Annex - Guidelines for the Verification and Company Audits by the Administration of Part III of the Ship Energy Efficiency Management Plan (SEEMP)

1 Introduction

1.1 The Guidelines for the verification and company audits by the Administration of part III of the Ship Energy Efficiency Management Plan (SEEMP) have been developed to assist Administrations with carrying out the verifications and company audits required by regulation 26.3.3 of MARPOL Annex VI.

1.2 The aim of these Guidelines is to:

• .1 provide guidance to Administrations to effectively and efficiently carry out verifications of, and company audits related to, the Ship Energy Efficiency Management Plan (SEEMP) to ensure compliance with regulation 26.3 and with regulation 28 of MARPOL Annex VI; and

• .2 ensure that the SEEMP includes the relevant elements in accordance with regulation 26.3 of MARPOL Annex VI, as applicable, and that the SEEMP is reliable, while minimizing the costs and associated burdens to the ship and the Administration.

1.3 The verification of and the company audits related to the SEEMP may be carried out by the Administration or an organization recognized by it.^footnote

1.4 It should be noted that the Organization has adopted separate 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity (resolution MEPC.348(78), adopted 10 June 2022).

2 Definitions

For the purpose of these Guidelines, the definitions in MARPOL Annex VI apply.

3 Responsibilities

3.1 The responsibilities of Administrations and ships are set out in MARPOL Annex VI. These Guidelines do not change those responsibilities or create any new obligations.

3.2 An Administration may authorize an organization to carry out verifications of, and company audits related to, the SEEMP, and issue the Confirmation of Compliance, submit the data to the Organization and perform other actions authorized by the Administration. In every case, the Administration assumes full responsibility for all tasks conducted by the Administration, or any organization duly authorized by it (hereinafter referred to as "the Administration").

3.3 Verification of, and company audits related to, the SEEMP do not relieve the company, management, those undertaking delegated SEEMP tasks, officers or seafarers of their obligations as to compliance with those requirements in regulation 28 of MARPOL Annex VI.

3.4 The company is responsible for:

• .1 informing relevant personnel and those undertaking the delegated SEEMP tasks about the content of the SEEMP;

• .2 appointing responsible members of staff to accompany the verifier; and

• .3 providing access and evidential materials as requested by the verifier.

4 Verification of the SEEMP and Documentation

4.1 To facilitate the verification, the Administration should indicate what documentation, if any, the company should submit along with its SEEMP.

5 Initial, Periodical, Additional Verifications and Company Audits

5.1 The verification and audit process for the SEEMP according to regulation 26.3.3 of MARPOL Annex VI should normally involve the following:

• .1 initial verification;

• .2 periodical verifications;

• .3 additional verifications; and

• .4 company audits.

5.2 The initial, periodical, additional verifications and company audits should be based on documentary evidence.

Initial verification (regulation 5.4.6 of MARPOL Annex VI)

5.3 The Administration should perform an initial verification to ensure that for each ship to which regulation 26.3 of MARPOL Annex VI applies, the SEEMP complies with regulation 26.3.1 of MARPOL Annex VI. In accordance with regulation 5.4.6 of MARPOL Annex VI, this process must be done prior to 1 January 2023 for existing ships or before a new ship is put in service.

5.4 On satisfactory assessment of the SEEMP part III, the Administration can issue the Confirmation of Compliance (sample format in the annex to this document).

Periodical verification (regulation 5.4.6 of MARPOL Annex VI)

5.5 If any of the elements in regulation 26.3.1 is updated, and in any case every three years, the Administration should perform a periodical verification to ensure the SEEMP complies with regulation 26.3.1 of MARPOL Annex VI in accordance with regulation 5.4.6 of MARPOL Annex VI.

5.6 On satisfactory assessment of SEEMP part III, the Administration should issue the Confirmation of Compliance (sample format in the annex to this document).

Additional verifications (regulation 6.8 of MARPOL Annex VI)

5.7 The Administration should, in the case of a ship rated as D for three consecutive years or a ship rated as E, perform an additional verification to ensure that a plan of corrective actions has been established in accordance with regulations 28.7 and 28.8.

5.8 On satisfactory verification of the plan of corrective actions, the Administration can issue the Statement of Compliance according to regulation 6.8.

Company audits

5.9 The Administration should, in accordance with regulation 26.3.3, perform periodical company audits to:

• .1 verify that the SEEMP for which the Confirmation of Compliance has previously been issued complies with regulation 26.3.1 and, in the case of non-compliance, require remedial action;

• .2 confirm that the ship is being operated in accordance with SEEMP part III, regardless of its rating;

• .3 verify the progress made in the (corrective) actions to be taken in the execution of the three-year implementation plan and the plan of corrective actions;

• .4 verify self-assessment and improvement of actions taken; and

• .5 verify the assignment of responsibilities related to the implementation and monitoring of measures.

5.10 The periodical company audits may include annual audits of the company (company audits) and verifications on board the ship (shipboard audits).

5.11 These additional shipboard verifications and company audits, if undertaken, should be six months after the issuance of the Statement of Compliance at the latest.

6 Elements of Verification

6.1 Verification could consist of, but not be limited to, the following elements:

• .1 verification of the method of calculations of the CII and that there is a proper description of the method to report ship data to the Administration;

• .2 assessment of the effectiveness (of the combination) of measures, so that when implemented the ship will with reasonable assurance achieve the required annual operational CII, including the goal as set in accordance with paragraph 4.1.7 and 9.7 of the SEEMP Guidelines; and

• .3 robustness of the three-year implementation plan and, where applicable, the plan of corrective actions, including whether realistic timelines for implementation of actions have been included.

7 Combination with ISM Audits

7.1 Verification of implementation aspects of the SEEMP on board (monitoring, self-evaluation and improvements, etc.) could be combined with the ISM audits.

7.2 The verifications may be carried out in accordance with guidelines on implementation of the ISM Code referred to in Chapter 15 of the ISM Code.

Annex - Sample Format for Confirmation of Compliance