The main findings in this area relate to the issue of guidance to assist in implementation and enforcement and of administrative instructions to implement applicable international rules and regulations. Other findings against implementation relate to documentation and provision of guidance concerning mandatory convention requirements that are expressed as "to the satisfaction of the administration" or "approved" and a small number of findings related to the availability of resources to ensure compliance.
Implementation is addressed in sections 15, 16 and 17 of the III Code and forms a major component of Part II. In essence it says a flag state should:
This single area of the III Code covers a large portion of a flag state’s activities which possibly contributes to the number of findings allocated to this.
An issue that comes up repeatedly in this section of the III Code is the requirement to develop policies, guidance, and instructions. Experience from several audits makes it clear that this is something the auditors expressly look for, and they will raise a finding when there is no guidance, even if there is no evidence of a deficiency as a result. Effectively a flag state is expected to have a comprehensive set of administrative instructions, procedures and guidance documents for use by its customers, its internal staff, and by ship’s crews.
This requirement needs to also be seen in the requirements from the common part of the Code for records to demonstrate conformity, documented procedures, continuous improvement, training programmes, review and analysis of non-conformities, review of corrective actions, etc. All of these and other sections of the Code imply the creation of an effective quality management type system.
Taking that a step further, it seems clear that to avoid findings in the area of implementation a flag state need to ensure that it:
These are a wide range of responsibilities and explains why this one head of "implementation" generates such a high percentage of the identified findings.
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