Increasing the possibility of performing remote ISM, ISPS and MLC audits

  • Published: 20/05/2020

Updated and expanded guidance on remote ISM, ISPS and MLC audits during the coronavirus pandemic

REMOTE SURVEY
REMOTE SURVEY: Lead auditor, Bjørn Gunnar Garnes, conducts a remote audit of the company Lustrabaatane AS from his home office in Bergen.
PHOTO: Sjøfartsdirektoratet

There are reasons to believe that the corona pandemic and subsequent restrictions will continue for a long time, and the Norwegian Maritime Authority (NMA) has therefore chosen to expand the range of remote surveys to include all audits and supervisions for SMC, ISPS and MLC in cases where physical supervision on board the vessel or the company's office is not possible due to the risk of infection or restrictions. The NMA will allow the recognised organisations (RO) to carry out remote surveys for ships and companies for which the ROs are delegated certification duties.

 

The following surveys can be managed with remote survey techniques:

  • renewal and annual DOC audits at the company's office;
  • renewal and intermediate SMC audits on board the ship;
  • renewal and intermediate ISSC verifications on board the ship;
  • renewal and intermediate MLC inspections on board the ship;
  • verifications of interim SMC, DOC, ISSC and MLC audits;
  • additional audits.

 

Requests for surveys must be submitted in the regular way, and the NMA will determine if it is possible to carry out a remote survey.

Remote surveys will require the use of digital communication solutions, such as a telephone, Skype, Teams, video conference options, etc. The company must make sure that documents are presented electronically by means of remote access, e-mail and conferencing tools, including audio, video and data sharing.

This will apply until further notice.

Possibility of extended deadline

When a remote survey is not possible, an extended deadline of three months will be granted, as stated earlier.

Alternative ways to comply with the requirements for internal audits

ISM 12.1, Part A of the ISPS Code, sections 9.4.8 «procedures for auditing the security activities» and 9.4.1 lay down requirements for carrying out internal audits, which may be difficult to conduct during the corona pandemic (Covid-19).

Therefore, the NMA has decided that companies may carry out internal audits for both ISM and ISPS remotely by means of digital communication solutions and data sharing and by the help of shipboard personnel (if applicable).

The company must carry out a risk assessment

An approval by the NMA is not required, provided that the company carries out a risk assessment of the remote audit process.

Moreover, documented procedures for an alternative internal audit process must also be established. If alternative processes are not available, internal audits due by 31 December 2020 will have the deadline extended by three months.

If the 12-months interval for internal audit is exceeded, this must be reported in the non-conformity systems and handled according to the company's internal procedures for non-conformity management.

 

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