The Maritime Safety Committee (MSC) has made it clear that neither the drafting of the definition of the SSO nor the provisions of the ISPS Code relating to his responsibilities, training etc. were aimed at preventing the master from being designated as SSO.
According to the ISPS Code, it is the responsibility of the Company and the Company Security Officer to appoint the SSO.
This naturally has to be endorsed by the Administration of the flag State and/or the Recognized Security Organization through the approval of the Ship Security Plan and issuing of the International Security Shipping Certificate and/or the relevant training certificate by the Administration as appropriate.