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Competence Is Not a Certificate: Why IMCA Competence Assurance Has Outgrown the Spreadsheet

On offshore projects in the Gulf of Mexico, the North Sea, and beyond, assurance eventually comes down to one question. A client vetting team, a marine assurance auditor, or a vessel inspector wants proof that the person operating the crane, running the ballast console, piloting the ROV, or supervising the dive is competent to do it on a specific vessel, on a specific scope, today. The question isn’t whether someone was qualified in the abstract or trained at some point in the past, but whether they are competent now, with evidence to show for it.

For compliance and HSE leaders, this moment is familiar, as is the feeling of not knowing what the answer will be until someone opens the file. Answering that question with confidence is the heart of IMCA competence assurance, and it is exactly where the spreadsheets many offshore contractors still rely on start to fall short.

Table of Contents

Why IMCA Sits at the Center of Offshore Assurance

The International Marine Contractors Association (IMCA) is the international trade association for offshore marine contractors, the companies that build and maintain energy infrastructure at sea and below the waterline. Its roots go back several decades, and over that time it has turned the hard lessons of the industry, many of them learned through incidents, into a shared body of recommended practice that no single operator or flag state could build alone.

That body of practice is also far larger than most people outside the industry realize. IMCA reports that its Technical Library offers more than 500 guidance documents and information notes, that nearly 10,000 people regularly receive its Safety Flashes, and that its online Safety Flash archive holds more than 2,000 reports. According to IMCA’s eCMID overview, the system standardizes offshore vessel inspection through IMCA-recognized Accredited Vessel Inspectors and a searchable database, which has reduced how often vessels are inspected, all while improving the quality and consistency of those inspections. All of this work is organized across four technical divisions that mirror how offshore work is done, covering Diving, Marine, Offshore Survey, and Remote Systems and ROV.

For anyone in a compliance or HSE role, the key point is that IMCA guidance is recommended practice, not law, yet it has become the price of entry. Operators build it into how they select vessels and crews. For example, the offshore vessel vetting process published by energy operator Repsol requires a DP survey in compliance with IMCA M219 alongside checks on crew competence and STCW certification. So when a major operator issues a scope in the North Sea or the deep water Gulf, IMCA alignment rarely wins the job on its own, because it is the baseline that lets a contractor bid at all.

Offshore oil rig at sunset

Meeting the IMCA baseline gets a contractor in the door, but the bigger goal is making sure every person in a safety-critical role can actually do the work safely. That’s the purpose of competency assurance, and frontline leaders in offshore energy have been clear about what it takes to make it work day to day.

Learn More: How Competency Assurance Supports Safe Operations

What IMCA Competence Assurance Requires

Accepting IMCA’s importance is the easy part. Understanding what the framework asks of an organization is harder, since the ask is more demanding than many people outside the assurance function realize.

IMCA C001 and the Division Guidance

The structure starts with IMCA C001, Guidance on competence assurance, assessment and verification. Beneath it sit four division-specific documents, C002 through C005, which IMCA’s guidance register lists for the Marine, Diving, Offshore Survey, and Remote Systems and ROV divisions. Read together, they reveal a design philosophy that IMCA does not hand out a certificate to collect. Rather, it provides a framework that member companies use to build and run their own competence programs for every safety-critical position they crew. IMCA’s current C001 guidance dedicates sections to competence assurance schemes and how to implement them. In other words, the obligation is not to possess a document but to operate a system.

The Assessor and Verifier Roles

IMCA Information Note 1468, The role of the assessor and verifier, makes that system concrete by defining two distinct roles. The assessor is, in IMCA’s words, “a skilled, knowledgeable and objective judge” of competence who works closely with personnel to gather evidence and then assesses that evidence against the required standard. IMCA specifies that the evidence must be “current, suitable, sufficient and authentic.” The verifier, meanwhile, provides “quality control and quality assurance” of completed assessments and makes sure every assessor applies the competence guidelines to the same standard.

Under this model, competence is not a status someone reaches and files away, but a dated, evidence-backed claim about a specific person in a specific role, produced by one accountable party, checked by a second, and expected to hold up when a third party comes looking. The certifications and offshore medical certificates that support a person’s competence expire, assessments need refreshing, and the record must remain defensible months or years later, no matter who is sitting in the compliance chair that day.

Where Spreadsheets Earn Their Reputation, Then Fall Short

Spreadsheets deserve some credit, since many organizations have built competency matrices in Excel with real care, and those matrices have taken the industry much further than memory and a filing cabinet ever could. A well-maintained matrix shows who is cleared for what, and for a single vessel with a stable crew and a patient auditor, it can pass the test.

The trouble is that offshore reality does not hold still long enough for that snapshot to stay accurate, and the IMCA framework is designed to test exactly what a spreadsheet cannot hold, and the gap often shows up in multiple places.

A Spreadsheet Stores a Date, but the Standard Requires Evidence

IMCA’s guidance doesn’t stop at whether someone was cleared for a role. It asks for evidence that meets the IN 1468 criteria of current, suitable, sufficient, and authentic. A spreadsheet cell with a date and a pair of initials meets none of those on its own. The real evidence, such as assessment records, workplace observations, and knowledge checks, usually lives somewhere else entirely, in inboxes, shared drives, or a binder in someone’s office. The spreadsheet points to proof it doesn’t contain, and when an auditor asks to see that proof, the scramble begins.

Competence Is a Continuous Cycle, and a Spreadsheet Is Passive

Reassessment intervals lapse, medicals expire, certifications age out, and most offshore certifications are time-limited. For example, BOSIET and FOET are typically only valid for four years and medical certificates are valid for one to two years.

The IMCA framework treats competence as something to be maintained and revalidated rather than banked, but a spreadsheet can’t do that on its own. A spreadsheet doesn’t send a warning, so everything depends on someone remembering to check. If that check doesn’t happen, an expired certificate or overdue reassessment often isn’t caught until the crew is already preparing to mobilize. In one example we’ve heard, a crew member showed up for a crew change and only then did anyone find out their certificate had expired, because the spreadsheet tracking hadn’t been updated. With offshore vessel day rates running into the tens of thousands, every hour spent sorting that out is expensive.

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Verification Demands a Chain of Custody, and a Spreadsheet Has No Roles

The assessor and verifier model only works if you can show who assessed each person, who verified that assessment, when each step happened, and which version of the competence guidance it was measured against. In a shared spreadsheet, anyone with access can change any cell, and nothing stops one person from acting as both assessor and verifier. Version history can technically show who edited what, but piecing it together is slow, manual work that teams mobilizing crews on short notice don’t have time for. That makes it hard to keep the roles separate, or to quickly prove that verification really happened instead of being filled in the week before an audit.

Offshore Crews Mobilize Fast, and a Spreadsheet Is Only a Snapshot

Crews change constantly, especially in disciplines like ROV and offshore survey, where many workers are freelancers or contractors. When a crew change comes together overnight, whoever makes the call needs to know which replacements are cleared and current before anyone boards the helicopter or crew boat. A spreadsheet answers that as of the day it was last saved, which is rarely the day it’s needed.

Worker inspecting industrial oil equipment.

Few teams feel this pressure more than crewing leaders who staff offshore units across multiple regions. Yinson’s Head of Crewing shares how connecting workforce competency to compliance helps keep crews safe and units running.

Learn More: How Oil and Gas Regulatory Compliance Drives Safer Crews

Frameworks Converge on One Person, and a Spreadsheet Splits Them Apart

A single crew member may fall under IMCA competence guidance, OPITO and GWO training standards, STCW certification, flag and class requirements, and a client’s own competency matrix, all at once. Each framework comes with its own requirements, renewal dates, and owner. An ROV supervisor moving onto an offshore wind project, for example, might need a current IMCA competence assessment, GWO safety training, a valid offshore medical, and the client’s site induction, each tracked by a different team. Manual tracking spreads that one person across separate sheets owned by separate people, so when one item lapses, no one may notice until it surfaces during a mobilization or an audit.

An Audit Should Be a Query, but a Spreadsheet Turns It Into a Fire Drill

When a client auditor or vessel inspector arrives, they expect complete, current records for each individual, mapped to the relevant competence guidance. With spreadsheets, the request can trigger days of consolidating files, chasing evidence, and reconciling versions, and it can still turn up gaps no one knew existed. Often, the problem isn’t that the crew wasn’t competent but that the organization couldn’t prove it quickly or cleanly enough. In an assurance audit, competence without evidence is treated the same as no competence at all.

None of this means the people managing these spreadsheets are doing poor work. If anything, organizations have been asking skilled, diligent people to hold together a real-time, multi-framework, evidence-backed, dual-verified, constantly expiring system with a tool built to add up columns of numbers. It’s remarkable that it works as often as it does.

IMCA’s own leadership points to the same issue. In an August 2026 interview with SAFETY4SEA, IMCA CEO Iain Grainger said the industry’s challenge lies “not in identifying the risks but ensuring that standards are applied consistently,” and that critical controls for fatal and serious injury risks need to be in place “at the point of work, every day, across every operation.” A static record can’t deliver that kind of consistency, because consistency comes from a living system rather than a saved file.

Interview with IMCA CEO Ilain Grainger on IMCA competence assurance

The Standard Did Not Change, but the Conditions Did

IMCA has not moved the goalposts, and the obligation to assure, assess, and verify the competence of safety-critical personnel is the same as it has always been. What has changed is the environment around it. Heavier reliance on freelance and contract crews, more overlapping frameworks for each person, and tighter competition for skilled workers have pushed past what a manual system can carry without eventually dropping something. Advisory firm RSM UK reports that offshore energy businesses are increasingly turning to contractors, energy recruitment firm Orion Group notes that many workers now hold both OPITO and GWO certifications to move between oil and gas and renewables, and UK industry body Offshore Energies UK has warned that competition for skilled workers is increasing.

Grainger, IMCA’s CEO, is equally direct about where the sector is heading. In the SAFETY4SEA interview, where he called for standards to be applied consistently across every operation, he also named digitalization, automation, and AI as forces that “will continue to transform how offshore operations are planned, monitored, and delivered.” He then pointed to IMCA’s plans to develop its Skills learning platform “by digitalising competence to ease transferability and flexibility of skills.” When the standards body itself is moving competence into digital systems, the direction is clear.

When a manual system does drop something, the cost isn’t just administrative. It can mean a stop-work, a failed vetting, a lost bid, or, in the worst case, an incident involving someone in a safety-critical role who should never have been cleared for it. Compliance and HSE leaders are responsible for preventing that exposure, and a snapshot can’t manage it.

Under IMCA, competence isn’t a certificate someone holds but a state an organization maintains and can prove, continuously, for every person on every vessel. Meeting the standard on a single day takes effort, but meeting it every day, across a fleet, in real time, and proving it the moment someone asks, takes the right system. At the scale offshore work operates today, software is no longer the edge. It’s the floor.

What to Look for in a Competence Management System

Replacing spreadsheets takes more than moving the same data into a nicer format. Competence management software built for offshore work should map directly to what IMCA competence assurance asks for, including:

  • Evidence attached to every record, so each competency links to the assessment, observation, or knowledge check behind it
  • Automatic alerts before reassessments, medicals, and certifications expire
  • Assessor and verifier roles, with a time-stamped audit trail of who did what and when
  • One profile per person that brings IMCA, OPITO, GWO, STCW, and client requirements together
  • Real-time readiness by role, vessel, and project, so mobilization decisions reflect today’s status
  • Audit-ready reporting that pulls complete records for an inspector in minutes rather than days


Software alone won’t carry the program, though. In Kahuna’s experience, competence assurance stalls when it’s treated as optional, so it also needs leadership backing, clear ownership, and assessors and verifiers who are trained to use it. The right system makes that ownership easier to sustain. Kahuna helps energy and field service organizations replace disparate spreadsheets and systems with one source of validated skills data, where skills are proven on the job and confirmed by a qualified validator, so program owners and leaders can see who is qualified, what is about to expire, and where the gaps are before an auditor or a mobilization exposes them. See how Kahuna supports competency management for energy teams.

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Frequently Asked Questions About IMCA Competence Assurance

IMCA competence assurance is the process the International Marine Contractors Association (IMCA) recommends for offshore marine contractors to prove that people in safety-critical roles can perform them to the required standard. Under IMCA C001, companies run their own competence programs in which assessors gather evidence of performance and verifiers check that assessments were done correctly and consistently.

IMCA C001 is IMCA’s Guidance on competence assurance, assessment and verification. It sets out the overall framework, while four division-specific documents, C002 through C005, cover the Marine, Diving, Offshore Survey, and Remote Systems and ROV divisions, according to IMCA’s guidance register.

Break each role into the competencies it requires, set a clear standard for each one, and gather evidence against that standard, such as workplace observations, records of work completed, or knowledge checks. Then judge whether the person is competent or not yet competent, and have a second reviewer confirm the assessment was fair and consistent. For offshore contractors, IMCA’s competence framework gives a common starting point, with guidance for roles like dive supervisors, ROV pilots, and surveyors working in offshore oil and gas and offshore wind. Each company still has to apply it to its own crews, vessels, and equipment.

Certifications such as OPITO and GWO safety training, STCW seafarer certificates, and offshore medicals show that someone completed required training or met a legal requirement, and most expire on a fixed cycle. IMCA competence assurance goes a step further by confirming, with evidence, that the person can perform a specific safety-critical role on the job. Offshore contractors usually need to track both, because a crew member can be competent in a role and still be unable to mobilize if a mandatory certificate has lapsed.

Yes. Contractors are expected to assure the competence of everyone they put in a safety-critical role, whether those people are employees or not. In ROV and offshore survey, where many workers are freelancers, IMCA offers a Freelance Competence Assessment Portfolio so individuals can demonstrate their experience, skills, and competence from one job to the next.

Ask whether the system can map your diving, marine, survey, or ROV roles to IMCA’s competence guidance, store the evidence behind each competency, and keep assessor and verifier sign-offs separate. If you rely on freelance divers, ROV pilots, or surveyors who move between contractors, ask how their records follow them. It also helps to ask how quickly the system can produce a complete record for one person during a client audit or vessel vetting.

Start by standardizing your competency data. Spreadsheets often track the same competency under different names from one vessel, project, or team to the next, so agree on one set of roles, competencies, and evidence requirements based on IMCA’s division guidance before anything moves. From there, check each person’s records against that standard, flag anything missing or expired, and confirm who acts as assessor and verifier. Every company’s starting point looks a little different depending on how many spreadsheets you have, how they’re built, and whether you manage contractors alongside full-time crew, so it helps to plan the move with your software provider rather than importing spreadsheets as they are. That way, the new system starts from one consistent baseline instead of carrying old gaps forward.