Results of Assessments

  • Results of Assessments

A fundamental question at the end of each assessment year is always whether the Recognised Organisation’s (RO’s) Quality Management System has been adequately tested. QACE’s assessment is that, while the situation must continue to be monitored, the auditing standards are now at a high and consistent standard, a statement that is supported by the other observers of the scheme.

QACE would bring to the attention of its interested parties the following points:

While the ROs continue to demonstrate the very highest levels of competence and professionalism, the downturn in the marine industry business has affected the RO’s with significantly reduced workloads. A number have realigned their services and reduced staffing levels. At the same time, many marine organisations are carrying out similar exercises which may include reducing their technical capability. As a result, the industry can become increasing dependent on the RO’s services. Cost cutting can put pressure on the necessary surveyor support systems and affect areas such as training.

While QACE has not identified specific issues with any of the RO’s the situation is monitored as part of the assessment and questions are raised during the biennial Individual Recommendations meetings.

A final point on the issue is the need for the RO’s to include in their risk mitigation, the necessary flexibility and planning to react quickly, when the market emerges from recession, to have adequate resources in place when new projects are generated and workloads return to previous levels.

Keeping up with the ever-increasing flow of new requirements that must be implemented into the RO’s Rules and instructions is another major influence, that affects the ability of surveyors to get it right first time. QACE Collective Recommendation 4 draws attention to the issue and increasing the effectiveness of how the process is audited.

QACE has these issues at the forefront of its consideration of the assessment of the RO’s management systems.

What is being done with all the information?

In some more detail, when a summary of the assessments is prepared, several points are extracted that are relevant as potential recommendations for improvement to the RO or, as part of a trend across the ROs, as a potential Collective Recommendation (CR), or best practice. Trending items may also be relevant for potential issues to be raised in relation to the QSCS standard. Issues can also relate to opportunities for improvement to be raised with the audit bodies during the annual End-User Workshops.

Collective Recommendations 2019

  • Results of Assessments

1/ Focus on report sampling 

Following last year’s recommendation regarding concerns over the report checking process and the accuracy of survey reports, QACE continues to highlight the issue by bringing a focus for the auditors to ensure that sufficient time is given to audit sessions to ensure an effective sample of survey and audit reports is completed. Survey and audit reports are the record of the effectiveness and completeness of the survey and are the best place to determine the overall standard of surveying and reporting. The technique is to ensure that the sampling across the ROs is consistent and leads to confirmation, over time, that the actions the ROs are taking, generally and individually, over their report checking is working. It is particularly important that sub-offices and remote surveyors’ reports are sampled during regional or area Control Office audits.

2/ Evidence to support the downgrading of major, and deletion of ISM non- compliances

ISM audit findings have been identified where evidence of corrective action is not available or is not considered appropriate.  It is essential in ensuring the effectiveness of implementing the International Safety Management Code, with shipping companies and onboard ships, where non-conformities and especially major non-conformities are identified, that effective corrective action is evidenced and recorded before the findings are downgraded or closed. Pressure can be brought to bear where a finding delays the ship, involves a costly action or requires the implementation of improved maintenance regime.

3/ The effectiveness of ACB audit finding Corrective Actions 

Particularly when undertaking the audit finding trend analysis for each RO’s biennial individual recommendations there are occasions where identified findings are repeat of trends, identified from previous years’ trends. Just as in the case for recommendation 2, this may indicate earlier ineffective corrective actions.
Both the RO’s and ACB’s trend analysis should focus on these potential situations, if they exist, whether or not a review of the effectiveness of previous corrective action is required.

4/ The effectiveness of Fleet Monitoring and Ship Targeting 

A new procedural requirement has been issued regarding this important risk-based control. The ROs have all had an associated process in place for several years. To be effective the criteria for targeting should be tailored to reflect the RO’s fleet profile. There are different issues associated with larger, multiple ship type fleets and for smaller older ship fleets. An important element is the risk criteria that the RO applies, which should include as a minimum, ship’s age, PSC performance, poorly performing flags and most important surveyor feedback (PR17). Ineffective implementations are reactive in nature, for example, where a ship is only targeted after it has already been detained twice. One of the major benefits of an effective regime is a good PSC record. At the same time, a poor PSC record may indicate ineffective fleet monitoring. Decisions to remove a ship from targeting are to be based on data-driven evidence. Best practice includes a defined period for the ships to remain under monitoring and targeted ships subject to a minimum of two unscheduled surveys during the period. At the termination of the period the ship must evidence improved maintenance or class suspension is to be implemented. Associated QACE requirements are planned.