The International Maritime Organization (IMO) has set the schedule concerns the uniform implementation of Maritime Cyber Risk Management in Safety Management Systems after 1 January 2021
The proper management of cyber risks is expected to be verified by Administrations or recognized organizations approved by administration during the first annual review of a company’s DoC following 1 January 2021 in accordance to circular MSC 101/4/4.
IMO has set standards to establish Maritime Cyber Risk Management in Safety Management Systems in resolution MSC.428(98).
The managers of vessels for which SMC & ISSC apply are encouraged to start preparing their own company Cyber Risk Management (Cyber Security) in the nearest opportunity before their first annual ISM DOC.
The European Commission announced an official circular on 20/10/2020 (2020/c 349/01) by which the non-compliant vessels towards the IHM (EUSRR) requirement will be able to prolong the application of the compulsory requirement which will be forced on 01/01/2021 for all EU flagged vessels and non-EU flagged vessels calling EU ports. The maximum period of the extension will six months i.e. until 30/06/2021.
The main reason of this new extension is due to the non-availability for HazMat experts to perform the required survey/sampling from the ships due to travel restrictions and difficulties caused by COVID-19. This will give a gab to the recognized HazMat experts, laboratories and ROs to perform their evaluation/analysis basically.
The European Commission through this circular has set guidelines for the applicability of the extension for the non-compliant vessels. The extension will be evaluated in case by case basis and it will be subject for PSC officer evaluation for the case. For this reason it can’t be guaranteed unless owners forward subjective reasons with evidences for extension request such as:
– contract agreement with approved HazMat expert exists;
– HazMat expert couldn`t attend the vessel for reasons caused by COVID-19;
– no HazMat expert available in the last ports of call;
– HazMat expert conducted the survey/sampling and all samples are pending for analyzing report by an approved laboratory which caused delay due to COVID-19;
– IACS Recognized Organization that will evaluate the IHM (Part I) and all reports caused an un-intention delay for issuing SoC due to COVID-19.
Upon satisfactory evaluation of the case, the PSC officer will give extension for maximum period 6 months until 01/06/2021 or in some cases for 4 months.
For more detailed information please read circular (2020/c 349/01) in this this link https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020XC1020(01)&from=EN