Proposed changes to safety management systems
We are seeking feedback on proposed changes to Marine Order 504 relating to safety management systems.
Marine Order 504 (Certificates of operation and operation requirements – national law) 2018 (MO504) outlines certificate of operation and safety management system (SMS) requirements for domestic commercial vessels (DCVs).
The proposed changes to Marine Order 504 are aimed at improving the safety outcomes of the SMS requirements and making them easier to understand, fit for purpose and practical for the diverse range of DCVs across Australia.
2023
- 1 August – MO504 Phase 1 changes came into effect
2024
- 28 May – Consultation opens
- 7 June, 11am AEST – Online information session
- 28 July, Midnight – Consultation closes
- Second half of 2024 – New Marine Order 504 made available to industry
2025
- 1 June – MO504 Phase 2 requirements come into effect
The key proposed changes include:
- simplifying SMS requirements for smaller, less complex vessels and operations
- strengthening fatigue management
- enhancing the management of risks from drug and alcohol use
- ensuring that roles and responsibilities for the safe operation of the vessel are clear
- updating the assembly station requirements to be more practical
- aligning procedures for onboard operations and emergency preparedness with risk
- addressing risks to vessel stability
- amending the certificate of operation renewal criteria to reduce administrative burden.
In addition to the key proposed changes, we are also proposing other minor administrative and editorial changes to improve the marine order.
See proposed changes
Owners, operators, masters and crew of domestic commercial vessels will need to implement the new requirements.
The simplified SMS changes will apply to smaller, less complex vessels including:
- Class 2 vessels less than 7.5m carrying up to 4 day passengers
- Class 3 vessels less than 7.5m
- Class 4 vessels less than 7.5m (all class 4 vessels still need to meet the requirements in Schedule 2 of MO504)
See vessels eligible to operate under a simplified SMS
The review of MO504 was initiated in 2021 to ensure alignment with the recently reissued Marine Order 505 (Certificate of competency – national law) 2022 (MO505). Following engagement on the proposed changes, industry feedback advocated for the SMS provisions to also be reviewed. Based on this feedback, it was decided to split the review into two phases.
The Phase 1 review of MO504 focused on improving crewing arrangements and lifejacket wear requirements. The Phase 1 changes came into effect on 1 August 2023.
The Phase 2 review of MO504 is focused on improving the SMS provisions to ensure they continue to improve safety outcomes and are easy to understand, fit for purpose, practical and proportionate to the risk.
We will review your feedback and expect to make the new Marine Order 504 available in the second half of 2024.
We expect the new Marine Order 504 to come into effect in June 2025. This will give owners and operators time to make the required changes. During this time, we will run an education and safety campaign explaining the requirements.
Should we do more to address the risk of fatigue?
Survey findings and feedback from industry have indicated that more needs to be done to address the risks of master and crew fatigue in the DCV industry.
Fatigue affects an individual’s ability to do their job effectively and safely and is a factor that significantly increases the risk of incidents.
In addition to seeking feedback on the proposed changes to MO504, we invite your views on a proposal to expand the existing requirement for 10 hours rest in each 24-hour period to all masters and crew working on DCVs.
See hours of rest
Background—Phase 1 review of Marine Order 504
Last year we sought your feedback on changes to operational safety in MO504, in relation to crewing arrangements, and lifejacket wear. Find out more about the requirements that came into force on 1 August 2023.