review of the published findings of Transportation Safety Board in
their reports on shipping accidents. To join the two together, that is the delivery of
approved courses by the Institutions with the examination and certification process may
undermine the potential gains for safer ship operations arising from the introduction of
inherent quality control in the process of course approval.
iii) If the process of examination and certification of seafarers and
the Approval process were carried out together there would be a tendency for the
development of prescriptive solutions to training problems. This would be contrary to one
purpose of the Approval process in that it would not address the objective of continuous
improvement of training by the institutions through course development.
iv) The Approval process is a system based on internal monitoring and
reporting on credit courses. For internal audits it is a basic tenet that these are
carried out by a body that is not involved in the area to be audited, that is, personnel
of the Ship Safety Training and Certification Section are not involved in actual delivery
of approved courses. The same principle should apply to external audits of the results of
the approved courses, in this case personnel of the Ship Safety Training and Certification
Section are not responsible for drafting the examinations used in the approved courses,
the institution submits the instructors' suggested examination with the application for
Course Approval. Thereafter, the requirement for continued approval is to ensure that
replacement examinations are of the required standard. This audit principle is breached if
the same party carries out the approved courses and the examination standards setting
process, and effectively the certification procedure.
v) The conduct of an approved course has the focus on the formative
evaluation of candidates during training while evaluation of the course concentrates on
the summative examination of candidates for certification, each involves a different set
of priorities, remedies, skills, and obligations. Therefore to combine the two would
inevitably lead to a compromise whereby neither the approved course nor the examination is
carried out efficiently and effectively.