The DryBMS Audit Planning and Close Out Standard: What Excellence Actually Requires

DryBMS audit planning and close out — Subject Area 5 in the DBCE framework — covers whether a company’s internal audit programme is planned, staffed, reviewed and followed through to close-out, assessed against the same Basic-through-Excellence structure as every other subject area. DBCE’s principle for it: the company performs audits of operating and management processes to assure compliance with legal and company requirements and to drive risk reduction and performance improvement, with findings followed up for close out.

Unlike Bridge Procedures and Standards, Cargo and Ballast and Mooring and Anchoring, this one isn’t on DBCE’s list of seventeen priority areas. That designation makes no difference to the overall score, though — it’s DBCE’s suggestion of where to focus improvement first — and in my reading it doesn’t make Subject Area 5 any less important. This is the subject area meant to find the problems in all the others, including the seventeen that are on the list.

It’s the DryBMS counterpart to TMSA Element 12, covered in The Audit Is Closed. The Problem Isn’t. — with one structural difference. TMSA Element 12 folds internal audit, inspections and management review into a single element. DBCE separates them: audits sit here, under Performance, while shore-based inspections of the ship’s condition are a separate subject area, Inspection Planning, Review and Close Out (18), under Plant.

What Basic Actually Covers

At Basic, DryBMS audit planning and close out expects an annual internal audit plan covering the scope of operations, to verify the effectiveness of the SMS. Audits are led and staffed by competent personnel who are independent of the areas being audited as far as practical, and the company has procedures for recording and following up observations and corrective actions, and for verifying that close-out was effective — that last part sits at Basic, not higher up.

The targets are specific. The plan is defined at the beginning of the year or a set period. A formal process lets management conduct planned, systematic audits of all offices and vessels within a 12-month period. And the objectives are established from management priorities, management system requirements, statutory, regulatory and contractual requirements, and the risks to the organisation. The suggested evidence is mostly paperwork with a coverage test built in: the audit plan for the year, scope and objectives, all shore departments and vessels included, the plan communicated to those being audited, a defined distribution list for reports, and auditor training records.

Intermediate and Advanced: Where the Declaration Gets Harder to Sustain

In DryBMS audit planning and close out, Intermediate is where the audit system starts being tested rather than just run. Audit teams include formally trained and certified auditors — the lead auditor carries the necessary certification, though other members can join without one if they have the expertise to bring value and credibility to the audit. Auditees include department managers, and the plan extends to contracted-out offices such as manning agents. The company has developed audit protocols and checklists, holds a close-out meeting with the head of the department audited, and management review and approve both the plan and the protocols.

Then comes the requirement that changes the character of the whole subject area: the company compares results from internal audits to external audits, to verify the effectiveness of its own audit system. The suggested evidence is that internal audit reports reflect the real situation and are confirmed by external audits or inspections such as class, port state and vetting. Alongside that, audit is part of line managers’ job descriptions, with evidence that they take part in carrying out audits.

Advanced asks the programme to look at itself. Checklists and protocols are reviewed and revised periodically, with management reviewing and approving them at periodic intervals. The company analyses audit results, compares them across vessels, and identifies trends and common areas for improvement, with an analysis of trends as the evidence. It’s the same shift the Element 12 article describes — from closing findings one at a time to asking what they say collectively.

What Excellence Actually Requires for DryBMS Audit Planning and Close Out

Excellence in DryBMS audit planning and close out puts senior management and outsiders inside the audit programme. The status of the audit plan becomes part of management meeting agendas, and management actively monitors the plan at periodic intervals. The company uses external resources within the audit plan with the aim of improving the safety management system — audit teams may consist of external subject-matter experts or consultants. And senior managers take part in audits of offices and vessels. The suggested evidence is management involvement in and approval of the audit plan, protocols and processes, the selection and use of external experts, and senior management participation in audits.

DBCE’s scoring cascade has a second gate that’s easy to miss. Beyond the rule that Intermediate, Advanced and Excellence are scored at 5% of the self-assessed score unless Basic is 100%, the guidance adds that Advanced and Excellence are also scored at 5% unless both Basic and Intermediate are 100%. DBCE’s scoring methodology summary gives a worked example: Basic fully met, then 75% at each of the other three levels. Intermediate counts in full because Basic was fully met, but Advanced and Excellence are reduced because Intermediate wasn’t, and the total is 100 + 75 + 3.75 + 3.75 — about 183%, or 1.83 out of four.

For DryBMS audit planning and close out, that gate matters, because Intermediate is where the comparison against external results sits. A well-run programme with no honest comparison to class, port state and vetting outcomes could lose its Advanced and Excellence credit on that one gap. It’s the same reason over-declaring TMSA stages costs more than it gains.

RightShip’s RISQ (version 3.2) looks at the same ground from the ship. Question 4.3 asks whether the latest shipboard internal and external audits and the superintendent inspection reports are available, and whether corrective action is being taken on recorded non-conformances; its guide to inspection expects internal audits at intervals not exceeding twelve months, with the reports on board. That’s the same twelve-month coverage DBCE sets at Basic, but RISQ checks it at the ship, one vessel at a time, while DBCE’s Intermediate asks the company to compare its internal results with what class, port state and vetting found. Question 4.4 adds the Master’s own periodic review of how effective the SMS is, reported ashore with feedback. What a RightShip RISQ Inspection Actually Tests covers the RISQ side.

The Practical Point

An internal audit programme can be complete on coverage and still say very little. Read across the four levels and each one asks a harder question than the last. Basic asks whether the audits happen and whether close-out is verified. Intermediate asks whether the audit reports match what outsiders find. Advanced asks what the pattern across audits is telling the company. Excellence asks whether anyone senior has taken part, and whether anyone external has been invited to challenge the programme itself.

A self-assessment that declares Advanced on the strength of a full audit calendar hasn’t yet answered the question Intermediate asks. And because the cascade scores everything above a weak level at 5%, a conservative declaration at the level the evidence actually supports — including an honest comparison of internal findings with external ones — is the stronger position.

For a fleet running both tanker and dry bulk tonnage, TMSA and DryBMS compliance covers what both frameworks demand from the same evidence base.

If you’re working through a DryBMS self-assessment and want an independent read on where DryBMS audit planning and close out genuinely sit, get in touch.

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