme providing Tanker companies with a means to improve and measure their safety management systems.

TMSA 3 revised and updated all twelve of the existing elements from the previous two editions and introduced a thirteenth – ‘Maritime Security.’

What are the 13 key elements of TMSA 3?

The 13 key elements of TMSA 3 are as follows:

Leadership and the safety management system

Recruitment and management of shore-based personnel

Recruitment, management, and wellbeing of vessel personnel

Vessel reliability and maintenance including critical equipment

Navigational safety

Cargo, ballast, tank cleaning, bunkering, mooring and anchoring operations

Management of change

Incident reporting, investigation, and analysis

Safety management

Environmental and energy management

Emergency preparedness and contingency planning

Measurement, analysis, and improvement

Maritime security

the newest element ‘Maritime Security‘ mainly consists of:

Use of Risk Assessment solution to identify and mitigate risks
Define and maintain a stock of equipment for vessel hardening as per BMP 4 guidelines.
Define Operational Security Area and monitor the number of transits of vessels as per Operation Security Reports made in the solution.
Circulate travel advisory and threat level data sharing to vessels using the document system.
Verify armed guards qualification criteria before employing them onboard vessels using our standard measurement list

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The International Association of Classification Societies (IACS) has published nine of its 12 recommendations on cyber safety for ships.

IACS initially addressed the subject of software quality with the publication of UR E22 in 2006. Recognizing the huge increase in the use of onboard cyber-systems since that time, IACS has developed this new series of recommendations with a view to reflecting the resilience requirements of a ship with many more interdependencies. They address the need for:

• A more complete understanding of the interplay between ship’s systems
• Protection from events beyond software errors
• In the event that protection failed, the need for an appropriate response and ultimately recovery.
• In order that the appropriate response could be put in place, a means of detection is required.

Noting the challenge of bringing traditional technical assurance processes to bear against new and unfamiliar technologies, IACS has launched the recommendations in the expectation that they will rapidly evolve as a result of the experience gained from their practical implementation. So, as an interim solution, they will be subject to amalgamation and consolidation.

More than 90 percent of the world’s cargo carrying tonnage is covered by the classification design, construction and through-life compliance rules and standards set by the 12 member societies of IACS.

The 12 Recommendations are:

Recommended procedures for software maintenance of shipboard equipment and systems (published)

Shipboard equipment and associated integrated systems to which these procedures apply can include:
– Bridge systems;
– Cargo handling and management systems;
– Propulsion and machinery management and power control systems;
– Access control systems;
– Ballast water control system;
– Communication systems; and
– Safety system.

Recommendation concerning manual / local control capabilities for software dependent machinery systems (published)

IMO requires through SOLAS that local control of essential machinery shall be available in case of failure in the remote (and for unattended machinery spaces, also automatic) control systems. For traditional mechanical propulsion machinery, this design principle is well established. The same design requirement applies to computerized propulsion machinery, i.e. complex computer based systems with unclear boundaries and with functions maintained in the different components.

Contingency plan for onboard computer based systems (published)

Computer based systems are vulnerable to a variety of failures such as software malfunction, hardware failure and other cyber incidents. It is not possible for all failure risks to be eliminated so residual risks always remain. In addition, a limited understanding of the operation of complex computer based systems together with fewer opportunities for manual operation can lead to crews being ill-prepared to use their initiative to responding effectively during a failure.

IMO and Classification Society rules contain many context specific examples of requirements for independent or local control in order to provide the crew with the means to operate the vessel in emergencies or following equipment failures. These requirements have generally been introduced when automation or remote control is introduced to individual pieces of equipment or functions and address concerns regarding its possible failure of the new features. The introduction of technologies which integrate different vessel’s functions creates the opportunity for two or more systems to be impacted by a single failure simultaneously.

Where, due to high computer dependence, manual operation is no longer practical or where the number of systems simultaneously affected is too high for manual operation to be practical with existing crew levels then the value of local control as a form of reassurance is limited, however the crew will still need to be provided with practical options to try to manage threats to human safety, safety of the vessel and/or threat to the environment.

If the practical options are not considered during the design and installed during construction of the vessel then the vessel and its crew could be, due to the introduction of new technologies, exposed to risks which they cannot manage.

Practical options could include limiting the extent of potential damage so that manual control is still achievable or providing backup systems which could be used in a worst case systems failure. Whatever form of contingency is provided to address failures it is important that it is well documented, tested and that the crew is aware and trained.

Requirements related to preventive means, independent mitigation means, engineered backups, redundancy, reinstatement etc. are dealt with in the other relevant recommendations.

Network Architecture (published)

Ship control networks have evolved from simple stand-alone systems to integrated systems over the years and the demand for ship to shore remote connectivity for maintenance, remote monitoring is increasing.

Incorporation of Ethernet technology has resulted in a growing similarity between the once disconnected fieldbus and Internet technologies. This has given rise to new terms such as industrial control networking, which encompasses not only the functions and requirements of conventional fieldbus, but also the additional functions and requirements that Ethernet-based systems present.

The objective of the present recommendation is to develop broad guidelines on ship board network architecture. The recommendation broadly covers various aspects from design to installation phases which should be addressed by the Supplier, system integrator and yard.

Data Assurance (published)

Regulation strongly focuses on system hardware and software development, however, data related aspects are poorly covered comparatively. Data available on ships has become very complex and in a large volume, meaning a user is unlikely to spot an error and it would be unreasonable to expect them to do so. Cyber systems depend not only on hardware and software, but also on the data they generate, process, store and transmit. These systems are also becoming more data intensive and data centric, often used as decision support and advisory systems and for remote digital communication.

Data Assurance may be intended as the activity, or set of activities, aimed at enforcing the security of data generated, processed, transferred and stored in the operation of computer based systems on board ships. Security of data includes confidentiality, integrity and availability; the scope of application of Data Assurance covers data whose lifecycle is entirely within on board computer based system, as well as data exchanged with shore systems connected to the on board networks.

Physical Security of onboard computer based systems (to be published Q4, 2018)

Network Security of onboard computer based systems (published)

Network security of onboard computer-based systems consists in taking physical, organizational, procedural and technical measures to make the network infrastructure connecting Information Technology and/or Operational Technology systems resilient to unauthorized access, misuse, malfunction, modification, destruction or improper disclosure, thereby ensuring that such systems perform their intended functions within a secure environment.

Vessel System Design (to be published Q4, 2018)

Inventory List of computer based systems (published)

For effective assessment and control of the cyber systems on board, an inventory of all of the vessel’s equipment and computer based systems should be created during the vessel’s design and construction and updated during the life of the ship: tracking the software and hardware modifications inside ship computer based systems enables to check that new vulnerabilities and dependencies have not occurred or have been treated appropriately to mitigate the risk related to their possible exploitation.

Integration (published)

Integration refers to an organized combination of computer-based systems, which are interconnected in order to allow communication and cooperation between computer subsystems e.g. monitoring, control, Vessel management, etc.

Integration of otherwise independent systems increases the possibility that the systems responsible for safety functions can be subject to cyber events including external cyberattacks and failures caused by unintentionally introduced malware. Systems which are not directly responsible for safety, if not properly separated from essential systems or not properly secured and monitored in an integrated system, can introduce routes for intrusion or cause unintended damage of important systems. It is necessary to have a record and an understanding of the extent of integration of vessels’ systems and for them to be arranged with sufficient redundancy and segregation as part of an overall strategy aimed at preventing the complete loss of ship’s essential functions.

Remote Update / Access (published)

Information and communications technology (ICT) is revolutionizing shipping, bringing with it a new era – the ‘cyber-enabled’ ship. Many ICT systems on-board ships connect to remote services and systems on shore for monitoring of systems, diagnosis and remote maintenance, creating an extra level of complexity and risk. ICT systems have the potential to enhance safety, reliability and business performance, but there are numerous risks that need to be identified, understood and mitigated to make sure that technologies are safely integrated into ship design and operations.

Communication and Interfaces (to be published Q4, 2018)

OCIMF is pleased to announce the release of the seventh edition of the SIRE Vessel Inspection Questionnaire (VIQ7).

This edition has undergone an extensive revision process which has brought the VIQ up-to-date with respect to changes in legislation and best practices. The SIRE Focus Group, which has led the work on the revision of this document, has examined the questions to determine whether these continue to remain relevant and has reduced the overall set of questions by up to 90 questions.

The section on Structural Condition in the existing VIQ6 (Chapter 7) has been reduced and merged with Chapter 2. A new chapter (Chapter 7) has been developed to cover Maritime Security which has 21 new questions covering Policies and Procedures, Equipment and Cyber Security.

The section on Mooring (Chapter 9) has been significantly reviewed to incorporate the revisions and best practices that will be introduced in the Mooring Equipment Guidelines, Fourth Edition (MEG4). Operators will be encouraged to align their procedures and equipment with the guidance provided in MEG4 as soon as possible.

The existing chapter on Communications (Chapter 10) has been reduced and merged with Chapter 4, which is now a section on Navigation and Communications.

A set of 10 questions on LNG Bunkering has been added to the section on Engine and Safety Compartments (Chapter 10). These questions have been developed in conjunction with advice and guidance from SIGTTO and SGMF.

The following templates within the seventh edition of the SIRE Vessel Inspection Questionnaires (VIQ7) are now available to integrators upon the OCIMF Staging environment and will be released to the Production environment on the 17September 2018.

Template 4401 – VIQ7 (Petroleum)
Template 4402 – VIQ7 (Chemical)
Template 4403 – VIQ7 (LPG)
Template 4404 – VIQ7 (LNG)

Release of the seventh edition of the SIRE Vessel Inspection Questionnaire (VIQ7): 17 September 2018

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GDPR TMSA Cyber Security

Tanker owners should be prepared for new EU and IMO cyber security regulations as they must already comply with maritime security requirements under OCIMF’s TMSA 3, writes Martyn Wingrove

There are increasing amounts of cyber security-related regulations that shipping companies will have to comply with, but tanker owners are already ahead of the game. Ship operators will need to include cyber in ship safety and security management under the ISM Code from 1 January 2021.

Before that, they need to be aware of cyber and data security regulations, including the EU general data protection regulation (GDPR) and the EU directive on the security of networks and information systems (NIS).

Much of the requirements under these forthcoming or new regulations are already within Oil Companies International Marine Forum (OCIMF)’s third edition of the Tanker Management and Self Assessment (TMSA) best practice guidelines. This came into force on 1 January this year, with a new element on maritime security and additional requirements of key performance indicators and risk assessments.

Regulation changes were outlined at Riviera Maritime Media’s European Maritime Cyber Risk Management Summit, which was held in London on 15 June. The event was held in association with Norton Rose Fulbright, whose head of operations and cyber security Steven Hadwin explained that “data protection and cyber security needs to be taken seriously from a legal point of view.”

Data, such as information on cargo and charterers, could “become a considerable liability”. If data is lost “then GDPR could be in play” said Mr Hadwin. Regulators “could impose a fine of up to 4% of that organisation’s global annual turnover.”

PwC UK cyber security director Niko Kalfigkopoulos explained the legislation and reasoning behind the NIS Directive, which went into full effect in May this year. “These regulations have teeth” he said because of the potential size of fines and damage to a company’s reputation from being a victim of a cyber attack. This is one of the reasons why boardroom executives should be aware and understand what is required for compliance.

Class support

During the summit, class societies provided cyber security guidance as they collectively attempted to define cyber secure ship notations. Lloyd’s Register cyber security product manager Elisa Cassi said shipping companies should have a third party monitor their IT network and the operational technology (OT) and employ staff to “stop people sharing data or compromising procedures”.

Tanker owners “need to identify any compromise before an attacker tries to penetrate”, Ms Cassi explained, noting that shipping companies need to “investigate the vulnerabilities through analytics and machine learning”, understand the behaviour of potential threats and use predictive analysis.

ABS advanced solutions business development manager Pantelis Skinitis said shipowners need to change passwords on operational technology, such as ECDIS and radar, as some remain unchanged since they were originally commissioned on the ship. He also advised owners to verify vendors and service engineers and that their USB sticks are clean of malware.

ABS has created cyber safety guidance for ship OT, particularly for ships coming into US ports and terminals. In its development, ABS identified the risks, vulnerabilities and threats to OT. “Managing connection points and human resource deals with the biggest threat to OT systems on board,” said Mr Skinitis.

DNV GL has developed new class notations covering cyber security of newbuildings. It has also produced an online video for instructing shipping companies to become more aware of cyber threats. During the summit, DNV GL maritime cyber security service manager Patrick Rossi said ship operators should set up multiple barriers to prevent hackers.

These should include firewalls, updated antivirus, patch management, threat intelligence, intrusion detection, emergency recovery and awareness testing. OT should be segregated from open networks, only official ENC-provider USBs and update disks should be used and cleaned of malware before being inserted into ECDIS and these systems should be segregated from the internet.

Cyber regulations and guidance for shipping

EU General Data Protection regulation (GDPR) came into effect from 25 May 2018

IMO – Resolution MSC.428(98) – from January 2021 cyber security will be included in the ISM Code

TMSA 3 – cyber security was added to tanker management and assessment in January 2018; EU directive on the security of networks and information systems (NIS Directive) from May 2018

EU privacy rule (PECR) of individuals traffic and location data

Rightship added cyber security to inspection checklist

BIMCO – guidelines based on International Association of Classification Societies

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TMSA 3, From January 2018, tanker operators are required to use TMSA3 to monitor and improve performance. In comparison with TMSA2, the new edition of TMSA is more extended in length and presents new challenges to ship operators with the introduction of new requirements.

It is noticeable that for the first time, this self-assessment tool for oil tankers introduces maritime security as Element 13 referring also to cyber security.

Cyber security is currently one of the most discussed topics on the industry and many considerable efforts have been made so far to mitigate threats. Thus, TMSA 3 aims to establish procedures in order to respond to industry’s needs.

‘’For the first time, TMSA introduces maritime security as Element 13 including cyber security’’

Also it features an expanded best practice guidance to complement the KPIs and enhanced guidelines for risk assessment, auditing and review ashore and onboard along with guidance for all related tools to be employed.

Other major changes introduced are the expansion of Element 6 on Cargo, Ballast, Tank Cleaning, Bunkering, Mooring & Anchoring Operations, and an updated Element 10 combining Environmental and Energy Management.

In the latest edition, special focus has been given on the continuous improvement cycle by taking into consideration additional KPIs towards effective performance management. Specifically, TMSA3 introduces 85 new KPIs in total. In this context, 25 KPIs have moved to a lower level and there are indexes concerning customer focus, leadership and engagement of people.

On the whole, the TMSA3 addresses issues regarding performance management. The method that a shipping company uses to measure performance is a prominent topic for discussion within the maritime industry. The new edition makes an effort to overhaul the process, not only with the streamline of KPIs but also with the introduction of non-financial measurements and the assessment of soft skills.

Furthermore, TMSA3 introduces a different approach by focusing on the human element and behavioral safety suggesting that crew competence is the tool for crew retention and development.

TMSA 3 at a glance

Expanded best practice guidance to complement the KPIs.
Revised and enhanced best practice guidance to remove ambiguity and duplication.
Additional requirements for HSSE strategic planning, KPI setting and performance monitoring, review and improvement.
Streamlining and merging of elements to improve consistency and make self-assessment easier.
Enhanced guidelines for risk assessment, auditing and review ashore and onboard along with guidance for all related tools to be employed.
Extensively Revised Element 6 and 6A – Cargo, Ballast, Tank Cleaning, Bunkering, Mooring and Anchoring Operations, with additional KPIs and guidance.
Extensively Revised Element 10 – Environmental and Energy Management (previously Environmental Management) incorporates the OCIMF Energy Efficiency and Fuel Management paper that was a supplement to the TMSA 2.
A New element: Element 13 – Maritime Security.

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MARITIME CYBER SECURITY

Changes in the cyber security industry

MARITIME CYBER SECURITY, A recent set of attacks against critical infrastructure entities, such as oil and gas pipeline operators, utilities and even some city and state governments reveal new motives and methods. The attackers were not out to steal data but were looking to disrupt services. The attackers used a new attack vector that has not been seen before. Instead of attacking their primary targets directly, they attacked less secure vendors that those targets use. We will be looking at how they did this and then how it can be prevented.

Step one – Reconnaissance

Before launching an attack, hackers first identify a vulnerable target and explore the best ways to exploit it. The initial target can be anyone in an organization. The attackers simply need a single point of entrance to get started. Targeted phishing emails are common in this step, as an effective method of distributing malware.

The whole point of this phase is getting to know the target.
The questions that hackers are answering at this stage are:

Who are the important people in the company? This can be answered by looking at the company web site or LinkedIn.
Who do they do business with? For this they may be able to use social engineering, by make a few “sales calls” to the company. The other way is good old-fashioned dumpster diving.
What public data is available about the company? Hackers collect IP address information and run scans to determine what hardware and software they are using. They check the ICAAN web registry database.

The more time hackers spend gaining information about the people and systems at the company, the more successful the hacking attempt will be.

Step two – Weaponization

In this phase, the hacker uses the information that they gathered in the previous phase to create the things they will need to get into the network. This could be creating believable Spear Phishing e-mails. These would look like e-mails that they could potentially receive from a known vendor or other business contact. The next is creating Watering Holes, or fake web pages. These web pages will look identical to a vendor’s web page or even a bank’s web page. But the sole purpose is to capture your user name and password, or to offer you a free download of a document or something else of interest. The final thing the attacker will do in this stage is to collect the tools that they plan to use once they gain access to the network so that they can successfully exploit any vulnerabilities that they find.

Step three – Delivery

Now the attack starts. Phishing e-mails are sent, Watering Hole web pages are posted to the Internet and the attacker waits for all the data they need to start rolling in. If the Phishing e-mail contains a weaponized attachment, then the attacker waits for someone to open the attachment and for the malware to call home.

Step four – Exploitation

Now the ‘fun’ begins for the hacker. As user names and passwords arrive, the hacker tries them against web-based e-mail systems or VPN connections to the company network. If malware-laced attachments were sent, then the attacker remotely accesses the infected computers. The attacker explores the network and gains a better idea of the traffic flow on the network, what systems are connected to the network and how they can be exploited.

Step five – Installation

In this phase the attacker makes sure that they continue to have access to the network. They will install a persistent backdoor, create Admin accounts on the network, disable firewall rules and perhaps even activate remote desktop access on servers and other systems on the network. The intent at this point is to make sure that the attacker can stay in the system as long as they need to.

Step six – Command and control

Now they have access to the network, administrator accounts, all the needed tools are in place. They now have unfettered access to the entire network. They can look at anything, impersonate any user on the network, and even send e-mails from the CEO to all employees. At this point they are in control. They can lock you out of your entire network if they want to.

MARITIME CYBER SECURITY.

Step seven – Action on objective

Now that they have total control, they can achieve their objectives. This could be stealing information on employees, customers, product designs, etc. or they can start messing with the operations of the company. Remember, not all hackers are after monetizable data, some are out to just mess things up. If you take online orders, they could shut down your order-taking system or delete orders from the system. They could even create orders and have them shipped to your customers. If you have an Industrial Control System and they gain access to it, they could shut down equipment, enter new set points, and disable alarms. Not all hackers want to steal your money, sell your information or post your incriminating e-mails on WikiLeaks, some hackers just want to cause you pain.

MARITIME CYBER SECURITY

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Maritime Cyber Attack

Cyber attacks like the NotPetya malware that struck Maersk are raising concerns about cyber risk and its effects on resilience, according to specialty insurer XL Catlin

Shipping industry firms and port operators are worried about linkage between cyber-attacks and supply chain risk, insurer XL Catlin has warned.

Big interdependencies between systems mean maritime firms face major business continuity risks from online threats.

“The problem is that nobody knows, other than the computer systems, where your goods are,” said Pascal Matthey, head of global lines for marine risk engineering at XL Catlin.

“You might never find your container again. Refrigerated containers might lose power, which would mean huge damage,” said Matthey.

Maersk was among those organisations worst hit by the NotPetya contagious malware attack last year.

The global shipping and logistics firm had to reinstall some 4,000 servers, 45,000 PCs, and 2,500 applications; the process took 10 days and cost the company around $450m.

The company was forced to temporarily switch to manual systems – pen and paper, and lots of overtime – resulting in a temporary 20% drop in volumes.

Another cyber-attack, revealed in 2013, struck two shipping companies operating in the Belgian port of Antwerp, and had reportedly gone undetected for about two years before that.

An organised crime group allegedly used hackers to infiltrate computer networks, allowing cocaine and heroin, hidden in containers shipped from South America, to be intercepted by criminals.

“The idea was not to harm the port but to get things out by hacking the system,” said Matthey, based in the specialty insurer’s Zurich office.

He warned about the potentially catastrophic consequences of a cyber-attack by terrorists, such as targeting a ship and interfering with its steering or navigation to cause a collision in congested waters, such as a port or major trade artery such as the Panama Canal.

Maritime Cyber Attack

“What happened on 9/11, you could perhaps now do with a ship, by steering a large vessel into an oil or gas terminal, which could have disastrous consequences,” said Matthey.

XL Catlin is among those re/insurance firms involved in developing blockchain applications – distributed ledger technology for smart contracts, sharing data instantaneously between the relevant counterparties.

A new blockchain platform for marine insurance contracts at XL Catlin and MS Amlin is expected to go live this year.

Maritime Cyber Attack

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MARITIME CYBER RISK !

The insurance losses and liabilities arising from cyber risks is an increasing area of focus for both shipowners and their insurers, argues Mr. Adrian Durkin, Director (Claims) and Mr. Colin Gillespie, Deputy

Potentially owners may be exposed to gaps in cover arising from cyber incidents – an unsatisfactory situation in today’s connected world. For example, an owner’s hull and machinery insurance may contain a cyber risk exclusion which mirrors, or is derived from, institute clause 380.

There are also cyber exclusions in war risk policies that relate to computer viruses. The war risks clause is derived from market clause 3039. Many other market insurance policies specifically exclude losses or liabilities arising as a result of cyber risks.

Why is Cyber Excluded?

Cyber risks present a range of issues for insurers. Cyber risks are relatively new – claims data relating to these risks is quite limited. Another difficulty is that cyber security is not yet well established in the maritime industry. The sheer complexity of the information technology, operational technology and internet available across the industry also presents a challenge, as does the potential for cyber problems to spread quickly across the globe. As a result the likelihood, extent and costs associated with claims involving cyber risks are difficult to calculate and potentially significant, hence the reluctance to offer cover.

It is in an owner’s interests to scrutinise their various policies in order to identify potential gaps in their insurance cover. It is possible to close the gaps by working with insurers and brokers. This may require owners to demonstrate that they have robust cyber risk management practices in place both ashore and afloat. An additional premium may be payable. The market is responding to these risks – albeit slowly.

P&I Cover for Cyber Risks

The International Group of P&I Clubs’ poolable cover does not exclude claims arising from cyber risks.

This means that club members benefit from the same level of P&I cover should a claim arise due to a cyber risk, as they would from such a claim arising from a traditional risk. As always cover is subject to the club rules.

While there are currently no internationally agreed regulations in force as to what constitutes a prudent level of cyber risk management or protection, this does not mean that owners, charterers, managers or operators of ships can ignore the need to take proper steps to protect themselves in the belief that their club cover will always respond.

If a claim with a cyber element arises, an owner may need to demonstrate that they took all obvious steps to prevent foreseeable loss or liability. As more and more potential cyber risks are being identified, clubs will expect to see the operation of sensible and properly managed cyber risk policies and systems both ashore and on vessels.

MARITIME CYBER RISK

Don’t delay – act now

Barely a month goes by without news of a major cyber-attack affecting a large or high profile commercial or government entity. Cybercrime is a rapidly growing global threat in all industries and the maritime supply chain is vulnerable as the problems experienced by Maersk in 2017 have demonstrated. In that incident problems ashore had a knock on effect on vessels, highlighting the fact that as marine transport operations become more connected, the more chance there is of problems impacting across the system both ashore and afloat.

The authorities and large charterers are concerned about the risk to operations ashore and afloat and are taking steps to drive change in the industry. Actively managing cyber risks is now both a commercial and compliance priority.

Cyber Risks & ISM Code

The IMO’s Maritime Safety Committee (MSC) has confirmed that cyber risks should be managed under the ISM Code.

Resolution MSC.428(98) affirms that an approved safety management system should take into account cyber risk management and encourages administrations to ensure that cyber risks are appropriately addressed in safety management systems no later than the first annual verification of the company’s Document of Compliance after 1 January 2021.

TMSA 3

Cyber risk management has been included in TMSA 3 under elements 7 and 13. KPI 7.3.3 includes cyber security as an assigned responsibility for software management in the best practice guidelines. Under element 13 cyber security is specifically identified as a security threat to be managed. It seems clear that the oil industry has recognised the need for action from tanker owners and is encouraging action through commercial pressure via TMSA 3. For tanker operators the time to act is already here.

Rightship Inspections

Cyber risk management now forms part of Rightship inspections and a company’s cyber security maturity may be one aspect dry bulk charterers will take into account.

A Daunting Task?

The prospect of dealing with cyber security will be daunting for many shipping companies. It’s new, involves things that may not be fully understood, and most of us are not likely to have received any formal training in such risks.

What is a definite plus is that shipping companies will be very familiar with the risk management framework suggested by the IMO Guidelines on Cyber Risk Management and industry Guidelines on Cyber Security Onboard Ships. We can also use the experience gained in other sectors of industry that have already put cyber security systems in place.

2021 is not far away, but the potential for cyber risks to result in losses or liabilities is clearly already upon us.

Cyber risks can affect almost every part of a shipping company. There will be lots to do to identify risks and vulnerabilities and to take steps to prepare for, and respond to, cyber threats. It’s time for us all to act.

By Adrian Durkin, Director (Claims) & Colin Gillespie, Deputy Director (Loss Prevention), North P&I Club

OCIMF published the third edition of its Tanker Management and Self-Assessment guide (TMSA3) in April 2017. As of 1 January 2018, this will replace the TMSA2 and tanker owners will be required to follow the new self-assessment procedure.

So are there any major changes?

Well actually, yes. The latest TMSA version introduces an entirely new element – Maritime Security (element 13). The new element aims “to establish and maintain policies and procedures in order to respond to and mitigate identified security threats covering all company activities including cyber security.”

In complying with the aim, security plans should be put in place, which also address cyber security risks, and should cover shored-based locations, vessels and personnel.

Are there any tools available to help tanker members comply with the Maritime Security element?

Yes, resources are available and the best thing is they are free!

IET Standards in conjunction with the Department for Transport have created a comprehensive code of practice for cyber security onboard ships. This code follows on from previous work the Department for Transport has done on port cyber security.

Additionally, an industry working group (which included OCIMF) have created Guidelines on Cyber Security onboard Ships.

What other changes are there?

Elements 6, 6A and 10 have all had revisions, with element 10 now incorporating the OCIMF Energy Efficiency and Fuel Management paper that had previously been a supplement to TMSA2. Additionally TMSA3 also has 19 more KPIs than TMSA2 showing the focus on continuous improvement.

SOURCE : UK P&I CLUB

ARTICLE AUTHOR

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OCIMF/EBIS Transition Update – Taskforce Formed