Lessons from the Coordinated Audit on Marine Pollution from Ships

When maritime accidents occur, the environmental damage caused by ships is not only serious but also, in a way, spectacular—it brings to mind miles of beaches polluted with oil, black waves, and dying birds and fishes. However, ships at sea can cause serious environmental damage in other, less spectacular, ways. Ships may

  • burn fuel and illegally discharge used oil and/or bilge water,

  • wash out tank vessels containing unpackaged chemicals, producing polluted rinse water, and

  • generate domestic garbage from their crews.

In 2000, the audit institutions of Cyprus, Greece, Italy, Malta, the Netherlands, Turkey, and the United Kingdom decided to carry out a coordinated audit of marine pollution from ships. The International Convention for the Prevention of Pollution from Ships at Sea, better known as the Marpol Convention, was the common denominator among them.

During the national audits, the SAIs examined their countries’ performance in preventing and dealing with pollution from ships, assuming that their countries’ ratification of the treaty meant that they consider this an important policy objective. The SAIs considered the activities of their respective national maritime authorities within the context of international requirements and their own policies and promises to Parliament.

Joint Report on the Coordinated Audit

The 2006 joint report on the coordinated audit 1 has two parts. The first part outlines an ideal situation: a country called “Maretopia” that has adopted many good measures to prevent marine pollution from ships and reduce the environmental damage that could result from accidents. To describe such an ideal state, the report either drew on good practices found in one or more of the national audits or converted identified bad practices into good ones.

In the second part, the report returns to reality and presents findings from the national audits. In some cases, the report points to similarities in the national findings. In others, the report cites observations worth mentioning because of their nature or relevance for other countries. The report summarizes how countries took action to prevent pollution by (1) carrying out surveys and inspections of ships and waste collection in ports and (2) dealing with offenders and preparing for incidents.

The countries that were part of the audit differ in the ways in which their respective authorities deal with surveying and inspecting ships. Because of these differences, the insights from one country are not automatically applicable to others. At the same time, it would be a waste if lessons learned in one country were not used in other countries insofar as they can be applied, perhaps after adjusting them to different circumstances.

One of the report’s purposes was to encourage countries inside and outside this group of seven to emulate good practices other countries have developed to combat marine pollution and to learn from others’ mistakes. In a number of cases, responsible national authorities have already taken action to address the weaknesses identified during the audits (see, for example, the Netherlands Court of Audit, Marine Pollution from Ships, 2006, www.rekenkamer.nl/Actueel/Onderzoeksrapporten/Introducties/2006/10/Marine_pollution_from_ships).

Lessons for Future Cooperative Audits

Dealing with Diversity

In doing a joint or coordinated audit, the first thing you must acknowledge is that national contexts will always be different. Each nation will have its own way of allocating responsibilities to the national, regional, and municipal levels of government. In addition, tasks and duties assigned to government bodies (such as ministries, port authorities, or inspectorates) and private companies will vary from country to country.

To coordinate an audit with the participation of seven SAIs, you must deal not only with contextual diversity but also with different audit backgrounds, traditions, rules, and practices. We encountered differences in the following areas:

  • the authority of the SAI to examine particular topics or bodies;

  • the existence and availability of information; and

  • audit expertise, techniques, experience, and preferences.

To do justice to this diversity, an “audit à la carte” approach was adopted. The various SAIs were allowed to make their own decisions on the timing, scope (in terms of selection of issues), and audit techniques employed. However, to ensure the comparability of individual audit findings, an audit scheme of criteria for the four main elements of the coordinated audit was established. From the beginning, all the SAIs agreed to audit the following: (1) surveys and inspections of ships, (2) waste collection in ports, (3) dealing with offenders, and (4) preparing for incidents.

This common scheme and the audit design required extensive consultation among participating SAIs. Although this was time consuming, it was crucial to make this investment to establish a common understanding (even language) and, hence, comparable findings. In fact, looking back, we might have made the audit scheme even more specific to eliminate unequal judgments of similar practices. For example, if one national audit team assessed the quality of ship inspections in depth and was consequently critical of the responsible inspectorate, it would be unfair to cite a bad practice in that country and not in another country where the audit team dealt on a more superficial level and found few areas for improvement.

Dealing with a Coordinated Audit’s Long Lead Times

Some SAIs completed their audits before others. The earlier audits provided an extensive framework of standards, questions, and methodologies that were available for the other participating SAIs when they started their audits. This facilitated their audits, which was particularly helpful when the SAI had limited experience with this kind of audit.

The publication of a joint report depends on individual SAIs completing their audits in a timely fashion. A joint report cannot be published until the last national report is done. In the end, the time to complete our coordinated audit stretched from 2001 to 2005. This rather lengthy period reduced the comparability of results in the various audits. For practical reasons, the texts were not updated for the joint publication: this saved the participating SAIs a great deal of work (both in terms of research and communication with the auditees). To avoid misunderstanding, the final joint report noted that the overview was based on the official texts of the national reports.

Allowing for some flexibility in extending the audit phases over a longer period of time can help to improve the possibilities for audit institutions to participate, but there is a price to be paid. Although the coordinating SAI may begin to develop the joint report before some national reports have been formally adopted, this may be a rather risky undertaking. Many SAIs are not in a position to exchange findings before their conclusions and recommendations have been officially adopted.


Carrying out a coordinated audit on an international theme like the prevention of marine pollution from ships poses special challenges to auditors; however, in the end, it can lead to relevant outcomes for all participating SAIs and their national governmental agencies. Participants have to invest thoroughly in common terminology and audit criteria to deal with audit diversity. In our case, it was helpful to undertake a joint audit effort based on an international convention. The Marpol Convention not only provided common policy objectives but also specified the requirements for the prevention of pollution and other measures.

Some of our experiences with Marpol found their way into the 2007 INTOSAI/Working Group on Environmental Auditing (WGEA) paper aptly titled Cooperation Between SAIs: Tips and Examples for Cooperative Audits. This paper was based primarily on experiences with cooperative environmental audits and is available on the WGEA Web site at www.environmental-auditing.org (under WGEA Publications).

All of the paper’s 22 tips apply to the Marpol audit. Still, given the diversity in audit practices, the importance of discussing how differences can affect the entire project can hardly be overemphasized. It is crucial to establish a basic level of mutual respect and trust if communication is to be helpful: only then can participants discuss their reservations, doubts, or uncertainties in an open way. Many auditors with international experience recognize the difficulty in achieving clarity on the meaning of audit concepts and criteria. Obscuring the picture by not speaking out when doubt or disagreements occur will eventually make it much harder to reach consensus in the final stage.

Long time frames call for modesty in the presentation of findings. In the end, depicting Maretopia—where the best practices of all countries involved were put together to form an alluring picture—helped us greatly in getting to agreement on the joint report. It may even have led the various national authorities to better surveys, waste collection, preparedness for incidents, and dealing with offenders. To improve efforts to prevent marine pollution from ships, it may be helpful to assess the effectiveness of our work. At this time, the Netherlands Court of Audit (NCA) is doing just that by carrying out a national “looking back” or “follow-up” audit. The NCA is revisiting the Dutch authorities involved and looking into the actions they have taken since the audit findings were published.

For additional information, contact the author at peter.vanderknaap@rekenkamer.nl.

The author, performance audit director with the NCA, wishes to thank Marlies Alberts, NCA project coordinator for the coordinated audit on marine pollution from ships, for her valuable comments on an earlier version of this article, which was originally presented at the May 2009 EUROSAI/OLACEFS meeting. He also acknowledges the kind help of Hayo van der Wal, Arien Blees, Rogier Zelle, and all the members of the NCA’s Working Group on Environmental Auditing as well as the international colleagues who helped to make this audit a success.

1 Netherlands Court of Audit, Marine pollution from ships—Joint report based on national audits 2000 –2003, The Hague, October 18, 2006 (http://www.courtofaudit.com/english/News/Audits/Introductions/2006/10/Marine_pollution_from_ships).