7 Managing an Oversight Programme
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Statutory Documents - IMO Publications and Documents - International Codes - RO Code - Code for Recognized Organizations – Resolution MSC.349(92) and Resolution MEPC.237(65) - Part 3 – Oversight of Recognized Organizations - 7 Managing an Oversight Programme

7 Managing an Oversight Programme

  7.1 General

  7.1.1 The flag States are required to verify that the organizations recognized to perform statutory certification and services on their behalf fulfil the requirements of this Code. The purpose of this verification is to ensure that the RO is performing its statutory certification and service in compliance with this Code and its agreement with the flag State.

  7.1.2 The flag State should develop, implement, and manage an effective oversight programme of the ROs that act on its behalf.

  7.1.3 An oversight programme should include various monitoring activities, which may inter alia consist of audits, inspections and audit observations (potential non-conformities). The flag States' oversight programme of their ROs should be developed after carefully assessing the factors associated with the RO as well as the extent of access to the RO's records of statutory certification and services that are made available to the flag State. The programme should also consider the delivery of statutory certification and services with respect to the provisions of the Conventions and with respect to the national requirements and instructions published by the flag State. Factors should include:

  • .1 the scope and frequency of high level audits of the RO carried out by flag States and independent accredited bodies, and of internal audits carried out by the RO;

  • .2 the extent to which audit findings, observations (potential non-conformities) and corrective actions are made available to the flag State;

  • .3 the extent to which remote monitoring of the RO can be undertaken by the flag State which can manifest itself in several different ways depending on the scope of information that is electronically available to the flag State. Remote monitoring can include:

    • .1 review of the contents of survey reports associated with statutory certificates issued by the RO;

    • .2 review of the effectiveness of the control and rectification of deficiencies and outstanding requirements within the deadlines established by the flag State through the RO; and

    • .3 review of the RO's country-specific instructions to determine that the flag State's national requirements are properly and completely addressed by the RO;

  • .4 flag State inspections carried out on board ships to check the end-result of the certification process, with a specific interest in their national requirements and/or implementation of instructions issued to the RO; and

  • .5 port State control detentions and deficiencies allocated to the responsibility of the RO.

  7.1.4 An oversight programme should also include all activities necessary for planning and organizing the types and number of monitoring activities, and for providing resources to conduct them effectively and efficiently within the specified periods.

  7.1.5 Those assigned the responsibility for managing the oversight programme should:

  • .1 establish, implement, monitor, review and improve the oversight programme; and

  • .2 identify the necessary resources and ensure they are available and provided, as required.

  7.1.6 An oversight programme should also include planning, the provision of resources and the establishment of procedures to conduct monitoring activities within the programme.

  7.2 Oversight programme objectives and extent

  7.2.1 Objectives of an oversight programme

  7.2.1.1 The flag State should establish objectives for an oversight programme, to direct the planning and conduct of monitoring activities.

  7.2.1.2 The following objectives should be considered:

  • .1 management priorities;

  • .2 flag State intentions;

  • .3 flag State system requirements;

  • .4 statutory, regulatory and contractual requirements;

  • .5 need for ROs to be evaluated;

  • .6 flag State, ROs, and other requirements;

  • .7 needs of other interested parties; and

  • .8 risks to the flag State.

  7.2.2 Extent of an oversight programme

  7.2.2.1 The flag State's oversight programme should reflect the size, nature and complexity of the flag State's authorization programme, as well as the following factors:

  • .1 the scope, objective and duration of monitoring activities to be conducted;

  • .2 the frequency of monitoring activities to be conducted;

  • .3 the number, importance, complexity, similarity, and locations of the ROs;

  • .4 standards, statutory, regulatory, and contractual requirements and other monitoring criteria;

  • .5 the need for accreditation or registration/certification of ROs;

  • .6 conclusions of previous monitoring activities;

  • .7 the concerns of interested parties; and

  • .8 significant changes to an RO or its operations.

  7.2.2.2 A flag State may enter into a written agreement to participate in combined monitoring/oversight activities with another flag State or States that have authorizations with the same RO provided that the level of detail regarding individual flag State requirements and individual flag State performance are addressed at a level equivalent to an oversight programme conducted by each of the individual flag State. Conversely no flag State may be compelled by another flag State or organization to accept oversight of an RO by others in lieu of conducting its own individual flag State oversight unless it so elects by written agreement or is so provided in the law of that State. A copy of all such agreements should be submitted to IMO for the information of the Member States.

  7.3 Oversight programme responsibilities, resources and procedures

  7.3.1 Oversight programme responsibilities

  7.3.1.1 The flag State is responsible for managing its oversight programme. The flag State should utilize competent individuals that have an understanding of the oversight requirements, audit principles, and the application of audit techniques. They should have management skills as well as technical and business understanding relevant to the activities to be monitored.

  7.3.1.2 Those assigned the responsibility for managing the oversight programme should:

  • .1 establish the objectives and extent of the oversight programme;

  • .2 establish the responsibilities and procedures, and ensure resources are provided;

  • .3 ensure the implementation of the oversight programme;

  • .4 ensure that appropriate oversight programme records are maintained; and

  • .5 monitor, review and improve the oversight programme.

  7.3.2 Oversight programme resources

 When identifying resources for the oversight programme, the flag State should consider the following:

  • .1 financial resources necessary to develop, implement, manage, and improve oversight activities;

  • .2 auditing techniques;

  • .3 processes to achieve and maintain the competence of staff, and to improve oversight performance;

  • .4 the availability of staff and technical experts having competence appropriate to the particular oversight programme objectives;

  • .5 the extent of the oversight programme; and

  • .6 travelling time, accommodation and other oversight needs.

  7.3.3 Oversight programme procedures

  7.3.3.1 The flag State's oversight programme procedures should address the following:

  • .1 planning and scheduling of oversight activities;

  • .2 assuring the competence of assigned personnel;

  • .3 selecting appropriate personnel and assigning their roles and responsibilities;

  • .4 conducting monitoring activities;

  • .5 conducting follow-up, if applicable;

  • .6 maintaining oversight programme records;

  • .7 monitoring the performance and effectiveness of the oversight programme; and

  • .8 reporting on the overall achievements of the oversight programme.

  7.3.3.2 For flag States with a limited authorization programme, the activities above may be addressed in a single procedure.

  7.3.4 Oversight programme implementation

 The implementation of a flag State oversight programme should include the following factors:

  • .1 communicating the objectives of the oversight programme to relevant parties;

  • .2 coordinating and scheduling monitoring activities relevant to the oversight programme;

  • .3 establishing and maintaining a process for the evaluation of assigned personnel and their continual professional development;

  • .4 selecting and appointing assigned personnel;

  • .5 providing necessary resources to the oversight programme, specifically the corresponding monitoring activities;

  • .6 robust execution of monitoring activities according to the oversight programme;

  • .7 ensuring the control of records of the monitoring activities;

  • .8 ensuring review and approval of monitoring activity reports, and ensuring their distribution to interested parties; and

  • .9 ensuring follow-up, if applicable.

  7.3.5 Oversight programme records

  7.3.5.1 The flag State's monitoring records should be maintained to demonstrate the implementation of the oversight programme and should include the following:

  • .1 all records related to monitoring activities, such as:

    • .1 plans;

    • .2 reports;

    • .3 non-conformity reports;

    • .4 corrective and preventive action reports, and

    • .5 follow-up reports, if applicable;

  • .2 results of oversight programme review; and

  • .3 records related to personnel covering subjects, such as:

    • .1 assigned personnel competence and performance evaluation;

    • .2 monitoring and/or audit team selection; and

    • .3 maintenance and improvement of competence.

  7.3.5.2 Records should be retained and suitably safeguarded.

  7.4 Oversight programme monitoring and reviewing

  7.4.1 The implementation of a flag State oversight programme should be monitored and, at appropriate intervals, reviewed to assess whether its objectives have been met and to identify opportunities for improvement.

  7.4.2 The flag State should develop and use performance indicators to monitor the effectiveness of its oversight programme for ROs. The following factors should be considered:

  • .1 the ability of assigned personnel to implement the oversight plan;

  • .2 conformity with the requirements of the RO Code, monitoring activities, and schedules; and

  • .3 feedback from clients, ROs and assigned personnel.

  7.4.3 The flag State should consider the following performance indicators when evaluating the performance of the ROs:

  • .1 port State performance of ROs;

  • .2 results of RO's internal audits;

  • .3 results of quality management system audits performed by third-party organizations (ACBs);

  • .4 the results of previous performance monitoring; and

  • .5 condition/compliance of ships that receive survey and certification from the ROs.

  7.4.4 The flag State should, on a periodic basis, evaluate its overall performance with respect to the implementation of administrative processes, procedures and resources necessary to meet its obligations as required by the conventions to which it is party.

  7.4.5 Other measures to evaluate the performance of the flag States may include, inter alia, the following:

  • .1 port State control detention rates;

  • .2 flag State inspection results;

  • .3 casualty statistics;

  • .4 communication and information processes;

  • .5 annual loss statistics (excluding constructive total losses (CTLs)); and

  • .6 other performance indicators as may be appropriate, to determine whether staffing, resources and administrative procedures are adequate to meet their flag State obligations. Other performance measurement indicators may consist of the following:

    • .1 fleet loss and accident ratios to identify trends over selected time periods;

    • .2 the number of verified cases of detained ships in relation to the size of the fleet;

    • .3 the number of verified cases of incompetence or wrongdoing by individuals holding certificates or endorsements issued under its authority;

    • .4 responses to port State deficiency reports or interventions;

    • .5 investigations into very serious and serious casualties and lessons learned from them;

    • .6 technical and other resources committed;

    • .7 results of inspections, surveys and controls of the ships in the fleet;

    • .8 investigation of occupational accidents;

    • .9 the number of incidents and violations under MARPOL, as amended; and

    • .10 the number of suspensions or withdrawals of certificates, endorsements and approvals.

  7.4.6 The oversight programme review should also consider:

  • .1 results and trends from monitoring;

  • .2 conformity with procedures;

  • .3 evolving needs and expectations of interested parties;

  • .4 oversight programme records;

  • .5 alternative or new auditing practices or monitoring activities; and

  • .6 consistency in performance between audit teams in similar situations.

  7.4.7 Results of oversight programme reviews can lead to corrective and preventive actions and the improvement of the oversight programme.


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