BERMUDA MERCHANT SHIPPINGNOTICE
Piracy Counter Measures2022-012

Application
Ship Owners, Managers, Masters and Officers of Bermuda Registered ships

Summary
Piracy continues to be a significant threat to seafarers and to maritime transport
in the following areas in particular:- Red Sea
- The Gulf of Aden
- The Arabian Sea- The Straits of Hormuz- Large areas of the Indian Ocean- The West African Coast and the Gulf of Guinea
This notice details the views and recommendations of the Bermuda Shipping andMaritime Administration on the practice of carrying armed security teams andincludes the latest interim guidelines from the IMO for the guidance of owners,managers, and masters.

References
IMO Circular MSC.1/Circ.1405/Rev.2
IMO Circular MSC.1/Circ.1406/Rev.3
IMO Circular MSC.1/Circ.1443
Best Management Practices to Deter Piracy and Enhance Maritime Security in theRed Sea, Gulf of Aden, Indian Ocean and Arabian Sea
Best Management Practices to Deter Piracy and Enhance Maritime Security off theCoast of West Africa including the Gulf of Guinea
MCA Marine Guidance Notice MGN 440 Amendment 1
Department for Transport Interim Guidance to UK Flagged Shipping on the Use ofArmed Guards to Defend Against the Threat of Piracy in Exceptional
Circumstances
Department for Transport Guidance to UK Flagged Shipping on Measures toCounter Piracy, Armed Robbery and Other Acts of Violence Against MerchantShipping

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This Notice was issued on 3rd March 2022 and supersedes BSN 2018-012 issued on
31st July 2018

1. General Security advice.
(1) Red Sea, Gulf of Aden, Arabian Sea, Straits of Hormuz and Indian Oceana. An international joint naval force in the area offers a level of protection andsupport for ships of all nationalities in these areas; however this protection
and assistance depends for its effectiveness on the co-ordinators of the forces
being aware of the identity and location of ships in the area. The Bermuda
Shipping and Maritime Authority (BSMA) requests that all Bermuda ships cooperate with the naval forces in the area and register with the naval coordinators at Maritime Security Centre Horn of Africa (MSCHOA) prior to entry
into the risk area. The registry form for vessels can be found at the MSCHOA
website at; www.mschoa.org
b. Bermuda registered vessels should register with MSCHOA and also provide
an initial report to the UK Maritime Trade Operations Office (UKMTO) atukmto@eim.ae Tel (24hrs): +44 2392 222 060 Tel: +971 50 552 3215 Fax: +971
4 306 5710.
c. The BSMA recommends that all ships follow the published “BestManagement Practices to Deter Piracy and Enhance Maritime Security in theRed Sea, Gulf of Aden, Indian Ocean and Arabian Sea” (BMP5) a copy of whichis available on the MSCHOA website.
d. It is recommended that LRIT is NOT turned off on entering the high risk area.
Bermuda has granted access to the LRIT data for Bermuda ships to the naval
forces in the area and this is used to track ships and allow the available forces
to make the fastest possible response when required.
e. In the event that a Bermuda vessel does come under attack and is
subsequently able to do so, the Company or the ship should notify UKMTO(Tel: +44 2392 222 060 Email: watchkeepers@ukmto.org ) and send a copy of
the report to the BSMA at: survey@bermudashipping.bm.
(2) Coast of west Africa and Gulf of Guinea
a. The maritime security situation off the coast of West Africa is complex anddynamic. A Voluntary Reporting Area (VRA) has been established by theMaritime Domain Awareness for Trade – Gulf of Guinea (MDAT-GoG).
b. The BSMA advises all Bermuda ships using the VRA to contact MDAT-GoG atwatchkeepers@mdat-gog.org upon entering the VRA. Further information
can also be found at https://gog-mdat.org/home.
c. The BSMA recommends that all ships follow the published “BestManagement Practices to Deter Piracy and Enhance Maritime Security off
the coast of West Africa including the Gulf of Guinea” (BMP West Africa).
d. In the event that a Bermuda vessel does come under attack and is
subsequently able to do so, the Company or the ship should immediately

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notify MDAT-GoG (Tel: +33 298 228888) and when it is safe to do so, send a
copy of the report to BSMA at: survey@bermudashipping.bm.

2. Carriage of Armed Security Teams;(1) The carriage of Privately Contracted Armed Security Personnel (PCASP) is not
explicitly recommended in the Best Management Practices; however BSMArecognises that shipowner’s have an obligation to protect their crews andsupports this intent when the circumstances are such that putting an armed
team on board is considered to be the only effective solution.
(2) Bermuda laws and regulations do not expressly prohibit the carriage offirearms or armed teams onboard Bermuda ships and the BSMA will not object
to their carriage on board.
(3) A decision to use armed security teams must lie with the owner and should betaken after consideration of all the issues and an analysis of the risks. An ownertaking this course should do so in consultation with their insurance
underwriters, P&I Club, charterers and legal counsel.
(4) The BSMA is not in a position to approve Private Maritime Security Companies(PMSC), however will accept PMSC’s approved by the UK Administration. It is
recommended that shipping companies only employ private security
providers that are accredited to the current ISO 28007-1:2015 “Guidelines forPrivate Maritime Security Companies (PMSC) Providing Privately Contracted
Armed Security Personnel (PCASP) On Board Ships”.
(5) Owners should also note that the carriage of firearms on board vessels is not
accepted in some port locations and that it will be necessary to plan carefully
to avoid serious problems in some ports if an armed security team and its
weapons cannot be disembarked in advance.
(6) In any case where the carriage of an armed team places the total complement
on board in excess of the vessel’s life-saving appliances capacity it will benecessary to contact BSMA which will consider, on a case by case basis, theissue of a temporary exemption for the period necessary.
(7) Whenever a decision is made to place an armed team on board there is norequirement to inform the BSMA; however interested parties (such ascharterers) may require a “Letter of non-Objection” from the vessel’s Flag
Administration.
a. Please send such requests to: survey@bermudashipping.bm(8) If a “Letter of non-Objection” is requested the following information is to beprovided:a. Number of armed security guards to be placed on board
b. Location and date that the security team and weapons will be placed onboard.
c. Location and date that the security team and weapons will disembark thevesseld. The name of the Private Maritime Security Company employed

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3. Recommendations;(1) The guidance contained in BMP 5 or BMP West Africa should be always
followed in the areas of high risk. The carriage of any armed security personnel
should only supplement the above BMP guidance, and should in no way
replace it.
(2) Owners and managers should take great care in the selection of PrivateMaritime Security Companies. Before the services of a PMSC are engaged thevessel owners and managers must check their credentials andlicences/permits to ensure that they have been issued by an appropriate
authority and are operating legally against identified threats. Employing theservices of a disreputable Company could increase the risks faced by ships andtheir crews.
(3) It is essential that "Rules of Engagement" are clear, agreed and understood by
the onboard command structure and known to all onboard. The “Rules ofEngagement” should clarify exactly the circumstances when a response withweapons is permitted, the steps of escalation and the Master’s overall authority
to call for a cease fire.
The master always retains overriding authority and the ultimate
responsibility for protecting the crew, ship and cargo.
(4) Masters cannot delegate the above responsibility to a PMSC.
(5) Any armed security team must be briefed fully by the master on the nature andrisks associated with the ship’s cargo.

4. MSC.1/Circ.1405/Rev.2 – Guidance to Shipowners, Ship Operators

and Shipmasters(1) The IMO has developed interim guidelines regarding the use of Privately
Contracted Armed Security Personnel on Board Ships.
(2) The BSMA agrees with the content of these guidelines and recommends themto all owners and managers considering the engagement of private armed
security teams to protect their ships.

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