Summary of proposed changes
The table below outlines a summary of the proposed changes to the Surveyor Accreditation Guidance Manual Part 2.
- Theme 1: Re-alignment of survey processes with risks for certain vessels
Topic Location of change Proposed change Reason for change Who is affected Impacts on industry Enhanced Flexibility for CE certification of Class 2 vessels Table 3 This change introduces an 'L' designation in Table 3, allowing Class 2 vessels used solely for leisure type activities to utilize the same CE structural certification as leisure class vessels.
AMSA simplifies certification for Class 2 vessels to align with Class 4. This is in recognition that some Class 2 vessels are strictly for leisure.
The structural standards for class 2 and 3 vessels can be more rigorous than those for leisure vessels. This allows for workboat and fishing boat functions.
AMSA acknowledges some class 2 vessels are only used for leisure activities. This amendment allows these vessels to be put into service with the same structural certification as a class 4 vessel.
This amendment reflects AMSA’s acknowledgment of the specific structural risks for Class 2 vessels only used for sport and leisure, offering a more tailored approach to their certification and regulation.
Accredited Marine Surveyors
Owners and Operators of Class 2 Vessels
Owners and Operators of Class 2 Vessels:
Users can now opt to select CE modules that were limited to class 4 leisure class vessels, if their vessel use is only recreational.
This change may lead to a more streamlined and cost-effective process for getting these vessels into service.
Accredited Marine Surveyors:
Certifying and surveying vessels will need to adjust their assessment practices for these Class 2 vessels. They must understand the implications of the ‘L’ designation and ensure that these vessels meet the required standards.
Easing Design Approval Requirements for restricted C vessels 7.5.2 Surveyors can now recommend approval for a restricted C vessel based on a condition survey and expert opinion.
Extensive design documentation is no longer required if the vessel is suitable for its intended operational area.
Under previous SAGM, EX40 requirements, surveyors needed to collect construction documentation, including design calculations, drawings, and builder’s statements, for vessel certification.
Operational data and risk analyses revealed no significant incidence of structural failures in vessels of this size that might jeopardise safety or cause harm.This evidence guided the decision to streamline the documentation requirements. This reflects a practical approach to vessel certification while maintaining safety standards.
Accredited Marine Surveyors, Owners
Operators of Restricted Class C Vessels
Vessel Builders and Designers.
Surveyors can now approve restricted Class C vessels based on condition surveys and expert opinions.
This reduces documentation, especially for mass-produced or second-hand vessels, streamlining the certification process.
Restricted Class C vessel owners and operators can benefit from a faster certification process, especially for vessels without design documentation.
Vessel builders and designers dealing with mass-produced or second-hand vessels will experience a reduction in certification documentation requirements.
By reducing costs and time delays, we hope to improve the certification process.
Note: this change solely relates to the structure of the vessel. Evaluating stability, equipment, engineering, and other related aspects of the vessel is still necessary. Specific assessment and recording are essential.
Removing category A requirement for new build restricted C vessel Clause 7.3 A table (Table 10) now represents the simplified categories of accreditation required to conduct an Exemption 40 survey. The earlier provisions were complex and hard to understand. This update simplifies things and is in line with our efforts to make SAGM more straightforward. Accredited Marine Surveyors
Vessel Owners and Operators
Accredited Marine Surveyors: Marine surveyors conducting EX40 surveys are the ones primarily impacted by this change.
By simplifying accreditation categories, we can increase the pool of surveyors for surveys of EX40 vessels.
Enhancing work prospects for a range of accredited surveyors.
Vessel Owners and Operators: This change offers benefits to owners and operators of new build restricted Class C vessels.
It has the potential to make surveys more streamlined and efficient.
With an increase in surveyors, vessel owners may see reduced wait times and potentially more competitive pricing.
- Theme 2: More flexibility for high and medium survey schedule
Topic Location of change Proposed change Reason for change Who is affected Impacts on industry Enhanced Flexibility in Year 3 Survey Choice – Medium frequency vessels Table 8 We updated Table 8 to give vessel owners more choice in deciding how to conduct their year 3 survey. AMSA now allows owners to conduct the year 3 survey for a medium frequency vessel in or out of the water. This change aims to maintain safety while offering greater operational flexibility to owners. Vessel Owners and Operators of Medium Frequency Vessels
Accredited Marine Surveyors
Vessel Builders and Maintenance Service Providers.
Vessel Owners and Operators of Medium Frequency Vessels: now have more flexible scheduling surveys, leading to improved planning and cost savings with minimized disruptions.
Accredited Marine Surveyors: Surveyors can offer more flexible survey options to their clients.
Vessel builders and maintenance service providers might notice shifts in demand for slipway services as owners choose in-water surveys.
This has the potential to impact the availability and scheduling of slipway facilities.
Enhanced Flexibility in Year 3 Survey Choice – High frequency vessels Table 8 With the update to Table 8, vessel owners have greater freedom to choose how to conduct their periodic surveys.
The owner now has the freedom to swap the order of surveys in years 2 and 3.
Conduct the out-of-water survey in year 2 and the in-water survey in year 3, for example.
This change aims to maintain safety while offering greater operational flexibility to owners. Owners and Operators of High Frequency Vessels
Accredited Marine Surveyors
Vessel Maintenance and Repair Services
Owners and operators of High Frequency Vessels now have more flexible survey scheduling.
This can lead to better operational planning, potential cost savings, and fewer disruptions to vessel operations.
Accredited Marine Surveyors can now schedule surveys with greater flexibility.
This will have a positive impact on the distribution of their workload and the planning of surveys.
Vessel Maintenance and Repair Services: there may be shifts in demand for slipping and in-water repair services in vessel maintenance and repair. Due to the flexibility offered in survey scheduling.
- Theme 3: Increased details from NSCV listed in SAGM
Topic Location of change Proposed change Reason for change Who is affected Impacts on industry Verification of shipyard quality management system moved up into SAGM (from NSCV) to ensure they are clear for surveyors Clause 3.3 Clause 3.3 has been updated to more clearly state that a surveyor is responsible for verifying that the vessel's builder possesses the necessary capability to construct the vessel according to the required standards. According to feedback received from accredited surveyors, they were unaware of the existing obligation to verify shipyard capacity. Accredited Marine Surveyors
Vessel Builders
Vessel Owners and Operators
Accredited Marine Surveyors: Surveyors will need to collaborate more closely with builders to understand their construction processes, including evaluating the builders capabilities, understanding construction methodologies, quality systems and the specific standards applicable to vesel construction.
Vessel Builders are required to work more closely with surveyors and may be held more accountable for their construction processes and quality systems.
Vessel Owners and Operators: The increased collaboration between vessel builders and surveyors, along with heightened accountability for construction processes and quality systems, will ensure better adherence to quality and safety norms, leading to superior build quality.
Table 2 – Content of information and plans Table 2 Table 2 now details surveyable plan approval items, expanding the evaluation criteria against the NSCV standards. This change enhances vessel safety by ensuring comprehensive evaluation of vessels against the applicable standards in the NSCV. Accredited Marine Surveyors
Vessel Owners
Vessel Designers
Accredited Marine Surveyors need to ensure that their evaluations are thorough and aligned with the detailed descriptions provided.
Vessel Owners: The changes indirectly affect those who own and operate vessels.
Table 2 improves surveyor capacity to check and confirm adherence to safety standards during vessel construction.
Vessel Designers are indirectly impacted by this change.
It reinforces the value of complying with NSCV standards during the entire design and construction process.
Table 6 – Construction and alteration surveys Table 6 Table 6 provides a comprehensive description of construction survey items evaluated according to the NSCV standards. By evaluating vessels against the NSCV standards, this change improves vessel safety. Accredited Marine Surveyors
Vessel Owners
Vessel Designers
Accredited Marine Surveyors must ensure evaluations in line with the detailed descriptions in the updated standard.
Vessel Owners: Changes to table 6 will have an indirect impact on owners of newly built vessels.
Table 6 provides clear, crucial information for surveyors to ensure vessel safety and compliance.
Vessel Designers: The change indirectly impacts vessel designers.
It reinforces the importance of following NSCV standards in design and construction.
Vent Pipes and Insulation Test Table 8 Vent pipes and insulation test added to table 8 for clarity. This change enhances vessel safety by ensuring the evaluation of vessels against NSCV standards. Accredited Marine Surveyors Accredited Marine Surveyors: Negligible impact, as these are already surveyable items and reportable on form 901.
- Theme 4: Refinements and clarifications to existing standards
Topic Location of change Proposed change Reason for change Who is affected Impacts on industry New Definition – Additional Survey Definitions means a survey, either full or partial, according to the circumstances, undertaken:
- on a repair resulting from investigation or incident;
- following replacement, or repair of the structure, equipment, systems, fittings, arrangements and material; or
- outside the frequency prescribed by National Regulator.
Note: additional surveys are not conducted on vessels that have experienced a change under Marine Order 503, Schedule 1.
Vessels affected by such changes must undergo the surveys as specified in both Marine Order 503 and this manual, relevant to the specific type of change.
Feedback indicated that reporting obligations were unclear for additional and partial surveys. Accredited Marine Surveyors
Vessel Owners and Operators
Vessel Owners and Operators: Engaging an Accredited Surveyor is already necessary for owners to comply with the requirements.
However, the clarification in SAGM could lead to more interactions with surveyors, especially following incidents or major repairs. This may affect operational schedules and costs.
Accredited Marine Surveyors: Engaging an Accredited Surveyor is already necessary for owners to comply with the requirements.
The clarification in SAGM could lead to more interactions with surveyors, especially following incidents or major repairs.
This may affect operational schedules and costs.
New Definition – Partial Survey Definitions means a survey where only some aspect of the specified survey task were completed in accordance with this Manual. Feedback showed that reporting obligations were unclear for additional and partial surveys. Accredited Marine Surveyors
Vessel Owners and Operators
Accredited Marine Surveyors need to understand the components of a partial survey and ensure their reports comply with the updated definition and standards.
This clarity is helps both survey completion and owner certification.
Vessel Owners and Operators should understand the consequences of a partial survey on their vessels.
Choosing between a partial survey and a full survey is crucial for compliance and informed decision-making in vessel maintenance and operations.
New Definition – Full Survey Definitions means a survey where all aspects of the specified survey task have been completed in accordance with the requirements of this Manual. Feedback showed that reporting obligations were unclear for additional and partial surveys. Accredited Marine Surveyors
Vessel Owners and Operators
Accredited Marine Surveyors: must understand what makes up a full survey.
Having clear instructions benefits both survey completion and owner certification.
Vessel Owners and Operators: need to understand the requirements of a full survey and how it varies from a partial survey.
This helps ensure compliance and make informed choices concerning vessel maintenance and operations.
Use of own forms Clause 2.9 The surveyor has the option to use either forms from Annex 1 or their own forms, which should match the level of detail in Annex 1.
Note: Using the preferred form(s) in Annex 1 helps the National Regulator process the surveyor's recommendation(s) faster.
By tailoring forms to individual vessels, surveyors can constantly enhance their survey processes.Accredited Marine Surveyors
Vessel Owners and Operators
Vessel Builders and Designers
Accredited Marine Surveyors: Surveyors can use custom forms for different vessels or survey situations, which could make their surveys more efficient and relevant.
They need to ensure that their forms match the level of detail in Annex 1.
Vessel Owners and Operators: may benefit from surveyors using customized forms that may be more relevant to their specific vessels.
The result could be more precise and efficient survey methods.
Vessel Builders and Designers: Builders and designers may find that surveyors using tailored forms can more accurately reflect the unique aspects of their vessel designs.
This can lead to a more effective survey process.
RO recommendation form and content Clause 2.9 A Recognised Organisation should include the level of detail specified in Annex 3 in their recommendation to the National Regulator. Recognised Organisations (Ro’s)
Vessel Owners and Operators
Recognised Organisations (ROs): should include all specified details from Annex 3 in their recommendations to the National Regulator.
Adjustments may be necessary for their reporting formats and processes to match the new standards.
Vessel Owners and Operators: Owners and operators who rely on ROs for certifications and surveys will be indirectly affected.
Standardised RO forms should reduce processing times.
Recommendation with dispute Clause 2.9.5 The change clarifies that disputed recommendations are only for cases where a surveyor believes a non-compliance was previously accepted by a Marine Safety Authority (MSA). AMS have been incorrectly using disputed recommendations.
The dispute process is only for historical non-compliances that an MSA may have accepted.
Surveyors should only recommend disputes when they believe the MSA had already accepted a non-conformance.In other cases where the vessel does not comply, the correct recommendation to submit is “Not Recommended.”.
Accredited Marine Surveyors
Vessel owners and operators
Accredited Marine Surveyors: need to apply the 'not recommended' classification for non-compliant vessels correctly, rather than misusing dispute recommendations.
Understanding when to use each classification ensures accurate reporting and compliance with the revised standard.
Vessel Owners and Operators: are impacted by this change as it alters the reporting and resolution process for vessel deficiencies.
The correct classification by surveyors can determine the subsequent steps for compliance.
Instructions to surveyors Clause 2.10 Surveyors using a Quality Management System (QMS) with their own instructions must match the level of detail in the manual and AMSA Instructions to Surveyors (ITS). This change seeks to make survey processes clearer and more effective by enforcing consistent levels of detail and thoroughness in surveyor instructions.
It is not dependent on whether they use a QMS or the standard manual and ITS.
This standardization is crucial to ensure safety remains high across the national system.
Accredited Marine Surveyors using a QMS
Vessel Owners and Operators
Accredited Marine Surveyors who use a QMS with their own instructions are directly affected.
They must ensure that they make their instructions as detailed as those in the standard manual and ITS.This may require them to revise their current QMS documentation to align with the specified requirements.
Vessel Owners and Operators may experience changes in survey processes or reporting as surveyors update their QMS to comply with the requirement.
By ensuring consistent survey instructions, AMS can achieve greater service uniformity.
Duplicated 503 text removed Clause 3.2 & 4.12 Duplication of requirements specified in Marine Order 503 have been removed. This change allows for the separate amendment of 503 from SAGM 2. Accredited Marine Surveyors
Vessel Owners and Operators
Accredited Marine Surveyors must examine both SAGM Part 2 and MO 503 in order to understand the initial survey requirements.
Vessel Owners and Operators: to understand survey requirements, owners and operators should refer to SAGM Part 2 and MO 503.
Verification of Plan Approval Comments by attending Surveyors Clause 3.9.2 and Table 6 Addition of items
(j) outstanding plans or other documents that must be assessed before the plan approval of the vessel is complete; and
(k) plan approval comments that must be verified by the surveyor undertaking the construction surveys of the vessel during the build process.
Addition to table 6 of
Verification the vessel is constructed in accordance with the approved plans and design documentation
Current form and content of surveys have resulted in communication breakdowns between plan approval surveyor and construction surveyors.
This affected outcomes for safety and owners.
Marine Surveyors (Plan Approval and Construction Surveyors)
Vessel Builders and Designers
Vessel Owners and Operators.
Marine Surveyors (Both Plan Approval and Construction Surveyors): To maintain consistency, it is necessary to clarify the application of this requirement in all relevant surveys.
Vessel Builders and Designers: must continue to provide documentation and respond to plan approval comments.
It is important to note that they will be subject to more rigorous verification.
Vessel Owners and Operators: can expect a more consistent and thorough approach from surveyors because of the clarification.
This has the potential to result in more predictable and reliable outcomes during vessel construction and approval.
Sister vessels Clause 3.9.5 Clarified that basis vessel stability book must be provided
(d) a copy of the basis vessels stability book.
Accredited Marine Surveyors
Shipbuilders and Shipyards
Vessel Owners and Operators
Accredited Marine Surveyors: Making use of the vessel's basis stability book can aid accredited marine surveyors in making informed assessments.
Especially when ensuring that sister vessels meet the stability criteria.
Shipbuilders and Shipyards: Builders must have the stability book of the original vessel ready when constructing sister vessels for compliance and certification.
Vessel Owners and Operators: will be indirectly impacted by the change.
Stability information is essential for the effectiveness of continuous safe loading checks.
Surveys required vs Mars Letter Clause 3.10.2 New note:
Note 2 Applicable surveys listed in Table 6 are mandatory, regardless of whether they are included in the survey requirements letter produced by the MARS system. AMSA employs a risk-based strategy to lessen the administrative workload for AMS.
For example, AMSA does not require submission of fire safety reports through MARS for smaller vessels. However, it is still a legal requirement for these vessels to undergo a survey and demonstrate compliance with the relevant fire safety standards. A surveyor may be asked to provide their survey record for this activity at a later date.
The updated note clarifies which surveys are required and how the SAGM and MARS system-generated letters relate to one another. Accredited Marine Surveyors Accredited Marine Surveyors: must ensure they conduct surveys as required by the Surveyor Accreditation Guidance Manual, even when AMSA does not ask them to upload these to MARS. Lightship verification Clause 4.9 Clarified that the vessel’s stability must be re-assessed against the applicable stability criteria if lightship exceeds specified limits. Feedback from AMS that wording was unclear about what action is required if lightship exceeds tolerances. Accredited Marine Surveyors
Vessel Owners and Operators
Enhanced clarity is the main outcome of this editorial change. It simplifies understanding and compliance with the requirements for everyone involved. Scope and depth of a periodic or renewal survey Clause 4.11 (b) in order to be satisfied the condition of the vessel and its equipment correspond with the particulars of the applicable service categories and the vessel is fit to operate without danger to the vessel, or persons on board and that the vessel complies with the applicable legislation, exemptions and standards. Wording aligned with international practices (Harmonised System of Survey and Certification (HSSC) Code Accredited Marine Surveyors Enhanced clarity is the main outcome of this editorial change. It simplifies understanding and compliance with the requirements for everyone involved.
Following international standards helps avoid misunderstandings.This leads to a more consistent approach for all vessels and surveyors.
Ensuring compliance with safety standards in the industry.
Vessel Changes Clause 4.12.3 (3) an owner is responsible for ensuring their vessel continues to meet the standards that apply to the vessel, see MO503 section 11(1)(f), including after changes not mentioned within Schedule 1. Changes, including those not mentioned in Schedule 1, may require the owner to have an additional survey of their vessel conducted. Guidance manual has been unclear on what surveys are required for non schedule 1 changes, resulting in inconsistent safety outcomes.
The clarification aims to resolve previous inconsistencies in safety outcomes, leading to more uniform safety standards across the industry.
Accredited Surveyors
Vessel Owners and Operators
Accredited Surveyors: Surveyors may see an increase in requests to conduct surveys for vessels undergoing changes not outlined in Schedule 1.
Vessel Owners and Operators: Owners or operators now have clearer guidelines to follow to ensure their vessel meets the applicable standards.
In certain situations, owners may need to involve an AMS more often than before.
Part RO Survey Clause 5.2(1) (b) for a vessel ≤ 35m long, sufficient surveys to enable the issuance of a statement of compliance for all or part of the classification rules mentioned in this chapter.
According to industry feedback, there was a preference to involve an RO for certain parts of the survey.For example, structural approval on vessels under 35m.
Recognised Organisations
Vessel Owners and Operators
Recognised Organisations: can expand their client base by providing more tailored services.
Vessel Owners and Operators: Owners and operators of vessels < 35m can opt to engage an RO for specific aspects of surveying based on their needs.
For example, only for structural approval rather than a full survey.
Recommendation and supporting documentation expectation matrix Annex 1 We changed the table to make it easier to understand and read. The industry provided feedback expressing uncertainty about the deadline for a particular report. Accredited Marine Surveyors Accredited Marine Surveyors: The clearer guidance allows surveyors to prepare compliant documentation.
Plan approval letter example Annex 2 Example letter expanded to ensure it includes all content mentioned in SAGM 2 3.9.2 Addresses the problem of inconsistent plan approval letter submissions that resulted in processing delays and application refusals for owners Accredited Marine Surveyors
Vessel Owners and Operators
Accredited Marine Surveyors: Clearer guidance on submissions should assist surveyors and designers in preparing compliant documentation.
Vessel Owners and Operators: May experience indirect benefits from fewer application delays or rejections due to improved completeness and accuracy in plan approval letter
RO recommendation example Annex 3 Example RO recommendation template provided in Annex 3. RO's at the AMSA RO meeting received the recommendation template and agreed to adopt it. Recognised Organisations
Vessel Owners and Operators
Recognised Organisations: Adjusting the submission processes to include the specified level of detail is necessary to comply with the Annex.
Vessel Owners and Operators: Should experience fewer application delays or rejections due to more accurate and complete RO recommendations.