- Surveyor Accreditation Guidance Manual 2 consultation closed
- Shaft surveys explained
- Frequently asked questions related to AMS Audits
- Focused Certification Campaigns
- Monitoring Conditions
- Lithium Batteries
- Surveyor workshop feedback
- Supporting AMSA’s ‘be electrically safe’ education campaign
- Invisible gases, real risks
- Survey Matters suggestions
Surveyor Accreditation Guidance Manual 2 consultation closed
The consultation for SAGM Part 2 was open for a period of 8 weeks between 1 February and 2 April 2024.
The draft and a summary of the proposed changes were published on our website and stakeholders were asked to submit feedback online, via email, or through AMSA Connect.
AMSA promoted the consultation via posts on our website and social media channels. It was also highlighted in the AMSA Update and Survey Matters newsletters which have a combined reach of over 22,000 people.
A public consultation webinar covering the key changes was held on 22 March 2024. The 21 attendees asked a range of questions during the webinar which were addressed at the time and are also included in the consultation results.
AMSA also raised awareness of the consultation process through its regular stakeholder engagement activities. This included the Regional and National Safety Committee forums.
AMSA received a total of 9 submissions during the consultation period. 7 submissions came via the online form, 2 came via email.
The submissions included a total of 92 comments. 12 comments from the webinar have also been considered.
Most respondents indicated that they supported the proposed amendments. A few submissions also provided recommendations for improvements to the draft order.
Accessing the report
Visit the consultation report webpage for a detailed review of the feedback and proposed amendments.
Shaft surveys explained
Shaft surveys play an important role ensuring the reliability of vessel propulsion, however not all vessels require a shaft survey. As the name suggests, a shaft survey is a survey on a propulsion shaft which transmits mechanical power from the prime mover to a propeller to generate thrust.
Which shafts need surveying?
Almost all the propulsion drive systems include a shaft of some form, but shaft surveys are required only for shafts that are not part of a proprietary propulsion devices such as stern drives, azimuthing propellers (Z drives, electric pods), water jets and outboard engines. The logic behind this is that shafts within such proprietary propulsion devices are covered by their maintenance, and usually sits within the vessel allowing routine inspections and maintenance.
Contrary to this, a traditional propeller shaft in a stern tube cannot be inspected or maintained when in water so requires special attention when out of water. This includes both propeller and intermediate shafts in a shaft line. Refer NSCV C5A, Chapter 3 for propulsion systems requirements.
For Classed vessels shaft surveys are as per the class rules and covered under the machinery survey.
When you need a shaft survey?
A shaft survey must be completed at the initial survey which has a 5-year validity unless a transitional assessment is triggered. It is important to identify vessels that have no surveyable shaft/s so the shaft surveys can be removed from the survey schedule.
At a transitional survey, a shaft survey is required only if the change affects the shaft, or the vessel wants to enter a new survey cycle with a 5-year validity.
Changes that may affect a shaft include, prime mover power increase invalidating original shaft size calculations, shortening or lengthening the shaft, repositioning of the shaft line or withdrawal of the shaft, even if it is to swap ends or a like for like replacement.
At the end of each 5-year renewal survey cycle, a shaft survey will be required to assess its condition.
What level of details are required?
Initial survey stage (new build or transitional), the survey must cover all three stages, plan approval, construction and commissioning as scoped in Chapter 3 of the Marine Surveyors Accreditation Guidance Manual Part 2.
Renewal survey, details as required in AMSA 638 Shaft Survey Report is the minimum expected as applicable to the arrangement and situation. The information AMSA expects to see in the Shaft Details section of the AMSA 638 form is shown in the image below.
A typical shaft survey would include a visual inspection followed by non destructive testing (NDT) such as dye penetrant or magnetic particle to detect hairline cracks in any suspicious areas around keyways etc. Precision measurement of diameter, taper and straightness will be required to detect excessive wear or deformation.
To determine allowable tolerances, industry best practices such as IACS Guidelines for Non-destructive Examination of Hull and Machinery Steel Forgings and standards such as ISO 4566 and ABYC P-6 can be referred to.
Bluing of tapers is compulsory if mating surfaces have changed due to either installation of a new shaft or propeller or both, swapped ends or rebuild.
Associated components of the shaft such as couplings, brackets, bearing clearance, propellers and safety guards must also be surveyed during this time. Survey of the stern tube and stern gland or seal will also be required to ensure the water and weather tight integrity of the vessel.
Finally, a running check of the shaft is recommended where possible. Excessive vibration, overheated bearing housings or leaking glands could be indicative of defects such as shaft misalignment or loose propeller.
Frequently asked questions related to AMS Audits
AMS has been receiving questions recently from some AMS regarding the audits performed in accordance with the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the Regulations).
Q: What are the main steps involved in the accredited marine surveyor audits?
A: The following steps outline the audit process.
- AMSA informs the AMS about the audit commencing. This includes details of the survey codes being audited.
- The AMS provides AMSA with any additional documentation, if applicable, within the timeframe.
- AMSA conducts the audit.
- AMSA sends an audit findings report to the AMS.
- AMS responds with a proposed corrective action plan (CAP) by deadline (where required).
- AMSA assesses the CAP and either agrees to it or proposes alternative actions.
- AMS implements CAP and provides a response back to AMSA within the required deadline.
- AMSA evaluates corrective action and informs AMS about the audit outcome when the audit is closed.
Q: What types of findings can be made under audit?
A: There are five types of findings:
- Positive Observation
- Neutral Observation
- Negative Observation
- Minor Non-Conformance
- Major Non-conformance
Q: Should I respond to all the findings?
A: You are only required to respond to non-conformances. In these instances, you must provide a corrective action plan for each non-conformance. You are not required to respond to observations.
Q: What is a corrective action plan?
A: The substance of the corrective action should be proportionate to the level of the non-conformity identified. A corrective action plan is a response that outlines the steps intended to resolve an issue.
A corrective action must:
- Correct any immediate issues specific to the vessel mentioned in the audit finding. For example, the owner must provide an extra five coastal lifejackets and a confirmation email with photographic evidence.
- Correct systemic issues (issues with your survey process), to prevent re-occurrence, for example by incorporating:
- lessons learnt (e.g. vessels must carry life-saving equipment for 100% complement for all classes); or
- improvements to survey techniques and procedures (e.g. add an additional step in my survey process – “Inspect survey documentation to verify the classes and complements indicated on the vessel’s certificate of survey”)
Q: How should I propose a corrective action for a non- conformance finding?
A: Your correction action response should include the following:
- The finding number.
- The planned/implemented corrective action specific to the vessel and survey in question.
- Improvements in survey practice to avoid repeating the non-conformance.
- Supporting documentation (if applicable)
- The anticipated completion date.
Q: What should I do if I notice some findings are not applicable or incorrect?
A: The findings are recorded based on the information available to AMSA at the time of the audit. AMSA acknowledges desktop audits don’t provide an opportunity for the auditor to discuss the finding directly with you. If you believe any finding is not applicable or incorrect, please provide sufficient justification including a written explanation of your interpretation of the requirement/s and supporting information. AMSA will assess this new information and may consider downgrading the findings.
Q: How would I know if the corrective action is accepted or not accepted?
A: AMSA will notify you once all the findings and the audit are closed. During this time, we may also inform you about any downgraded findings. In case any corrective actions are incomplete or not acceptable, AMSA will request further documentation or a different course of action.
Focused Certification Campaigns
AMSA is undertaking compliance assessments based on intelligence analysis in order to identify current and emerging compliance risks.
AMSA is developing targeted strategies to effectively address safety and compliance priorities, using a planned approach with clear goals and using the full range of tools available.
As published in November 2022 Survey Matters the top three causes for refusal of certificates of survey applications were:
- Survey process breakdown
- Incorrect intact stability
- Fire safety non-compliance
AMSA selected items 1 Survey process and 3 Fire safety non-compliance to focus on in the 2023-2024 certification campaign to increase compliance and reduce refusals.
Results
Since July 2023, 21% or around 160 applications were unable to be quickly processed due to issues with the plan approval letter content and fire systems.
Plan approval affected around 120 applications this year.
This is consistent with the previous data AMSA had on refusals which indicates plan approval failure as the largest reason for refusal of an application.
In the 2023-2024 period to date two applications were refused as the vessels were either not fitted with structural fire protection or fitted with the incorrect type of structural fire protection.
One application was refused because the plan approval process had not been followed resulting in incorrect surveys being completed.
One application was refused because the stability assessment had not been correctly conducted.
The impact of delays must be considered alongside the impact of refusals, especially given the number of hours wasted on reworking plan approval letters and the reassessment of applications.
Fire safety concerns remain a serious issue and can lead to significant delays or application refusals. These problems are particularly challenging as they may require the replacement of fire safety systems or fittings.
Monitoring Conditions
Several accredited marine surveyors currently hold accreditation with monitoring conditions. Most of these conditions were applied in the early days of AMSA taking over delivery of the Surveyor Accreditation Scheme. A common example of a monitoring condition is provided below:
“Before undertaking the first 2 surveys in this category, the surveyor must provide the National Regulator with a survey plan and obtain approval. The surveyor must also enable a person nominated by the National Regulator to undertake monitoring of the surveyor for conduct of the first 2 surveys in this category”
AMSA may remove the conditions from your accreditation if you have fulfilled the requirements.
What is the process?
Our accreditation team will email you the details of your monitoring conditions. If you would like them removed, you can provide AMSA with evidence that you have completed the surveys and fulfilled the requirements.
AMSA will review the reports and if satisfied:
- Initiate a variation of your accreditation to remove the condition(s). You will not need to apply and there is no fee.
- Issue you a notice of decision letter outlining the approved variation.
- Update MARS accordingly.
- Update the web list, where applicable, to remove the asterisk from your categories.
Note: Conditions will be retained if AMSA isn’t satisfied the requirements have been fulfilled.
This process is only applicable for monitoring conditions. All other variations to accreditation require an application and payment prior to assessment.
Lithium-Ion batteries
The use of Lithium-Ion batteries in the marine environment is increasing as the battery chemistry has numerous advantages, these advantages also come with higher risks. Lithium-ion batteries are not a direct drop-in replacement for lead acid batteries. They must be treated as a system as they have a communication link, different charging requirements, higher fault currents, different venting hazards and may require additional fire protection and detection systems.
The term Drop-In replacement is not an accurate term due to the points raised below. The Drop-in replacement term is being used in the market referring to the physical size of the battery occupying the same area as a lead acid battery but does not refer to the compatibility with the vessels electrical system.
Regulatory Compliance
Standards and Certifications: In Australia, lithium batteries must be installed in accordance with AS/NZS 3004.2 – 2.9.3 – Additional requirements for Lithium-Ion batteries.
Safety Concerns
- Fire and Explosion Risks: Lithium Batteries have the ability to enter a state known as thermal runaway, which can lead to fires or explosions. Once thermal runaway of a battery is reached there is no easy way to extinguish the ensuing fire. Batteries can enter thermal runaway due to internal failures such as internal short circuits caused by manufacturing faults or external failure caused by operating the battery outside of its operating envelope, e.g. over/under voltage, extreme temperatures. The marine environment can also expose the batteries to vibration, moisture, and temperature variations which may fall outside of the battery operating envelope.
- Installation and Maintenance: Proper installation and maintenance are crucial to avoid safety risks. Lithium batteries must be installed with appropriate ventilation, must use suitable chargers, and undertake regular inspections of battery health.
Compatibility
- System Integration: Lithium batteries must be compatible with existing marine electrical systems. This includes ensuring that the battery management system (BMS) integrates seamlessly with the boat’s power management system.
- Charger Compatibility: Not all chargers are suitable for lithium batteries. Using an incompatible charger can lead to overcharging or undercharging, which can damage the battery and pose safety risks.
- Additional passive and active fire safety requirements may be required.
Environmental Factors
Marine Environment Challenges: The harsh marine environment, characterized by high humidity, saltwater exposure, and varying temperatures, can affect the performance and longevity of lithium batteries. Batteries must be designed to withstand these conditions.
Conclusion
While drop-in lithium batteries offer significant advantages for marine applications, including higher energy density, longer lifespan, and better performance, they also present hazards. Ensuring regulatory compliance, addressing safety concerns and ensuring compatibility with existing systems are all critical for their use on Domestic Commercial Vessels.
Surveyor workshop feedback
Following on from the AMS workshop we are keen to receive any feedback from attendees. Feedback ensures that AMSA can create workshops that are tailored to the needs of the industry.
The feedback period will remain open until Friday 5th of July. Click here to complete the survey.
You can also view full recordings of all 3 days of the workshop here.
Supporting AMSA’s ‘be electrically safe’ education campaign
Commencing in May 2024, and in alignment with the 2023/4 National Compliance Plan, AMSA has begun a ‘be electrically safe’ education campaign, with a focus on electrical fault and fire prevention. This campaign is not related to new regulations, but rather the reality that electrical installations and test records are among the top deficiencies identified during DCV inspections.
The purpose of this campaign is to raise awareness and educate DCV owners, operators and crew about the risk of fire from batteries and electrical installations on board vessels, and the importance of mitigating against and managing this risk as part of a vessel’s safety management system.
As part of this campaign, a new AMSA webpage provides guidance surrounding common electrical hazards and recommended best practices. The information shared covers lead-acid batteries, lithium-ion batteries, portable device charging and wiring.
AMSA encourages accredited surveyors to share these safety recommendations with DCV owners, operators and crew during inspections when electrical issues are detected and or discussed.
Your support will assist AMSA in improving awareness of the campaign’s key messages, which aim to provide implementable actions that help, where needed, change behaviour over time.
Invisible gases, real risks
Toxic, explosive and highly flammable, hazardous gases can quickly accumulate on board a vessel when sources are not appropriately monitored, maintained, or managed.
Incidents involving prolonged, confined or highly concentrated exposure to gases are a serious concern and can cause death in a matter of minutes.
When undertaking a survey, ensure you check sources of hazardous gases are well maintained, compliant and correctly stored.
Hazardous gases are produced through waste or a by-product of operations such as sewage systems (hydrogen sulphide), CO2 cylinders (carbon dioxide) or combustion of fuels (carbon monoxide).
Survey Matters suggestions
AMSA wants to make sure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels.
We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications.