Survey Matters March 2024

In this edition

• Draft instruction to surveyors now available – Ultrasonic thickness measurement for metallic vessels
• Do you know all your transitional requirements?
• Have your say on the proposed changes to SAGM Pt 2
• Stability booklets – Required loading conditions
• Conditions of specific exemptions and how they relate to survey
• Survey Matters suggestions

Read past editions

Draft instruction to surveyors now available – Ultrasonic thickness measurement for metallic vessels

AMSA has developed a draft instruction to surveyors (ITS) which outlines the processes and acceptable options for ultrasonic thickness measurement of metallic hulls required by SAGM Part 2 for a 10-year renewal survey.

The instruction provides information on the rationale for UTM as well as information on how to conduct a thickness measurement survey and acceptance criteria.

As part of the ITS development, AMSA welcomes any feedback from accredited marine surveyors on the form and content of the attached draft.

Any comments and feedback can be directed to dcvsurvey@amsa.gov.au, with ‘DCV-ITS feedback’ in the subject line. This will ensure that all feedback can be easily collected and collated.

Click here to access the draft DCV-ITS-021 UTM for Metallic Vessels.

Do you know all your transitional requirements?

Marine Order 503, Section 11 (g) requires an owner to notify AMSA of any changes to the vessel structure, arrangements, material or scantlings, including changes not mentioned in Schedule 1. Marine Order 503 Section 11 (h) states that a vessel must not be operated if a change in Schedule 1 occurs, and a vessel may only recommence operations if a new certificate of survey has been issued after meeting the survey criteria of Section 9 (1).

If the vessel is an existing vessel, and a change under Schedule 1 occurs, the vessel becomes transitional and it must meet either the NSCV standards, or the transitional standards listed in Schedule 2.

Regardless of whether surveys are only required to address the extent of the change under Section 9 (1), all the transitional standards now apply and there are certain mandatory upgrades that must be made.

AMSA uses the opportunity at transition to require these upgrades to be made to ensure vessels and personnel safety levels are brought in line with the objectives of the National System and contemporary safety standards.

As a minimum, the following upgrades must be verified against the transitional standards, regardless of the changes that trigger the transition:

• Fixed fire extinguishing and detection system as required by NSCV C4 must be installed
• Residual current devices are to be fitted in accordance with AS/NZS 3000 Electrical installations (already required for all vessels under state and territory law)
• LPG appliances & engines must comply with NSCV C5C & C5D respectively
• Intact stability must be reassessed with the person weight updated to meet the NSCV Part C6 requirements, and intact stability re-approved
• Safety, communications and navigation equipment must meet NSCV C7A, C7B and C7C respectively.

If you are engaged by an owner to undertake the surveys required under MO 503 Section 9, you should inform them of these additional requirements, as compliance may require modifications and upgrades to the vessel.

The surveyor who conducts the commissioning survey must complete the checklist for transitional vessels renewal survey on page 5 of the AMSA 901 - Survey report and recommendation form (or surveyors equivalent) confirming compliance.

Note: If the vessel has been assessed as a transitional vessel previously but has triggered again due to another Schedule 1 change, this checklist should be completed again by the commissioning surveyor.

Useful resources:

AMSA 241 - Marine Order 503 – Existing Vessel Transitional Vessel Concept Flowchart

Have your say on the proposed changes to SAGM Pt 2

AMSA is currently seeking feedback on proposed changes to the Marine Surveyor’s Accreditation Guidance Manual, Part 2 (SAGM Pt 2).

Background

SAGM Pt 2 sets clear standards and criteria for Accredited Marine Surveyors and Recognised Organisations (class societies), outlining the procedures for surveying domestic commercial vessels to ensure compliance with safety regulations and standards.

SAGM Pt 2 came into force on 1 July 2018 and has been the prescribed survey standard for more than 5 years.

Since the introduction of the manual, we have gathered valuable learnings and feedback, which we have now applied to enhance its clarity and effectiveness through these proposed revisions.

Key Changes

The following summarises some of the key changes in the draft document:

• Class 2 vessels used only for leisure type purposes, will be allowed to use the same CE certification as Class 4 vessels for structural approval
• Owners of medium-frequency survey vessels will be provided the flexibility to complete a year 3 survey either in water or out of water, and owners of high-frequency vessels will have flexibility to swap their year 2 and 3 surveys
• Alignment of construction documentation requirements for restricted C (EX40) vessels with risk levels, reducing the necessary documentation
• Clarification that Accredited Marine Surveyors may use their own reporting forms, provided these have the required level of detail 
• Inclusion of reporting obligations for repair and damage surveys
• Survey tables expanded to remove ambiguity and improve consistency and reliability in the survey processes 
• Various other minor changes

Further information

The below link takes you to the consultation page. On this page, you can find more information about the proposed changes including the draft standard and a summary of all the proposed changes.

An online information session is scheduled for Friday the 22nd of March. You can register your interest in attending at the link below.

Feedback is sought on the proposed changes. This link can also be used to provide your feedback using an online form. The consultation process closes at midnight on the 2nd of April 2024. Please ensure all feedback is provided by this date.

Click here to access the consultation hub.

We encourage everyone to review the proposed changes, attend the information session and provide us your feedback.

Stability booklets – Required loading conditions

AMSA audits accredited marine surveyors to ensure the correct procedures and protocols set out in the National Law - Marine Surveyors Accreditation Guidance Manual (SAGM) and the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the regulations) are being implemented.

AMSA regularly performs audits related to stability approvals from accredited marine surveyors (AMS). Most of the submissions from accredited surveyors are found to be compliant and many positive observations are noted.

However, during recent audits, findings regarding the extent of loading conditions presented in stability booklets have become common. Rather than just demonstrating compliance with the applicable stability criteria, AMS are encouraged to focus on providing clear guidance to an operator for them to be able to operate the vessel within the allowable limits. Below is some guidance on how to identify what loading conditions to include in stability documentation.

NSCV requirements

It is a required outcome of NSCV C6A for the intact stability to be safe over the range of foreseeable conditions of loading. Clause 2.2 states:

Note 1 clarifies the extent of the term “foreseeable conditions”.

Requirements for the form and content of a stability booklet are found in the National Standards for Commercial Vessels (NSCV), Section C6C, Annex F. This annex details all the information required to be included in the stability book and is a normative (compulsory) part of the standard (see also December 2019 edition of Survey Matters).

Clause F5 / Table F1 of Annex F outlines the required contents of a stability book and points to clause F9 for the loading conditions. Clause F9 stipulates that a range of loading conditions be presented in the stability book and highlights the need to include any loading conditions that may have marginal stability characteristics (worst case scenarios). It also includes an important note about consulting with the operator to ensure the loading conditions of all intended operations have been assessed. Table F.3 outlines the standard departure and arrival loading conditions applicable to all vessels, and Table F.4 includes the minimum vessel-specific loading conditions to be included in a stability book. It is important to note that Table F.4 requires all vessels to include a lightship condition.

Importance

Vessels may vary significantly in design and operation and there may be additional conditions over and above the minimum requirements that must be analysed to ensure all limiting conditions have been identified. For certain vessels the limiting conditions may be readily identifiable, however, they may not be so clear for other vessels that, for example, are variably loaded (vertically, longitudinally and transversely); have movable ballast; have lifting and grounding effects; have multiple consumables tanks; or have tracked or wheeled plant loaded from the shore.

By analysing the full range of loading conditions and looking in detail at activities that can impose additional heeling moments on the vessel, all potential operating profiles are analysed prior to the vessel entering service. Worst-case loading conditions (limiting conditions) must be identified by the surveyor (preferably in collaboration with the operator) and guidance addressing these conditions must be included in the stability book in accordance with clause F9.

Conditions of specific exemptions and how they relate to survey

Specific exemptions (SPEXs) may have conditions imposed to ensure the safety of the vessel or its occupants. These conditions can relate to the operation of the vessel, its equipment, or its design. The legal onus to ensure these conditions are met is placed on the owner, the master or both. This is due to the way the National Law is written whereby it is a strict liability offence for an owner or master to breach a condition of an exemption (Sections 144 and 145). For many smaller vessels the owner is also the master, but this is not always the case – particularly for larger fleet vessels.

Surveyor’s obligations during survey

In accordance with SAGM, a surveyor is required to verify that a vessel complies with applicable legislation, exemptions, and standards. This means that as part of any survey (initial or periodic), if a SPEX has been granted to the vessel, there may be certain conditions that must be verified by a surveyor as part of the survey process.

Surveyors should ascertain whether a vessel is subject to a SPEX and consider whether any conditions listed on the SPEX must be considered as part of the survey process. If the vessel has a SPEX and is undergoing periodic or renewal survey there will be a note on the face of the CoS and the SPEX will also be indicated in the Vessel Report. The owner is required to keep a copy of the SPEX with the Certificate of Survey.

Conditions relating plan approval

If the vessel is undergoing plan approval and a CoS is yet to be issued, the surveyor should consult the owner for a copy of any SPEXs granted by AMSA.

Conditions relating to vessel design will generally be directed to the owner but will require that certain things be verified by a surveyor on the owner’s behalf during the plan approval phase. Examples of conditions pertaining to vessel design are as follows:

• The owner must ensure that the vessel’s structure meets the requirements of ISO12215 for an ISO category B vessel.
• The owner must ensure the vessel complies with single compartment subdivision with the collision bulkhead damaged.

Conditions relating to construction surveys

Some SPEXs contain conditions that must be verified by a surveyor during initial construction survey but would not require ongoing verification once the CoS is issued. The conditions will generally be directed to the owner and require verification by a surveyor on their behalf. Examples of conditions pertaining to vessel construction are as follows:

• The owner must ensure the minimum height of the bulwarks/guardrails is 850mm
• The owner must ensure the power of the propulsion engine does not exceed 450kw
• The owner must ensure that the width of the crew stairs between the main deck and wheelhouse is no less than 585mm.

Conditions relating to commissioning and periodic surveys

If the vessel is undergoing commissioning survey and a CoS is yet to be issued, the AMS should consult the owner for a copy of any SPEXs granted by AMSA. If the vessel has a SPEX and is undergoing periodic or renewal survey there will be a note on the face of the CoS and the SPEX will also be indicated in the vessel report. The owner is required to keep a copy of the SPEX with the certificate of survey. These conditions will either be directed to the owner, or to both the owner and master.

Examples of conditions pertaining to commissioning and periodic surveys are as follows:

• The owner and master must ensure that an additional 4.5kg ABE fire extinguisher is carried.
• The owner and master must ensure that an additional portable powered 11kL/hr bilge pump with wandering hose is provided onboard.
• The owner must ensure that signage is provided on either side of the watertight door stating “MUST BE CLOSED AT SEA”.

Reporting

Surveyors can make a comment on the AMSA901 form (or equivalent) listing the items relating to a condition of a SPEX that have been verified as part of their survey. Alternately a separate report can be compiled, listed as supporting documentation on the AMSA901 (or equivalent), and uploaded into MARS. The benefit of a separate report is that photographic evidence can be provided which is encouraged by AMSA for transparency (SAGM 2.6), and we recommend this in particular for initial commissioning surveys.

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.