Guidance Notice - Small unmanned autonomous vessels

Overview

Operators of small unmanned autonomous vessels under 12m must apply for AMSA for specific exemption from a certificate of survey.

This guidance outlines AMSA's compliance approach to considering these applications. Our approach is based on the Exemption 02 and Exemption 40 frameworks currently applied to conventional vessels operating out to C water limits. This will help designers, builders and owners prepare an exemption application and provide supporting documentation.

Your exemption application should consider the matters outlined in this guidance. It is a guide and does not limit or replace a decision maker's discretion to grant, refuse or impose conditions on an exempion under s 143 of the National Law.

Scope

This guidance applied to autonomous vessels which are:

less than 12 metres long
non-passenger vessels (Class 2 vessel) or fishing vessels (Class 3 vessel) under the National Standards for Commercial Vessels (NSCV) Part B, and
only operational in the following areas:
- operational area C
- operational area D, or
- operational area E.

This guidance does not apply to autonomous vessels that:

carry any persons whilst underway
carry dangerous goods
engage in vessel towage operations and are not set up for this purpose
have an inboard engine which operates on fuel that has a flashpoint of less than 60°C, or
operate at greater than 10 knots.

It is also generally expected vessels following this guidance will be supported by a rescue vessel, capable of assisting, reporting on or recovering the vessel within 6 hours.

Note vessels ≥ 12 metres in length, operating within ‘B’ waters or that do not fall within the parameters listed above are generally considered to be survey type vessels. Survey vessels are expected to be certified under the survey framework and to do so will either need to comply with the deemed to satisfy solutions or be assessed against the required outcomes of the NSCV in support of an equivalent solution. After which a certificate of survey may be sought. In extraordinary situations AMSA may consider exemptions from some survey requirements.

Definitions

Accredited Marine Surveyor - means a surveyor who is accredited in accordance with Part 3 of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013.

Exemption - means an exemption from a requirement of the National Law granted under section 143 of the National Law.

Certificate of Survey - means a certificate issued under section 38 of the National Law.

Competent person - means a person who has acquired through training, qualification/s or experience the knowledge and skills to carry out specific inspection tasks.

Conventional solution - a deemed to satisfy solution that meets required outcomes of the standards – see NSCV Part B. A conventional solution may vary depending on vessel use, operational area, speed and other performance factors considered by the standards.

Conventional vessel - a vessel that meets the requirements of the law (the NSCV required outcomes), by generally complying with the deemed to satisfy solutions. A conventional vessel’s design and arrangement of systems will vary depending on use, operational area, speed and other performance factors considered by the standards.

Equivalent means of compliance – means a proposed solution that is ‘at least as effective’ as compliance with the survey requirements or standards that apply to the vessel. Equivalent means of compliance are approved under Marine Order 503.

Recognised Organisation – means an organisation specified in schedule 1 of Marine Order 1 (Administration) 2013.

Unmanned Autonomous Vessel - a vessel that conducts autonomous operations without any persons on board in operation.

Manned Autonomous Vessel - a vessel that conducts autonomous operations with persons on board in operation, either in full or partial autonomy.

Guidance for unmanned autonomous Vessels under 12m long in C, D and E waters

This table sets out recommended areas of consideration for a specific exemption application. The extent and complexity of the application submitted may vary depending on the size, type, service category, operation and complexity of the unmanned autonomous vessel. Similar solutions providing an acceptable safety outcome may also be considered.

Area of consideration	Guidance
Design and construction	The design and construction of an autonomous vessel is to be fit for purpose, for the intended operation.
Vessel flotation	An autonomous vessel is to be arranged with a combination of watertight compartments or low-density flotation materials so that it is incapable of sinking, if the single largest compartment becomes damaged.
Stability	An autonomous vessel, in all loading conditions, is to have stability characteristics fit for the purpose for which the vessel is intended by the owner.
Machinery - fuel tanks, pipes, etc	If there is an underdeck fuel tank on-board the autonomous vessel, it is expected to comply with clause 4.7 of NSCV Subsection C5A. Fuel piping for any non-portable fuel tank is generally expected to be of seamless, heavy gauge metal. However, a flexible fuel line may be used in accordance with clause 4.7.1.5 of NSCV Subsection C5A; and between the fuel shut-off valve or cock and the main engine. If a flexible fuel line is used, it is expected to comply with: the requirements for type A1 mentioned in ISO 7840:2013 Small craft — Fire-resistant fuel hoses; or the requirements for type A mentioned in SAE J1527: Marine fuel hoses; and be securely installed to avoid chafing and allow regular inspection. However, a flexible fuel line from the fuel filter to the outboard engine supplied by the engine manufacturer is not expected to comply with the standards mentioned above. A remote fuel shutoff of a failsafe close type is expected, as close to the tank as practicable. A fuel filter is expected, positioned after the shutoff valve mentioned above. If shafting is fitted, then it is expected to comply with either of the following standards; or with another standard approved by the National Regulator: ABYC Standards and Technical Information Reports for Small Craft, P-6 (ANS) Propeller Shafting Systems, July 2010; NSCV Subsection C5A.
Electrical	Other than the requirement to have an emergency power supply located above the weather deck, an autonomous vessel is expected comply with NSCV Subsection C5B.
Vision, communication and navigational systems	The owner is to appoint a competent person, to be responsible for the control and operation of an autonomous vessel when it operates. An autonomous vessel is to be arranged to ensure that the competent person responsible for control and operation of the vessel has sufficient information to identify navigational hazards, assess the risks and take appropriate measures to control the risks in both normal and abnormal conditions of operation. An autonomous vessel is to be arranged to enable the competent person responsible for control and operation of the vessel to comply at all times with the person’s obligations under the International Regulations for Preventing Collisions at Sea (COLREGS). An autonomous vessel is to be arranged to eliminate or reduce to acceptable levels the risk of operator error, fatigue or system errors arising due to the design and arrangement of the vessel’s operational systems. An autonomous vessel is to have means to inform other vessels of its location, nature, size, course and status, to help avoid collision or contact.
Watertight and weather tight integrity	An autonomous vessel is to be designed and constructed to prevent, or limit to an acceptable level, the likelihood of progressive flooding, disabling of essential or emergency systems and excessive heel and/or trim, in all reasonably foreseeable weather conditions. An autonomous vessel is to be provided with a means to monitor bilge levels in any propulsion machinery space, and in all other compartments that contain seawater pumping systems.
Steering systems	The autonomous vessel’s steering equipment is to be fit for the purpose for which the vessel is intended by the owner, the person who conducts the inspection and drafts the report must be satisfied that sufficient inspection, testing, trialling or evidence has been supplied.
Failure Mode and Effect Analysis (FMEA)	An autonomous vessel is to be subject to a failure mode and effect analysis of the following systems; and any other system affected by automation: The directional control system; Propulsion machinery systems and their associated controls. Essential auxiliary systems and their associated controls. Any automatic safety devices that could shut down essential machinery or systems. The FMEA analysis must determine that the risks associated with any likely failure of any of these items of equipment will remain within the acceptable range. Note 1: Examples and procedure for failure mode and effect analysis are specified in Annex C of NSCV F1C and High-Speed Craft Code Annex 4. Note 2: Engineered solutions for controlling risk are preferred over operational solutions.
Provision of essential safety information	An autonomous vessel is to have a vessel operating manual which contains at least the following information (as applicable): General description of the vessel and its equipment including: the rules and regulations to which the vessel has been designed and built service category recognised organisation and class notation (if applicable) measured length maximum speed, and operational areas. Procedures for maintaining and checking the integrity of buoyancy compartments. Details of the stability of the vessel, likely to be of direct practical use to the person in control in an emergency. Damage control procedures. Description and operation of machinery systems. Description and operation of auxiliary systems. Description and operation of remote control and warning systems. Description and operation of electrical equipment. Loading procedures and limitations, including maximum operational weight, centre of gravity position, and distribution of load. Cargo securing arrangements and procedures depending on operational restrictions or damaged conditions. Description and operation of fire-detection and fire-extinguishing equipment. Drawings indicating any structural fire protection arrangements. Description and operation of radio equipment and navigation and collision avoidance aids. Information regarding the handling of the vessel. Maximum permissible towing speeds and towing loads, where applicable. Indication of emergency situations or malfunctions jeopardising safety, required actions to be taken and any consequential restrictions on operation of the vessel or its machinery. A description of the worst forecast weather and sea conditions before which the vessel should seek shelter, and any restrictions on speed arising from structural considerations over the range of anticipated operating conditions. Limiting values of all machinery parameters requiring compliance for safe operation. consideration of the results of any FMEA reports developed during the vessel design (see above).
Maintenance and servicing manual	An autonomous vessel is to be supplied with a maintenance and servicing manual containing at least the following information: Detailed, illustrated description of all vessel structure, machinery installations and all installed equipment and systems required for safe operation of the vessel. Specifications and quantities of all replenishable fluids and of structural materials which may be required for repairs. Operational limitations of machinery in terms of values of parameters, vibration and consumption of replenished fluids. Limitations of wear of structure or machinery components, including lives of components requiring calendar or operating time replacement. Detailed description of procedures, including any safety precautions to be taken or special equipment required, to remove and install main and auxiliary machinery, control systems, transmissions, propulsion and flexible structure components. Test procedures to be followed subsequent to replacement of machinery or system components or for malfunction diagnosis Procedure for lifting or dry-docking the vessel, including any weight or attitude limitations. Where a vessel may be dismantled for transportation, instructions must be provided for dismantling, transport and re-assembly. A servicing schedule, included in the maintenance manual or published separately, detailing the routine servicing and maintenance operations required to maintain the operational safety of the vessel and its machinery and systems.
Fire equipment	An autonomous vessel with a main engine that has an engine power of >120 kw, located in an enclosed space, is to have a means of smothering fire in the space.
Other equipment	To be specified by the applicant within their application as necessary.

General notes

AMSA may impose condition on an exemption and may request additional information about the design documents, systems assumptions, and inspections carried out on an unmanned autonomous vessel.

For vessels operating in C waters, the person carrying out the review and inspection of an autonomous vessel should be an Accredited Marine Surveyor or Recognised Organisation.

In D or E waters, AMSA may accept submission from a competent person.

How to submit your application

To apply for specific exemption please complete the online AMSA form 547.

Your application will be assessed against the national law criteria, the AMSA policy for exemptions, and the requirements outlined in this guidance document.

AMSA may enforce conditions on the exemption, including requirements for periodic inspection.

In general, AMSA may require an initial inspection, and an in- and out-of water periodic inspection, conducted within the three months before or the three months after each five-year anniversary of the vessel’s approval.

For a vessel operating in C waters, the inspection should be done by an Accredited Marine Surveyor or recognised organisation.
For a vessel operating only in D or E waters, AMSA may allow the inspection to be done by a competent person, or authorised person.
The inspection will generally include:
- a physical inspection of the vessel
- verification of the ‘failure mode’ and ‘effect analysis’, operating manual, and maintenance and servicing manual, and
- testing of the vessel or its equipment, unless the competent person considers it appropriate to rely instead upon third party documentation.

Note: Examples of third-party documentation includes CE certification for structural components and expert reports from automation system designers and manufacturers.

More information

Read more information about the operational requirements that apply to under the National Law Act.