Understanding the RMI Circular on the Authorisation Procedure for Embarkation of Armed Security Personnel

Introduction

Maritime security remains a critical aspect of global shipping operations, particularly in regions prone to piracy and security threats. Ensuring the safety of vessels, crew, and cargo necessitates a combination of regulatory compliance, preventive measures, and, in certain cases, the deployment of Privately Contracted Armed Security Personnel (PCASP). To provide structured guidance on this subject, the Republic of the Marshall Islands (RMI) has issued Circular RA-03, outlining the procedural requirements for authorizing the embarkation of PCASP on RMI-flagged vessels.

This blog presents a comprehensive analysis of the RMI Circular RA-03, detailing best practices, international maritime security regulations, procedural requirements, and advisory notes for shipowners, operators, and masters.

Global Best Practices for Anti-Piracy Measures

The shipping industry follows well-established international best practices to deter piracy and enhance maritime security. These include:

• Best Management Practices to Deter Piracy and Enhance Maritime Security (BMP5): This document provides updated security measures tailored for vessels transiting high-risk areas such as the Red Sea, Gulf of Aden, Indian Ocean, and Arabian Sea. It includes guidance on risk assessment, watchkeeping, and onboard security enhancements.
• Global Counter Piracy Guidelines for Companies, Masters, and Seafarers (GCPG): Developed for shipping companies and maritime professionals, this guideline offers practical security strategies to counter piracy risks globally.
• IMO MSC.1/Circ.1405/Rev.2: Issued by the International Maritime Organization (IMO), this circular provides guidance on the use of Privately Contracted Armed Security Personnel (PCASP) on board ships navigating designated high-risk areas. It also establishes clear policies on engagement protocols, use of force, and liability concerns.

The Role of Privately Contracted Armed Security Personnel (PCASP)

PCASP teams are hired by shipping companies to enhance onboard security and protect vessels and crew from piracy threats. However, the use of PCASP is not a substitute for best management practices or preventive security measures. Instead, shipowners and operators should consider deploying armed guards only after conducting a thorough risk assessment that evaluates the necessity, potential consequences, and compliance requirements of such a decision.

The engagement of PCASP must align with:

• National laws of the flag state.
• International maritime security conventions.
• Port state regulations where the vessel will call.
• Rules of engagement and use of force policies.

Key Provisions of RMI Circular RA-03

To standardize the authorization and deployment of PCASP on RMI-flagged vessels, the RMI Administration has issued Circular RA-03, which establishes the following regulatory requirements:

1. Authorization Procedure for Embarkation of PCASP

• Shipowners, operators, or masters who wish to deploy PCASP must comply with the procedures outlined in RMI Circular RA-03.
• The authorization process ensures that all security personnel meet the required qualifications and that the vessel remains compliant with maritime security laws.

2. Letter of Non-Objection (LONO)

• The RMI Administration issues a Letter of Non-Objection (LONO) upon receipt of a formal request from the shipowner, operator, or master.
• A LONO is required for vessels that will be calling at ports with an armed security team onboard. Certain port states demand this document to ensure that the presence of PCASP aligns with their local laws and regulations.
• To obtain a LONO, shipowners and operators must submit:
  • The completed Information Request Form (RA-01) in its original Word document format.
  • Submission must be made to shipsecurity@register-iri.com at least two (2) days prior to the embarkation of the PCASP team.

3. Mandatory Post-Voyage Assessment

• At the conclusion of each voyage, a post-voyage PMSC-PCASP Assessment Report (RA-02) must be completed and submitted to the RMI Administration.
• This report ensures continuous performance evaluation of security personnel and helps improve maritime security strategies based on real-world operational data.
• The assessment must be sent to shipsecurity@register-iri.com immediately upon completion of the voyage.

4. Responsibilities of Shipowners, Operators, and Masters

• Ensure compliance with international maritime security regulations when engaging PCASP.
• Confirm that the PCASP team adheres to the applicable laws of the flag state, port states, and international regulatory frameworks.
• Verify that all security personnel meet the standards outlined in IMO Circular MSC.1/Circ.1405/Rev.2.
• Maintain detailed documentation of the deployment process, including risk assessments, engagement policies, and incident reports.

Compliance and Advisory Notes

To maintain operational compliance, shipowners, operators, and masters must:

• Strictly adhere to the procedures outlined in RMI Circular RA-03 when engaging PCASP.
• Submit all necessary regulatory documents, including Forms RA-01 and RA-02, within the specified timelines.
• Conduct a comprehensive risk assessment before deploying armed security personnel onboard.
• Ensure that PCASP teams operate within the framework of international maritime security regulations.

Shipowners and operators must also remain informed about updates to maritime security laws and ensure compliance with relevant IMO guidelines, flag state directives, and port state regulations.

Conclusion

The RMI Circular RA-03 serves as a vital regulatory document for shipowners, operators, and masters seeking to deploy armed security personnel onboard RMI-flagged vessels. By following the established authorization procedures, compliance protocols, and assessment requirements, maritime stakeholders can ensure safe and legally sound operations in high-risk waters.

For reference, the following enclosures are available:

1. RMI Circular RA-03 – Official guidelines on the authorization procedure for the embarkation of armed security personnel.
2. Administration Forms RA-01 and RA-02 – Essential documents for LONO application and post-voyage assessment.

For additional information or queries, shipowners and operators are encouraged to contact the RMI Administration at shipsecurity@register-iri.com.