Name and/or version and brief description of procedures
A procedure is an overarching document that outlines the general steps and guidelines for a specific process or task. The description of any activity referenced in the monitoring plan must be detailed enough to serve its purpose: providing sufficient information for the administering authority to make an informed decision on whether to approve the monitoring plan. This is only achievable when the procedure is described in enough detail to assess compliance with the legal requirements of the MRV Maritime Regulation.
NEa expects that the "description of the procedure" should at least briefly cover the following:
- The purpose of the procedure
- The measures taken to achieve the procedure's goals
- How these measures are defined
- How quality assurance for the procedure is maintained
- Who is responsible for executing the procedure
- Who is responsible for controlling and maintaining the procedure
- What actions are taken in case of deviations
- When the procedure should be reviewed
Common deficiencies of the procedure
Version number and/or reference to existing procedure: The version and/or the reference number are not filled in.
Name of Person or position responsible for this procedure: The individual or position responsible for the procedure's operation is often listed instead of the manager accountable for quality control. Generally, the chief engineer is responsible for the operational execution of the procedure, while a role such as superintendent, energy manager, or HSEQ manager from the technical department is tasked with overseeing and maintaining the procedures at a management level. The individual who should be listed as responsible is the manager accountable for quality control, rather than the operational staff.
Location where records are kept: The location where records are kept should be clearly specified. General descriptions such as "on board" or "onshore" are too vague and do not provide sufficient detail. The purpose of listing a precise location is to ensure that inspectors or company personnel can easily locate the documents when required. This may include specifying exact locations, such as a particular office, department, or storage area on board the ship or at the onshore facility, so that the records are accessible without unnecessary delays. Accurate record-keeping locations contribute to efficient audits, inspections, and overall compliance.
Name of the IT system used (where applicable): It is often not filled in. It is essential to specify which IT system is used as part of the data flow, as this ensures transparency and helps verify data management processes.
Describing a procedure:
- The procedure description is often overly detailed and resembles a work instruction. The NEa does not expect a detailed document outlining specific step-by-step instructions for executing an activity.
- The procedure description is insufficient, as it omits essential general steps necessary for the process or task.
What is expected: The procedure should provide a clear, concise overview of the general steps and directives needed to ensure compliance and quality control. It should focus on the overarching process rather than minute operational details, offering enough information to understand the purpose, key measures, and responsibilities involved without becoming a detailed work manual.
Reference : Guidance document The EU ETS and MRV Maritime, General guidance for shipping companies, Final Version, 4 July 2024
