Impartiality and independence
How a company that supplies parts and also inspects, tests and certifies the equipment those parts go into keeps the finding separate from the sale.
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The standing position
ShipCertify inspects, tests, calibrates and services equipment aboard commercial vessels, and issues reports and servicing or test certificates for the work carried out. It also supplies the parts and consumables that equipment needs. The two are kept apart at the only point that decides anything: what is recorded as found, and whether an item meets the acceptance criterion. A report or certificate states what was examined, tested, serviced or calibrated, on what date, against which instrument and against which criterion, and it says the same thing whoever supplies the replacement. This holds for work carried out from our own six service bases, for regional mobilisation of our technicians from a base, and for work delivered through a partner firm at a port where we hold no base. The order we place with a partner carries the same requirement as a condition of the order: the finding is recorded against the acceptance criterion that applies to the item, as-found values are recorded before any adjustment, the report names the firm and the technician who attended, and no part of the partner’s fee depends on what the attendance finds or on what is sold as a result of it. A firm that will not accept that condition is not given the work, and a partner attendance is reviewed before issue on the same terms as our own.
Ownership and group relationships
A vetting department asks first who owns the company that signs the report, because a shareholding is the risk to impartiality that no procedure inside the company can control. ShipCertify is a Seaway Group company. That question is not answered on this page with an assurance, because an assurance given by the company being asked about is worth little to the department asking; it is answered by disclosure, for the scope in front of you. Any shareholding, common ownership, directorship or standing supply arrangement between us and a manufacturer, shipowner, ship manager, charterer or equipment supplier with an interest in the outcome of an attendance is treated as a risk to impartiality, recorded in the impartiality review described below, and set out in writing before the attendance is accepted where it bears on the scope quoted. A procurement department that needs the group relationships bearing on a scope stated in writing should ask at enquiry stage, to compliance@shipcertify.com, and the answer is given with the quotation, for that scope and that port. Where such a relationship exists it is a risk to be identified and controlled on the record, not a fact to be left out.
Who relies on the report being independent
A report is not read only by the person who ordered it. A class surveyor takes it as evidence at survey; a port State control officer uses it to decide whether a deficiency is raised or a ship is detained; a P&I club and a hull underwriter use it after a casualty to establish what condition the equipment was in and when it was last proved; a charterer’s vetting inspector uses it to decide whether the vessel is acceptable. Every one of them is relying on the document being independent of whoever wanted a particular outcome. A finding written to suit a commercial interest is worthless to all of them, and it is worse than worthless to the crew who will reach for the appliance when it matters.
The conflict, stated plainly
We sell the part and we test the system it goes into. A company that profits from replacing an extinguisher, a hydrostatic release unit, a battery or a radar component, and that also decides whether the installation passes, has a structural conflict of interest: a failure generates a sale and a pass does not. That is true of us across all eight disciplines we work in, and it is true whether the parts order and the attendance are quoted together or separately. The conflict is not dissolved by good intentions, and we will not claim it away. It is managed, and what follows sets out how, so that a reader can judge the arrangement instead of accepting an assurance about it.
What separates the finding from the sale
Four things do the work. A finding is recorded against the instrument and the acceptance criterion that apply to the item — a pressure, an expiry, a tolerance, a load, a functional result — and never against what would be commercially convenient. A failed item is reported with the reason it failed and the evidence for it, whether or not we supply the replacement, and an item that meets the criterion is recorded as meeting it even where a sale was there to be made. The client is free to source a replacement from anyone, and we will still test, certify and record the installation wherever the scope and the applicable instrument allow it. In calibration and instrument work, as-found values are recorded before any adjustment is made, so the document shows the condition the equipment was actually in when we arrived and not only the condition it was left in.
How the people doing the work are paid
The technician who finds the defect should have nothing to gain from finding it, and nothing to lose from not finding it. That question runs past the attending technician to the operations director who plans the attendance and the documentation staff who issue the report. None of them is paid in a way that moves with what an attendance finds: no element of pay, bonus or commission for a technician, an operations director or documentation staff is linked to parts sales, to the value of a quotation or to the outcome of an inspection, and no target is set for any of those three things. Nor is a report issued on the attending technician’s signature alone. Before issue it is checked by an operations director who did not carry out the attendance, against the record of what was examined, the instrument used and the acceptance criterion applied; where an item is recorded as failed and a replacement is quoted on the same job, that check is carried out by an operations director with no part in the quotation. The documentation staff then issue it. They do not alter a finding: a correction can come only from the technician who made it or from the reviewing director, and the reason is recorded on the face of the document.
When a client asks for a pass
It happens. The vessel sails tonight, an item is out of test, the charterer is waiting, and someone asks whether the report can be written another way. The answer is no, it is given in writing to the person who asked, and the finding stands. A recorded finding is not withdrawn because it is inconvenient; it is amended only where evidence shows it was wrong — a repeat test, a corrected reading, the wrong acceptance criterion applied — and the amendment and its reason are recorded on the face of the document. We would rather lose the order than issue a document that a surveyor, an underwriter or an investigator would later find to be untrue. A request to change a finding is recorded on the job file the same day it is made, with the vessel, the port, who asked and what was asked for, and it goes to an operations director who had no part in the attendance. That director answers the person who asked in writing within 12 hours while the vessel is still alongside, and within two working days otherwise, and the record is kept whether or not the request is pressed further. Where it is pressed after that answer, further inspection, testing and certification work for that customer is declined until an operations director who does not hold the account has reviewed it, and a parts order is never traded against a finding. Every such record is read at the impartiality review.
Where we draw the line, and when to use another supplier
We will supply parts to a vessel and also inspect, test or certify the equipment they are fitted to, and we say so on this page rather than routing the two through separate names to look independent. Where a standard, a flag administration, a class society or the client’s own procedure requires the inspection, thorough examination or certification to be carried out by a body independent of the supplier, we do not offer both on that scope: the inspection should be placed with another supplier, and we will supply the parts and support the attendance without touching the finding. If full separation is what a procurement department wants for its own reasons, that is a legitimate requirement and it costs nothing to state at enquiry stage — we will quote the parts alone or the attendance alone. Saying this loses us work, and it is the only honest answer to the question.
Raising an impartiality concern
Anyone may challenge a finding, or raise a concern that a commercial interest influenced one — a master or superintendent, an owner or manager, a class surveyor, a competing supplier, a port agent, or one of our own people. Write to compliance@shipcertify.com stating the vessel, the port, the date of attendance and the report or certificate number. It is handled under the complaints and appeals procedure on this site, which sets out who reviews an appeal, the independence required of that reviewer, and the periods for acknowledgement and for an answer. Nobody is penalised for raising a concern on reasonable grounds, our own technicians included, and that holds where the concern turns out not to be made out.
Accreditation status
ISO/IEC 17020 requires an inspection body to identify the risks to its impartiality on an ongoing basis — including risks arising from its activities, from its relationships, and from the relationships of its personnel — and to be able to demonstrate how it eliminates or minimises them. ISO/IEC 17025 requires a calibration laboratory to be impartial, and to be structured and managed so that impartiality is safeguarded. This page is written against those principles; it is not a claim to be accredited to either standard. What applies to a particular scope is answered for that scope, in writing, and not on a marketing page. Where an authorisation or accreditation applies to a quoted scope, its documentation is provided on request with the quotation, for that scope and that port, naming the instrument, the authority that granted it and the reference under which it can be checked on that authority’s own public register — which is where a buyer should verify it, rather than on a supplier’s website. Nothing on this page states that any is held.
Ownership and review
The risks to impartiality change when the business changes, so they are identified again whenever a service line is added, a base opens, a partner enters the network, or a supply arrangement with a manufacturer is put in place. This statement is reviewed at least every 12 months, and out of cycle when any of those occur. Accountability for it rests with the operations director accountable for compliance, who holds no responsibility for parts sales and none for winning the work under review. The review is not left to that one person: it is carried out with two other operations directors from different bases, neither of whom holds the accounts being examined, and it takes in every impartiality concern raised under the complaints and appeals procedure, every recorded request to change a finding, and every relationship identified under ownership and group relationships above. What the review decides, and what is changed as a result, is recorded with its date.
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