Monitoring & Auditing of

ROs

Bernardino Rio Senior Assessor

Department B.2.2
Lisbon / April 2018
Directive 2009/15/EC

Working relationship (Art. 5)

• Written agreement
• Provisions of Appendix II of IMO
resolution A.739(18)
• Liability provisions
• Provisions for audit by the administration
• Possibility for ship inspection
• Compulsory reporting of fleet information

2
Directive 2009/15/EC

MONITOR:

to watch, keep Collect

track of, or
check usually information
for a special
purpose

Report
Analysis
/Action

3
Directive 2009/15/EC

• 3. The Administration should establish

a system to ensure the adequacy of work
performed by the organizations authorized
to act on its behalf. Such a system should,
inter alia, include the following items:
.1 Procedures for communication…
IMO Res .2 Procedures for reporting (…) and
A.739(18), processing of reports by the Administration
Appendix II .3 Additional ship’s inspections by the
Administration
.4 The Administration’s
evaluation/acceptance of the certification
of the organization’s quality system…
.5 Monitoring and verification of class
related matters…”

4
Directive 2009/15/EC

Article 9
1. Each Member State shall satisfy itself that the
recognised organisations acting on its behalf for the
purpose of Article 3(2) effectively carry out the
functions referred to in that Article to the satisfaction
of its competent administration.
2. In order to carry out the task referred to in paragraph
1, each Member State shall, at least on a biennial
basis, monitor every recognised organisation acting
on its behalf and shall provide the other Member
States and the Commission with a...
5
Monitor

Observe and check the progress or quality of

(something) over a period of time; keep under
systematic review:
is concerned with continual observation

6
RO Code, Part 3

PART 3 of the RO Code

OVERSIGHT OF RECOGNIZED ORGANIZATIONS
1 PURPOSE
Part 3 of the RO Code provides guidance on flag
State's oversight of ROs authorized to perform
statutory certification and services on its behalf.
Part 3 also provides guidance on the principles of
oversight that may include ship inspection, auditing,
and monitoring activities.

7
RO Code Part 3, 5

Monitoring and verification:

- Oversight of RO quality management system;
- Observation or systematic review of audit reports
of the quality management system audits
conducted by an independent third party;
- Verification and inspection of ships

8
RO Code Part 3, 5

Monitoring and verification:

- Oversight of RO quality management system;
- Observation or systematic review of audit reports
of the quality management system audits
conducted by an independent third party;
- Verification and inspection of ships

9
DEFINITIONS (ISO 9000:2015)

Audit
systematic, independent and documented process for
obtaining audit evidence and evaluating it objectively to
determine the extent to which audit criteria are fulfilled
Audit criteria
set of policies, procedures or requirements used as
reference against which objective evidence is compared
Audit scope
extent and boundaries of an audit

10
PRINCIPLES OF AUDITING
(ISO 1911:2011)

a) Integrity: the foundation of professionalism

b) Fair presentation: the obligation to report truthfully
and accurately
c) Due professional care: the application of diligence
and judgement in auditing
d) Confidentiality: security of information
e) Independence: the basis for the impartiality of the
audit and objectivity of the audit conclusions
f) Evidence-based approach: the rational method for
reaching reliable and reproducible audit conclusions
in a systematic audit process

11
Audit Criteria

• FS Agreement
• International Conventions requirements including
RO Code
• Regulation (EC) 391/2009

12
Types of Audit

SYSTEM AUDIT

PROCESS AUDIT

PRODUCT
AUDIT

13
Types of Audit

• System audit
 e.g. Quality Management System Audit
• Process audit
 e.g. Transfer of class process
• Product audit
 e.g. supplementary surveys [RO Code Part 2,
20.1 and 20.2]

14
FS Audit

- A second party audit

- Assess the capability of the company (RO) to meet
contract (FS agreement) requirements

15
System Audit

• System audit
• An audit conducted on a management system;
• Conducted against system requirements: e.g.:
 IACS QSCS;
 ISO 9001:2015, etc.

16
Process Audit

• Process audit

Verification that the inputs, actions and outputs are in

accordance with the process requirements

17
EMSA’S EXPERIENCE

European Commission: assessment of the EU recognised organisations

EMSA entrusted by the Commission with the task of carrying out the
necessary inspections.

Since 2004, more than 260 inspections:

head offices, region / field/ site offices visits to ships

18
EMSA’S EXPERIENCE

Resources and
Objectives
competence

RO
monitoring

Inspection planning and Evaluation and

execution improvement

19
EMSA’S EXPERIENCE

Knowing the ROs Inspections

• IMO • What to look
• IACS at/potential issues
• Annual information • Inspection record • Assessment criteria
• Industry
• PSC performance • Where to look / • EU law / FS
• FS /PS requirements
• RO related news ( RO Locations
own site, specialised • IMO requirements
press, etc.) • Class rules
Knowing the context
RO profile
- Developments

20
EMSA’S EXPERIENCE

PREPARATION
REQUEST FOR RO ANALYSIS OF
INFORMATION INFORMATION WORK PLAN,
• UPDATED PROCEDURES • FOCUS AREAS CHECKLISTS, ‘AIDE-
• DETAILED • SCOPE OF INSPECTION MEMOIRE’
INFORMATION ABOUT • SELECTED FILES
LOCATION ACTIVITIES

21
EMSA’S EXPERIENCE

EXAMINATION OF
STAFF INTERVIEWS
RECORDS

INSPECTION

OBSERVATION OF FINDINGS PRESENTED

ACTIVITIES AT CLOSING MEETING

22
ISM

REQUEST FOR INFORMATION

•List of shipboard and office audits
•Details of company,
•Details of ship: IMO, Flag, Type, etc.
•Date of audit

23
ISM

ANALYSIS
Look at PSC records of ships / Companies (Equasis, Seaweb)

Cross check audit dates vs PSC/FS inspections

Identification of ships detained shortly before/after audit; poor

performing ships/companies

Select files for review

24
ISM

File for review?

Intermediate audit Annual surveys

Ship detained
completed 9 completed 17
January 2018
November 2017 December 2017
17 conditions
No NC
of class Drills
identified
imposed

Only two Survey results

ISM related
‘observations’ indicate lack of
deficiencies
imposed maintenance

25
ISM

What was found?

Management
Auditor Audit control
Lack of records of Insufficient time Assignment of
qualification and Application of auditor
training criteria for NC None of the issues
Non exclusive assessment were identified by
auditor Audit procedures internal verification
The NES employer not followed of the job
was also the
managing company
for the ship !!!

26
TOC &COF

REQUEST FOR INFORMATION

•List of TOC
•Details of ship: IMO, Flag, Type, YB,
etc.
• Date of survey(s)

27
TOC & COF

ANALYSIS
Look at PSC / survey history of ships

Cross check TOC dates vs PSC/FS inspections

Identification of ships detained shortly before/after TOC

Select files for review

28
Transfer of Class and Change of Flag

With what? With whom?

Materials & Qualified
Equipment surveyor(s)

INPUTS Transfer of
Class & Change OUTPUTS
Owner’s request
FS requirements of Flag Class & Statutory
certificates
Information to FS
How?
What results?
(Support processes, (performance
procedures & Methods indicators)

29
TOC & COF

Inputs Owner’s request

FS Agreement

Status & plans from LS

30
TOC & COF

With Use of exclusive surveyors

whom?

Qualified according RO
systems
Knowledge of IMO Res
A1104(29)
31
TOC & COF

How? Availability of updated

procedures and instructions
FS requirements

Plans and drawings.

32
TOC & COF

With Use of approved service

what? suppliers

Use of qualified/authorised
service technicians
Measurement tools
calibrated
33
TOC & FOC

Performance Has RO identified/set any performance indicator?

& Results
Handling of Retroactive Requirements

Handling of CC and statutory conditions

Handling of exemptions and equivalences. Acceptance by

gaining FS
Handling of equipment required to be certified

Confirmation of class and statutory surveys in required scope,

including FS specific instructions

34
TOC & COF

Output Issue of full term certificates

Ship meeting class &

statutory requirements,
including FS specific

Report to FS

35
TOC & COF

File for review?

TOC surveys completed 6 June 2016

Bulk carrier >30 Year

Record show repeated TOC /COF in recent years

Poor PSC record

Class suspended before TOC & COF

36
TOC & COF

What was found?

Management
Surveyors Survey control
One of the attending Class entry survey Deviation from rules
surveyors was not not in required scope & statutory
qualified for ESP BC Insufficient time requirements
given the type and authorised by HO
age No contact with FS
In water survey in lieu prior to issue
of DD, against certificates despite
requirements deviation from SOLAS
and LL requirements
Statutory surveys not
as required

37
Workshop No. 1 - Planning

Briefing.
- You are provided with the following documents:
- RO agreement
- RO profile
- RO procedures for Transfer of Class & Change of flag
- FS instructions for ToC & CoF
- Review the documents and:
- Prepare an audit programme for a HO inspection
- Prepare a checklist for verification of compliance with the RO with the
agreement.
- Prepare a checklist for examination of ToC & CoF
- Examine the ToC & CoF case provided

38
Workshop No. 2 - Competence

Briefing.
- You are provided with the following documents:
- RO quality manual
- RO training and qualification procedure
- RO monitoring procedure
- RO staff training and qualification records

- Review the documents against the requirements of

the Agreement and RO Code and determine to what
extent the RO meets the requirements.

39
Workshop No. 3 - File review

Briefing.
- You are provided with the following documents:
- Ship PACIFICA Survey status prior to ToC & CoF
- Ship PACIFICA ToC & CoF survey report.
- Refer also to the documents provided and checklist developed in
workshop #1
- Review the documents and determine to what extent
the applicable requirements have been complied with
- What other documents /audit trails would you like to
examine / follow?

40
Workshop No. 4 - File review

Briefing.
- You are provided with the following documents:
- Renewal survey records. Ship ‘TEREBELLUM’

- Review the documents and determine to what extent

the applicable requirements have been complied with
- What are your conclusions about the surveys done/
competence of society?

41
Workshop No. 5 - File review

Briefing.
- You are provided with the following documents:
- Renewal survey 23 January 2017
- Class Occasional survey(following PSC detention) and single voyage
declaration 26 February 2017
- ISM audit 19 October 2017
- PSC detention 23 October 2017

- Review the documents and determine to what extent

the applicable requirements have been complied with:

- What are your conclusions?

42
Directive 2009/15/EC
twitter.com/emsa_lisbon
facebook.com/emsa.lisbon