The code has a fairly long section on flag state surveyors. The very first paragraph of the section on flag state surveyors (Paragraph 28) makes it clear that it is referring to ALL personnel who manage, perform, and verify work relating to and affecting safety and pollution prevention. Hence the obligations under this head also cover independent inspectors who conduct inspections and surveys on behalf of the flag states well as the flag state’s own exclusive surveyors.
The summary of audit findings makes reference to recurrent findings in the areas of:
All of these point to the overall sense that there needs to be a quality management system as these are all elements that are standard in something like the ISO 9001 standard. Clearly the IMO auditors and the code expect some form of documented system that covers these areas. Without it, a finding against implementation or against flag state surveyors is guaranteed.
The code is very specific and requires flag states to ensure that as a minimum, personnel responsible for performing surveys, inspections, and audits on its ships have appropriate qualifications and seagoing experience, or a relevant degree, or accreditation through a formal training programme.
The code devotes quite a lot of detail to the need for a documented system for the qualification of personnel and the updating of their knowledge and says that the qualifications should encompass:
In addition and importantly, the code requires that the surveyors should be issued with an identification document to be carried when performing tasks.
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