Marine Safety and Security Readiness Assessment for the upcoming International Maritime Organization (IMO) Audit

Internal audit report outlining results of the assessment of the Marine Safety and Security Readiness Assessment for the upcoming International Maritime Organization (IMO) Audit at Transport Canada as well as management's action plan in response to recommendations identified in the audit.

On this page


  • To share our observations and recommendations of our assessment of the Marine Safety and Security (MSS) Program
  • To formally request a management action plan, which was subsequently presented at the February 2020 Audit Committee meeting
  • The overall objectives of the project was to review and determine:
    • the extent to which MSS, and its partners responsible for implementing IMO instruments, are ready for the upcoming IMO audit and how MSS addressed the 2007 IMO audit findings
    • how MSS compares against the elements of the Modern Regulator Assessment Framework, which includes the review of how MSS measures the performance of its programs
    • how MSS allocates and monitors its resources to efficiently deliver its programs


MSS is the head of Canada's maritime administration and the lead agency responsible for ensuring Canada reports to the IMO on the implementation and enforcement of marine safety, security and environmental protection programs. A number of government entities such as the Canadian Coast Guard and the Transportation Safety Board support TC in fulfilling Canada's IMO obligations.

The IMO is a specialized agency of the United Nations and is the global standard-setting authority for the safety, security and environmental performance of international shipping. Its main role is to create a regulatory framework for the shipping industry that is fair and effective, universally adopted and implemented by its Member States, which includes Canada.

The IMO audited Canada in 2007 under the IMO voluntary audit scheme. In 2020, Canada will be audited under the IMO's new mandatory audit scheme that started in 2016.

Project approach

This project was a joint endeavor with our Evaluation colleagues who assessed MSS's performance measurement capacity.

We organized the project work into three parts:

  • IMO requirements gap assessment
  • Assessment of MSS against the elements of the Modern Regulator Assessment Framework
  • Assessment of MSS's resource planning and monitoring

Our observations are summarized under each part listed above.

IMO requirements gap assessment


The 2020 IMO audit will focus on MSS as it is the lead organization for Canada. It will assess Canada's compliance with IMO commitments by:

  • assessing the status of Canada's regulations to determine if they incorporate IMO Conventions
  • reviewing the implementation of MSS Programs to determine if MSS is providing oversight of the Canadian seafarer certification process as well as vessel oversight for safety, security and environmental requirements

To assess MSS adherence to IMO conventions, we used the ~ 150 IMO requirements and sub-requirements (outlined in the IMO Instruments Implementation Code (III Code)) as criteria.

  • We incorporated the findings from the 2007 IMO audit into the criteria to determine if/how they have been addressed by MSS
  • We obtained information related to each criteria (i.e. processes, procedures in place) from documentation review and interviews with MSS staff
  • The Evaluation team included performance measurement elements in the relevant criteria
  • We assessed whether MSS met, partially met or did not meet each criteria
    • As of May 31, MSS meets 72%, partially meets 18% and does not meet 2% of the criteria
    • We have not assessed 3% of the criteria due to a lack of information as well as 5% of the criteria for which MSS is not the lead
    • MSS is currently reviewing the assessment results
  • To simplify reporting the results, we have categorized the criteria and our observations into six themes, and relevant sub themes


IMO Theme Observations
Marine Strategy There is no overall Canadian National Marine Safety StrategyFootnote 1 that identifies and explains all of the departments and stakeholders, what their respective roles and responsibilities are, and how they work together to ensure Marine Safety in Canada.
Legislative Requirements Updates to Canadian legislation and regulations to bring into force changes to IMO conventions are not always accomplished in a timely fashion.
Inspection Program Ensuring MSS inspectors remain fully qualified to exercise their delegated authorities is a challenge since some mandatory training programs for marine inspectors are either not available or not up-to-date.
Delegated Authority to Third Parties (Recognized Organizations)

MSS has an oversight program to perform quality assurance assessments of the Recognized Organizations (ROs) who have been delegated authority to certify Canadian Flag vessels. Although an enforcement mechanism to deal with non-compliance with the terms and conditions of the agreements with ROs has not been established, one is currently under development.

MSS is required to ensure ROs have “adequate resources in terms of technical, managerial and research capabilities”, as per IMO criteria. MSS focuses on the ROs' capacity to get the work done, but does not believe they have the authority to review or make recommendations regarding the RO's staff compliment/qualifications.

IMO will likely focus a lot of its attention to this area, and as such, MSS should ensure it is well prepared to defend its position regarding this criteria.

Data Analysis to Identify Systemic Non-Compliance Issues and Risks

MSS does not have an overall information management strategy. Each directorate has its own information system(s). While there is an inventory that describes all of the databases available within MSS, there is no comprehensive list of data elements maintained in each database.

MSS does not conduct trend analyses using performance indicators due to staff having a lack of capacity, awareness and knowledge to perform this function.

While MSS does report on performance, it does not use all of the key indicators suggested by IMO. In addition, the analyses that are done do not segregate results between IMO requirements vs non-IMO marine requirements.

MSS' lack of an overall marine data strategy results in a lack of mapping/awareness of overall public risks.

Program Delivery

MSS does not have a Quality Management System (QMS) to support national standardization and continuous improvement.

MSS has an out of date list of reception facilities for waste as well as an out of date list of fuel oil suppliers.

Exemptions and Equivalencies granted to Canadian flagged vessels traveling internationally, per the IMO requirements are being tracked but they have not been reported to IMO. MSS is also responsible for updating Canada's dashboard on the IMO website but the information is outdated.

Follow-up of previous audit/evaluation

In 2007, MSS prepared an action plan to address the seven IMO audit findings. Currently, only one of the seven findings has been addressed. Of the six remaining findings, two will be completed: One by the Fall of 2019 and the other March 31, 2021. Work to address one finding remains ongoing. Completion dates for the remaining three findings have not been provided.

In 2016, MSS prepared an action plan to address the three findings from the U.S. Coast Guard independent evaluation of the Standards of Training, Certification and Watchkeeping. All three findings will be addressed by October 2019.

Assessment of MSS against the elements of the Modern Regulator Assessment Framework


To assess the current state of the MSS Program against the characteristics of a modern regulator, we developed a Modern Regulator Assessment Framework.

We drew from many external and internal sources (e.g., A Framework for Regulatory Excellence - Penn Program on Regulation; TC Safety and Security's Regulatory and Oversight Framework & Continuum of the Transportation System) to develop characteristics of a modern regulator to assess MSS's current capacity and capability related to:

  • Assessing Risks in the Transportation System
  • Selecting Cost-Effective Interventions
  • Designing and Implementing Oversight Strategies
  • Assessing Performance to Continually Improve
  • Maintaining and Enhancing Foundational Authorities

We assessed the MSS Program's current state against the Framework through documentation review and leveraging the IMO requirements gap assessment work and Evaluation's assessment of the state of MSS's performance measurement capability. MSS is currently reviewing the assessment results and developing an action plan.


Risk assessment

Risk assessment
Criteria Expected to see Progress and achievements Gaps and areas for further improvement
1. Evidence based identification and assessment of Risks / Opportunities to the Transportation System (Safe, Secure, Clean and Efficient)

The Program identifies and analyzes overarching issues and risks to the whole transportation system using reliable data and decides whether to intervene to try and mitigate the risks and identify strategic opportunities to improve the level of safety/security.

Expected Results:

A well-defined risk profile for targeting resources to improve the level of transportation safety and/or security while considering all potential economic efficiency and environmental impacts.

In the past some risk-related work had been conducted (ex. 2015 MSS National Risk Survey: environmental scan through analysis of research papers and survey of program staff).

Like all S&S Programs, MSS scans their internal and external environment using the S&S Planning Environment Document (PED). As part of the SWOT exercise, external opportunities, threats and risks are identified. TC's Transformation Team this summer will be assisting all modes to develop their 2020-21 PEDs to help improve the quality of their risk assessments.

Transformation Team is also leading the Public Risk Management Process initiative to develop a methodology and oversight framework to enable the management of risks to the whole transportation system; however, MSS is not included in the initial pilot projects (the focus is on Aviation Security & Rail Safety).

MSS does not have a well-defined risk profile of the marine transportation sector to help support the selection of intervention strategies and targeting resources.

The majority of MSS work (approx. 95%) focusses on planned non-risk-based activities (certification) with fixed cyclical schedules. The regulations may have been risk-based when first established, but there has not been an ongoing review to assess if the cycle is still warranted.

Although MSS collects oversight data, there are important data information gaps (e.g., passenger volumes; number of small fishing vessels).

The TC Transformation Team should consider working with MSS sooner as part of the Public Risk Management Process initiative.

Selection of interventions

Selection of interventions
Criteria Expected to see Progress and achievements Gaps and areas for further improvement
2. Select Cost-Effective Intervention(s) to Address Safety/Security Transportation Risks/Opportunities

The Program selects and implements appropriate interventions to respond to risks and to take advantage of opportunities to cost effectively support a safe, secure, efficient and clean marine transportation system.

Expected Results:

Program resources deployed in areas of greatest risk/need in a manner that has the greatest impact.

The Program has the flexibility to respond to emerging trends, issues, and innovative opportunities and it strikes the right balance in creating social and economic value.

MSS carried out some targeted interventions to mitigate identified risks in some areas (Concentrated Inspection Campaigns (CICs), Small Vessel Oversight (on-site audits of small vessel manufacturers (vs previous paper-based reviews).

MSS follows a defined process for implementing interventions that involve Regulation. MSS follows the standard regulatory development process including public notification via the Canada Gazette process. MSS along with the other S&S Programs develops a Regulatory Action Plan (RAP) that lists the legislative and regulatory instruments priorities to address safety, security and environmental risks. S&S is taking steps to adapt the transportation regulatory framework to support innovation and economic growth.

MSS has implemented some intervention strategies, but it does not have a process to identify the most cost effective intervention measure or combination of measures. And there is no process in place to assess the performance of existing intervention strategies to confirm they are still required and/or working cost-effectively.

Currently there is very little use of Education, Outreach and Awareness as an Intervention Strategy; MSS management recognizes the need for these activities and some work was carried out in 2017-18 to support the Fishing Vessel Regulations which helps to improve compliance, especially for pleasure craft and small vessel operators. There is a need to assess the costs and benefits of using Education, Outreach and Awareness and other non-regulatory interventions and to try to secure required funding.

Design and implement oversight strategy

Design and implement oversight strategy
Criteria Expected to see Progress and achievements Gaps and areas for further improvement
3. Design and Implement a Cost-Effective Oversight Strategy to Assess Compliance and Monitor the Performance of the Transportation System (Oversight and Compliance)

The program is well designed with clearly defined activities to implement the instruments selected to mitigate the transportation risks (i.e. choice and combination of oversight tools such as regulatory authorizations, inspections, audits, enforcement).

Expected Results:

Risk in the Transportation sector is managed proactively and consistently, based on an evidence-informed approach.

The recently developed S&S Integrated National Oversight Plan (NOP) is a good step towards providing a better understanding of external and internal factors that are impacting the operational environments of all S&S Programs to identify the drivers behind Program oversight priorities. The Integrated Regulatory Framework Plan (RFP) covers all the key policy, legislative and regulatory functions of S&S.

An improved NOP reporting tool is in development (Collaborative Online Reporting of Activities Ledger (CORAL)) to provide oversight data more readily to Managers.

MSS's National Time and Activity Reporting System (NTARS) codes were simplified and aligned to NOP activities in 2018 to help provide more useful data to eventually support better salary planning.

Through the Delegated Statutory Inspection Program (DSIP), external third parties (Recognized Organizations) are delegated to conduct inspections and issue Canadian maritime documents to vessels enrolled in DSIP.

S&S currently monitors completed activities and reports on them in the NOP; however, the actual costs of these activities is not calculated nor is the impact of the activities on the performance of the transportation system measured. i.e. the impact of MSS activities on the safety and security of the Marine Transportation system is not measured.
3. Design and Implement a Cost-Effective Oversight Strategy to Assess Compliance and Monitor the Performance of the Transportation System (Oversight and Compliance)

The Program is efficiently delivered and operating as designed.

Expected Results:

Staff/Delegates have access to consistent, clear and useful guidance and tools (e.g., Standard Operating Procedures –SOPs)The Program has a high level of credibility and strong reputation in the Transportation sector and amongst the public

Recently S&S developed a standard for the development of SOPs for oversight activities. The results of this work will support MSS when it will be in a position to develop a Quality Management System.

The Marine Safety Management System (MSMS) is a compilation of documentation used to administer the Marine Safety programs and policies. The Marine Security Inspection and Compliance Manual provides guidance to marine security inspectors in the performance of their duties.

The Multimodal Personnel Document Issuing System (MPDIS) now tracks inspector credentials and technical training.

TC developed training related to the delegated oversight activities and now delivers it to the delegated inspectors that work for RO's.

The Regions monitor vessels through DSIP, ROs inspect ships, and MSS audits the ROs. MSS has a process in place to conduct oversight of ROs (i.e. Audit Program, work instructions).

MSS will be developing a National HR Staffing and Succession Plan in 2019-20.

There is no MSS QMS process to help ensure SOPs are followed as intended.

SOPs in some of the parts of Marine Safety are up to date, while others are not. SOP updates are completed on an ad hoc basis. MSS needs to develop a plan to meet the newly established S&S SOP Standard.

TC's Multimodal Integrated Technical Training (MITT) group is responsible for ensuring inspectors receive required technical training. Some mandatory training courses are not up to date and some may not be offered when inspectors require them for their credentials. In these cases, MSS issues temporary certificates to their inspectors.

In its 2018-19 NOP, MSS identified recruitment challenges such as:

  • recruiting a dynamic technical workforce that reflects demographic and geographic needs
  • losing technical expertise and corporate knowledge due to retirement.

Performance Measurement Framework

Performance Measurement Framework
Criteria Expected to see Progress and achievements Gaps and areas for further improvement
4. Review and Assess Program Results to Continuously Improve the Program's Effectiveness and Efficiency An effective performance measurement structure is in place to improve program delivery and accountability to maximize TC's contribution to a safe, secure, efficient and clean marine transportation system.

MSS has instruments, processes (e.g. Departmental Results Framework - DRF, Performance Information Profiles- PIPs) and methodologies (e.g. Directory for Methodologies) in place to collect data on indicators and targets of the outputs and outcomes of the program.

MSS collects data through approx. 35 database systems.

It is not clear to MSS staff how PIPs, their indicators, outputs and outcomes are aligned with other key MSS planning and reporting documents (PED, NOP, RAP, Integrated Risk Management, Integrated Planning and Reporting). There is a lack of awareness and understanding in the MSS program and among senior management on the development and design of the PIP indicators.

MSS cannot analyze activity costs and assess efficiency and support cost-effectiveness options analysis as the department's financial system is not designed to capture this information. However, MSS has conducted some activity costing for specific activities as part of Cost Recovery modernization work.

MSS data is not integrated, is prone to data entry error and is not reported on systematically. Reports are created by manually extracting the data.

MSS does not have sufficient resources (internal and or/external) with the skills, knowledge, and experience required to collect and analyze data as well as to aggregate and summarize compliance and other safety data for the marine transportation system.

4. Review and Assess Program Results to Continuously Improve the Program's Effectiveness and Efficiency An effective performance measurement structure is in place to improve program delivery and accountability to maximize TC's contribution to a safe, secure, efficient and clean transportation system.

MSS carries out Quality Assurance for one specific part of their Program, the Standards of Training, Certification and Watchkeeping for Seafarers (STCW) Convention.

MSS has processes in place to ensure the improvement of performance measurement instruments and processes (i.e. indicator re-development, adapting tracking and reporting tools to address new information/needs). As a result, there has been an improvement in the completeness of MSS PIP templates. The Directory for Methodologies lists hyperlinks to specific methodologies related to the core responsibility indicators.

MSS does not collect performance information in accordance with its performance measurement structure.

MSS does not have an overall Quality Management System to monitor adherence to national standards and support continuous improvement.

MSS has received limited performance measurement support from Corporate Planning and Reporting.

There is a lack of communication/ consultation from MSS NCR to other programs and regions for PIP indicator design.

Some MSS staff are not aware of the existence of the MSS logic model and the S&S generic logic models and they lack an understanding of the results chain for MSS; PIP design and the selection of appropriate indicators to measure performance.

Performance information/reports are not fully used to gather lessons learned and to inform program design and delivery (i.e. real time feedback).

There is a lack of discussion around performance information (especially the short term outcomes and medium term outcomes) at the senior-management level.

MSS does not have integrated reporting and communication tools to link into relevant horizontal initiatives (e.g. OPP, Transformation). Work on departmental priorities (e.g. OPP, Transmountain Pipeline, Whales) increases the pressure on the mandatory/core activities, impacting their delivery.

Foundational Authorities

Foundational Authorities
Criteria Expected to see Progress and achievements Gaps and areas for further improvement
5. Foundational Elements: Purpose, Authority, Public Trust, Communication

The Program has a clear mission, goals, objectives.

The Program has appropriate authorities and the Public and industry easily understand their rights and obligations.

The majority of MSS oversight activities are prescribed in more than 100 acts, regulations, standards, memorandums of understanding and memorandums of agreement (ex. Canada Shipping Act 2001, International Maritime Organization (IMO)).

MSS develops several planning documents to plan and monitor its work (ex. National Oversight Plan (NOP), Regulatory Action Plan (RAP), Workplan).

MSS' participation in the IMO international standard setting builds trust and support and aligns with overall Canadian direction.

MSS derives its authorities primarily from CSA, MTSA, AWPPA. Each will be assessed against 11 modern authorities Legislative Modernization team has identified for TC.

As data requirements are defined to better support risk assessment, intervention selection, oversight program design and measuring program performance, then MSS should determine if regulatory changes are required to ensure MSS can assess or compel the reporting of required data from industry to TC.

Once a profile of the marine transportation system risks is developed, and existing and potential intervention strategies are assessed, required changes to the existing authorities should be identified and as part of the Regulatory Action Plan planning process priorities and timelines for obtaining new authorities or modify existing authorities should be set.

5. Foundational Elements: Purpose, Authority, Public Trust, Communication

The Program exercises its authorities in a manner engendering public and industry confidence and trust in the independence of the Program and its decisions.

The Program effectively consults and engages the public, industry, other government departments, all levels of government and international authorities.

MSS must follow the TC Values and Ethics Code, Conflict of Interest and Post Employment.

Senior Management responds to issues raised by the Standing Joint Committee for the Scrutiny of Regulations (SJCSR).

MSS consults and engages with stakeholders such as the Canadian Marine Advisory Council (CMAC), Interdepartmental Security Working Group (IMSWG) and the IMO.


Assessment of MSS resource planning and monitoring


  • To assess how MSS allocates and monitors its resources to efficiently deliver its programs we examined the extent to which:
    • there are clear methodologies, guidance/rules and the necessary analysis conducted to support the planning, budgeting, forecasting and reporting of MSS activities
    • RC Managers (RCMs) and Corporate Services support functions, involved in planning, budgeting, forecasting, and reporting, understand their roles, responsibilities and accountabilities and have the necessary knowledge, experience and capability to fulfil their roles
    • there are effective systems and tools in place to assist Corporate Services to generate sufficient, accurate, relevant, and timely information for analysis to support RCMs' decision making
  • We interviewed MSS's planners, TC Corporate Finance and Corporate Planning and Reporting to determine their perspectives regarding MSS resource management
  • We used a new reporting tool (Power BI) to carryout various analyses of the last six fiscal year's of MSS financial data to demonstrate how existing data could be analyzed to provide better support to management for planning and decision-making
  • We also used 2018-19 MSS data to test the type of analysis and reports that could be created to respond to the Department's new requirement for all Programs to plan, monitor and report specific expenditures throughout the year (New Expenditure Monitoring process)


Resource management

Resource management
Criteria Expected to see Progress and achievements Gaps and areas for further improvement
1. There are clear methodologies, guidance, or rules developed and the necessary analysis conducted to support the planning, budgeting, forecasting and reporting of MSS activities.

A costing methodology in place which is effective and is consistently used across MSS. (Planning)

Common business practices regarding how budgets should be allocated to different management levels (DG, director, managers, etc.) to hold managers accountable are defined, documented, and communicated. (Budgeting)

Common business rules (e.g. use of SMS global costs, discounts, overtime etc.) are clearly defined, documented and communicated, and their uses are monitored. (Forecasting)

Sound performance measures are established to incentivize the desired behaviors from RC Managers (RCMs) and Corporate Services support functions. (Reporting)

MSS has recently started to work with the newly formed Data Science unit within the Digital Services Directorate, to try and link data from multiple sources to start to try and cost activities.

There is a lack of costing methodologies and guidance to appropriately support budget allocation decisions.

MSS has many systems to collect data (e.g. NTARS) but these systems do not link to the financial system.

Due to a lack of data analysis capability, no historic or detailed data analysis has been conducted to support better planning, budgeting, forecasting, and reporting.

Due to the complexity of the MSS structure with multiple Program Inventories (PIs) that MSS contributes to or receives funding from, resource management is complicated and requires comprehensive data trend analysis, as well as standard guidance or rules to ensure consistent data entry practices among MSS related Program Inventories (PIs) and regions.

2. RCMs and Corporate Services support functions involved in planning, budgeting, forecasting, and reporting understand their roles, responsibilities and accountabilities, and have the necessary knowledge, experience and capability to fulfil these.

Roles, responsibilities, and accountabilities are clearly defined and understood by people involved in planning, budgeting, forecasting and reporting, and how they are all interrelated.

RCMs have sufficient knowledge, experience, and capability to cost the activities, manage the risks resulting from budget changes, promptly identify and report surplus/ deficits, review and understand the reports/information/data provided by Corporate Services supporting functions to identify discrepancies/issues for further investigation/analysis

Corporate Services supporting functions understand program's business, and have the capability to challenge the resource management decisions made by RCMs.

There is sufficient, continuous, open, transparent, and timely communication (HQ & Regions, RCMs with Corporate Services supporting functions) regarding activities that will impact the budget and forecast.

All TC RCMs were provided with basic financial management training to help improve budget planning and forecasting across the department. Administrative support positions have also recently received training.

Some roles and responsibilities are not clear, especially for helping ensure the quality of financial data entry. To date FMAs have not received any specific training or guidance to standardize financial data entry protocols/rules which would help reduce the risk to data quality.

Recommendations related to FMA training from Financial Management Quality Control's (FMQC) 2016-17 assessment of Budgeting, Forecasting, and Reporting have not been implemented according to the most recent MAP response.

3. There are effective systems and tools in place, Corporate Services supporting functions use them to generate sufficient, accurate, relevant, and timely information for analysis and support RCMs' decision-making.

Program's activities are costed based on relevant risk and performance data including historical trends. RCMs adequately cost core on-going activities. (Planning)

Budget allocations based on defined needs supported by risk and performance data, historical trends, and clear linkages to government priorities, and also clear simple guidance in place. (Budgeting)

Complete, accurate and timely data are input into corporate financial and HR systems to reflect the realities. Both RCMs and Corporate Services exercise the validation. (Forecasting)

The reports/ analyses provided by Corporate Services supporting functions to RCMs are sufficient, accurate, relevant, and timely. The presentations are understandable and highlight the issues/ risks to facilitate RCMs' decision-making on forecast adjustment and identification of surpluses/ deficits timely. (Forecasting)

The Department has planned some initiatives (ex. Expenditure Plan process) to improve expenditure monitoring, salary planning, and management of financial commitments. Also ADMs and RDGs have new flexibilities to reallocate a percentage of their budgets, however, there is no specific guidance for FMAs and managers to follow.

There are no documented procedures/ rules to follow in order to effectively plan the activities, allocate the budget, forecast, and report. The IPR process and guidance are high level and the management reporting requirements have continually changed over the past few years.

There is an opportunity to build on and continue to use the data visualization analysis tools developed by the Internal Audit team to better support MSS's strategic planning and decision-making.

Resource management summary

The Internal Audit team has offered to facilitate sessions with a small MSS working group made up of MSS HQ, regional and Corporate Finance representatives to further explore the financial data regarding:

  • Trends and Patterns: what observations can be drawn from the data – period to period patterns in a fiscal year, patterns across multiple years, patterns of specific responsibility center (branch, division, sub-division, RC, region, etc.)
  • Data Integrity: whether there are any anomalies that may point to data entry or system related problems that would need to be investigated and resolved – i.e., what if anything would need to be fixed to improve data quality to support meaningful analysis
  • Dashboard Display: what changes to the dashboards (additions/simplifications) would help identify issues and support meaningful analysis

Recommendations and management action plan

To address the observations from our IMO requirements gap assessment; assessment of MSS against the Modern Regulator Assessment Framework and our assessment of MSS's resource planning and monitoring we recommend MSS:

Recommendations and management action plan

Management Action Plan

International Maritime Organization Requirements
1. Implement process improvements to support all mandatory IMO conventions and updates are incorporated into its legislation, regulations and policies in a timely fashion.

MSS has the authority under the CSA to incorporate by reference into national regulations changes made to IMO conventions.

Canada's implementation of this authority is part of a systematic approach and 5-year regulatory plan.

MSS continues to work within our legislative and regulatory framework to meet IMO requirements. (Ongoing)

2. Develop, in coordination with Other Government Departments and stakeholders, an overall Canadian National Marine Safety StrategyFootnote 2 that identifies and explains their respective roles and responsibilities and how they work together to uphold Marine Safety in Canada. Development underway of an overall National Marine Safety Framework that consolidates other strategies (Transportation 2030, NOP, OPP, etc.) and identifies and explains all of the departments and stakeholders, and how they work together to ensure marine safety in Canada. (February 2020)
3. Complete implementation of all past IMO findings and findings from the US Coast Guard's assessment of Standards of Training, Certification and Watchkeeping prior to IMO's 2020 Audit of Canada.

Although the 2007 IMO Audit findings were previously closed, further action is being undertaken to address new gaps:

Given new electronic reporting requirements, to the IMO, MSS is working to submit outstanding electronic reports

Review of on-the-job training documents, including policies and procedures, for inspectors initiated, and workplan with detailed timelines is under development. (2021)

Elements of the Modern Regulator Assessment Framework
4. Develop a comprehensive risk profile of the marine transportation sector to provide the foundation for examining its current mix of intervention measures to help ensure resources are targeted to the areas of greatest risk. To support this work the participation of MSS in TC's Transformation initiative to improve Public transportation risk assessment should be accelerated. 4.1 Be actively involved in determining and assessing public risks to the marine transportation system as part of the Oversight Modernization project in collaboration with the Public Risk Management team (Ongoing)
5. Implement a process to identify and select the most cost effective regulatory and/or non-regulatory intervention measures. The process should be designed to assess the performance of existing intervention measures to help ensure their cost-effectiveness.

5.1 The Departmental Regulatory Affairs (DRA) Group is currently developing a process for selecting the most cost-effective regulatory and/or non-regulatory interventions based on evidence-based identification and assessment of risks (“Regulatory Playbook”)

5.2 Once the Regulatory Playbook is finalized, MSS will use it moving forward. (Ongoing)

6. Clearly define the data required to monitor the performance of the Marine Transportation sector and measure MSS's performance in contributing to marine transportation safety and security. The governance, infrastructure and processes to collect, analyze and report results should be improved to support timely decisions and continuous improvement. As well, MSS should continue and as feasible accelerate its efforts to develop reliable activity cost data to support the identification and selection of cost-effective intervention measures.

6.1 Complete the roll-out and implementation of the Collaborative Online Reporting and Activities Ledger (CORAL) to digitize the planning for the oversight function

6.2 Complete an instructional guide on reporting on the National Oversight Plan (NOP)

6.3 Continue to work with the Digital Services Directorate (DSD) on the Department's Data Strategy, and expand on the MSS data needs

6.4 In collaboration with the Digital Services Transformation Office (DSTO), develop new digital solutions to modernize MSS services, which will enhance service delivery, and reporting capabilities for several programs (Ongoing)

7. Implement a Quality Management System (QMS) for all of MSS to monitor adherence to national standards and support continuous improvement. To support QMS implementation, MSS Standard Operating Procedures should be renewed/developed according to the recently established Safety and Security SOP standard.

7.1 In collaboration with Corporate Human Resources, create four QA positions and staff these positions as soon as possible

7.2 Develop a national QA Framework

7.3 Develop a three-year QA Action Plan (March 2020)