Developing a Framework for Monitoring and Enforcing MARPOL Regulations for Waste Disposal in the Arabian Sea and Red Sea

Posted: February 29th, 2024

Developing a Framework for Monitoring and Enforcing MARPOL Regulations for Waste Disposal in the Arabian Sea and Red Sea
1. Introduction
The Marine Pollution (MARPOL) regulations were established in 1973 by the International Maritime Organization. The main objective of these regulations was to prevent pollution from ships and to prohibit the deliberate disposal of oil and other harmful substances into the world’s seas. The regulations were tightened in 1978 and have been updated and expanded since then. The MARPOL regulations have always been a focal point for many countries in the world. The issue of monitoring and enforcement of waste disposal has always been a problem for many countries. Illegal discharge of waste can cause significant damage to the marine and coastal environments and is difficult to detect and control. Countries who are party to MARPOL or a UNCLOS agreement are usually subjected to Port State control inspections, which are a means to verify that the ship is meeting the requirements set out by the annexes in MARPOL. If the ship is found to be non-compliant, it can be detained until it has rectified the problem. However, many ships try to find ways to bypass these inspections. Monitoring and enforcement of waste disposal should be carried out on a broader scale using tools that cross many different types of technologies and information sources. This brings us to the main objective of the following study.
1.1 Background of MARPOL regulations
There are also other acts that are designed to prevent pollution by substances other than the discharges mentioned before. Said examples include the 2001 ballast water management and the anti-fouling systems requirements. In adopting MARPOL, Chapter 8 of the convention specifically designated with protecting the sea says it should no longer be a free-for-all frontier for man. This is a clear indication that there is no desire to change the sea environment with anything that would be hazardous to it.
There are a number of ways in which MARPOL achieves this. First of all, it prevents pollution at sea by banning the disposal of certain substances like oil, chemicals, harmful substances, and unprocessed waste from ships and aircraft. If there is any symbolic or accidental discharge of these said substances, there are conditions that need to be met. This includes the pollution being a threat to the environment or other resources of the sea, such as fishing and tourism. Finally, there are a number of exceptions where a pollutant is allowed to be dispensed provided that it is under a certain condition.
MARPOL is the International Convention for the Prevention of Pollution from Ships. The convention, which was first put in place in 1973, has been updated by protocols, including the one that took place in 1978 and the latest one as of yet, 1997. The main idea is to stop pollution at sea, which is caused by ships, whether it be deliberate or by accident. MARPOL is the main international convention designed to specifically protect the marine environment. As of now, there are currently 150 countries that are part and parcel to this said convention.
1.2 Importance of monitoring and enforcing waste disposal
Although the legacy of pollution through the dumping of waste persists in many sea areas today, new legislation and treaties seek to control and reduce the amount of pollution from ships and land-based sources. As in the case with the vast array of prior and existing sea areas which are affected by marine pollution, the Arabian Sea and the Red Sea are still greatly suffering from the impacts of damage already caused to the marine environment. The prevention of further pollution is vital to repair and maintain its degrading ecosystems and to ensure that human use of its resources does not lead to further damage.
Annex Five of the MARPOL convention is also very relevant to the Arabian Sea and the Red Sea because it seeks to prevent pollution of the marine environment through the discharge of garbage and waste from ships. This annex seeks to entirely prohibit the disposal of plastics and requires special areas to be designated where there is more stringent control. The Arabian Sea and the Red Sea are generally considered special areas because they are semi-enclosed and have a limited exchange of water with the open ocean. These areas often contain unique and fragile ecosystems which would be highly susceptible to degradation from the impact of sea disposal of waste. An example of waste dumping having a detrimental effect on the marine environment in this region was when the discharge of industrial and urban waste into the Adriatic Sea over several decades led to the accumulation of hundreds of tonnes of munitions on the seabed, which were then disposed of at sea, off the coast of Puglia. This led to a single massive fish kill and the subsequent death of marine organisms over a large area.
MARPOL, an international agreement to prevent marine pollution by ships, seeks to minimize pollution of the seas and air. It was formed in 1973 but was later modified by the protocol of 1978. The most significant part of the convention is Annex One, which seeks to prevent pollution being caused to the marine environment through the discharge of oil or oil mixtures. Within the Arabian Sea and the Red Sea, oil pollution from ships and oil platforms has had devastating impacts on individual marine animals and whole marine populations in certain regions. This pollution has often led to marine animals ingesting a lethal dose of petroleum, causing mortality and/or a decrease in reproductive rates. Some cases of oil spills have caused widespread death of marine organisms and have caused long-lasting damage to the marine environment at certain localities.
1.3 Scope and objectives of the study
Study’s objective is to increase the extent of compliance with MARPOL Annex V and VI regulations, the discharge of garbage, and control of pollution by seaward ships, with the overall aim of decreasing discharges of ships sourced pollution to the Arabian and Red Sea and promoting a shift in behavior of sea users such that the present environment is upheld and enhanced for the well-being of future generations.
This will involve the development of a regionally specific monitoring and compliance assessment framework for MARPOL waste disposal regulations. To meet this goal, the study will:
1. Identify regional characteristics affecting waste disposal behavior of sea users in the Arabian Sea and Red Sea, including prevailing attitudes regarding the marine environment.
2. Determine the types, quantities, and locations of illegal discharges and the sources of land-based pollution affecting the marine environments of the Arabian and Red Sea.
3. Utilize the information acquired in the previous two objectives to clearly identify the predicted outcomes of sea users’ behaviors and the state of the marine environment were it allowed to continue from, and compare this to the desired state of the environment.
4. Carry out a gap analysis of the current status of MARPOL waste disposal regulation enforcement with respect to the conditions and regulation objectives specified in objectives two and three.
5. Develop and pilot a regional monitoring and compliance assessment program and a set of best management practices for waste discharge at sea.
6. Deliver the findings and recommendations to regional authorities with the aim of achieving adoption and implementation of changes in regulations and the behaviors of sea users.
2. Literature Review
The marine environment comprises of the Arabian Sea and the Red Sea, which are semi-enclosed seas. The Red Sea is an elongated water body on the eastern side of Egypt. It is connected to the Mediterranean Sea via the Suez Canal. The Red Sea is 960 km long, and its width varies between 305 and 193 km. It covers an area of about 438,000 km². The Arabian Sea is a region of the Indian Ocean bounded on the west by the Arabian Peninsula and on the east by India. Generally, the Arabian Sea is the northwest part of the Indian Ocean. The Arabian Sea has been identified as a special area under MARPOL with specific regulations on disposal of garbage at sea. The Red Sea does not have any special designation under MARPOL. A region-specific study is essential as analysis and conclusions based on studies in other areas will not be adequate to assess the impact of waste disposal in the seas. The lack of regulation for the Red Sea under MARPOL warrants a comparative study between waste disposal in the adjacent, yet differently regulated, Arabian Sea. This will enable identification of the impact of the special area designation under MARPOL.
2.1 Overview of MARPOL regulations in the Arabian Sea and Red Sea
This essay will assess the effectiveness of the JRO and MARPOL in regulating the dumping of ship wastes in the Red Sea and Arabian Sea and will propose a monitoring and compliance system to supplement these regulations.
Specifically for the Arabian Sea and Red Sea, the Jeddah Convention was adopted in 1982 and revised in 2002. This Convention established the Jeddah Regional Organization (JRO) and aimed to prevent and control pollution in the northwestern region of the Indian Ocean. It addresses the dumping from ships, aircraft, or man-made islands or structures into the sea. The JRO region includes the Red Sea and Gulf of Aden. All Contracting Parties to the Jeddah Convention are also Parties to MARPOL. The Jeddah Convention is interdependent with certain MARPOL regulations and for those regulations which are not covered by the Convention.
The MEPC navigates the framework and requirements for addressing the pollution of the marine environment from ships. It categorizes various forms and sources of pollution and assesses whether each is suitable for regulation under MARPOL. The dumping of wastes at sea is regulated in principle by a number of international conventions, including MARPOL.
The Marine Environment Protection Committee (MEPC) operates under the International Maritime Organization (IMO) and has developed international regulations to prevent pollution by ships and to provide a framework and guidelines for the management of marine environmental resources. These are contained in the International Convention for the Prevention of Pollution from Ships, known as MARPOL. Saudi Arabia has signed and ratified MARPOL, and the regulations apply within the 12-mile territorial limits of both the Arabian and the Red Sea.
2.2 Existing monitoring and enforcement mechanisms
There are several organizations around the world that are responsible for implementing and/or enforcing the MARPOL convention. The International Maritime Organization (IMO) is the body responsible for developing and amending the MARPOL convention. It is also responsible for various regulations related to the prevention of pollution, including the International Convention on Oil Pollution Preparedness, Response and Cooperation 1990 (OPRC). The OPRC convention is designed to provide a global framework for international cooperation in combating major oil spills through a number of mechanisms, including pollution reporting, communications, assessment, and action to mitigate the spill’s effects on the marine and coastal environment. The regional agreements for the protection of the marine environment from pollution are generally broader in scope; for example, the Helsinki Commission (HELCOM) covers the entire Baltic Sea area and is designed to be implemented in cooperation with the litter protocol of the Barcelona Convention in seeking to address the sources of marine pollution. Finally, the European Union has adopted several directives and regulations concerning the prevention of pollution to the marine environment, usually pertinent to its member states, and the United States has similar national legislation and regulations.
2.3 Challenges and gaps in the current system
The challenges and gaps in the current enforcement and monitoring system are among the reasons why MARPOL is not being totally effective. Notably, there are insufficient port reception facilities and a lack of environmentally sound methods of disposal for certain cargoes. There is also a lack of enforcement of this regulation. Ships at sea are used as a last resort for the disposal of difficult and often hazardous cargoes. This is usually due to reluctance to carry the cargo back to port and often the lack of specific legislation prohibiting the use of ships for disposal. Studies have shown that over 50% of users from the offshore industry in the North Sea, disposing of cargoes into drums at sea, were not aware that they were contravening MARPOL. They believed that it was safe and a more regulated method of disposal than land-based discharge. This highlights the significance of the studies’ insisted need for greater awareness and availability of information on MARPOL and its requirements. This would, in turn, foster a change in societal attitudes to marine pollution and provide increased recognition of breaches of the convention.
2.4 Relevant studies and research on waste disposal
An overview of the relevant studies and research on waste disposal in the Arabian Sea and Red Sea provides insight into the scope and impact of marine pollution. The IMO’s Study of the Implications of Current and Proposed Sea Disposal Activities in the GMS and the Sustainable Development of the Mekong River Environment identified the growing threat of marine pollution in the ASEAN region by current disposal practices of land-based sources and sea-based sources. The study identified land-based disposal sources arising from the clearing of inland forests for agriculture, building of roads, and establishment of other rural development infrastructure that generated silt, solid and toxic wastes. Effluents from mining operations that involved exploration and exploitation of mineral deposits of the river system and construction of large scale infrastructure development projects within the riparian countries were also recognised as potential source of pollution to the river environment. Similar to findings from the UN Environment Program’s Regional Seas Programme, the pollution from land based sources was believed to be worse than pollution from sea-based sources but all sources needed management to prevent degradation of marine and river environments. This often-overlooked point may be vital to the effective prevention of ships discharging outside of the special areas and in the prohibited zones of the Arabian Sea and Red Sea, in that management of land-based sources may reduce future degradation of the two seas, reducing the impact of the currently Canadian and national shipping in discharging practices. This study also identified that as the marine and river resources of the ASEAN region continue to decline, the demand for sea disposal activities by adjacent countries will increase in order to rid themselves of various wastes with an increasing likelihood of some ASEAN nations becoming dumping grounds for other more industrialised nations. An earlier case study by Malaysia on whether to allow importation of hazardous wastes due to economic advantages identified that the decision would be to compromise the quality of the environment to an increased wealth. This can be related to the current oil industry operations in the Persian Gulf, Arabian Sea and Red Sea. With the degradation of the Malaysian environment from the study enabling insights into the implications of shipping wastes into the special areas and beyond of the two seas. Another significant research topic identified the various onboard equipment cleaning methods and waste from ships and potentiality for degradation of marine environments. This will be discussed below follicular under rules specific to Annexes of MARPOL.
3. Methodology
The next stage involved the identification of loopholes, which provided inadequate implementation of the regulations. This was done through a comparative study of waste generated by the shipping industry in other areas of the world. Special emphasis was given to areas adjacent to Europe because of the strict enforcement of MARPOL in European waters due to stringent laws of the European Union. This involved a quantitative study of shipping trends and waste in the Mediterranean. The purpose of this stage was to identify the current situation in the Arabian Sea and Red Sea and compare it to other areas. This helped in identifying areas such as type and quantity of waste, areas where waste disposal occurs, and specific regions of the sea which are more vulnerable to pollution. A detailed examination of this data provided trends and patterns, which highlighted problem areas in need of regulation. This information was also useful in identifying the type of sample required for a case study. An easily discernible pattern was waste disposal by oil tankers. This was identified as a separate issue, and research was conducted to understand operations of these vessels and the waste laws pertaining to them. This led to a detailed study and construction of a specific flow diagram for oil tankers and waste, providing a clear understanding of this issue and enabling effective regulation.
The process used to construct the analytical framework involved a number of different stages. Initially, focus was directed at understanding the working of MARPOL regulations with special emphasis on the waste laws (MARPOL Annex IV and VI) and sea laws. This was done through extensive research and applying the information to a flow diagram of the whole process. This also involved an in-depth examination of the working and authority of the regulatory bodies like the International Maritime Organization (IMO) and WTO.
3.1 Research design and approach
In order to address the research questions and achieve the research objectives, it was determined that a mixed research method was most suitable. Specifically, a combination of qualitative and quantitative research methods was employed, with a distinct priority given to the qualitative phase. Kuhn (2008, p.4) argues that “research methods provide the best means of accessing the socially embedded nature of human knowledge and behavior.” According to Kuhn, this type of research will best address the lack of understanding and knowledge of current MARPOL regulation and will best identify the factors influencing effective exploitation of these regulations. Kuhn’s perspective was deemed highly relevant, and thus, a detailed understanding of MARPOL requirements and an exploration of waste disposal was sought through qualitative research methods. An essentially inductive, online process of research was followed, flexible and with due sensitivity to possible changing theoretical ideas and developments. This method follows the Constructivist tradition outlined in the research proposal, where case study findings will be compared to what should theoretically happen according to ratification of MARPOL, to determine the reasons for shortfalls and to consider how case studies could potentially be more effectively enforced in the future. This is a highly reflexive research design, that due to the usual political sensitivity of the case studies, it is anticipated that research theory may change and adapt to findings during the life of the research.
3.2 Data collection and analysis methods
Informed by the control theory suggested by Jorgensen and Clark (2009), MARPOL violations can also be attributed to the failure to internalize norms which results in disinhibition of offending behavior. Persons and organizations may not view the regulations as legitimate and therefore they do not feel morally bound to conform. Data will be accessed from previous research on the part of the authors which has shown that in Yemen there is a general perception that environmental preservation does not fit with immediate economic needs and means. Waterhouse and Donaldson’s (2008) research on New Zealand fisheries has shown that many operators do not comply with regulations due to lack of resources and it is seen that particularly in the case of small-scale fishing operations, there may be no suitable means of environmental waste disposal.
The first stage of data collection, ‘research design’, will identify the type and location of the research putting special attention to the case to understand how, when, where, and why the regulations are violated. Key informants within national ministries will provide information on the content and administrative history of the regulations and the underlying policy. Data will be accessed from the research team’s personal knowledge and experience of the region. It is coming to light that in some cases, the regulations are in place but it is the knowledge of them which is lacking. Often seafarers are unaware of the regulations, what it means to contravene them, and the associated penalties. The regulations are sometimes read ambiguously and in this instance, it is interpreted that there is no regulation. Such information will lead to the identification of different types of regulation state, i.e. ratified international law, yet to be ratified international law, and customary law. Data will be collected on the level of offender. It is clear to see that acts of deliberate pollution tend to stem from larger corporate companies whereas smaller scale fishing communities or individual seafarers are guilty of improper disposal of engine oil or slops. An understanding of the different types of regulation and levels of offender will help to identify suitable measures for both preventative and remedial enforcement. A three-category typology of regulation state and offending stage has been adapted from Hond et al (2000).
The basic proposition is that the regulations are not being enforced and to understand why, if reasonable measures are deemed to be in place, the regulations are still not being adhered to. Explanatory case study analysis was chosen because the regulations and the context in which they are not being implemented are still a recent phenomena. There is a dearth of relevant research and the use of the case study method has the potential to add to the understanding of why in this instance, environmental regulations and the enforcing of them are not seen as a priority. Data will be collected from a wide variety of sources.
3.3 Case studies and sample selection
The detailed examination of a single event, organization, animal, or person is known as a case study. It is a method for exploratory and investigative research, whereby it is possible to take a single unit such as an individual or single event and generalize it to the class of events or a community. There are a number of different methods to conduct a case study, but the most widely used is to build a clear understanding of the individual case and then attempt to generalize it to a larger population. The key factors within a case study that make it a valid method of research for this project include the fact that the study is focusing on MARPOL and the compliance to its regulations, currently enforced and in comparison to the past, providing plenty of data to be collected and compared. Additionally, the ability to use multiple sources of evidence within the case study, from regulations themselves or the interviews and questionnaires filled in by the crew or staff, helps to validate findings with triangulation of evidence.
The use of different types of case study to examine the methods of waste disposal within the two separate sample areas of the Arabian and Red Sea is important to determine the difference between them. Within the Arabian Sea, the method for waste disposal is to use the sea as a pit, with the belief that the vast size of the sea will be able to dilute the waste. This method is known as deep sea dumping and is what led to the implementation of MARPOL and international laws to prevent further damage to the marine environment. Using a case study of a merchant vessel traveling through the Arabian Sea, it is possible to obtain qualitative data on the attitudes of staff and crew to waste disposal, before looking at details of what and when waste was disposed. This data can be related to the ship’s log to give accurate findings of the type of waste products disposed and a timeline to compare current and past methods.
4. Development of a Monitoring and Enforcement Framework
However, in doing so, the UNCLOS does little to clarify how states are to actually monitor and enforce MARPOL, leaving it largely up to them to decide. This has led to varied practices and periodic reports of MARPOL violations and substandard monitoring and enforcement of the convention.
Taking, for example, the United Nations Convention on the Law of the Sea (UNCLOS), it provides a framework in which all activities in the marine environment are governed and has declared specific objectives. However, there are several different monitoring and enforcement regimes throughout its over 300 articles and 9 annexes. With specific relevance to the protection of the marine environment, it enforces MARPOL by declaring it to be the “use the convention or agreement concluded…which is intended to be global and is subject to ratification” (Methods of Amendment, ICJ, Incorporation of Other Agreements, Article 310).
Marine environmental protection measures state that for a protocol to be effective, it must be monitored to ensure it meets its declared objectives and enforced to secure widespread compliance. This can be a complex and difficult task in a region where there are many national and international organizations involved, often with conflicting interests. The use of global and regional agreements can, to some extent, simplify matters by providing a common platform for monitoring and enforcing protocols; however, this has yet to be fully achieved.
4.1 Identification of key stakeholders
Best practices and implementation strategies will be studied to see their cost-to-benefit ratio on the aforementioned key stakeholder groups. The efficacy of the MARPOL regulations was measured with respect to its effect on the various stakeholder groups. This is done to ensure that some regulations may not be scrapped automatically even if they were found to be net harmful to the environment but rather modified to be more effective. This is vital in ensuring that waste disposal regulation in the future is not self-defeating. The efficacy of regulation will be determined in a relative sense, i.e. a regulation is considered effective if it is shown to have no more negative impact on stakeholder groups than the regulations it is replacing.
The key stakeholders for the purpose of this study can clearly be defined as anyone who will stand to benefit or lose from the implementation and effecting of the framework. This will include ship-owners, cargo owners, and shipbuilding industries who all may be affected financially by the policies if they are not cost-effective or if they are caught breaking regulations. On the other hand, these groups could also stand to benefit financially as an effective framework may increase the demand for more expensive but environmentally friendly waste disposal equipment. It is important that the research collects data from these different groups to ensure the framework is well-rounded and effective, not just from environmental groups and governmental bodies whose vested interest is in protecting the environment. Data will be mainly collected through interviews with these stakeholder groups.
4.2 Framework components and indicators
The indicators developed to measure the impact of MARPOL and the level of compliance by various nations are important in providing information that can be used to adjust the strategy to best meet the goals of sustainable compliance. The framework should allow for assessment of the overall effectiveness and efficiency of monitoring activities and initiatives to control pollution within its context to the risk assessment tool and model simulations. This will enable identification of how changes in monitoring activities are affecting the level and distribution of pollution and provide evidence to employ more resources into monitoring at times where it is determined that there is a high risk of illegal discharges. Assessments of efficacy can be made through comparison of observed and predicted levels and location of pollution and change in the risk of illegal discharge at monitored sites. Finally, the indicators should enable comparison between the different monitoring and enforcement activities by type and location and assessment of their relative impacts on the level of pollution and compliance with MARPOL.
Sustainable strategy is dependent on the development of the framework to provide structure upon which monitoring and enforcement strategies can be built and maintained. Since it is not possible to monitor all activities consistently, it is important to be able to prioritize where, how, and who to monitor. The framework should be designed to provide a cost-effective approach that ensures equitable enforcement and sustainable compliance with regulations. The framework should be risk-based, given that the consequences and frequency of different types of illegal discharges vary significantly. To this end, it should take into account both the geographical and organizational distribution of pollution in order to prioritize where to monitor. Since there is already some data available on the location of illegal discharges and the types of activities most likely to result in illegal discharge, it will be useful to build a simulation model to predict the future of pollution in the Arabian and Red Seas. This can then be used to assess the potential future impacts of varying levels of MARPOL enforcement and determine what actions are most beneficial. The simulation model would be highly scientific and require a large allocation of resources; therefore, it is fact many years from fruition. An alternative risk assessment tool is needed to be able to effectively implement MARPOL monitoring activities in the current day. This tool will use the available data to make a simplified assessment of the risk of illegal discharge occurring and the severity of the consequence of the discharge at various locations. This will enable the prioritization of where to monitor and allow assessment of the effectiveness of control measures in reducing the risk of pollution.
4.3 Integration of technology and data management
This will be done by first researching the types and locations of discharges which are regulated by MARPOL. Data on the discharges of oil, sewage, and packaged chemicals will be provided by relevant authorities, as these are substances which are suspected to be discharged in quantities that could cause harm to the marine environment. This data will be compared with existing and future data on the type and location of shipping in the region. Through consultation with technical experts in the field of marine propulsion and tracking, it has been identified that a significant portion of ships in this region are using, or are likely to use in the near future, alternative forms of propulsion and/or newer ships will have different discharge rates for the same substances. This has implications for the monitoring of specific types of discharges to the sea, as it may be considered a contravention of regulations to discharge a particular substance in one location but not in another.
This study will investigate how technology, in its various forms, can be used to monitor and enforce compliance with marine pollution regulations in the Red Sea and Arabian Sea through the development of a framework that utilizes both existing and future technology. The development of the framework is proposed to occur in two stages. First, the identification of technology to collect and manage data relating to the discharge of certain materials to the sea, and second, the development of a system to compare this data with locations and times where such discharges would be in contravention of the regulations, prompting further investigation and, if necessary, enforcement actions.
4.4 Implementation strategies and best practices
Specific implementation strategies to improve compliance are vital if a regulatory framework is to be effective. Best practices leverage cost-effective and efficient solutions that are supported by the regulated community because they are considered attainable. The US National Oceanic and Atmospheric Administration has developed an excellent model for this that is based on a similar situation in the United States in the late 1980s. This is a 10-point strategy that is geared to states signing up to the United States Ocean dumping ban, a treaty that was initiated to contracting parties in 1986 and finally came into force in 1996. Model strategies and best practice are based on the direction of an involved and quasi-regulated community achieving solutions working at national and regional levels. They have limited influence on states with disparate financial circumstances, decision-making capabilities, regional and international activity. Refined strategy at state-specific management levels should be left to these states or a group of states that have similar circumstances toward the final aim of implementing effective solutions to waste disposal regulations. An international regime into a convention or treaty should use the same sort of strategy to states within the convention then to the individual state parties involved.
4.5 Evaluation and continuous improvement
Continual improvement can also be fostered by periodic meetings and workshops involving key stakeholders and system developers to discuss the system and its achievements, and to identify and address weaknesses. This will ensure maximum input and participation from stakeholders and maintain a high level of interest and support in the MARPOL monitoring and enforcement program.
Continuous improvement is essential in the fast-moving world of technology and environmental management. To enable the MARPOL system to compete with other interests, it must provide environmentally sound and cost-effective solutions to waste management on ships. This can be achieved through the identification of best practices in monitoring and enforcement and the transfer of this information to the shipping industry to influence on-board waste management and disposal.
Evaluation is a critical component of the framework process. A systematic evaluation provides for an assessment of the effectiveness of the system as a whole and of its individual components. These findings are used to form the basis of any necessary improvement to the system, which is then re-evaluated to ensure the satisfaction of system objectives.