Port and flag State control 

Risk area 1: Deficiency and detention rates

Port State control (PSC) inspection data showed an increase in both deficiency and detention rates from 2021 to 2022. For flag State control (FSC) inspections there was a decrease in the number of detainable deficiencies in 2022 when compared to 2021.  

Focus (C)

AMSA will continue to focus its inspection efforts on those vessels considered a higher risk to Australia.

AMSA will focus flag State control inspections on vessels that undertake international voyages or are based permanently overseas. 

AMSA will conduct at least 2,400 port State control inspections based on vessel priority

Risk area 2: Fire safety

The focus of the 2023 joint Concentrated Inspection Campaign² is fire safety. This builds upon AMSA’s focus on fire safety in the 2022-23 National Compliance Plan.³  

Focus (C)

AMSA will participate in the Tokyo Memorandum of Understanding joint Concentrated Inspection Campaign on Fire Safety from 1 September to 30 November 2023.

Risk area 3: Planned maintenance

Planned maintenance issues continue to be reflected in the 2022 data with marine incidents showing that failures associated with propulsion machinery or vessels equipment was 34 per cent higher than in 2020. 

Focus (C)

AMSA will continue to highlight the importance of effective planned maintenance as part of the vessel’s safety management system. Planned maintenance will also continue to be a key focus during all vessel inspections.

Regional focus areas

Risk area 4: Regional safety focus (VIC): Verified gross mass measurement of containers

Since 2016, shippers have been required to obtain and document the verified gross mass (VGM) of packed containers before loading. 

Industry continues to raise concerns with AMSA regarding the registered weights of containers at the terminal deviating significantly from the verified gross mass weight recorded on shipping documentation. 

Focus (D)

In the 2022-23 National Compliance Plan AMSA commenced a campaign with the aim of reducing the average error in the verified gross mass of containers in Victorian container ports.  AMSA will continue to engage with relevant stakeholders across the freight network for containers shipped through Victorian ports to further reduce errors.

Footnotes

^2. This Concentrated Inspection Campaign forms part of the Tokyo Memorandum of Understanding (MOU) focused inspection activity.

^3. AMSA, ‘Fire Safety’, Maritime Safety Awareness Bulletin Issue 17, AMSA, Australian Government, 29 March 2023, accessed 6 June 2023

Maritime Labour Convention

Risk area 1: Living and working conditions

Since the implementation of the Maritime Labour Convention, 2006 (MLC) AMSA has made a significant contribution to improving the living and working conditions of seafarers on vessels. We will continue to apply a zero-tolerance approach to breaches that compromise seafarer welfare. The Maritime Labour Convention 2022 annual report presents an analysis of MLC complaints and follow-up actions undertaken by AMSA in Australia. 

Conditions of employment (Title 2) continue to make up the majority (56.9 per cent) of MLC complaints received in 2022. This includes seafarer employment agreements (SEAs), wages, hours of work and rest, entitlement to leave, repatriation, and crewing levels. There was an increasing trend in complaints related to Health Protection, medical care, welfare, and social security protection (Title 4) (including bullying and harassment) over the last few years (24.3% of all MLC complaints in 2022). 

Health and safety protection and accident prevention (within Title 4) also accounted for 58.5 per cent of all MLC-related PSC deficiencies in 2022. This issue is further evidenced in marine incident data with AMSA recording 195 serious injuries and 9 operational fatalities of seafarers between 2020 and 2022. This suggests that safe working conditions and associated practices remain an issue on board vessels visiting Australia.

We will continue to do our part to ensure seafarers on vessels visiting Australian ports are being afforded the requirements under the MLC.⁴  

Focus (C)

AMSA will conduct safety education focusing on safe working conditions and practices on board vessels.

Additional activities

In addition, AMSA will:

• Undertake a review of Marine Order 11 (Living and working conditions on vessels) 2015 to capture the 2022 Amendments to the MLC, which were approved by the 110th session of the International Labour Conference in June 2022. These amendments will come into force on 23 December 2024. The changes include the requirement to record and report all seafarer fatalities to the ILO, Personal Protective Equipment being fit for purpose, clarification on requirements for medical treatment ashore and where repatriation entitlements end. (C)

Footnotes

^4. MLC complaint follow up is done either through an onboard inspection and/or via the flag State. AMSA will also continue to promote the use of the on-board complaints process.

Domestic commercial vessels

Risk area 1: DCV inspection targeting

AMSA employs a targeting prioritisation model that is risk-based. The analysis of more comprehensive inspection data has allowed further refinement of risk profiles for targeting purpose. 

Focus (C)

AMSA will conduct at least 2,300 inspections of domestic commercial vessels based on vessel priority.⁵  

Risk area 2: Marine Order 504 (Certificates of operation and operation requirements – national law)

Following changes to Marine Order 505 (Certificates of competency) 2022 which commenced on 1 January 2023, Marine Order 504 was reviewed to ensure that both marine orders remain aligned. The review has been split up into two phases.  

• Phase 1. Commencing 1 August 2023, will introduce changes to provide consistency with Marine Order 505 along with clarifying and strengthening key aspects related to operational safety. 
• Phase 2. Commencing in late 2024, will focus on changes to safety management system provisions, including simplified safety management for smaller vessels.

Focus (C)

AMSA will conduct a separate safety campaign during 2023-24 to provide guidance to assist owners, masters and crew to comply with the changes to Phase 1 of the revised Marine Order 504.⁶  A focused inspection campaign will be conducted focusing on lifejacket wear requirements. 

Risk area 3: Safe navigation

Contact, collisions and groundings accounted for 62 per cent of all incident vessel consequences in 2022. Forty-six point three per cent of these vessel consequences were mainly associated with shortfalls in the control and navigation of a vessel.  

Safe navigation forms the basis of appropriate crewing assessment in Marine Order 504 with voyage planning being one element of the controls to minimise the risk of navigational accidents.

This focus area will be aligned with other activities related to changes to Marine Order 504.

Focus (D)

As part of the Marine Order 504 implementation, AMSA will highlight the importance of voyage planning including maintaining a lookout and consideration of safe navigation when determining appropriate crewing for domestic commercial vessels. 

Risk area 4: Electrical (including battery) safety

Since 2021 electrical installations and test records were in the top 3 deficiencies identified during domestic commercial vessel inspections. Frequently identified issues included battery terminal housing, wiring and fittings.  

Several serious incidents have highlighted the risks posed by batteries used for vessel power and propulsion and carried for recreational use in personal devices or transported as cargo.

Focus (C)

AMSA will conduct an education campaign focusing on electrical safety in particular highlight the risks associated with batteries onboard vessels. 

Risk area 5: Reporting culture

Analysis of incident reporting data reveals that certain vessels classes continue to under report marine incidents. 

Since 2019 only 5 per cent of Class 3 (Fishing) and Class 4 (Hire and Drive) vessels have reported a marine incident to AMSA. This, compared to 25 per cent of Class 1 (Passenger) vessels that have reported an incident suggests that Class 3 and Class 4 vessels are possibly not attuned to the importance of safety learnings associated with reporting marine incidents.

Focus (C)

AMSA will continue to educate domestic commercial vessel owners, masters and crew on the importance of reporting marine incidents with a focus on Class 3 (Fishing) and Class 4 (Hire and Drive) vessels.

Regional focus areas

Risk area 6: Regional safety focus (NSW): Risk of hazardous gases 

Incidents involving hazardous gases on vessels are a concern including gases produced as waste or a by-product of operations such as sewage systems (hydrogen sulphide) or combustion of fuels (carbon monoxide). A passenger fatality in 2019 on a Class 1 passenger vessel was likely the result of exposure to hazardous gases on board.⁷ 

Hazardous gases are a potential risk that should be considered when carrying out the risk assessment of the operation of the vessel.

Focus (C)

AMSA will conduct and education campaign in NSW focusing on Class 1 and Class 4 vessels to ensure the risks posed by hazardous gases are adequately considered when conducting risk assessments.

This will be followed up by a focused inspection campaign in NSW.

Risk area 7: Regional safety focus (NT, QLD and WA): Vessel adventure rides and experiences

AMSA received frequent reports of unsafe operations and investigated very serious and serious incidents involving vessels operating “adventure” rides in recent years. 

Analysis of these reports identified operation, design and certification requirements and considerations that are unique to the safe operation of vessels operating adventurous, often high-speed experiences for passengers.

Focus (DC)

AMSA will conduct a safety campaign targeting owners, masters and others involved in the operation of vessel adventure rides and experiences. The safety campaign will comprise industry nights and education activities, and a focused inspection campaign on the fleet of vessels in NT, QLD and WA identified as offering adventurous vessel rides and experiences.

Risk area 8: Regional safety focus (Torres Strait and Top End): Safe vessel operations

There is an increasing trend in the number of Indigenous owned and operated domestic commercial vessels and qualified crew, particularly across the “top end” of Australia. 
AMSA will continue to support through ongoing engagement with the Aboriginal and Torres strait communities. As relationships are developed between AMSA and Aboriginal and Torres Strait Islander organisations, safety management system workshops will be offered to indigenous stakeholder groups and vessel owner/operators

Focus (D)

AMSA will conduct safety management safety education with Aboriginal and Torres Strait Islander domestic commercial vessel owners and operators including providing guidance on changes to operational safety requirements following the review of Marine Order 504. 

Risk area 9: Survey instructions

Following analyses of survey findings of Accredited Marine Surveyors (AMS), AMSA identified the following key areas that require more robust guidance and education: 

• Ultrasonic Thickness Measurements (UTM) (10 Yearly Surveys) 
• 10 Yearly Foam Buoyancy Inspections 

Focus (D) 

AMSA will conduct an education campaign to support AMS which will include the development of Instructions to Surveyors and associated guidance in consultation with stakeholders.

Risk area 10: NSCV C4 Fire safety and plan approval compliance 

Fire is a serious issue that can lead to catastrophic results. Significant fires resulting in the total loss of the vessel have occurred in the last 5 years. In 2016 the 1770 was declared a total loss following an engine room fire⁸. The investigation concluded that incorrect fitment of structural fire protection allowed the fire to spread through the vessel into adjacent spaces. AMSA data analysis indicates that 16% of Certificate of Survey (CoS) application refusals relate to incorrect structural fire protection, making this the second largest cause for AMSA refusal of certificates of survey on newly constructed vessels. 

Plan approval letters play a pivotal role in maintaining safety, compliance, and transparency throughout the certification process. Despite their significance, AMSA frequently receives plan approval recommendations that either lack the necessary plan approval letters or contain insufficient information to discern the applied standards or survey processes

Focus (D)

AMSA will implement a risk-based fire safety assessment. Vessels in the high-risk category will be flagged for a focused “high risk” fire safety assessment. AMSA will increase the quality of plan approval letters by reviewing them at initial survey and providing focused education through available channels.

Footnotes

^5. AMSA continues to refine the domestic commercial vessel inspection targeting algorithm. Targets are guidance based on data from the time of publication and may change.

^6. AMSA, Changes to operational safety requirements from 1 August 2023, AMSA website, n.d.

^7. Office of Transport Safety Investigations (OTSI), Ferry Safety Investigation – Passenger fatality – MV Lady Rose Sydney Harbour – 02 February 2019, OTSI, New South Wales Government, accessed 6 June 2023.

^8. AMSA, Spirit of 1770 company fined for reckless operation, AMSA website, 2020, accessed 6 June 2023

Environmental

Risk area 1: MARPOL Annex V – Domestic commercial vessels

In 2022, AMSA carried out a survey on domestic commercial vessels to identify the extent of awareness of the requirements of the International Convention for the Prevention of Pollution from Ships (MARPOL).⁹  

The results highlighted a need to raise awareness of the regulations aimed at preventing both accidental pollution and pollution from vessel operations that apply to domestic commercial vessels. The 2023/24 focus will be on MARPOL Annex V and the prevention of pollution by garbage from domestic commercial vessels.

Focus (C)

AMSA will conduct an education campaign on the requirements of MARPOL Annex V: (Regulations for the prevention of pollution by garbage from ships), including the development of education and guidance material specifically targeting the domestic commercial vessel industry. 

Footnotes

^9. AMSA, Focus on pollution prevention – domestic commercial vessel education campaign, AMSA website, 2023, accessed 6 June 2023