What are the steps of verification?
According to the ISO 14065 standard, which is the adopted standard for the accreditation of verifiers under the EU MRV Regulation, the verification process includes the following 8 steps.
Step 1 – Risk Analysis
The aim of the risk analysis is to identify where there are risks of misstatements or non-conformities in the procedures and emissions report, so that the verification activities can be focused on the higher risk areas.
The verifier considers the following inputs:
- The assessed Monitoring Plan and any changes to-date
- The nature, scale and complexity of the ship operator's operations and MRV processes
- The complexity of IT systems used to handle fuel data and other relevant information
- The existence of an environmental or a quality management system
- The existence of quality control and assurance processes related to data monitoring
- The organisational structure of MRV and how it is integrated into the business
- The availability of information and data in terms of access, completeness and accuracy.
Step 2 – Verification Plan
Based on the outcome of the strategic and risks analysis, the verifier prepares a plan, which includes:
- A programme that includes the nature, scope and timeframe of verification activities
- The list of people to interview, and IT systems and processes to observe
- A data analysis plan setting out the data to be sampled and tested
- The details of any site visit at the shipping company's office, if required.
Step 3 – Business Process Analysis
The verifier implements the verification plan in order to assess the reliability, credibility and accuracy of the monitoring systems, confirm that the collection of the data has been carried out in accordance with the applicable rules and check that the relevant records of the ship are complete and consistent.
The process analysis is based on interviews, document review, observation of systems and processes, and corroboration of information. The process includes:
- Interview with staff involved in the data collection and transformation processes
- Observation of IT systems or spreadsheets used to process fuel data and other information
- Review of documents including quality manuals, MRV manuals, calibration certificates and documented quality procedures and maintenance activities
- Review of voyage documentation including relevant logs, noon reports, bunker fuel delivery notes, etc.
Step 4 – Data Analysis
The verifier conducts a thorough analysis of fuel data and other relevant information to identify data gaps and highlight implausible and potentially erroneous values.
The verifier assesses the reliability, credibility and accuracy of the reported data and information relating to carbon emissions, in particular:
- Attribution of fuel consumption to voyages
- Reported fuel consumption data and related measurements and calculations
- Choice and employment of emission factors
- Calculations leading to the determination of the overall carbon emissions
- Calculations leading to the determination of the energy efficiency
- Check data credibility by comparing reported data with estimated data based on ship tracking data (e.g. AIS) and ship characteristics, such as the engine power
- Perform consistency checks between the total volume of fuel purchased by the ship and the aggregate fuel consumption during voyages
- Conduct data sampling of fuel data and other relevant information on selected voyages
Steps 5 – Reporting
Throughout each stage, the verifier maintains an Issues Log that lists all issues arising. This is shared with the shipping company so that there is a common list of issues to be closed out before completion of the audit.
Some issues that are not critical can be viewed as 'improvement opportunities' and carried forward for future implementation.
At the end of the verification, the verifier evaluates its findings and conduct a materiality analysis on any outstanding errors and misstatements. An opinion statement is then drafted which compiles all work papers and collected evidence into a verification pack.
Step 6 – Technical Review
Before a decision can be made to issue the final verification opinion, the verification pack must be independently reviewed and validated by an independent technical reviewer.
The objective of the independent review is to ensure that the verification process was conducted in accordance with the verification rules, that due professional care and judgment have been adopted, and that any verification risks have been minimised.
Steps 7 and 8 – Final Verification Report & Document of Compliance (DoC)
The verifier submits a verification opinion statement and a document of compliance to the ship operator. The document of compliance must be kept on board the ship to demonstrate compliance with the obligations for monitoring, reporting and verification.
The verifier must inform the Commission of the issuance of the document.
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