The following set of frequently asked questions (FAQs) and answers has been developed in response to enquiries from members, personnel involved and third parties. It will continue to be expanded and enhanced in light of experience and further enquiries.
Simply click on a question to view the answer to it.
IMCA's guidance on competence assurance and assessment is designed to facilitate improved safety in the offshore industry by providing a framework for marine contractors to assess and demonstrate to others the competence of their 'safety-critical' personnel. The guidance provides criteria to be applied in the different operational sectors covered by the IMCA divisions - marine, diving, remote systems & ROV and offshore survey.
"IMCA's competence assurance and assessment guidance was launched in 1999 to provide a framework within which IMCA's contractor members could demonstrate the competence of their personnel to clients and regulators. Although it has necessarily taken some time for IMCA members to implement their in-house schemes based on this framework, I believe that the effort put in to set up these schemes has been worthwhile and will deliver real benefits in improved safety.
During the past five years, there has been an increasing global emphasis on the importance of using competent personnel and this is set to continue. This framework, with its focus on workplace assessment, where skills and behaviour are considered, as well as its international perspective, provides a suitable mechanism for the demonstration of competence now demanded internationally in the offshore industry.
The framework covers safety-critical positions identified within the four technical divisions of IMCA - Marine, Diving, Offshore Survey and Remote Systems & ROV. Due to the diverse nature of the needs and positions covered by the four different divisions, there have been clear differences in approach in taking implementation forward within member companies. The framework, when first launched, identified 42 different safety-critical positions. It has now been extended to include a further 13 positions and may be extended in the future.
The objective application of the assessment process by offshore assessors is paramount if in-house schemes are to be truly beneficial. Our clients, insurers and regulators expect us to demonstrate that a robust process is applied within our industry. Failure to self-regulate could result in the imposition of impractical and inappropriate systems."
Steve Preston, Heerema Marine Contractors - IMCA President
IMCA is the trade association that represents international marine contractors, interfacing mainly with the and gas operators and governments and other regulatory bodies. As a trade association IMCA cannot enforce compliance. IMCA also recognises that member organisations can apply unique approaches in their enterprises and that any attempt to impose rules will be of advantage to some, and disadvantage others.
Trade associations do not regulate in the way that legislators do. They provide guidance to members and work to update and introduce new guidelines wherever there appears to be a need. Members working to those guidelines is a way of the industry 'self-regulating'. Self-regulation is the logical result of action by industry participants to address a number of concerns.
Self-regulation improves the conduct of an industry and helps drive out unsafe practices. It is also far easier to implement quickly and this flexibility can be a vital benefit.
One of IMCA's main areas of focus is training, competence and recruitment, with the objective to ensure endorsement of and continually develop IMCA competence schemes and to provide the framework for recruitment and training to sustain our industry. Creating the IMCA competence guidelines helps to achieve this objective without directly disadvantaging any member company. Each organisation can then individually or collectively develop their system - all IMCA has done is to point the industry in the right direction.
It depends. Competence can be like getting back on your pushbike when you finally decide to exercise after years of ... no exercise. You are a bit wobbly, your balance is a bit lacking, but it soon becomes natural. Unfortunately it can be that there are new ways of doing things. If so, if you have not kept yourself up-to-date, perhaps your way is no longer correct. It can also be easy to fall into bad habits. Would you be happy getting on a helicopter if its pilot hadn't flown for a year, or two years, three or five?
There is no single answer which covers all circumstances.
This question is probably the most frequently asked question and IMCA tried to address this in information note IMCA TCPC 13/02. Its recommendation is that a three-year revalidation period might be appropriate, but that this is dependent on a number of issues or circumstances. Each company, in preparing or committing to a particular approach to assessing competence, needs to consider the conditions that would invalidate any previous competence assessment. These conditions were considered to include:
Whether the person was carrying out the same job during the time period;
Performing the same job suggests that revalidation is not an issue provided the person can show evidence of continued proficiency. In other words, keeping the evidence of competence current. This is normally additional evidence of the type originally required in the initial assessment;
Technological developments;
Appraisal arrangements;
Whether their record of competence was being regularly maintained.
No. At least not in comparison with what people in other industries have to do!
Paperwork is however a necessary part of compiling the competence assessment records - if it has not been written down, it never happened. This provides the competence audit trail for the employing contractor, and to be realistic, proof of your own capability if you want to move amongst the industry contractors.
No - this is not something driven simply by an administrator's desire to implement a grand plan. Rather, it is an initiative whereby the industry, through IMCA, addresses requests from IMCA's contractor members for industry-wide guidance to help them meet external demands from regulators and clients and also their own internal operational needs. The implementation of in-house competence schemes is the responsibility of each contractor, but by adopting the guidance, adapting and extending it as necessary to meet company requirements, members avoid the need to 'reinvent the wheel' and have an advantage in that clients and regulators may already be aware of the guidance and be familiar with it through their own corresponding membership of IMCA and through use by other contractors.
No - IMCA does not approve any establishments for issuing general competence certificates under its competence assurance and assessment guidance. Assessments should generally be carried out on-the-job by employing contractors, although some may choose to use the services of third party organisations to assist in the implementation and ongoing conduct of their assessment procedures. In either case, the contractor may opt to utilise 'certificates of competence', which will either be issued directly by the contractor or the third party. Any queries relating to these will need to be referred to the issuer direct. IMCA provides the framework for the parties to assess competence. IMCA also provides guidance on competence of auditors.
IMCA does not issue certificates of competence. IMCA's role in direct certification is very limited indeed and only involves certain positions in the diving industry (offshore diving supervisors and life support technicians). Other than this, certificates may feature the IMCA logo when indicating IMCA membership on the part of the issuing organisation, but they are not imcaissued or imcarecognised certificates.
Certificates are not mandatory under the IMCA guidance, but some contractors may find them useful. There should, however, be an auditable trail of work experience and assessment records, which can include logbooks, competence records (combined in the IMCA logbook series), computer-based records, certificates or other documents. Those working for companies with schemes in line with the IMCA guidance will be able to be assessed and achieve a record of their training, experience and competence assessments that will be more easily transferable and ready for other such companies. Many companies take advantage of IMCA logbooks and the stand-alone ‘IMCA Record of Competence’ for recording these details in a formalised, consistent manner.
IMCA guidance recommends that competence assessment should be ongoing and that a three-year revalidation period might be appropriate, (see "How long does competence last"), but the specific requirements will be down to the employing contractor's work practices and interpretation of the guidance in formulating its own competence scheme. Employees will need to contact their certificate issuer if they find themselves with an expired assessment record.
As set out above, IMCA does not issue general competence certificates, but contractors or third parties on their behalf may do so. The IMCA logo in this context signifies the issuing body's membership of IMCA. This means it has access to the range of IMCA guidance - not just on competence, but also safety, training, and other good practice operational guidance. It also has the opportunity of providing: input into reviews of guidance; participation in workshops and other events where implementation of the competence guidance can be discussed and outstanding issues progressed; and access to other forums for reaching consensus on cross-industry methodologies.
There is a requirement within industry in some areas of the world, including the UK, for employees to demonstrate ongoing competence in their chosen discipline.
Originally, people would obtain qualifications and attend training courses which led to them gaining employment, and perhaps apprenticeships in industry. This ensured a person was competent initially but provided no means of monitoring the performance of the individual as they progressed through their career.
Competence schemes make sure that individuals are continually assessed against current legislative, technical and operational practices.
The need to ensure competence and the benefits for those being assessed are addressed elsewhere in the FAQs and guidance. It follows that the need to ensure a team consists of competent personnel is essential not just when a team is put together, but also continuously to ensure personnel remain competent and aware of the skills and awareness required. The value of reiterating ways of working, risks and ways of minimising them through proper safety awareness via toolbox talks before starting an operation is obvious. Regular maintenance and inspection of equipment is a must. Review of safe operating procedures is a vital part of ensuring people and operations remain safe. Making sure personnel are competent to act in these safety-critical positions is just as important in this process.
Certification under STCW shows that you have been effectively trained to work in your position. Competence assessments prove that you can perform the work today.
The two approaches complement each other. The training received under the STCW process provides the skills base and knowledge. The correct attitude to working comes from experience, with the effectiveness being measured by the competence assessor.
It depends. Competence can be like getting back on your pushbike when you finally decide to exercise after years of ... no exercise. You are a bit wobbly, your balance is a bit lacking, but it soon becomes natural. Unfortunately it can be that there are new ways of doing things. If so, if you have not kept yourself up-to-date, perhaps your way is no longer correct. It can also be easy to fall into bad habits. Would you be happy getting on a helicopter if its pilot hadn't flown for a year, or two years, three or five?
There is no single answer which covers all circumstances.
This question is probably the most frequently asked question and IMCA tried to address this in information note IMCA TCPC 13/02. Its recommendation is that a three-year revalidation period might be appropriate, but that this is dependent on a number of issues or circumstances. Each company, in preparing or committing to a particular approach to assessing competence, needs to consider the conditions that would invalidate any previous competence assessment. These conditions were considered to include:
Whether the person was carrying out the same job during the time period;
Performing the same job suggests that revalidation is not an issue provided the person can show evidence of continued proficiency. In other words, keeping the evidence of competence current. This is normally additional evidence of the type originally required in the initial assessment;
Technological developments;
Appraisal arrangements;
Whether their record of competence was being regularly maintained.
IMCA issued specific guidance on this to its members shortly after issuing the full set of competence guidance, which recommended that a three-year revalidation period might be appropriate, but with a number of points of clarification as to why revalidation might be required and why it might be needed more or less often (see "How long does competence last?" above). It has now published these recommendations by way of the FAQs on this site, but this is not a new position. Members have since been implementing their own schemes, taking note of the guidance and implementing it in ways which reflect their own operations and requirements. This may mean that they do indeed require three-year or other fixed revalidation periods, or that they are able to be more flexible because of a lower level of staff turnover or movement between worksites/positions. Queries relating to this issue should be directed to the employing contractor - you may well find that they have already answered your questions in their own documentation.
To carry out assessments successfully, the assessor will need to be fully familiar with the assessment process. The assessor should be a supervisor or manager with the necessary knowledge and experience to be able to judge the competence being assessed. It is likely that the assessor would have been provided with suitable training on conducting assessments.
IMCA does not currently approve or formally recognise any particular assessor qualification. The type of training given to the assessor is for each member company to determine.
Guidance on assessor training was produced as guidance note IMCA C 007 in December 2000. Its references need updating to reflect changes in UK qualification titles for assessors from 'National Vocational Qualifications (NVQ) D32/33' to the new 'A' units, but otherwise remains valid.
The 'on-the-job' assessment of the competence of specific 'safety-critical' personnel is made by the employing contractor while the individual is in the work situation, or by an assessor engaged by the contractor to undertake that assessment on their behalf. The attainment of the specific competence can be noted in Part 4 of the IMCA Record of Competence (IMCA C 006 or as included in IMCA logbooks) or in the contractor's assessment documentation.
Training establishments would not be expected to complete the 'Competence Assessment Record' - Part 4 of the IMCA Record of Competence. They should only complete Part 3 - 'Training Record'. However, they can make recommendations and/or supply documentation to assist the contractors in making their assessment.
Personnel agencies would not be expected to complete the 'Competence Assessment Record'. They would, however, be expected to retain the records for those employed by this agency.
Agencies can, however, make recommendations and/or supply documentation to assist the contractors in making their assessment.
The D32/33 qualification does not have an expiry date and remains valid as long as the assessor continues to practice assessment in the work place on a regular basis.
It is possible to upgrade to an 'A' unit qualification by contacting an awarding centre, which will be able to provide the necessary guidance to achieve this. There is no need for D32/33 candidates to attend a training course to progress to the 'A' units.
The process for all new personnel entering the industry is for them to enter at the basic grade for that safety-critical position.
There will, however, be instances where experienced personnel have, for some reason, missed being grandparented into the scheme. Such personnel may be eligible to enter a more senior position but this would still be seen as a temporary, unsubstantiated position, requiring an additional focus for supervision for a suitable period. The length of this period will depend on performance at that position. Such personnel would be subject to the ongoing assessment arrangements of the employing contractor.
A particular worry can be for personnel who have been assessed in line with the IMCA guidance, but who then work for companies not operating such a scheme. If they return to a company operating under the IMCA framework, questions such as ‘How do I retain my ‘IMCA grading’?’ and ‘My assessment has expired - do I have to start again from the beginning?’ can be prominent in their minds. While working elsewhere, personnel should try to keep a record of their experience and any training they undergo. This will enable any future employer to assess their skills and competence. As mentioned above, even if a person has not got a current assessment record, they are able to be appointed at the appropriate grade on a ‘provisional’ basis and are likely to be able to demonstrate their competence to work at that grade under supervision without a problem.
The benefits to personnel in undergoing competence assessments are obvious in that they will have an industry-recognised record of training, experience and assessment that is transferable between companies which use the IMCA guidance. Even companies not following the guidance will be able to use the experience records and are able to obtain and refer to the IMCA guidance if they wish, without needing to implement such a scheme if they do not feel it is appropriate to their own operations. Keep maintaining your records of experience, e.g. via logbook entries, together with other training and assessment records, and you will be able to present good information to those employers using IMCA's industry guidance.
The IMCA competence guidelines were developed to provide offshore contractors with a framework to produce their own competence schemes.
Provided that the contractors' schemes are underpinned by the guidelines, and the assessment criteria used is similar, then proof of competence should be accepted by member companies other than that performing the assessment.
Member companies will obviously reserve the right to review and reassess the evidence, where appropriate.
Agency personnel are still expected to demonstrate competence in the work place in the same way as personnel working for contracting companies.
Agencies are responsible for ensuring that people on their books are provided with guidance on how to get graded within a competence scheme. It is in the interest of the contracting companies to assist the agencies in the assessment process, as they will require using freelancers within their offshore teams.
Personnel working for non IMCA member companies must take the responsibility to continue to gather evidence if they want this work to count towards their competence portfolio. This evidence can be presented to an assessor at a later date.
Personnel agencies are not in a position to allocate people to their relevant safety critical position - this must be undertaken by a contractor having ultimate operational responsibility for the work being carried out by the personnel involved.
However personnel agencies are encouraged to assist in this process by providing recommendations and supporting documentation to assist the contractors in making their assessment.
This contractor can then progress the relevant competence assessments as part of allocating that person to the relevant safety critical position.
In some industry sectors, supervisors are often employed on a freelance basis or through an agency, with junior personnel unsure as to how they can be assessed. Supervisors should be in a good position to understand the skills and knowledge requirements for a particular role and training in personnel assessment should not need to be overly cumbersome. Companies will have systems in place to help ensure freelance workforces include suitably trained assessors. However, in general, companies wishing to implement competence schemes will need to take steps to ensure sufficient freelance personnel they recruit are able to receive assessor training, whether this is by providing in-house assessor training (which can be part of extended company, project and role familiarisation) or by helping to finance attendance at a third-party course.
