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- Changes to safety management system requirements - 19 March 2025
- Changes to fatigue risk management - 19 February 2025
Changes to safety management system requirements
Topic: Safety management systems (SMS)
Presenters: Steve Whitesmith, Anita Markovski, Desley Thompson
Date: Wednesday, 19 March 2025
Who attended: Vessel owners or operators, seafarers, maritime industry professionals, national and state industry associations, State and Australian Government agencies, industry advisory groups
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- View the transcript
Markovski, Anita 4:36
Good morning, everyone, and welcome to today's webinar. My name is Anita Markovski, and I am AMSA's Advisor, Safety Liaison based in Sydney NSW. On behalf of the team and AMSA, we're excited to have you here as we dive into some of the upcoming changes to Marine Order 504.These changes will come into effect on the 1st of June 2025.
Today's the second in our series of three SMS webinars. The topic is changes to safety management system requirements.
Before I get into the housekeeping and introductions, I'd like to acknowledge country in the spirit of reconciliation, we here at the Australian Maritime Safety Authority would like to acknowledge the traditional custodians of country throughout Australia and also acknowledge the connections to land, sea and community. We pay our respect to their elders, past and present, and also extend that respect to all Aboriginal and Torres Strait Islander peoples here on the webinar today.
OK. With regards to housekeeping:
- Please be aware there is a 30 second delay.
- Today's webinar is being recorded. You will receive a link to the recorded webinar afterwards.
- If you'd like to turn on live captioning, please do so by clicking the “captions” at the top of your team's window.
- Throughout the presentation will break into multiple Q&A sessions.
- Please stick around until the end of the presentation.
- If you have any questions, please post these in the Q&A chat and our AMSA experts Nathan, David, Tobin, and Natalia will answer them along the way.
- You can choose to post questions anonymously if you like.
- We will make sure we respond to all questions either during the webinar or afterwards, and also give us a thumbs up if you see a question in the chat that you want answered too.
- We will also ask you to complete a short survey at the end of the presentation and we'd appreciate your feedback.
Now to introduce the team. Today we have:
- Steve Whitesmith, AMSA's Liaison Officer in Fremantle, WA.
- Desley Thompson, our Advisor Safety Liaison, Aboriginal and Torres Strait Islander, based in Cairns, Qld.
Our presenter today is Steve, and I'll hand over to you now to begin the presentation.
Whitesmith, Steve 7:32
Thanks Anita, and thank you to everyone who's attending today. As you can see from the slide, there are 7 areas that we'll cover in this webinar, so let's begin.We’ll start with drug and alcohol policy requirements in your safety management system. This has been added to address the risks associated with drug and alcohol use.
It is important to remember that this amendment is nonprescriptive and allows owners the flexibility to assess the specific risks to their operation with appropriate mitigations.
Your master and crew need to be involved in discussions about this policy.
When developing your drug and alcohol policy consider:
- Instruction on what is acceptable and unacceptable drug and alcohol use when working on a vessel: this could include whether to have a dry vessel where no alcohol, prohibited drugs or non-prescription medication are allowed, or whether to permit crew to have a limited supply of alcohol at the end of their work day. Where alcohol is allowed, consider how this will be managed and any impact it may have on crew ability to undertake duties during an emergency.
- Drug and alcohol disclosure: consider whether to request crew members to inform you about any prescription medications they're taking. This could be important to know in case there are any undesirable effects from the medication, such as drowsiness. It will also enable you to have a full understanding of medications required in a medical emergency.
- Drug and alcohol testing: consider whether to conduct drug and alcohol testing prior to crew boarding the vessel as part of your pre departure checks and also where a crew member may be unfit for duty or under the influence. Consider how you will manage a situation where the master or a crew member is determined to be under the influence of drugs or alcohol and unfit for duty.
As you can see from the slide, AMSA has developed some example policies to assist vessel owners in developing their own. These two examples could relate to masters and crew on a Class 1, 2 or 3 vessel.
Additional requirements would be required for passengers being carried on a Class 1 or 2 vessel, including responsible service of alcohol laws that may be applicable in your state or territory.
These examples relate to hirers and participants using hire and drive vessels.
Additional information would be required for staff of a hire and drive business.
Having developed your policy, it's important to undertake a trial to ensure it's working as intended. Trials should be for a reasonable period for 1-2 months to help identify and address any problems. Ask key questions and encourage honest feedback from masters and crew to be satisfied that your policy is working.
Once the policy has been developed, trialled and you're sure it's fit for purpose, you can implement the policy into your safety management system.
Your policy needs to be reviewed:
- following any incident where drugs or alcohol may be a contributing factor
- if the master or crew raise any concerns and
- as a minimum during your annual SMS review to reflect any changes in legislation, best practices or improvements you may identify.
It is also important to stay informed about any changes in legal requirements that may affect your operation.
We are now posting some useful links for you in the Q&A chat.Just prior to continuing the presentation, we would like to get an idea of how many of you already have a drug and alcohol policy. If you could add a thumbs up to the question in the Q&A chat. If you haven’t, we hope that today's presentation and our website information give you a few ideas.
Now let’s move on to master and designated person requirements. AMSA introduced these to help clarify and differentiate operational roles and responsibilities between the owner, master and designated person.
The designated person is responsible for monitoring and supporting safe vessel operations, pollution prevention, aspects of the vessel operation and providing a link between those on board and management of the organisation.
Designated person should be contactable by all crew working on the vessel and should be able to act on legitimate concerns.
They do not need to be contactable 24/7, only as appropriate for the type of operation.
To do this effectively, the designated person needs to have a direct access to the highest levels of shore based management and should be able to ensure adequate resources and shore based support can be provided to the vessel.
As noted in the slide, a designated person responsibility statement is not required for a vessel that meets the eligibility criteria for a simplified SMS and the owner is the designated person.
In developing your designated person responsibility statement, you need to include information on who holds the function of designated person. Noting this could be more than one person depending on the size and nature of your operation.
Their contact information and their roles and responsibilities.
As you can see from the slide in this example, when developing the designated person responsibility statement, the owner has considered the operations undertaken by vessels and crews, including:
- the size and complexity of the operations
- the need for out of hours contact with masters and crew, again, not 24/7 as this is the responsibility of the emergency contact
- the need for people with good knowledge of vessel operations and the safety management system
- and the ability of the person to ensure appropriate resources and shore-based support to the vessel.
You would also include details of who holds the function of designated person. And as mentioned before, this could be more than one person depending on the size and nature of your operation, as well as their contact information.
There is no policy change to the master's responsibility and authority statement. This amendment clarifies the existing requirements, as noted in the slide, a master's responsibility and authority statement is not required if the owner is also the master and their vessels meet the eligibility criteria for a simplified SMS.
Even though this amendment is only to clarify existing arrangements under marine Order 504, it is important that vessel owners review their master's responsibility and authority statement to ensure it is clear that the master has authority to make decisions for the safety of the vessel, the environment and persons on or near the vessel and may request the owner's assistance to ensure the safety of the vessel, the environment and persons on or near the vessel.
And you can see the links that have been added to the chat with information on our website about this.
And we'll now take a short break to go through some of the questions in the Q&A chat and also to answer some commonly asked questions. I'll pass over to Anita and Desley.
Markovski, Anita 15:37
Thanks to everybody who has posted questions in the Q&A chat. Please remember if we don't get to your questions during the webinar, we will afterwards. I will now read some of your questions and provide the responses given by our team.The first question is how can I find out about the possible side effects of medication that my crew are taking?
Thompson, Desley 16:09
So if a crew member is prescribed a new medicine, their pharmacist should provide them with a Consumer Medicine Information (CMI) leaflet. For further information, visit the Healthdirect Australia website or consult your local health care professional.Markovski, Anita 16:37
Thanks Desley.Another question around drug and alcohol tests, does AMSA expect a certain number of drug and alcohol tests to be conducted and recorded each year?
Thompson, Desley 16:52
That's another good question. No, you won't be required to conduct and record a minimum number of tests.Vessel owners and operators have the flexibility to assess the specific risks to their operation. Owners will be able to decide what controls – through testing or otherwise - need to be implemented to ensure a vessel is not being operated while a master or crew member is impaired. These controls may or may not include testing.
Markovski, Anita 17:20
Thanks Desley.There's another one on alcohol.
I believe a dry boat should be a basic safety precaution for all vessels. Why didn't AMSA prohibit alcohol for all crew on board commercial vessels?
Thompson, Desley 17:38
Yeah. No, that is a good question. So, vessel owners, in consultation with the master and crew, are best placed to develop a risk-based drug and alcohol policy. This includes determining what is acceptable and unacceptable drug use. This might include having a ‘dry vessel’ policy where no alcohol is permitted. Alternatively, crew may be permitted to have a limited supply of alcohol at the end of their day. Where alcohol is allowed, vessel owners should consider how this will be managed and any impacts it may have on the crew’s ability to undertake duties in an emergency.Markovski, Anita 18:25
Thank you, Desley. And here's another one.There are a lot of people who would probably want to know about this as well. What happens if I find out one of my crew is under the influence when at sea?
Thompson, Desley 18:40
Another good question. Yes. So, your drug and alcohol policy should consider how to prevent this occurring. This could include limiting alcohol consumption, running a dry boat, having a strict no drugs policy etc. However, in the event that someone is under the influence, be it alcohol, non-prescribed medication or possibly side-effects of prescribed medication, it is important to consider if they are a danger to themselves or others and how best to manage the situation.Markovski, Anita 19:20
Thank you, Desley. I'll now hand back to Steve to continue with the presentation.Whitesmith, Steve 19:27
All right. Thanks very much Anita and Desley and thanks everyone for your questions. Please keep them coming. We will now move on to procedures for vessel operations.Class 1, 2 and 3 vessel owners, including those eligible for simplified safety management systems, are required to include additional procedures for key vessel operations in their SMS. It is important to remember that only those relevant to your vessel and operation need to be added.
Owners must outline how they will manage the risks relating to these activities, if relevant to the vessel and its operation.
As you can see from the slide, vessels eligible for simplified SMS only need to include vessel access and we'll discuss this in more detail during the simplified SMS webinar in April.
It is important that you identify the procedures that are relevant to your operation, identify the risks involved with these procedures and the ways to control those risks. The risks and the controls both need to be recorded in your SMS risk assessment.
In the example shown we have chosen to look at passage planning. The risk assessment has considered several controls, including charts and nautical publications necessary for the intended voyage up to date, and this includes containing accurate, complete and up to date information regarding those navigational limitations and hazards which are of a permanent or predictable nature and which are relevant to the safe navigation of the vessel.
Master and Deck watch keepers are appropriately qualified and trained.
And master and deck watch keepers are to ensure that the intended route from point of departure to the intended destination is planned and cross checked. This is an example only and may not be applicable for your operation.
Having identified the risk and the controls you intend to put in place, you now need to consider who will be responsible for implementing and monitoring the controls.
In making this decision, you should consider the knowledge and training the person has and their ability to undertake the role as part of, or in addition to, their normal duties.
Each control measure put into place, someone needs to ensure that is implemented and followed depending on the control, this could be the owner, master or a crew member.
In this example, the majority of tasks have been given to the master.
Having gone through the risk assessment process, including identifying key controls and who is responsible for implementing and managing the risks, you can now develop your procedure again. This is an example only and may not be applicable to all operations.
Having developed your procedure, it's important to undertake a trial to ensure it's working as intended.
The trial should be for a reasonable period for between one to 2 months to help identify and address any problems.
Ensure you ask key questions and encourage honest feedback from the master and crew to be satisfied that it is working as intended.
This then forms part of your safety management system, including training for new masters and deck watch keepers.
The emergency plan must include a procedure for responding to loss of propulsion and oil or fuel spills if relevant to the vessel and its operation.
These changes came about because certain emergencies carry higher levels of risk, which need to be managed.
These new requirements are in addition to the existing emergency plan requirements, such as fire, loss of steering and collision.
It is important that you identify the emergency procedures that are relevant to your operation, identify the risks involved and the ways to control the risks, and then to record the risks and controls in your safety management system risk assessment.
In the example shown, we are considering loss of propulsion.
The risk assessment has considered controls, including:
- the outboard motor to be serviced in accordance with the manufacturer's instructions
- the Coxswain is appropriately qualified and trained, and
- emergency procedures implemented, and crew trained.
Again, this is an example only and may not be applicable to your operations.
Having identified the risks and the controls you intend to put in place, you now need to consider who will be responsible for implementing and monitoring the controls.
In making this decision, you should consider the knowledge and training the person has and their ability to take the role as part of or in addition to their normal duties.
In this example, the owner has shared the responsibilities between the master and themselves.
As with all the examples shown throughout the presentation, this is an example only and may not be applicable to your operation.
Gone through the risk assessment process, identifying the key controls and who's responsible for implementing and managing the risks, you can now develop your emergency procedure.
In this example we have used a 6 metre Class 2D workboat.
As with your other procedures, it's important to undertake a trial to ensure it's working as intended. The trial should be for a reasonable period to help identify and address any problems. Continue to ask key questions and encourage honest feedback from your masters and crew to be satisfied that this procedure, as with all your other procedures, is working as intended.
This then forms part of your safety management system, including becoming part of your normal training programme.
Now take a short break to go through some more questions in the QA chat and also to answer some commonly asked questions. I'll pass back over to Anita and Desley.
Markovski, Anita 26:34
Thanks for that, Steve, and thank you to everybody who's continuing to post questions in the Q&A chat. We'll go through some of those questions now and hopefully answer some of them.Hey, the first question is our designated person responsibility statement doesn't look anything like the example shown. Do we need to change it?
Thompson, Desley 26:58
Example shown is a guide to help industry in developing their own. So, if you already have a designated person responsibility statement and it covers the roles and responsibilities applicable to your operation, then you don't need to change it. We do recommend, however, that you review it to ensure that it remains current and includes details of the designated persons and their current contact information.Markovski, Anita 27:29
Thanks, Desley. Another question is, can the designated person and emergency contact be the same person?Thompson, Desley 27:40
Yes, they certainly can. However, it is important that we distinguish between the 2 functions. But for more information about that, you can have a look on the AMSA website. Actually, I think there might be a link in the chat now.Markovski, Anita 28:04
Thanks, Desley. The next question is, can the master be a designated person as well?Thompson, Desley 28:13
Thanks, Bonnie for your question. So, the designated person plays a key role in the effective implementation of the safety management system and does take responsibility for monitoring and supporting the vessel for all safety aspects. The role is usually shore-based to ensure continued support in the safety management system implementation. However, there is no set rule about who can hold the position of designated person as long as functions can be effectively managed. This will largely depend on the size of the organisation and of course the type of the operation.Markovski, Anita 28:56
Thanks Desley and another question we've got here is what if one of the procedures listed in MO504 is not applicable to my vessel or my operation?Thompson, Desley 29:10
So if a procedure for vessel operations listed in Marine Order 504 is not applicable to your vessel or operation, you don't need to include the procedure in your vessels SMS. For example, if your vessel doesn't have a confined space, you won't need to include a procedure for confined space entry. However, in some circumstances, you will find that additional procedures to those listed in MO504 are required to address risks identified by the vessel’s risk assessment.Markovski, Anita 29:50
Thanks Desley and now I'll hand back to Steve to continue with the presentation.Whitesmith, Steve 29:58
Thanks everyone for putting in your questions. There will be more opportunity at the end of the presentation, so please keep them coming. We now move on to assembly station requirements on the 1st of June 2025, the requirement to have an alternative assembly station no longer depends on the number of persons carried on board.The new requirement is that alternative assembly stations are only required if practical based on the vessel's layout characteristics and a risk assessment.
These new requirements apply to all Class 1, 2 and 3 vessels, except for those eligible to operate under simplified SMS.
And considering your assembly station requirements, you need to consider how an alternative assembly station can control risks, whether on alternative assembly station is practical, based on the vessel's layout characteristics and risk assessment, and where to locate an alternative assembly station.
Having considered these key questions and any others you may have, you need to update your risk assessment to reflect any changes.
Having reviewed your risk assessment, it's time to update your emergency plan. You should, as part of your plan, identify:
- at least one assembly station the primary assembly station for all persons on board
- an alternative to any primary assembly station that comes unusable or inaccessible during emergency (if it's determined as practicable in your risk assessment)
- arrangements for assigning a crew member to each assembly station
- a system for use in emergency for the crew to record and confirm the presence of all persons on board, and
- how often emergency procedures, including assembly station drills, will be practised.
If you operate passenger vessels, you will need to ensure that your emergency plan includes:
- the location of each assembly station
- what passengers must do in an emergency
- how passengers are to find, put on and secure life jackets
- placement of appropriate signage to guide passengers to the assembly station
- placement of ‘what to do in an emergency’ information in each assembly station, passenger cabin and other areas frequented by passengers.
- placement of appropriate signage and information on how to find, put on and secure life jackets in each assembly station, passenger cabin and other areas frequented by passengers. You can see the link to our website for further information. That's being added to the chat.
Being reviewed, your risk assessment identified key actions and who is responsible for implementing and managing the actions. You can now update your emergency plan.
In this example, we look at the emergency procedure for abandoning a vessel.
Having developed your plan, it's important to undertake a trial to ensure it's working as intended.
Trials should be for a reasonable period for one to 2 months to help identify and address any problems.
Ask key questions and encourage honest feedback from the master and crew to be satisfied that your plan is working as intended.
This then forms part of your safety management system, including training for crew.
Vessel owners are required to address operational risk to vessel stability by meeting the 2 requirements shown.
Identifying the risk to vessel stability and the risk assessment applies to all vessels except those eligible for simplified SMS, although even when operating under a simplified SMS, owners should still identify and manage risks such as vessel loading through the risk assessment process.
Vessel operators also need to keep a record of modifications affecting vessel stability for all Class 1-2 and 3 vessels.
AMSA introduced this requirement because failure to adequately assessed stability risks, including modifying your vessel can and has led to vessels capsizing.
When thinking of the key risks to your vessel’s stability, consider:
- any modifications you have undertaken or planned to undertake to your vessel including installing new equipment or fishing gear
- overloading or weight creep
- towing
- loss of watertight integrity
- free surface effects, including water on deck
- accidental flooding, and
- rough sea state and weather conditions that you may operate in.
Having considered these key questions and any others you may have, you need to update your risk assessment to reflect any changes.
It is important that owners, masters and crew all learn about stability risks and to assist with this, AMSA has some good resources on our website relating to stability, for fishing vessels, construction barges and towing operations.
The best way to verify if a risk to stability has been appropriately considered is to assess the vessel against the applicable stability criteria in the national standard for commercial vessels (NSCV), or, if applicable, the Uniform Shipping Laws Code.
Using competent persons such as accredited marine surveyors and naval architects will greatly assist with this.
Some instances operations may have to be modified for the vessel to remain stable and compliant with the stability book.
If you don't know, ask a competent person such as an accredited marine surveyor or naval architect.
Having reviewed your risk assessment, identifying key actions, risks and controls, these are added to your risk assessment and are then used to assist in updating your emergency procedure.
This then forms part of your safety management system, including as part of your normal training programme, and again this is an example only.
Already mentioned, modifications to the structure or equipment of a vessel may change its stability and the way it behaves at sea.
Previous coronal findings have found that vessel modifications were factors in vessel sinking or capsizing.
This requirement does not affect existing obligations to advise AMSA of vessel modifications such as the obligations under Marine Order 503, the certificates of survey, Exemption 40 for Class C restricted operations, and Exemption 2 for certificate of survey or non-survey vessels.
Under these requirements, vessel owners are legally required to inform AMSA of modifications made to their vessel.
Depending on the extent of the modifications, the vessel may need to have its stability reassessed by an accredited marine surveyor and undergo other survey requirements.
Despite these mandatory reporter requirements, it is important that masters and crew are also aware of any modifications made to the vessel that may impact stability.
This will help them decide how they use the vessel and what conditions are safe to operate in.
Examples of modifications shown in this slide may not apply to your vessel. However, they are a good starting point:
- addition or modifications to trawling, towing or lift apparatus apart from like-for-like replacement of apparatus that is addressed in the stability assessment of the vessel
- addition of external plastic curtains (clears)
- addition, removal or modification of the size or location of tanks such as fuel, fresh water, wastewater, lube oil, ballast water, sludge, live bait, fish tanks/fish bins or cargo tanks
- addition, removal, relocation or replacement of machinery including propulsion engines that are not a like-for-like replacement
- addition, removal, relocation or replacement of accommodation fit-out or equipment that would alter the displacement, trim or raise the centre of gravity of the vessel from the lightship condition for which it was previously approved e.g. cabins, refrigerators, air conditioners, compressors, cool rooms, ice rooms, and
- variation to the operational loading of the vessel including cargo and personnel weights and their location.
This example the vessel has recently undergone a refit of the main saloon area. The master has had the work assessed and signed off by an accredited marine surveyor and duly recorded in the logbook.
AMSA has a number of handy resources available on our website that you may find useful. Please see the link that has been added to the chat. You can also find these resources and others by adding keywords in the search function at the top of the AMSA home page. We'll also ensure links are included with the uploaded copy of this presentation and provided to webinar participants.
We're reaching the end of the webinar, but prior to finishing up we'd like to remind you to complete the short survey to ensure our webinars meet your needs.
I'll pass over again to Anita and Desley to go through some more questions in the Q&A.
Markovski, Anita 40:27
Thanks, Steve, and thank you to everybody today for contributing to our webinar by asking these great questions. And we have a few more to read out now.So first question is, if a crew is on board and takes a drug which effects their judgement, what measures can the master take to confine the crew?
Thompson, Desley 40:55
That's a good question. So, the master should try to prevent any situation escalating, so it is best to try to talk to the affected person calmly and try to keep them in a safe space. If the person's actions endanger the safety of the vessel or people on the vessel, the master can take any reasonable steps to secure the safety of the vessel.Markovski, Anita 41:26
Thanks, Desley. The next question is, can our corporate alcohol and drug policy be referenced in the SMS? Should we add high level dot points from the policy in the SMS?Thompson, Desley 41:42
So If you already have a drug and alcohol policy in place to meet your workplace health and safety (WHS) obligations, you should check that a copy is included in the vessel’s SMS, you have inducted all your existing crew/staff on the policy, you are inducting all new crew/staff when they join the vessel/operation, and you regularly train your crew/staff on the policy and how it works in practice.Markovski, Anita 42:18
Thanks Desley. The next question is do vessels operating under a simplified SMS need to include an assembly station?Thompson, Desley 42:30
Vessels that meet the eligibility criteria for a simplified SMS will not be required to include an assembly station in the vessel's emergency plan. However, owners are encouraged to include one where it is practical based on the vessel’s layout, characteristics and risk assessment.Markovski, Anita 42:53
Thanks for that, Desley. The next question is how can I get a copy of this presentation to share with my crew?Thompson, Desley 43:03
So we'll email all the attendees a copy of the presentation, the Q&A summary, and a recording of the webinar. This information will also be available on the AMSA website, but please allow about a week for our team to review the questions from the chats and they can prepare the responses as well.Markovski, Anita 43:25
All right. Thanks for that.The next question is, is the addition of a drug and alcohol policy a new addition for a vessel's SMS?
Thompson, Desley 43:39
Thanks for this question, Pat. As of the 1st of June 2025, there will be an explicit requirement in Marine Order 504 for a drug and alcohol policy to be included in the vessel's SMS. So, while this is a new requirement, many DCV owners and operators may already have a drug and alcohol policy in place due to the workplace health and safety obligations.Markovski, Anita 44:09
Thank you. The next question is I have members who are not eligible for a simplified SMS because they have a net reel or petrol inboard engine. They then need to adhere to the passage planning stipulation for a vessel 6m open vessel with no cabin/wheelhouse. This works well if on larger vessels, but this is not practicable.Thompson, Desley 44:41
Yeah, sounds very interesting. So, we intend to monitor the performance of the simplified SMS approach when it comes into effect on the 1 June 2025 and examine whether the eligibility criteria is fit for purpose, and balance safety and burden on industry.There will be a webinar focused on the new simplified SMS arrangements on 9 April 2025.
Markovski, Anita 45:11
Alright. Thanks, Desley. And the next question is, if our vessel does not qualify for a simplified SMS, but it is a small vessel 5.5 metres, do we need to have an assembly station?Thompson, Desley 45:31
If your vessel does not qualify for a simplified SMS, you will be required to identify an assembly station for the vessel in the vessel’s emergency plan.
Markovski, Anita 45:46
Thanks Desley.And now I'll hand back to Steve.
Whitesmith, Steve 45:55
And thanks, Desley. And again, thank you for all the questions. They will be added to the package that's sent out to you afterwards as well, so you'll get all those questions and more if we haven't been able to answer any. So just prior to closing, I'd like to remind everyone that there is one more webinar coming up on the changes to 504 if you haven't already done so, you can now register for the simplified SMS webinar on the AMSA website or through the link in the chat and we look forward to seeing you again on the 9th of April.Markovski, Anita 46:28
Thank you, Steve. We would like to thank everybody for attending today's webinar to help the team make sure the future webinars are valuable use of your time. We would appreciate your feedback.Please click on the link in the chat to conduct a short survey. If you haven't already registered for the next webinars, we encourage you to do so and please let others know. We hope to see you in April for our next webinar.
Thank you.
Presentation slides
Download the Changes to SMS requirements webinar presentation slides PDF9.97 MB
Q & A
Read answers to questions about new SMS requirements PDF288.71 KB that were asked by industry during the webinar.
More information
Changes to fatigue risk management
Topic: Fatigue risk management
Presenters: Steve Whitesmith, Mick Bishop, Desley Thompson
Date: Wednesday, 19 February 2025
Who attended: Vessel owners or operators, seafarers, maritime industry professionals, national and state industry associations, State and Australian Government agencies, industry advisory groups
Watch the webinar
- View the transcript
Thompson, Desley 4:42
Good afternoon, everyone, and welcome to today's webinar. My name is Desley Thomson, and I'm AMSA’s Safety Advisor Liaison Officer for Aboriginal and Torres Strait Islander people and communities. I'm based here in the Cairns Office in Far North Queensland.On behalf of the team and AMSA, we're excited to have you here as we dive into some of the upcoming changes to Marine Order 504. These changes will come into effect on 1 June 2025.
Today is the first in our series of three webinars about the changes to safety management system requirements, and our first topic today is fatigue risk management.
Before we go any further, I'd like to acknowledge the Traditional Custodians of Country throughout Australia and also acknowledge their connections to land, sea, and community. We pay our respects to their Elders, past and present, and also extend that respect to all Aboriginal and Torres Strait Islander peoples here today.
Just some housekeeping before the presentation:
- Today's webinar is being recorded, and you will receive a link to the webinar afterward.
- Please be aware that there is a 30-second delay.
- If you'd like to turn on live captioning, please do so by clicking the captions button, and it should automatically appear for you.
- If you have any questions, please post them in the Q&A chat. Our AMSA experts—Nathan, David, and Natalia—will answer these throughout the presentation.
- Questions can be posted anonymously too. If you see a question in the chat that you'd also like answered, give it a thumbs up to help prioritise it.
- We will make sure to respond to all questions either during the webinar or afterward.
- At the end of the presentation, we'll also ask you to complete a short survey. This will help us gauge whether our webinars are meeting your needs.
I'd now like to introduce the team helping me out today:
- Steve Whitesmith, AMSA’s Liaison Officer in the Fremantle Office, WA
- Mick Bishop, a Liaison Officer in the Townsville Office, QLD
Our presenter today is Steve. I'll now hand over to you to begin the presentation.
Whitesmith, Steve 7:25
Thank you, Desley, and thank you to everyone attending today. As you can see from the slide, there are seven areas that will be covered in this seminar, so let's begin.The fatigue management requirements under Marine Order 504 provide vessel owners with flexibility to chose how they manage the risk of fatigue for masters and crew. This could be through the use of a fatigue risk management plan. Whatever method is chosen, it must include a level of detail that matches the operation’s risk level, type, and complexity.
The requirement for fatigue management applies to all Class 1, 2, and 3 DCVs, including all operation types and voyage lengths. The level of detail required will be determined on the nature and complexity of the operation.
As mentioned earlier, these changes take effect from 1 June 2025. It is also important for vessel owners to continue managing risk of fatigue under state and territory work health and safety laws.
Why has AMSA made these changes? AMSA conducted a research survey in 2019 to understand awareness and perceptions of fatigue and its management for masters and crew working on DCVs.
Responses on sleep duration and quality at home indicated that one-third of seafarers commenced duty in a fatigued state. While at sea, 40% of respondents stated getting less than six hours of sleep in a 24-hour period.
Respondents were also less likely to recognise behavioural symptoms of fatigue, such as headaches, body aches, affected speech, and increased risk-taking.
Over 25% of respondents stated they experienced fatigue very often or most of the time, either immediately before or during their time at sea.
50% of respondents indicated they had either not received any fatigue management training or were unsure.
Fatigue is a hazard that can affect a seafarer's ability to perform their job safely and effectively. It also affects health and well-being. There is a common misconception that fatigue comes with the job, but the reality is that many maritime operations expose seafarers to conditions that lead to fatigue.
Fatigue has been identified as a contributing factor in several marine incidents. We will touch on a few of these later in the presentation.
Accident investigations and research reveal the serious impact of fatigue on safety, health, and welfare. While fatigue cannot be eliminated, it must be properly managed.
Aspects that elevate the risk of fatigue include:
- Inadequate sleep (both in quantity and quality). For example, sleep disorders such as sleep apnoea can affect the quality of sleep
- Shift work, which disrupts the body clock
- Duration of continuous work without adequate breaks
- Intense mental and/or physical workloads
- Stress, isolation, and separation from family
- Environmental aspects such as ship motion, vibration, temperature variation, light, and noise.
- In recent years, family and work demands, including increased use of electronic devices such as phones and time spent on social media have also affected sleeping habits.
Fatigue can have a profound impact on an individual’s ability to work safely. It has been shown to not only have an impact on their physical and cognitive abilities but also impact individual behaviour.
To give you some examples, we would like to get an idea of how many of you have experienced fatigue in your job.
It might be firsthand or you may have witnessed a colleague suffering from the risks of fatigue while working.
If you can add a thumbs up to the question in the Q&A chat, and then we'll go through the next few slides which might help you in considering this question.
Common physical signs of fatigue include inability to stay awake, head nodding, or falling asleep involuntarily. Difficulty with hand eye coordination, speech difficulties, slurred, slow or garbled speech, increased frequency of dropping objects like tools or parts, digestion problems, and insomnia.
And cognitive science of fatigue includes being preoccupied, lapses in concentration, misjudging distance and speed, and slower reaction times.
Common behavioural signs of fatigue include decreased tolerance and or displaying antisocial behaviour, irregular mood changes, irritability, depression, failure to anticipate danger and low motivation.
In fatigued, this can impact safety, performance, health and well-being, and in some cases, this has led to marine incidents with consequences similar to that shown in the photograph.
We'll discuss a couple of marine incidents later in the presentation.
Most dangerous aspect when fatigue is that we are poor judges of our own level of fatigue and performance because of what we know about fatigue and its consequences it's important that we manage the risks. This can be done through having a fatigue risk management plan.
Generally, the single most important factor to consider in managing the risk of fatigue is sleep.
People generally need 7 to 9 hours of good quality sleep to perform effectively. Anything less is a compromise. For example, if an individual only obtains 5 hours sleep, they have accumulated a sleep debt. Unless this sleep dead is recovered, it will lead to performance impairment. Sleep debt only goes away with good quality sleep.
Excessive nights of inadequate sleep add to this sleep debt. This leads to further reduction in performance and can lead to more severe fatigue symptoms such as micro sleeps, long term sleep debt has been shown to have a significant impact on health and well-being.
Another factor is time awake. The longer a seafarer remains awake, the stronger the drive for sleep, and the higher the levels of fatigue.
Long work hours are associated with poor performance and poorer safety and health outcomes.
How far you have to commute to work is also important to consider.
Seafarers may have to travel or drive long distances to the vessel and then have to work again, affecting their quantity of sleep. This is similar for crews who work part time or are volunteers with other employment. They can also be affected by quantity of sleep.
Everybody has a body clock, and this clock regulates the body's circadian rhythm.
Body Clock makes a person sleep or alert on a regular schedule, regardless of whether they are working or not.
Body clock programmes us to be active during the day and to sleep at night.
In normal conditions the sleep-wake cycle follows a 24-hour rhythm. However, the cycle is not the same for everyone.
Typically, we are most alert during the day and sleepy at night. The circadian through typically occurs between 2:00 and 6:00 AM and is referred to as the window of circadian low.
This is when we're at the lowest of our alertness and working during these times means we are more at risk of making mistakes and this has been scientifically proven.
Consequently, the time of day in which work takes place increases the risk of fatigue. Seafarer is working through the night can be expected to be sleepy, and when you look at the circadian rhythm diagram in the slide, you can see that the period that is dark red in colour between 2:00 and 6:00 AM, where they have to make additional effort to maintain alertness and performance.
Many seafarers working patents conflict with their body clock.
If you have to be awake and work at night or in the early morning, or working for extended periods, it can disrupt your body clock, resulting in increased risk of fatigue.
We will now take a short break to go through some questions in the Q&A chat and answer some commonly asked questions. I’ll now pass over to Desley and Mick.
Thompson, Desley 17:13
Thanks, Steve. Just in terms of the webinar poll.There's been a quite a few thumbs up and I can see a few that have had experience around fatigue at work, so it's a really important discussion that we're having today and thank you for those that have put their thumbs up and have noted that the poll as well too.
Also, thank you to those that that are posting some questions on the Q&A chat. I might read a couple of them and.
Get you Steve or Mick to answer them for me, if that's OK. So the first one is.
Whitesmith, Steve 17:49
That's fine.Thompson, Desley 17:53
Can I use an SMS app to develop my fatigue plan? How about this Steve, did you want to answer that one? Thanks.Whitesmith, Steve 17:58
Yep, I'll take this one. That’s a great question! As we know, SMS apps are becoming increasingly common, popular in the industry. If an app has the ability to include a fatigue risk management plan, it can certainly be used.However, under Marine Order 504, a vessel's SMS must be kept on board and be reasonably practical based on the vessel’s size and use. A copy must also be kept onshore. The requirement won’t be met if the SMS cannot be accessed while on board—for example, if it relies on internet access and hasn’t been downloaded. I’d recommend having a chat with your SMS provider and they will be able to provide information in terms of access to the SMS.
Thompson, Desley 18:45
Thanks for that response. That’s great to know because, as you said, there are quite a few apps available now.This next question is for you, Mick: Why doesn’t AMSA align the minimum rest hours in the domestic maritime industry with international standards—specifically, the 10-hour minimum break in each 24-hour period?
Bishop, Mick 19:24
Great question on fatigue risk management. Our approach considers a broader range of risks beyond just work and rest hours, including environmental factors, night work, and the suitability of the sleeping environment. This flexible approach better suits the diverse range of domestic commercial vessel operations, which vary from large vessels to small ones and from long trips to short ones, rather than applying a one-size-fits-all model.Thompson, Desley 19:55
You’re absolutely right—it’s a diverse industry, and having that flexible approach makes sense. Thanks for that, Mick.Next question for you, Steve: I already have a fatigue plan. Do I need to redo it?
Whitesmith, Steve 20:13
No, you don’t need to redo it, but you do need to review it. It’s important to ensure your plan complies with the requirements of Marine Order 504. You can review it anytime between now and 1 June to meet the upcoming changes. If you already have a plan, I’d encourage you to review it, compare it against the information we have online and what you’ve learned from today’s presentation, and ensure it meets all the necessary requirements—not just those of Marine Order 504, but all relevant standards.Thompson, Desley 20:15
OK.Thompson, Desley 20:47
That’s good to know. Thank you.OK, Mick, here’s a question for you: How are emergency service volunteers supposed to manage their work/rest hours, given that they often respond to emergencies after their day jobs, particularly in the evenings?
Bishop, Mick 21:07
That’s another great question. Volunteer organisations need to factor this into their risk management plans. When reporting for duty, volunteers should assess and communicate their current fatigue levels.For example:
- How well did they sleep the night before?
- How long have they been awake?
- What type of work have they been doing—manual or mental? (There’s obviously a big difference.)
- How long have they been working?
- What is their general health and well-being status?
Organisations should then use a fatigue management plan to determine a volunteer’s suitability for a given task. For example, should they be deployed on a rescue boat, or would it be safer for them to assist from the base during the operation?
Thompson, Desley 21:50
Those are really good things to think about—thanks for that, Mick.I’ll now hand back over to you, Steve, to continue the presentation.
Whitesmith, Steve 22:00
OK, thanks, Desley. Mick. So, yes, we'll continue, and we're now into the nuts and bolts of it in terms of the approach you take to developing your plan.As mentioned earlier, 50% of crew who undertook the fatigue survey indicated they had either not received any fatigue management training or guidance, or they were unsure. Educating yourself and the crew about the causes and consequences of fatigue is a good start. It is important to understand what causes fatigue and what can happen when a person is fatigued. Having a shared awareness of the causes and consequences will ensure that you and your crew are better placed to deal with fatigue and lessen its effects.
This should also include factors that increase the risk of fatigue at sea, identifiable signs and symptoms of fatigue, so that crew are educated to identify fatigue not only in themselves but in others. We discussed this earlier when we looked at the physical, cognitive, and behavioural signs of fatigue.
Effective fatigue coping measures can be adopted at sea, and fatigue risk management approaches assist in managing fatigue risks. It is important to document how you provide education and training to your masters and crew on fatigue in your plan.
Once the crew are educated, they can contribute to your fatigue risk management process. Open communication about managing fatigue is critical. You and your crew should feel comfortable having these types of conversations.
The risk of fatigue needs to be considered as part of the owner's risk assessment and appropriate crew determination within the vessel safety management system. The owner must develop the plan with assistance from the master and crew, drawing on the experience and expertise of all people involved in the operation.
Once educated on fatigue, the master and crew can then contribute to the development of the plan. It is important to make it clear that managing fatigue and its associated risks is a shared responsibility between the owner, the master, and the crew.
The master and crew not getting enough quality sleep is the main contributor to fatigue. This must be the primary consideration when putting together a fatigue risk management plan, so it is essential that seafarers are provided with adequate sleep opportunity. There may be instances when seafarers do not obtain adequate sleep, even when provided with the opportunity. Regardless of what circumstances are causing insufficient or poor-quality sleep, it is important to recognise these as potential shipboard hazards.
Developing good sleeping habits is key. There are simple strategies you can adopt to improve sleep, and more information on this is being added to the Q&A chat.
Maintaining fitness for duty is crucial. Seafarers must be fit for duty and able to maintain safe levels of alertness and performance. It can be helpful to monitor and assess seafarers' levels of fatigue before commencing work to ensure they can perform tasks safely. A fatigue assessment tool can assist with this.
Work with your master, crew, and anyone else who may be able to help identify factors contributing to fatigue risk in your operation. Consider the types of operations you undertake and think about what could go wrong if a person is fatigued, how it could endanger lives, and impact the environment.
A checklist and fatigue risk management tool are useful guides and are available on the AMSA website.
Working at night presents a high risk that crew may fall asleep because they are working against their circadian clock.
In these circumstances, you need to ensure you have the right control measures in place to manage the identified risks, with particular attention to working between midnight and 6:00 AM.
As shown on the slide, AMSA has highlighted two marine incidents through our Safety Lessons page where fatigue was a contributing factor to vessel groundings. Investigation findings included:
- For the lone crayfish vessel, the master acknowledged they fell asleep due to fatigue.
- For the 3B fishing vessel, no formal watchkeeping procedure was in place or documented. Extended wakefulness and intermittent rest periods resulted in the crew being fatigued, leading to a watchkeeping mix-up during the circadian low between 2:00 and 6:00 AM.
Having considered the risk of fatigue with input from the master and crew, record the risks identified in your risk assessment. In the example shown, key risk factors have been identified:
- Ensure crew have adequate fatigue training and awareness so they understand the risks.
- Limit the number of hours crew are required to work at night.
- Plan for a minimum of two crew members together on deck or on navigational watch.
- Ensure crew are fit for duty by providing adequate time for sleep before commencing duty and, where possible, allowing for short rest breaks.
Once identified, controls are added to the controls column in the risk assessment. Fatigue training awareness would be recorded under training risk control. Again, this is an example only and may not be applicable to your operations.
Identify the risks and the controls you intend to implement. You then need to consider who will be responsible for implementing and monitoring the controls. In making this decision, consider the knowledge and training of the person and their ability to undertake the role as part of or in addition to their normal duties. Each control measure requires someone to ensure it is implemented and followed. Depending on the control, this could be the owner, master, or a crew member. In this example, the owner has shared responsibilities with a breakdown of the areas of responsibility.
After going through the education and planning steps, it is time to implement your plan. This requires updates to existing procedures or the development of new procedures regarding fatigue. Once ready, undertake training for your master and crew, and when satisfied, put it into practice.
It is important to trial your plan to ensure it is working as intended. The trial should run for a reasonable period, typically one to two months, to identify and address any problems. Ask key questions and encourage honest feedback from the master and crew to ensure the plan functions as intended.
As you can see in this example, the owner has undertaken a review of the trial in consultation with the master and crew. For this particular risk, they have recorded three observations and will update the training manual.
Having completed the fatigue risk management plan, including a trial period and being satisfied that it is fit for purpose, the plan becomes part of normal vessel operations. The plan must be reviewed following any incident where fatigue may have been a contributing factor, if the master or crew raise any fatigue concerns, and at a minimum during your annual SMS review.
AMSA has a number of resources available on our website that you may find useful. The link is now being added to the chat. You can also find these resources by using the search function at the top of the AMSA homepage by entering the word "fatigue."
We will also ensure links are included with the uploaded copy of this presentation and provided to webinar participants.
We will now go through some more questions, and I will ask Mick and Desley to rejoin the chat.
Thompson, Desley 31:24
Thanks Steve. There's been a lot of questions that have come through and thanks to Nathan and David and Natalia, for looking after the Q&A section.I am going to read out some questions for you both, so this one's for you, Steve.
So will AMSA be inspecting our plans?
Whitesmith, Steve 31:43
Yes. So the fatigue risk management plan forms part of the SMS. The risk assessment component is part of your safety management system and you may well be asked by an inspector to produce a plan during an inspection or following an incident. So yes, certainly your plan can and will be inspected at some point in the future.
Thompson, Desley 32:04
OK. Thanks for that.Mick, so I run a small vessel and I only work when the sun is up and for a short period of time. Does my plan need to be that big?
Bishop, Mick 32:18
No, It doesn't. Operator has got the flexibility to develop a fatigue risk management plan that works best for them and their operation. So the scale of the plan will depend on the size and complexity of your operation as well as the length of the voyage.In fact, AMSA will be discussing shorter versions of the fatigue risk management plans in more detail in our simplified SMS webinar on the 9th of April, and we encourage small vessel operators to register at that time.
Thompson, Desley 32:50
Thanks for that Mick. So the next question is, actually it's more of a statement. I'm out at sea for a week at a time. It's not easy to get a good amount of sleep. Mick, what do you suggest I could do?Bishop, Mick 33:04
Good question. And there's a number of things they could look at to do with the environment as part of their plan. So, for example,- blackout curtains for darkness
- suitable temperatures very important and
- reducing noise levels if that's possible
- The other thing is calm anchoring areas if they're available.
There's also, apart from that, you can also look to provide risk breaks throughout the work period such as naps and meal breaks. All of those will contribute to helping address fatigue.
Thompson, Desley 33:41
That's great. Great suggestions there. Thanks, Mick.Whitesmith, Steve 33:48
All right. Thanks, Desley. Thanks, Mick. So, prior to closing out, we, we'd like to remind everyone that there are two more webinars on the upcoming changes to Marine Order 504, if you haven't already done so, you can register for these on the AMSA website or through the link in the chat.Thompson, Desley 34:08
Thanks everyone for attending today.I hope you enjoyed it as much as we did. So to help the team make sure that future webinars are valuable use of your time we'd like some feedback from you. So you'll see that in the chat now there's a link to conduct a short survey for us, please.
And like Steve said, if you haven’t already registered for the next webinar, please do so and please encourage others to attend as well too. So, we hope to see you in March for the next one.
Thanks everyone.Whitesmith, Steve 34:50
Thank you. Cheers.
Presentation slides
Download the Fatigue risk management webinar presentation slides PDF9.02 MB.
Q & A
Read answers to questions about fatigue management PDF162.31 KB that were asked by industry during the webinar.