Four ISSC verifications, the five-year validity and the four grounds on which the certificate ceases to be valid (ISPS Code A/19)

The International Ship Security Certificate (ISSC) is governed by section 19 of part A of the ISPS Code. There are four kinds of verification, the certificate runs for at most five years, and the intermediate verification is endorsed on the certificate. In shape it is the same five-year clock as the other convention certificates.

The difference sits in the grounds on which the certificate ceases to be valid. Verifications not completed in their window, a missing endorsement and a transfer of flag are shared with the other certificates. One more is added. When the Company operating the ship changes, the ISSC ceases to be valid on the spot. On a ship that is sold or changes its management company, watching only the expiry date misses this ground.

The interim certificate is a separate matter. An Interim ISSC lasts 6 months, cannot be extended, and consecutive issue is blocked.

Only the initial and renewal verifications create a certificate and the intermediate verification is endorsed on it

.2 a renewal verification at intervals specified by the Administration, but not exceeding five years, except where section 19.3 is applicable. This verification shall ensure that the security system and any associated security equipment of the ship fully complies with the applicable requirements of chapter XI-2, this Part of the Code and the approved ship security plan, is in satisfactory condition and fit for the service for which the ship is intended;

Section 19.1.1 splits verification four ways. Initial, renewal, intermediate, and any additional verifications the Administration determines. The initial verification comes before the ship is put in service or before the certificate is issued for the first time. The renewal verification runs at intervals set by the Administration, not exceeding five years. Both look at the whole of the security system and its equipment against chapter XI-2, part A and the approved ship security plan (SSP).

.3 at least one intermediate verification. If only one intermediate verification is carried out it shall take place between the second and third anniversary date of the certificate as defined in regulation I/2(n). The intermediate verification shall include inspection of the security system and any associated security equipment of the ship to ensure that it remains satisfactory for the service for which the ship is intended. Such intermediate verification shall be endorsed on the certificate;

There is at least one intermediate verification. If only one is carried out, it takes place between the second and the third anniversary date. There is no window of so many months either side of an anniversary here. The window is the period between the two anniversaries. Once completed, the verification is endorsed on the certificate. That endorsement connects directly to the grounds for loss of validity below.

Verifications are carried out by officers of the Administration. The Administration may entrust them to a recognized security organization (RSO) referred to in regulation XI-2/1 (19.1.2). Either way the Administration guarantees the completeness and efficiency of the verification (19.1.3). The certificate is issued after the initial or renewal verification, and is issued or endorsed by the Administration or by an RSO acting on its behalf (19.2.2).

19.1.4 The security system and any associated security equipment of the ship after verification shall be maintained to conform with the provisions of regulations XI-2/4.2 and XI-2/6, this Part of the Code and the approved ship security plan. After any verification under section 19.1.1 has been completed, no changes shall be made in security system and in any associated security equipment or the approved ship security plan without the sanction of the Administration.

After a verification, the security system, its equipment and the approved SSP cannot be changed without the sanction of the Administration. When equipment is to be replaced or the plan amended, the Administration’s sanction comes before the verification record.

Where the new five years start depends on when the renewal verification was completed

19.3.1 An International Ship Security Certificate shall be issued for a period specified by the Administration which shall not exceed five years.

The ceiling is five years. Section 19.3.2 splits the start of those five years three ways.

When the renewal verification was completed	New certificate valid from	Ceiling on the new expiry date
Within 3 months before the old expiry date	Date the verification completed	5 years from the old expiry date
After the old expiry date	Date the verification completed	5 years from the old expiry date
More than 3 months before the old expiry date	Date the verification completed	5 years from the date it completed

19.3.2.2 When the renewal verification is completed more than three months before the expiry date of the existing certificate, the new certificate shall be valid from the date of completion of the renewal verification to a date not exceeding five years from the date of completion of the renewal verification.

The first two rows use the old expiry date as the starting point. A verification finished after expiry still counts from the old expiry date. Only the third row moves the start to the completion date. Pull the renewal verification forward and the next five years move forward by the same amount.

Where a certificate was issued for less than five years, the Administration may extend its validity beyond the expiry date. The ceiling is the same five years. In exchange, the verifications under 19.1.1 that would have applied to a five-year certificate have to be carried out as appropriate (19.3.3).

Three routes extend past the expiry date and none of them adds to the next five years

19.3.4 If a renewal verification has been completed and a new certificate cannot be issued or placed on board the ship before the expiry date of the existing certificate, the Administration or recognized security organization acting on behalf of the Administration may endorse the existing certificate and such a certificate shall be accepted as valid for a further period which shall not exceed five months from the expiry date.

• The renewal verification is done but the new certificate cannot be issued or placed on board. The Administration or an RSO endorses the existing certificate, and it is accepted as valid for up to 5 months from the expiry date (19.3.4).
• The ship is not in the port where it is to be verified when the certificate expires. The Administration may extend the validity, but only to let the ship complete its voyage to that port. The extension cannot exceed 3 months, and on arrival the ship cannot leave that port without a new certificate (19.3.5).
• A ship engaged on short voyages that has not had either extension above. The Administration may grant a period of grace of up to 1 month from the expiry date stated on the certificate (19.3.6).

The same rider hangs on the last two. Once the renewal verification is completed, the new certificate cannot run past five years from the old expiry date as it stood before the extension. Time bought by an extension does not stack onto the next cycle.

Completing the intermediate verification early can pull the expiry date itself forward

19.3.7 If an intermediate verification is completed before the period specified in section 19.1.1, then: .1 the expiry date shown on the certificate shall be amended by endorsement to a date which shall not be more than three years later than the date on which the intermediate verification was completed; .2 the expiry date may remain unchanged provided one or more additional verifications are carried out so that the maximum intervals between the verifications prescribed by section 19.1.1 are not exceeded.

Finish the intermediate verification before the second anniversary and there are two routes. One is to amend the expiry date by endorsement. The new expiry date cannot be more than three years after the day the intermediate verification was completed. The other is to leave the expiry date as it is. In that case one or more additional verifications have to be carried out so that the maximum intervals in 19.1.1 are not exceeded.

Which route was taken is recorded as an endorsement on the back of the certificate. If an endorsement that changed the expiry date is not carried into the ledger, the renewal verification gets scheduled against the old date on the front.

Of the four grounds for loss of validity, the change of Company is specific to the ISSC

19.3.8 A certificate issued under section 19.2 shall cease to be valid in any of the following cases: .1 if the relevant verifications are not completed within the periods specified under section 19.1.1; .2 if the certificate is not endorsed in accordance with section 19.1.1.3 and 19.3.7.1, if applicable; .3 when a Company assumes the responsibility for the operation of a ship not previously operated by that Company; and .4 upon transfer of the ship to the flag of another State.

The first and second are verification and endorsement. Miss the intermediate verification between the anniversaries, or carry it out and fail to get the endorsement onto the certificate, and validity is lost before the expiry date. The fourth is transfer of flag. These three have the same shape as the grounds in the other convention certificates.

The third is specific to the ISSC. The moment a Company assumes responsibility for operating a ship it has not operated before, the certificate ceases to be valid. The SSP stands on the Company’s security arrangements, so when the Company changes, the certificate that verified that plan falls with it. A sale and a change of management company both land here.

Information does travel across. On a transfer of flag, the former flag Government transmits copies of the ISSC and of the verification reports to the receiving Administration as soon as possible. On a change of Company, the previous Company transmits copies of ISSC-related information to the new Company to facilitate the verifications in 19.4.2 (19.3.9).

An Interim ISSC runs 6 months and consecutive issue is blocked

Section 19.4.1 limits the interim certificate to four cases. A ship without a certificate on delivery or before entry or re-entry into service, a transfer of flag between Contracting Governments, a transfer of flag from a non-Contracting State to a Contracting Government, and a change of Company. They pair with the grounds for loss of validity in the previous section.

The interim certificate is issued only after the Administration or an RSO has verified the items in 19.4.2. The ship security assessment is complete, a copy of the SSP is on board, has been submitted for review and approval and is being implemented, the ship security alert system is provided, the company security officer has arranged drills, exercises and internal audits, and the master, the ship security officer and personnel with specific security duties know their duties.

19.4.4 An Interim International Ship Security Certificate shall be valid for 6 months, or until the certificate required by section 19.2 is issued, whichever comes first, and may not be extended.

Validity is 6 months. If the full ISSC is issued earlier, the interim certificate ends that day. There is no extension.

19.4.5 No Contracting Government shall cause a subsequent, consecutive Interim International Ship Security Certificate to be issued to a ship if, in the judgment of the Administration or the recognized security organization, one of the purposes of the ship or a Company in requesting such certificate is to avoid full compliance with chapter XI-2 and this Part of the Code beyond the period of the initial interim certificate as specified in section 19.4.4.

Issuing interim certificates back to back is blocked as well. Where the Administration or the RSO judges that one purpose of the request is to put off full compliance, no consecutive interim certificate is issued. A ship on a 6-month interim certificate needs a schedule that completes the initial verification inside that period.

Worth confirming

The passages above come from section 19 of part A of the ISPS Code as adopted in SOLAS/CONF.5/34. This article covers that text only. The following points rest with the flag Administration.

• How long a certificate is issued for is set by the Administration, inside the ceiling of five years.
• Whether additional verifications are established, and when, is for the Administration.
• Whether verifications, and the issue of interim certificates, are entrusted to an RSO is also for the Administration.

One more point is worth noting separately. The intermediate window differs from the other certificates. Other convention certificates use three months either side of an anniversary date, while the ISSC uses the period between the second and the third anniversary date. On one calendar the two clocks have windows of different shapes.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

• IMO · SOLAS XI-2 and the ISPS Code

Continue with the related operational guidance

• IAPP Certificate survey types, endorsements and validity by renewal timing
• Three layers of STCW security qualification and who each one applies to (Regulations VI/5 and VI/6)