1 The Maritime Safety Committee, pursuant to the
provisions of SOLAS regulationfootnote
V/19-1.14 and subject to the relevant provisions
of section 14 of the Revised performance standardsfootnote, has determined the following in relation
to the review and audit of the performance of LRIT Data Centres and
of the International LRIT Data Exchange.
2 The audit client is all Contracting Governments
to the 1974 SOLAS Convention (Contracting
Governments) acting through the Committee.
3 The auditor is the LRIT Coordinator.
4 The auditees are all LRIT Data Centres (DCs)
and the International LRIT Data Exchange (IDE).
5 The audit programme is a third-party audit conducted
by the LRIT Coordinator annually.
Audit programme objectives
6 The objectives of the review and audit of the
performance of DCs and of the IDE are:
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.1 to verify that the LRIT system operates in
accordance with the provisions of SOLAS regulation
V/19-1 and of the Revised performance standards, taking into
account the related provisions of the Technical specification for
the LRIT system and any relevant decisions of the Committee;
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.2 to verify that Contracting Governments and
Search and rescue services receive only the LRIT information they
have requested and are entitled to receive;
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.3 to verify that DCs operate in accordance with
the provisions of SOLAS regulation V/19-1 and
of the Revised performance standards, taking into account the related
provisions of the Technical specification for the LRIT system and
any relevant decisions of the Committee;
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.4 to verify that the IDE operates in accordance
with the provisions of SOLAS regulation V/19-1 and
of the Revised performance standards, taking into account the related
provisions of the Technical specification for the LRIT system and
any relevant decisions of the Committee;
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.5 to identify any need for initiating corrective
and/or preventative actions in the LRIT system; and
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.6 to identify opportunities for improving the
efficiency, effectiveness and security of the LRIT system.
7.1 The main criteria are SOLAS regulation V/19-1 and the Revised performance
standards.
7.2 The supplementary criteria are the Technical
specifications for the LRIT systemfootnote;
guidance, guidelines and recommendations approved or adopted by the
Committee in relation to the LRIT system; and instructions of the
Committee to the LRIT Coordinator in connection with the review and
audit of the performance of the auditees.
7.3 The documents setting out the main and supplementary
criteria are listed in appendix 1 which provides an index of all documents
relating to the long-range identification and tracking of ships as
on 21 November 2014.
7.4 After each session of the Committee and when
amendments to any of the technical documentation for the LRIT systemfootnote are agreed, the Secretariat should update
the information provided in appendix 1 accordingly and should forward
the revised copy of appendix 1 to the LRIT Coordinator and to all
auditees by using the contact details provided in the LRIT Data Distribution
Plan.
8.1 The scope of the audit is limited to matters
relating to the operation of the DCs and of the IDE to the extent
such matters can be reasonably and with confidence verified through
the audit evidence.
8.2 Matters relating to the implementation of
the provisions of SOLAS regulation V/19-1 and
of the Revised performance standards by Contracting Governments are
outside the scope of the audit and fall within the scope of the Framework
and procedures for the Voluntary IMO Member State Audit Scheme (resolution A.974(24)).
8.3 Specifically all matters which would require
the provision to the LRIT Coordinator of list(s) of ships which at
any particular time are required to transmit LRIT information in accordance
with the provisions of SOLAS regulation V/19-1.4.1 are outside the scope of the audit. For example, questions
such as whether all such ships have in fact been integrated and are
transmitting LRIT information or whether or how the provisions of
SOLAS regulation V/19-1.7 are implemented.
8.4 Unless the Committee decides otherwise, the
LRIT Coordinator is not required to audit the fee structure of DCs
or of the IDE.
9.1 The LRIT Coordinator and the auditee should
be well aware of the importance of the task they are about to perform
and should act with care and professionalism when discharging their
responsibilities related to the review and audit.
9.2 In this context, the LRIT Coordinator should:
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.1 conduct a fair, consistent, professional, independent
and evidence-based audit;
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.2 discharge its responsibilities in relation
to the audit in a timely manner;
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.3 cooperate and provide assistance to the auditee
on any matters related to audit;
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.4 establish communication with the auditee and
provide the auditee with necessary information related to the audit;
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.5 make audit findings available to the auditee
and seek contributions of the auditee within an established time frame;
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.6 prepare a complete, accurate, concise and clear
record of the audit and make copies available to the auditee;
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.7 submit a comprehensive report of the audit
to the Secretary-General of IMO; and
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.8 make available copies of the completed summary
audit reports to the NCSR Sub-Committee, for consideration.
9.3 On its part, the auditee will be expected
to:
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.1 cooperate with the LRIT Coordinator and to
discharge its responsibilities in relation to the audit in a timely
manner;
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.2 conclude a contractual agreement with the LRIT
Coordinator with respect to the legal, operational and financial commitments
of the audit;
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.3 settle its financial obligations vis-à-vis
the LRIT Coordinator in accordance with the arrangements it has made
with the LRIT Coordinator;
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.4 cooperate and make available to the LRIT Coordinator
the information and audit evidence required to enable the satisfactory
completion of an audit of its performance;
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.5 determine and propose corrective actions to
address any significant audit findings; and
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.6 keep the LRIT Coordinator informed of the status
of their finding note(s).
10.1 The LRIT Coordinator should establish the
details of the audit evidence it requires to be submitted for the
review and audit of the performance of DCs and of the IDE.
10.2 The audit evidence should, at least, consist
of:
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.1 replies to questionnaire(s) developed by the
LRIT Coordinator taking into account the audit objectives, criteria
and scope;
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.2 samples of LRIT information and samples of
LRIT messages, including related samples of journals, where such ones
are required;
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.3 statistics compiled by DCs and the IDE, as
appropriate;
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.4 records of communications between the LRIT
Coordinator and DCs and/or the IDE;
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.5 data and information contained in the production
environment of the LRIT Data Distribution Plan; and
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.6 data and information that may be obtained from
Search and rescue services.
10.3 The LRIT Coordinator should put in place
the necessary arrangements to ensure that all audit evidence is protected
from unauthorized access or disclosure as from the time such evidence
is received by the LRIT Coordinator.
10.4 The LRIT Coordinator is not normally required
to submit for the consideration of the Committee any of the audit
evidence.
10.5 The LRIT Coordinator should destroy all audit
evidence relating to the review and audit of the performance of a
DC or of the IDE immediately after the Committee has reviewed and
accepted its related report, or after the resolution of any pending
or outstanding issues or after the closing of any outstanding non-conformities,
whichever is later. The method for the destruction of the audit evidence
remains at the discretion of the LRIT Coordinator.
10.6 All DCs are required to provide to the LRIT
Coordinator at least one sample of LRIT information and LRIT messages
which covers 30 consecutive calendar days (the 30-day sample) during
the period which is to be covered by the audit. The LRIT Coordinator
should determine, in consultation with the DC concerned, the first
and last date to be covered by the samples. The DC and the LRIT Coordinator
should endeavour to reach a mutual understanding on the dates to be
covered by the sample in cases of any difference of opinion. If such
consultations do not yield an agreed approach, then the decisions
of the LRIT Coordinator shall prevail.
10.7 Taking into account the number of DCs subject
to audit and review in a given calendar year, it is recognized that
the IDE may be required to provide to the LRIT Coordinator the journal(s)
of all transactions for the whole calendar year. The LRIT Coordinator
and the IDE should consider and agree practical arrangements for the
provision of the IDE Journals to the LRIT Coordinator for the purpose
of review and audit of the performance of DC and of the IDE. The LRIT
Coordinator should provide relevant information to the Committee,
as appropriate.
10.8 The LRIT Coordinator may, if it finds it
fit and appropriate, require the submission of further audit evidence
as the circumstances may warrant.
10.9 The LRIT Coordinator should establish and
make known to all DCs and to the IDE the method(s) and format(s) to
be used for providing the audit evidence and in particular the samples.
The LRIT Coordinator should provide information to this end to the
Committee.
10.10 Notwithstanding the related provisions of
the Revised performance standards, the LRIT Coordinator should seek
the provision of audit evidence from Search and rescue services if
it finds it fit and appropriate.
Audit plan and procedures
11 The LRIT Coordinator should develop the audit
plans and procedures and should provide details of these to all DCs
and the IDE. The LRIT Coordinator should provide information to this
end to the Committee.
Audit findings and corrective actions
12.1 The LRIT Coordinator should evaluate the
audit evidence against the audit criteria and generate audit findings.
Audit findings can indicate either conformity or non-conformity with
the audit criteria. Additionally, some audit findings can identify
opportunities for improvements.
12.2 The LRIT Coordinator should determine and
grade all non-conformities as either major non-conformities or non-conformities.
Opportunities for improvements may be indicated as observations by
the LRIT Coordinator.
12.3 The DC concerned or the IDE should, in consultation
with the LRIT Coordinator, determine and propose the corrective action(s)
and the period within which the non-conformities should be dealt with
and closed. DCs and the IDE should always keep the LRIT Coordinator
informed of the status of their finding note(s). The completion and
effectiveness of corrective actions should be verified by the LRIT
Coordinator, normally at the next audit.
12.4 The LRIT Coordinator should, if it finds
it fit and appropriate, require the submission of further audit evidence
or samples with a view to ascertaining that the agreed corrective
action(s) have been implemented and the non-conformity has been dealt
with and/or that any further non-conformities have not occurred. If
the LRIT Coordinator does not see a compelling need to request submission
of further audit evidence, the verification of the corrective actions
should be undertaken at the next audit of the DC concerned or of the
IDE.
12.5 In case any identified non-conformity affects the
continuity of the LRIT system, the LRIT Coordinator should inform, as soon as is
practically possible, the members of the Operational governance body, as defined in
MSC.1/Circ.1376/Rev.2, and should provide to them relevant
details in order to enable them to determine the actions to be taken in accordance to
the instructions of the Committee.
13.1 Audit date should be considered as the date
on which the LRIT Coordinator will begin the audit analysis and by
which the LRIT Coordinator must therefore have received the required
audit evidence.
13.2 In this context, the LRIT Coordinator should,
in consultation with the auditee, determine and confirm the audit
date prior to audit. The auditee and the LRIT Coordinator should make
every attempt to resolve any diverging opinions concerning the audit
date. However, if an agreement cannot be reached, then the decisions
of the LRIT Coordinator shall prevail.
14 All correspondence, records, communications,
audit evidence and audit plans and procedures should be in the English
language.
15.1 For each of DCs and for the IDE, the LRIT
Coordinator should:
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.1 submit to the Secretary-General a detailed
audit report which should provide a complete, accurate, concise and
clear record of the audit and should include or refer to the following:
the audit objectives, the audit scope, particularly identification
of the unit or processes audited and the time period covered; a list
of the auditee representative(s); the dates when the audit activities
were conducted; the audit criteria; the audit findings; the audit
conclusions; and any statement of a confidential nature; and
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.2 make available to the Committee, through the
NCSR Sub-Committee, a summary audit report which should include or
refer to the following: the audit findings, including information
on non-conformities and their status; the audit conclusions; any uncertainties
and/or obstacles encountered that could decrease the reliability of
the audit conclusions; any areas not covered although within the scope
of the audit; any unresolved diverging opinions between the LRIT Coordinator
and the auditee; recommendations for improvement, if any; and agreed
follow-up action plans, if any.
15.2 The LRIT Coordinator should, prior to submitting
the detailed audit reports to the Secretary-General and making the
summary audit reports available to the NCSR Sub-Committee, forward
these, no later than one month after the completion of the audit,
to the auditee for its perusal and comments, if any.
15.3 Any comments of the auditee should be submitted
to the LRIT Coordinator within 15 days after the date of which the
report has been sent to the auditee and, unless the LRIT Coordinator
and the auditee agree to include these in the summary audit report,
these should be included in the detailed audit report.
15.4 The LRIT Coordinator and the auditee should
endeavour to resolve any difference of opinion in relation to the
contents of the detailed and the summary audit reports within five
days after the date the auditee has submitted its comments. If the
matter cannot be resolved, the comments of the auditee should be included
in the summary audit report for consideration of the issue by the
Committee.
15.5 The LRIT Coordinator should send copies of
the detailed and the summary audit reports submitted to the auditee
concerned. The detailed and the summary audit reports should be in
the English language.
15.6 The LRIT Coordinator should make the summary
audit reports available to the NCSR Sub-Committee in accordance with
the arrangements to be agreed between the Organization and the LRIT
Coordinator. The LRIT Coordinator should also provide information
at each session of the Sub-Committee, in accordance with the Guidelines
on the organization and method of work of the Maritime Safety Committee
and the Marine Environment Protection Committee and their subsidiary
bodies (MSC-MEPC.1/Circ.4/Rev.3), on the audits that have been
completed since the previous session of the Sub-Committee.
15.7 The summary audit reports should not be translated
in the three working languages of the Organization and should be made
available as documents containing information in the English language
only.
15.8 The Secretary-General should protect the
detailed audit reports from unauthorized access or disclosure and
should keep these for a period not exceeding five years as from the
date of completion of the audit they referred to and afterwards should
destroy these, provided there are no outstanding or pending issues.
15.9 The Secretary-General should make available
to the Committee or the NCSR Sub-Committee the detailed audit reports,
if requested. In such cases, the detailed audit reports should not
be translated in the three working languages of the Organization and
should be made available as documents containing information in the
English language only.
Reporting on the review and audit of the performance
of DCs and/or of the IDE
16.1 The LRIT Coordinator should report to each
session of the NCSR Sub-Committee on the review and audit of the performance
of DCs and/or of the IDE which had been conducted and completed since
the previous session of the Sub-Committee.
16.2 The anniversary date of the IDE is 15 October
of each year.
16.3 The anniversary date of a DC is the date
on which DCs:
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.1 which participated in the prototype testing
phase, become part of the production environment of the LRIT system;
and
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.2 which have undergone or are undergoing or are
to undergo developmental and integration testing, have completed or
are to complete the integration testing phase.
16.4 In addition, the anniversary date of an existing
DC may change in the way specified below if the DC concerned undergoes
additional testing for any of the following reasons:
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.1 if a NDC is to start providing services to
Contracting Government(s) other than that which established the centre
– Anniversary date remains unchanged;
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.2 if a NDC is to become an RDC or a CDC –
Anniversary date becomes the date on which the new testing was completed;
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.3 if a NDC that is already providing services
to other Contracting Government(s), or a RDC or a CDC is to start
providing services to Contracting Government(s) which was/were not
included in previous testing – Anniversary date remains unchanged;
and
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.4 if a Contracting Government is to become part
of the establishment of an existing RDC or CDC – Anniversary
date remains unchanged;
16.5 The review and audit of the performance of
DCs and of the IDE should be carried out within three months before
or after the anniversary date, provided the period between two consecutive
audits does not exceed 15 months. A DC or the IDE may still be liable
for review and audit of its performance even after it has ceased its
operations provided that it had been operational in the production
system at least six months since its first integration or anniversary
date, whichever applies.
16.6 A DC may request the LRIT Coordinator to
review and audit its performance on any date within three months before
or after the anniversary date referred to in paragraph 16.3 or 16.4,
provided the first audit is not held more than 15 months after the
date referred to in paragraph 16.3. If the audit, upon request of
the DC and subject to acceptance of the LRIT Coordinator, is carried
out more than three months before the anniversary date, the new audit
date should be considered thereafter as being the new anniversary
date. The LRIT Coordinator should provide to the NCSR Sub-Committee
information to this end as appropriate.
16.7 If the first audit of a DC cannot be carried
out within 15 months after the date referred to in paragraph 16.3
or 16.4, or if the period between two consecutive audits exceeds 15
months, the DC concerned should remain liable to complete that audit
at the earliest opportunity. This liability should accumulate until
all outstanding annual audits have been completed. The LRIT Coordinator
should provide to the NCSR Sub-Committee information to this end,
as appropriate. The audit will additionally report on the reason(s)
that led the DC to be audited after the maximum 15-month period, and
will recommend that the DC concerned takes all necessary measures
to avoid the need to conduct further audits in the future which exceed
the maximum 15-month period.
17 Appendix 2 provides related information on
a number of matters in connection with the review and audit of the
performance of DCs and of the IDE of a technical nature.
Audit programme review and monitoring
18 Contracting Governments acting through the
Committee should monitor the implementation of the audit programme
and, at appropriate intervals, should review it to assess whether
its objectives have been met and identify opportunities for improvement
or to initiate corrective or preventative actions.