IJCA - Volume 2 - Flipbook - Page 24
24 The International Journal of Conformity Assessment
the need to ensure that existing
policies and regulations were
taken seriously and correctly
implemented and enforced [20].
In 2013, the FSI Sub-Committee
was renamed the Sub-Committee
on Implementation of IMO
Instruments (III). Consequently,
the IMO created the IMO
Instruments Implementation Code
(also known as the III Code or IIIC),
which is the backbone of the IMO
Member State Audit Scheme. The
III Code establishes a Code (set of
rules) against which all member
states are audited in order to
determine their capability and
resources to meet international
responsibilities in the areas of
port state, coastal state, and flag
state.
As part of IMO audit process, this
study will check the fit of the ISO/
IEC 17000 series as part of the
member states’ functions.
There are various gaps that
need to be addressed in order
to properly control the auditing
process. To further complicate
the matter, there are various
management systems that may
apply to handle this process.
Such standards belong to the
17000 Series covering the
conformity assessment field. For
this purpose, the current paper
will try to identify gaps between
the standard practices of IMO
with regards to the member
state scheme and the conformity
assessment series. The objective
would be a linkage of the existing
practices IMO is doing with the
international practices.
The accreditation of Certification,
Inspection, Verification, and
Validation Bodies is a complex
process. Its importance varies as
the object of certification (system,
product, person, or plant) and
the object of verification and
validation change — due to the
generic nature of the normative
references used.
To enhance the effectiveness and
the credibility of the accreditation
process, it is necessary to
implement specific criteria
which, without overstepping the
intention and the words of the
standard, foster full application
on the part of accredited bodies,
while at the same time providing
unambiguous, objective, and
impartial references for the
assessments performed on such
entities by Accreditation Bodies
[21].
Currently, there are several
important issues that need to
be addressed, and which create
confusion in the implementation
and enforcement of the IMO
Member States Audit Scheme.
Ultimately, these issues
obstruct the effectiveness
and control of the auditing
processes associated with
maritime safety, environmental
protection, and management
of the human element. There
are a few management system
standards belonging to the 17000
Series covering the conformity
assessment field, which may be
applied as an effective solution to
handle this process.
In accordance with the set of
principles contained in paragraph
4.1.1 of the Procedures for the
IMO Member State Audit [11] (part
II), the Secretary-General has
determined the audit schedule for
implementation of audits under
the mandatory Scheme (based on
a random drawing of the names of
member states and an associate
member who have not completed
an audit under the voluntary
Scheme), followed by those
member states and associate
members that have completed
a voluntary audit in the order
in which they were previously
audited. The audit schedule —
which is set out in the Annex 6
“Audit schedule for the mandatory
Scheme” — presents the order of
audits chronologically [22]. Cycle
of audit should be determined for
reassessment/reevaluation. The
need for surveillance is necessary,
whereas the requirements can be
checked on a regular cycle. This
is very important to maintain the
validity of a report that acts as an
existing statement of fact about
the compliance level of a member
state. Typically, each iteration of
monitoring does not require a full
repetition of the initial assessment
to meet this demand [23].
Based on the overall audit
schedule as defined by Resolution
A1067, audits under the mandatory
Scheme will be conducted at
periodic intervals not exceeding
seven years, a relatively relaxed
way for continuous oversight of
the maritime administrations.
From the EU accreditation, the
surveillance is being conducted
over a four-year period, which is
considered a long time [24].
It is worth mentioning that IMO
has been exempted from the
initial plan as included in the
Annex 6 “Audit schedule for the
mandatory Scheme” countries,
such as Georgia, Angola, El
Salvador, Colombia, Indonesia,
and Cook Islands, which have
volunteered to conduct the audit
prior to it becoming mandatory.
Additionally, these countries have
postponed their mandatory audit,
on the basis they have performed
a voluntary one, until the rest
of the maritime administrations
finish with their audit obligations
and the cycle starts over.
Based on ISO/IEC 17011:2017
[25], clause 7.9 mentions that an