Survey Matters—May 2020

Since the last edition

We have added past editions of Survey Matters to the AMSA website. They can be found on the AMSA Newsletters page here. 

In this edition

• Providing MARS codes to surveyors
• Recommendations from the inquiry into the loss of FV Cassandra and FV Dianne
• Alternate survey processes
• Vessel system changes—transition implications
• EX40 Structural assessment
• Relationship between plan approval and construction phase surveyors

Providing MARS codes to surveyors

We understand surveyors face difficulties obtaining survey codes from clients in certain instances. To alleviate these difficulties we have put a new process in place to provide codes to surveyors.

If you are unable to obtain survey codes from the certificate holder, send an email to DCVApplications@amsa.gov.au . In your email, provide evidence that you've been engaged to conduct the survey(s). 

Examples of sufficient evidence:

• Acceptance of a quote
• An email or letter from the certificate holder requesting the surveyor undertake surveys 

This process is only available for survey codes, and does not extend to enquiries about applications or requests for copies of certificates. Please remember that if a surveyor needs to receive information about an application, you have to be added as a contact on the application.  

Recommendations from the inquiry into the loss of FV Cassandra and FV Dianne

The Queensland Coroner has handed down findings following the joint inquiry into the loss of the fishing vessels Cassandra and Dianne. 

The findings contain a recommendation that bulky items should be secured by restraining straps or bolted down where possible. This is an inexpensive measure to implement and relatively easy to achieve. 

The coroner also made recommendations relating to:

• Stability
• Hook-up recovery
• EPIRBs
• Lighting; and 
• Emergency grab bags. 

We request that you make your clients aware of these recommendations. 

The full coroner’s report is available on the Queensland Courts website. 

Alternate survey processes

Marine Order 503 includes a power permitting AMSA to approve alternate forms of initial or periodic survey. This allows AMSA to vary the survey processes for vessels, on a case by case basis. Importantly, this does not alter the standards that apply to the vessel, just the survey process set out in the Surveyor Manual.

To apply for an alternate survey process:

• complete an AMSA 1854 form (Application for an alternate survey process); and
• attach all relevant supporting documents and calculations. 

Email applications to dcvsurvey@amsa.gov.au. 

Note: we cannot process applications without adequate detail.

When you should seek an application for an alternate survey process

Generally speaking, you can seek an alternate survey process if you have considered the survey requirements specified in Marine Order 503 and believe there is a genuine reason it cannot practically be applied.

You may also propose an innovative or alternate process to satisfy the outcomes of a prescribed type of survey. For example an in water dive survey. 

When not to apply for an alternate survey process

Do not seek an alternate survey unless you have considered the prescribed process in Marine Order 503 and can justify why it cannot be practically applied. Unjustified applications will generally be refused. 

Do not seek an alternate survey process for transitional vessel changes that require “initial survey to the extent of a change plus renewal”. These are changes mentioned in clause 3, 4, 5, 6(a), (e) and (f) of schedule

AMSA considers this a straightforward process that generally doesn't require a formal approval. 

Dive survey approvals—your questions answered

Q: Will AMSA consider dive surveys instead of out of water surveys?

A: Yes, AMSA will consider a dive survey for a year 3 out of water survey. 

Q: Can a vessel undergo dive survey for years 3, 5 and 8?

A: Generally speaking, AMSA will only permit one dive survey in a five year period. However, we may consider longer docking cycles for permanently moored vessels with no appendages or propulsion. 

Q: Will AMSA impose conditions on a dive survey approval?

A: Generally, we impose the following conditions on a dive survey approval:

• The vessel must be inspected by an AMSA accredited marine surveyor for all components of the survey that cannot be reasonably inspected without the vessel out of the water.
• Divers shall be ADAS qualified or accredited by a classification society, recognised by the National Regulator;
• The following equipment must be available:
  • closed circuit colour television with sufficient illumination equipment
  • two-way communication between the diver and surface staff
  • video connected to the closed circuit television
  • still photography camera
  • equipment for carrying out thickness gauging, non-destructive testing and measurements, e.g. clearances, indents etc. as relevant to the work performed but be available
  • equipment for cleaning of the hull
  • The dive surveys must be witnessed and verified by an AMSA accredited marine surveyor, who shall retain a video copy of the inspection.
• The in-water visibility and the cleanliness of the hull below the waterline is to be clear enough to permit a meaningful examination which allows the surveyor and diver to determine the condition of the hull, plating, appendages and the welding (if applicable).
• The accredited marine surveyor is to be satisfied with the methods or orientation of the divers on the plating, which should make use where necessary of permanent markings on the plating at selected points.
• The shell plating is to be examined for excessive corrosion, or deterioration due to chafing or contact with the ground and for any undue unfairness or buckling. Special attention is to be paid to the connection between the bilge strakes and the bilge keels. Important plate deformation or other deterioration which does not necessitate immediate repairs are to be recorded. 
• If the dive survey reveals damage or deterioration that requires early attention, AMSA may require that the vessel be taken out of the water in order that a detailed survey can be undertaken and the necessary repairs carried out.
• A copy of the paint specifications and a letter of confirmation from the paint manufacturer stating that the paint system has been designed to give minimum five years protection are to be supplied to the attending surveyor for verification.
• The vessel should be fitted with a five year anode protection system.
•  An in-water dive survey may not be carried out for consecutive out of water surveys.

Approvals for transitional vessels—your questions answered

Q: Can AMSA provide a list of all approvals issued for transitional vessels?

A: AMSA has no plan to publish approvals on a public register. The circumstances of each approval differ, and variations may misrepresent the requirements of the approval.

Q: Is there a standard survey process for transitional vessels?

A: Yes, Marine Order 503 and the Surveyor Accreditation Guidance Manual (SAGM) outline the standard process in detail. You should only seek an alternate survey process after considering the standard process. You must justify a departure from the standard process.

Q: In what circumstances does AMSA approve an alternate transitional survey process?

A: Before applying, an applicant should consider the standard process for transitional vessels. AMSA only departs from standard processes where there is no reduction in safety outcomes. AMSA will not approve an alternate process if we believe it may jeopardise safety.

Q: What should I think about before applying for an approval?

A: Before applying, it is particularly important to consider:

1. All available records for the vessel. Where the design drawings and approval are not held by the applicant; apply to the State jurisdiction of initial approval for the vessel design approval file and any drawings held.
2. Parts of the vessel that MO503 specifies as subject to initial survey vs renewal survey.
3. Transitional standards applied to the vessel through MO503 which differ from the original approval.
4. What approved documentation is available for use in the survey process.

Scenarios

Note: the scenarios described below are general in nature and do not constitute an approval.

Design phase (plan approval) scenarios

Change in service category e.g. 1 → 2, 3 → 1 etc.

AMSA generally expects normal design phase plan approval covering all systems affected by the changed service category. The extent of plan approval for unaffected systems depends on the change to operational area or vessel modifications (if any). Refer to the other scenarios. 

Vessel keeping the same operational area category; or moving down in operation area category e.g. B → C, C →D etc.

Generally, this can occur on a change of service category or a vessel that has been out of survey for more than 2 years. AMSA will request submission of all available drawings and we will ask the surveyor to confirm the vessel hasn't been altered from these drawings. 

AMSA may accept reduced submissions without the original structural, watertight integrity, engineering and electrical plans, subject to conditions. This is only possible when there is clear evidence the vessel held a certificate from a state that fully implemented the USL code at the time of initial survey. 

Vessel moving up in operation area category e.g. C → B, D →C etc.

Generally, AMSA requires initial design phase surveys, including plan approval in this circumstance. 

Adding systems, fixed equipment, people, passengers etc.

AMSA expects design phase plan approval covering any and all systems of the vessel affected by the change in service category. For non-affected systems it depends on the change to operational area (if any) refer to the questions above. 

It is important to give thought to the extent of a change. For example, on a vessel fitting a net reel or crane – the extent of the change may include:

• has a deck structure been modified
• are there new pipes or wires for power or control
• do the pipes / cables pass through watertight or fire boundaries
• where does the hydraulics or power come from, are there new HPU’s or generators
• is there an effect on stability

Major modifications

AMSA expects the design phase surveys specified in MO503 and SAGM to be conducted

Construction phase scenarios

Vessel remaining in the same service category and or moving down in operation area category only e.g. B → C, C →D etc.

AMSA will generally approve the vessel to continue operating without construction phase surveys if:

• no modifications are occurring; and 
• there is evidence the vessel was USL compliant.

This is subject to the vessel remaining within its current cycle of surveys for:

• Shaft
• Hull
• Watertight and weathertight integrity
• Engineering
• Fuel tanks

We may request submission of previous survey reports. If there is no evidence of it occurring recently, AMSA will generally require a 10 year survey at the next renewal. 

Electrical: AMSA always requires a current state electrical certificate of compliance, RCD and insulation test report for transitional vessels.

Fire: AMSA always requires evidence that a NSCV C4 compliant fixed fire detection and extinguishing system is fitted to the vessel.

Generally, AMSA will not require a draft mark survey. 

Vessel moving up in operational area, adding a new service category or undergoing modification

Generally, AMSA requires the surveys specified in Marine Order 503 and SAGM to be conducted. 

Commissioning phase scenarios

AMSA requires all three commissioning activities (lightship, stability and commissioning) to be completed. 

Note: A lightship declaration is not an acceptable form of lightship survey for initial surveys.

Renewal survey scenarios

Generally, AMSA does not issue alternate survey process approvals for transitional scenarios requiring renewal survey only. These are changes mentioned in clauses 6(c), 6(d) and 8 of schedule 1.  AMSA accepts elements of recent renewal surveys as supporting documents for these changes. 

For example, if a vessel has undergone a scheduled renewal survey 2 years ago, AMSA considers the shaft reports to have 3 years remaining validity. So, provided the owner is willing to accept a short term 3-year certificate, new shaft surveys are not required.

For out of water surveys the same applies. The vessel will keep its current cycle, provided the owner agrees to receive a shortened certificate.

In all circumstances, lightship reports, lightship declarations and in water surveys are not carried forward. 

A new lightship measurement (not declaration) is required. If a lightship variation is measured, stability information must be updated or provided to include updated person weights as required.

Complete an AMSA 901 recommendation to cover equipment and systems. This includes:

• transitional vessel sections
• RCD test report
• insulation test report, and 
• fixed fire report

Vessel system changes—transition implications

Marine order 503 schedule 1 contains vessel changes which trigger a vessel to become transitional. One of the changes causing confusion for owners and accredited marine surveyors alike is clause 8:

So let's bring some clarity to the matter.

What is a like for like change? 

The scope of a like for like change is limited. Most changes impact the original scope of approval or affect additional systems. The examples below illustrate this: 

Survey Requirement 

The clause 8 changes require an application for a new certificate of survey. MO503 Division 2 requires the vessel to undergo a renewal survey (to the transitional standards).

Applicable Standards

All items and systems directly affected by the change must be designed, installed and surveyed against the relevant NSCV criteria. The rest of the vessel must meet the transitional standards contained in MO503 Schedule 2. 

Summary

Clause 8 changes require close examination of all items of the vessel but some of these items may not be immediately obvious. Areas directly affected by the change must meet the current standards. However, there are several areas of the vessel not directly affected that must be upgraded to the transitional standard requirements:

• the vessel must meet COLREG requirements
• fixed fire detection and extinguishing is required
• RCDs must be fitted 
• passenger weights need to be upgraded to NSCV requirements and intact stability re-approved
• safety, Communications and Navigation Equipment must meet NSCV requirement

EX40 Structural assessment

We receive some EX40 submissions that fail to provide sufficient detail about the structural assessment of the vessel. 

So let’s look at the requirements under EX40 and Part 2 of SAGM.

Division 2 of EX40 states:

Division 4 of EX40 states:

Chapter 7 of SAGM includes:

What does all this mean? 

All vessels applying for an EX40 permission must undergo an auditable assessment conducted by an accredited surveyor to determine that the vessel is fit for purpose. The assessment must have supporting documentation demonstrating structural adequacy which the surveyor must retain as per SAGM Part 2 7.5.2 (7).

Use the construction section of the AMSA 650 to describe this assessment. 

Explain on the AMSA 650 when a vessel is being assessed for compliance against a recognised code. For example; 

Vessel designer, Australian Excellent Plate Boats Pty Ltd, supplied approved drawings showing the vessel is designed in accordance with AS4132. The vessel was inspected and found to be built in accordance with the drawings.

When using a record of safe operational history to assess a vessel, document the history and provide a description on the AMSA 650.

For example:

The vessel is a Model XX built by Australian Excellent Plate Boats Pty Ltd. The vessel has been confirmed by the builder and through inspection as a production series boat to Sister Vessel AEPB01 UVI 123456. AEPB01 is designed to AS1799 and has been operating with the applicant for 5 years. Applicant uses AEPB01 for gill net fishing within 15 Nm of the NSW coast as evidenced by statutory certificate number XYZ987. This vessel has been inspected and will undertake the same operations.

There are other options available in SAGM such as direct calculations or testing. If these are not conducted to a recognised code or standard the surveyor must be able to justify the method applied.
SAGM 7.5.2 does not permit the assessment of fitness for purpose based solely on an accredited marine surveyor’s “professional judgement.” The basis for any judgement must be documented in a similar manner as described above.

Relationship between plan approval and construction phase surveyors

SAGM Part 2 Chapter 3 defines the three phases of initial survey. For construction phase surveys the manual states:

The construction phase surveyor must identify departures from the approved design. This requires consultation with the plan approval surveyor and re-approval to be undertaken as per SAGM Pt 2 3.10.2 (3):

Approved documentation must accompany any proposed modifications during construction of the vessel. It must also address construction solutions not reflected in the original approved documentation.

The construction phase surveys must be finalised based on the updated approved documentation.

The survey process requires cooperation between the plan approval and construction phase surveyors. This will ensure all items are adequately addressed and the vessel is built based on approved documentation.