• High volume of applications expected for renewal of marine surveyor accreditation – Plan ahead!
• Certificate of survey (CoS) and certificate of operation (CoO) requirements for domestic commercial vessels (DCVs)
• Marine safety incident – Person overboard
• New Exemptions
• Safety recall notice
• Proposed GES to allow ISO 12215 for vessels up to 24m
• Bringing a new build domestic commercial vessel into Australia: Key requirements
• Summary of Audits 2023-24
• Reminder – have your say on the surveyor accreditation scheme
• Survey Matters suggestions

High volume of applications expected for renewal of marine surveyor accreditation – Plan ahead!

We are expecting 106 applications to renew marine surveyor accreditation in 2025. This peak occurs every five years.

Ensure your application is complete and meets the requirements for renewal. An early application will ensure that your accreditation does not expire.  The Marine Safety (Domestic Commercial Vessel) National Law Regulations 2013 specifies that a renewal application must be made at least 3 months prior to expiry of your accreditation.

Key Information

Think about the application and supporting documents

• Considering the higher volume of application expected this year, we recommend preparing your supporting documents as early as possible
• Check the expiration date of your accreditation and expect a courtesy reminder from AMSA (Accreditation team) four months prior

Application AMSA804 form – familiarise yourself with the form

Supporting Documents

Continuing Professional Development (CPD) 

Ongoing professional development is a requirement to maintain your accreditation. Utilise any CPD you have or are currently undertaking with a professional association related to vessel survey, design, building or engineering. AMSA requires evidence of CPD to support your application. Some examples may include:

• Statement of continued professional development (CPD) from your professional association;or
• Copies of certificates relating to:
  • additional qualifications you may have attained since your initial or subsequent accreditation
  • short courses/safety training
  • technical meetings/conferences/workshops
  • mentoring
  • written publications (e.g., subscriptions to magazines)
  • webinars relevant to marine surveying
  • survey work outside of national law; or
  • completing online courses related to marine safety regulations

Evidence of current professional association membership relevant to surveying. Some examples are:

• AIMS stamp showing membership level and expiry date
• RINA letter confirming class of membership and expiry date
• IIMS membership card and expiry date
• IMarEST membership card and expiry date

NOTE: A tax invoice alone is insufficient, as it does not provide proof of payment, membership details, or the membership expiry date.

One photograph of yourself, taken within the last six months:

• with dimensions of 45mm x 35mm (not including a border)
• face centred from the neck up
• passport photograph taken at any Australian Post office will be preferred (if possible)
• white background
• scanned in high resolution of 300-600dp

Relevant fee

• Current fee as of 1 July 2024 is $317, however the fee will increase on 1 July 2025 when the annual indexation is applied

Where to send the application and supporting documents?

• A courtesy email will be sent four (4) months prior to expirationof marine surveyor accreditation by the Accreditation team
• Upon receipt, note the due date of submission
• Start to collate the abovementioned supporting documents and reply by return email to: dcvsurvey@amsa.gov.au

Certificate of survey (CoS) and certificate of operation (CoO) requirements for domestic commercial vessels (DCVs)

What is the issue?

Despite an extensive education campaign undertaken at the start of the National System, AMSA Marine Inspectors are continuing to see domestic commercial vessels operating without a CoO (or exemption from CoO) when conducting inspections. There are also DCVs being operated without a CoS (or exemption from CoS) but holding a CoO. In some cases, the certification has expired, and in other cases, the vessel has never held the required certification.

Aside from an inspection by an AMSA Marine Inspector or compliance partners, often the only interaction an owner has with the National System is when they have their vessel surveyed by an Accredited Marine Surveyor (AMS). As such, AMSA is requesting assistance from the AMS community to help raise awareness of the owners' obligations under National Law. Note that this assistance is entirely voluntary.

What are the rules?

Under the National Law , operators must conduct their business using safe vessels and have safe systems of work embedded in their operations. Operators must hold current CoS and CoO as per Marine Order 503 and Marine Order 504, unless exempt.

Some non – survey DCVs operate under exemptions (e.g. Exemption 2 or Exemption 40) which exempt them from holding a CoS.  However, depending on the exemption being applied, they must hold a non-survey permit, an Exemption 40 permit or, if they are a grandfathered "existing vessel” under Division 5 of Exemption 2, they will only require a CoO.

DCVs can operate without a CoO if they meet the criteria of Exemption 3 under Marine Order 504.

What can happen?

AMSA’s foremost concern is for the safety of people, property and the environment. Operators are required to ensure their vessel complies with the law and is operated safely.

AMSA Marine Inspectors can issue breach notices that result in penalties to operators found to be operating without the required certification.

What can an AMS do to help raise awareness with operators?

• When conducting surveys, advise the operator of their obligation to have a Certificate of Operation (if applicable). In most cases, if a vessel has a Certificate of Survey or an Exemption 40 permit, it will also need to have a Certificate of Operation.
• Show the operator how to access information on the AMSA website or contact AMSA Connect. 
• AMSA Connect operators are available from 8 am to 5 pm Monday to Friday AEDT by calling 1800 627 484or emailing AMSAConnect@amsa.gov.au. 

Marine safety incident – Person overboard

A near miss incident recently occurred on a passenger ferry operating on Sydney Harbour. While the vessel was underway, a passenger moved to the starboard upper deck to take a photograph. As the passenger leaned on the bulwark gate for support, the gate detached from its mounts and fell overboard.

The passenger partially fell through the bulwark feet first but was able to regain footing on the drainage gutter at the edge of the superstructure, preventing a complete fall from the vessel. The passenger promptly pulled themselves back onto the upper deck and sustained only minor injuries, requiring no medical treatment beyond basic first aid.

The detached gate fell into the water approximately three metres from the lower aft deck, where other passengers were present.

In response, the operators immediately secured the area and installed temporary barriers. The incident was reported to the Australian Maritime Safety Authority (AMSA), and the operator conducted an internal investigation in coordination with AMSA to determine appropriate corrective actions.

Investigation and findings

Inspections and investigations conducted by the operator revealed that the forward upper hinge pin was missing, and the hinge plate was bent. This evidence suggests that the hinge pin either failed or was not adequately engaged with the hinge pivot. Consequently, the failure of this hinge allowed the gate to detach from the remaining mechanisms and fall overboard.

The operators and AMSA’s investigations identified that the incident was likely due to a combination of factors related to the design and maintenance of the gate:

• Usage and Inspection: The upper deck gates on this class of vessels had not been operated since construction and were treated as fixed panels rather than functional components.
• Potential Corrosion and Material Fatigue: The hinges, made of dissimilar metals, likely experienced corrosion, weakening their integrity. A spring-loaded pin designed to handle outward loads may have been compromised due to wear or failure.
• Design: The inward-opening gates lack a physical stop or catch to prevent outward movement, making the hinge and pin mechanism vulnerable to stress.

The operator was not aware of the condition of the gate securing arrangements. It is probable that the dissimilar metals had failed at an inopportune time. The stainless-steel hinge was mated to an aluminium bracket which after time may have weakened until it gave way.

The operator has implemented an increased inspection and maintenance regime for these gates and has commenced a redesign of the hinge and closing mechanisms.

Previous incidents

This incident has similarities to that published in the December 2021 edition of Survey Matters. Since the publication of the article there have been at least three further incidents of a similar nature on Sydney Harbour alone.

Key takeaways

Surveyors are reminded of the potential for accelerated corrosion between dissimilar metals, which may be present in bulwark gate hinges and closing mechanisms. Given that bulwarks, gates, and railings play a critical role in ensuring the safety of passengers and crew, it is essential to thoroughly inspect the condition of access gates, hinges, and closing mechanisms during surveys. Any safety concerns identified should be promptly communicated to the Owner and Master, with defects requiring immediate rectification.

New Exemptions

AMSA is introducing new exemptions to provide a simplified process for certain vessels to obtain a certificate of survey and operate as Domestic Commercial Vessels (DCVs), including vessels with minor non-conformances or vessels built to Navigation Act 2012 requirements.  

The exemptions cover the following scenarios:

The updates to EX07 enable transitional and non-transitional vessels to continue to operate up to a maximum period of 12 months (when using the applicable division), while undertaking work to rectify non-conformances with the applicable standards in MO503. The exemption is only available where a surveyor has conducted an initial or renewal survey and considers that any non-conformance will not jeopardise the safety of the vessel or any person on board the vessel. An approval is required from AMSA and a surveyor must provide a survey report that meets the criteria in the exemption. For more information, please see sections 6 and 7, Division 2, of the updated EX07 here Exemption 07.

The new EX49 introduces a simplified process for vessels built to Navigation Act requirements to operate as DCVs, provided the vessel continues to meet the requirements that would apply if operating as a RAV, including the standards of the vessel’s classification society. Operators do not need approval for this exemption but will need to meet the eligibility conditions and apply for a certificate of survey. For more information, please see the new EX49 here Exemption 49. Surveyors are encouraged to review the exemptions which commenced on 1 March 2025.

Safety recall notice

The intention of this notice is to provide surveyors with important updates in relation to the following safety recalls. Please ensure you are aware of equipment recalls when undertaking surveys where these items are present.

Safety recall: Halkey Roberts 3F Single Point Manual inflators in lifejackets

Issue

Faulty “V96000 Halkey Roberts” manual inflators are installed in the following lifejackets:

• Life Jacket Solutions (LJS) – Model numbers T150M, G150M, B150M, WB100, PR150M, SRSS150
• Marlin – Model number MK150

The indicator status on the inflator may show the life jacket is ready for use even when the attached gas cylinder is empty, removed or not connected properly.

Hazard

Risk of drowning if the lifejacket does not inflate as expected when the manual inflator is deployed.

Identification

The grey plastic part of the inflator indicates a recalled product.

Recalled inflators are marked “V96000 Halkey Roberts ®” and have a manufacture date between 4 June 2021 and 15 April 2024 (this will be laser printed in the format MM/DD/YY).

V96000 Halkey Roberts Inflator

For further information please click on recall fact sheet and product recall page links above.

Surveyors’ responsibilities

• Notify the operator of the recall.
• Forward recall information to the client.
• Document non-conformances if recalled inflatable lifejackets are found on board during inspection.
• Communicate these findings to the vessel operator and AMSA (AMSA586).

Safety recall: Rocket Parachute Flares KP-16

Issue

Kokusai Kakoh company has issued a safety recall for its Rocket Parachute Flares KP-16. This is due to performance concerns related to altitude and burning time when fired.

Identification

• Checkif KP-16 flares manufactured between February 2021 and July 2024 are carried as part of safety equipment.
• Advise operator to contact nearest Comet distributor for a free replacement with Comet Red Parachute Signal Rockets.

For further information please click on recall fact sheet and product recall page links above.

Surveyors’ responsibilities

• Notify the operator of the recall.
• Forward recall information to the client.
• Document non-conformances if recalled inflatable lifejackets are found on board during inspection.
• Communicate these findings to the vessel operator and AMSA (AMSA586).

Proposed GES to allow ISO 12215 for vessels up to 24m

• In Australia, the National Standard for Commercial Vessels (NSCV) specifies the technical standards for Domestic Commercial Vessels (DCVs). Within this suite of standards, Part C Section 3 Design and Construction specifies the standards for construction of vessels.
• Currently, the deemed to satisfy solution for determination of scantlings in NSCV C3 allows the use of ISO 12215 as an alternative to the Lloyd’s Register Class Rules, however only for vessels up to 13m length in ‘light operations’.
• The 13m length in ‘light operations’ limit was imposed due to the risk that ISO 12215 was not complete at the time of drafting the NSCV C3 and ISO 12215 was meant for recreational vessels only.
• It has been over 10 years since the introduction of the NSCV C3 and a review of these limitations is warranted due to the following reason.
• ISO 12215 is for vessels up to 24m
• ISO 12215 has evolved over the years and is now applicable to both recreational and commercial vessels
• At its first major review in 2019, a new annex called Annex J has been introduced with additional requirements for commercial vessels
• ISO 12215 has been used for DCVs under 13m without issues
• AMSA has more understanding and experience using ISO 12215
• AMSA regularly receive specific exemption applications for vessels over the 13m limit
• The fastest way to implement this type of update to the NSCV standards is using a Generic Equivalent Solution (GES). The NSCV requires that equivalent solutions must comply with the required outcomes of the standard and are at least as effective as the deemed-to-satisfy solution. In this case, it has demonstrated compliance with the nine (9) required outcomes in Chapter 2 of NSCV C3 and similar effectiveness as the deemed-to-satisfy solution in Chapter 3 and 4 of NSCV C3.

AMSA is currently assessing if ISO 12215 with Annex J can fulfill the above criteria so the 13 m length limit can be removed and determine if “robust operations’ are allowed. A wide range of Class 1, 2 and 3 vessels expecting to operate in B, C, D and E waters will benefit if both can be achieved.

If AMSA assessments indicate that only the 13m limit can be removed, most of the work boats will still be excluded as they will fall into the ‘robust operations’ category.

• The goal of our assessment is to determine whether it is equivalent to the deemed to satisfy solution in NSCV.

How you can help

• If you have any suggestions, supporting evidence or information that you would like to share, please email to dcvsurvey@amsa.gov.au with the email subject ‘Suggestion/info for ISO 12215 GES”

Bringing a new build domestic commercial vessel into Australia: Key requirements

Do you have clients planning to build a vessel overseas and bring it into Australia to operate as a Domestic Commercial Vessel (DCV)? If so, several key factors must be considered before the journey to ensure a smooth transition into the national system. These include:

• Timeline
• Vessel Certification
• Transit Requirements
• DCV Certification

1. Timeline

Bringing a vessel to Australia involves multiple stakeholders, extensive planning, and various certification checks. To ensure a smooth process, contact AMSA Flag state control team as early as possible providing details of the intended voyage. AMSA can offer specific guidance on regulatory requirements

Once contacted, AMSA will arrange a stakeholder meeting to discuss:

• Vessel’s specifications
• Proposed delivery method
• Applicable regulatory requirements

Holding this meeting early in the process allows all parties sufficient time to prepare and comply with relevant regulations.

2. Vessel certification

An Australian commercial vessel proceeding on an international voyage is defined as a regulated Australian vessel (RAV).

RAVs must be built and maintained in class and comply with Australia’s Marine Orders 1-97 and applicable international conventions. AMSA advises that owners engage a classification society that is one of AMSA’s recognised organisations (RO’s) at the plan approval stage to ensure compliance with class and statutory requirements.

AMSA acknowledges that smaller vessels may face difficulties meeting all requirements. In such cases, the owner may apply for an exemption, waiver or equivalence by submitting an application to AMSA that is reviewed and endorsed by the RO.

AMSA will review the application and determine whether an exemption, waiver or equivalence may be issued.

⚠ Note: If the vessel is being transported to Australia as deck cargo on a ship, it does not require certification as a RAV. Some requirements may not apply for a vessel being towed without any crew onboard. Please contact AMSA for further guidance. An alternative method of bringing a vessel to Australia is to have it registered and certified with a Foreign Flag. A foreign registered vessel arriving in Australia may be subject to Port State Control inspection.

3. Transit requirements

Several additional compliance requirements must be met before the delivery voyage:

• Registration on the Australian General Shipping Register
  • All Australian vessels traveling to or from a foreign port must be registered.
• Asbestos Compliance
  • Importing asbestos or asbestos-containing materials is strictly prohibited. Contact the Australian Border Force to ensure proper inspection and certification measures before arrival.
• Ballast Water Management Compliance
  • The vessel will be subject to biosecurity controls and must report biofouling management through the Maritime Arrivals Reporting System before entering Australian waters.
• Minimum Safe Crewing Compliance
  • The vessel must have a minimum number of crew based on its size. Crew members must also hold the necessary qualifications. Apply for a Minimum Safe Crewing Document through AMSA.
• ISPS Code Compliance (if applicable)
  • If the vessel is a passenger vessel or cargo vessel of 500 gross tonnage or above, it must comply with the International Ship and Port Facility Security (ISPS) Code.

4. DCV Certification

Once the vessel arrives in Australia, it can transition from an RAV or Foreign-Flagged Vessel to a DCV, provided no further international voyages are planned.

The below outlines the required steps.

• Revoke statutory certificates
  • AMSA can revoke RAV certificates, with the express written permission of the applicant.
  • Foreign Flagged Vessels must consult their flag authority and provide evidence to AMSA that their registration has been cancelled and statutory certificates revoked. The vessel will also need to be registered with the Australian general shipping register if it is greater than 24m in tonnage length and capable of navigating the high seas.
• Complete the Certificate of Survey Application
  • The vessel must meet DCV survey requirements. It is recommended that the person responsible for recommending the DCV survey codes in MARS surveys the vessel and submits the required forms as soon as possible.
  • Survey work can begin while the vessel is still overseas and be finalised upon arrival in Australia.
  • EX49 may also be used to bring the vessel into DCV survey, see above for more details.

Plan ahead for a smooth process

Bringing a new build DCV into Australia requires careful planning to meet regulatory and safety requirements. Ensuring compliance from the design phase will save time and costs, helping you set sail with confidence.

Need help navigating the process? Visit AMSour websiteA.gov.au for guidance or contact the relevant AMSA departments below:

✉ FSC@amsa.gov.au – Flag State Control (International voyage queries)

✉ DCVSurvey@amsa.gov.au – Vessel Safety Unit (DCV-related queries)

Summary of Audits 2023-24

Major Audits 2023-24

During the financial year 2023-24, AMSA carried out major (scheduled) audits on 188 survey recommendations covering 28 accredited surveyor audits. The 28 surveyors were selected for the audits using AMSA’s surveyor risk rating tool.

Additionally, AMSA performed 21 audits based on feedback received from a member of the public or an AMSA Staff member affecting 13 Accredited Marine Surveyors (AMS). One surveyor was requested to show cause as to why their accreditation should not be suspended due to the failure to comply with a condition of accreditation referred to in Division 3.3 of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the regulations).

On-site monitoring surveys were also performed on 3 surveyors.

The pie chart below shows the percentage distribution of the findings identified during the Major Audits.

Compared to previous years, AMSA noticed a significant increase in major non-conformances (doubled) which jeopardises safety of personnel, the vessel or the environment and warranted immediate corrective action on the vessels or the surveyor’s survey practices. Some of the examples of major non-conformances identified include:

1. Insufficient lifesaving appliances (Lifejackets, buoyant appliances etc.) for the recommended complement for passenger vessels.
2. Incorrect lightship measurement recommended during periodic lightship check for passenger vessels, whilst the actual deviation in lightship has made the stability booklet invalid and triggered transitional surveys.
3. Stability booklets approved with incorrect criteria thus allowing the vessels to operate while they failed to meet the correct stability criteria.
4. Inadequate communication equipment for operation of vessels beyond LCS areas.
5. Periodic lightship surveys not performed for passenger vessels over 12 meters and were incorrectly recommended with lightship declaration.
6. Incorrect use of Temporary Operations Exemption. Some vessels which were issued with temporary operations following renewal/periodic surveys by the AMS had several major defects like damaged structural fire protection, damaged fire main/fire pumps, defective fire dampers etc, which were regarded as minor by the AMS to enable the vessels to operate.

In most cases, the surveyors promptly implemented the required corrective actions. However, in certain instances, AMSA, acting on the National Regulator's initiative, modified the certificates of survey for several vessels due to insufficient safety equipment for the complement they carry. These vessels had been deemed compliant by the surveyors despite lacking the necessary safety equipment.

During major audits AMSA identified multiple errors in periodic lightship checks conducted by various surveyors, where incorrect data was provided. In several instances, the deviations recorded in lightship data were significantly greater than the recommended values. As a result, transitional assessments were required, along with the development of new stability booklets.

In one instance, the surveyor promptly undertook the required corrective actions, including performing the inclining test and transitional surveys. However, in another case, the surveyor failed to implement the necessary corrective measures, leading AMSA, under the National Regulator's initiative, to revoke the vessel’s certificate of survey.

AMSA acknowledges and appreciates the numerous positive observations recorded during audits of several surveyors and we encourage surveyors to be self-motivated to strive for achieving excellence in surveying. This allows AMSA to perform the role of a modern regulator in a proactive way, through positive collaboration with the surveyors to achieve better safety outcomes.

Severe adverse findings – Surveyor counselled

One of the major audits identified several serious non-conformances for which the surveyor took corrective actions as required. The surveyor was provided counselling advise due to a likely contravention of conditions of accreditation as per Sec.32, 33 and 35 of Division 3 of the regulations. Some of the major findings for this surveyor are listed below:

• Oil residue on the lagging of the engine room hatch on a Class 1B Passenger vessel resulted in an onboard fire. This vessel had been recommended as satisfactory by the surveyor during a periodic survey undertaken a short time prior to the incident. The vessel owner and AMS undertook corrective actions and defective lagging was replaced.
• Inadequate scale of critical communication equipment onboard two vessels for operations beyond LCS areas. Both vessels were recommended for operations in B waters following a periodic survey.  
• One Class 1 vessel only carried 22 lifejackets, whilst the vessel was recommended by the surveyor to operate with 30 persons, including passengers, after the periodic survey.
• Insufficient buoyant appliances on board a 1D passenger vessel, which was recommended by the surveyor for higher passenger number. The surveyor failed to undertake corrective actions for this finding. AMSA varied the certificate of survey of the vessel on National Regulator’s initiative, following a show cause to the vessel’s owner.

Common audit finding - inadequate communication equipment

During the recent major audits, AMSA identified numerous instances of vessels being recommended by surveyors (and R.O surveyors) for operation beyond LCS areas without adequate scale of communication equipment (H.F radio or a satellite phone) during the commissioning and periodic surveys.

While some vessels were not installed with the adequate equipment, some of the surveyors weren’t aware of the equipment requirements and had failed to check the installation or function testing of a H.F radio. Guidance for testing of H.F radio can be found here.

Surveyors may require the owner to arrange for inspection and testing of radio equipment by a service technician if there is doubt of the equipment condition and functionality.

AMSA reminds surveyors to check the requirements of Marine Order 27 (Safety of navigation and radio equipment) 2016 or NSCV C7B 4.3 Table-2 or USL Code Sec.12 (as applicable) for the adequacy of the scale of communication equipment onboard all vessels.

⚠ IMPORTANT CORRECTION: An error has been identified with the AMSA901 form which did not permit the recording of satellite phone details. The error was identified through the audit process and associated feedback from surveyors.

The AMSA901 form has now been updated with tick box and a data entry field for the satellite phone section. Please see link below to access the updated AMSA901 form https://www.amsa.gov.au/forms/survey-report-and-recommendation. AMSA encourages surveyors to use the updated forms from the website when undertaking a survey.

Reminder – have your say on the surveyor accreditation scheme

Recently we invited surveyors to be a part of the industry reference group to review the surveyor accreditation scheme. If you would like to be a part of the review, please send an email to domesticsafetypolicy@amsa.gov.auwith a paragraph outlining your expertise, skills and experience and your interest in contributing to the review by 28 March 2025.

Survey Matters suggestions

• AMSA wants to make sure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels.
• We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications.

Quick links to articles in this edition

• Lightship declarations and the law
• New surveyor accreditation guidance manual part 2 now available
• Ensuring compliance of fixed fire systems on transitional vessels: type approval vs service certificates
• Electrical issues able to be identified by non-electrical periodic surveyors
• Timber boat surveying – with a focus on inspection of metallic fasteners
• Upcoming peak period for accreditation renewals
• New builds – duties of builders, designers and surveyors Survey matters suggestions
• Survey Matters suggestions

Lightship Declarations and the Law

The rationale underpinning the use of lightship declarations in SAGM Section 4.9, for Class 1 vessels less than 12m as well as Class 2, 3 and 4 vessels, has been raised several times in recent years. It has been argued that all vessels should perform a lightship check at 5-year intervals. While this may be attractive on a purely technical level there are other considerations at play.

While a lightship declaration might not have the same level of technical rigour as a lightship check, the latter was conservatively estimated to have a circa $50M impact on the DCV fleet collectively. This is a cost that was not previously imposed. An increase in the order of tens of millions would be exceptionally hard to justify without substantive incident data - particularly for vessels not previously subject to such an impost.

The requirement to perform a lightship survey has existed in the USL code since the early 1980’s. USL Code Section 8A Annex A Section A.5 required Class 1 vessels to perform a lightweight survey at an interval not exceeding 5 years, though in practice this was rarely enacted. Such a requirement did not exist for Class 2 & 3 vessels at the time.

During the development of NSAMS/SAGM, a decision was made to permit declarations for small Class 1 vessels as well as Class 2 and 3 vessels. At first glance, this might appear to be inconsistent, but the reality is that such a risk-based approach is more onerous than that of comparable jurisdictions worldwide, or in Australia previously under the USL Code.

The declaration is an important process to assist private marine surveyors to identify changes to a vessel which they may not have previously surveyed. Other countries (or class societies for that matter) do not require any periodic lightship declaration or measurement for non-passenger vessels.

Vessels undergoing modification are now captured in the transitional vessel process in Marine Order 503, which acts to prevent the stability related incidents of the past. Modifications that affect stability require that a lightship check be performed, and stability information updated as required. This is one of the primary reasons that lightship declarations are not accepted in alternate survey approvals when existing vessels undergo initial survey under Marine Order 503 Section 9.

Class 2 and 3 DCV’s that have perished in the past are often cited as reasons for conducting a full lightship check in lieu of a declaration. In most cases these vessels had undergone a significant change and would likely have transitioned under the current arrangements of Marine Order 503 and had their stability re-assessed.

As an example, the Canadian fishing vessel Tyhawk perished in 2021. The Tyhawk had added an additional deck (see figure 1 below). Were it a DCV, the addition of a deck is a change listed in item 7 (c) of Schedule 1 of Marine Order 503 and, under Section 9 (1)(c), would have required that the vessel undergo full initial survey including a lightship check and reassessment of stability.

Figure 1 Tyhawk following modification, deck added show in bare aluminium. Source: Transportation Safety Board of Canada, Marine transportation safety investigation report M21A0065.

AMSA requests that accredited surveyors explain the importance of the lightship declaration to an owner. A person, such as the owner or master of a vessel, might commit an offence under section 137.1 of the Criminal Code Act 1995 if the person gives information to AMSA knowing that the information is false or misleading, or omits any detail without which the information is misleading.¹

The message is that failing to declare pertinent changes (thus omitting to perform an act) is a serious offence. If the vessel were to later face a situation where a loss of stability leads to an incident, the connection between the false declaration and the incident would not be difficult to prove.

If the Owner or Master cannot be sure of any changes made to the vessel since the last inclining or practical stability test, or since the last Certificate of Survey was issued, they should engage the services of a competent person, such as a naval architect or an accredited surveyor. A lightship check and re-assessment of the stability against the relevant stability criteria may be subsequently required under SAGM 4.9.

The message to Owners or Masters in this case is, if you don’t know, don’t sign. To assist the AMS community in conveying this message, the AMSA 752 form will be altered to emphasise the legal importance of the declaration.

In summary, this is a risk-based solution. To require a lightship check at each renewal survey for every vessel would come at enormous expense to the industry and would vastly exceed standards applicable to the domestic fleet globally.  The declaration system under SAGM 4.9 (6) serves as an additional safety benefit and correctly highlights the duties that apply to owners of domestic vessels to inform surveyors and the national regulator when making changes that affect vessel stability.  

New Surveyor Accreditation Guidance Manual Part 2 now available

We have released the updated Surveyor Accreditation Guidance Manual Part 2 (SAGM) which comes into effect on 1 Jan 2025 and updated survey forms.

This manual outlines the standards and criteria required for the survey of domestic commercial vessels by Accredited Marine Surveyors and recognised organisations.

SAGM includes detailed technical, safety, and operational benchmarks established by AMSA, guiding surveyors in maintaining high standards of vessel safety and compliance.

1. Increased owner control and flexibility with survey cycles.

• Owners of high survey frequency vessels can now choose to conduct their out-of-water survey in either year 2 or year 3 of the survey cycle.
• Owners of medium survey frequency vessels can choose to conduct their year 3 survey either in or out of the water.

2. Simplified dual 2/4 class certification for leisure type vessels.

• Class 2 vessels engaged in leisure type activities (up to C waters) can now use the same CE certification for structural certification as Class 4 vessels, reducing regulatory burden for skippered Class 4 operations

3. Clearer reporting obligations for repair and damage surveys.

• A definition has been added for "partial" surveys, along with a process described to allow reporting to AMSA.

4. Use of own forms.

• The SAGM now allows any AMS to use their own survey reporting forms, provided these forms contain sufficient detail.

5. Easier entry survey for restricted C class vessels.

• Design documentation requirements for restricted C class vessels have been made less burdensome.

6. Significant detail added to the description of each survey type.

• A significant level of increased detail has been added to the descriptions of each survey type within Table 2 and Table 6.

Surveyors and organisations are encouraged to review the manual and to ensure familiarity before the changes come into effect on 1st Jan 2025.

Updated forms can be put into use immediately.

Updated forms

Ensuring Compliance of Fixed Fire Systems on Transitional Vessels: Type Approval vs Service certificates

Fixed fire systems on transitional vessels must meet the requirements of the NSCV C4 standard regardless of whether the USL Code applies to other fire safety items.

This article provides guidance on surveying fixed fire systems on transitional vessels, with a focus on the distinction between service certification and type approval, and there roles in confirming compliance with NSCV C4.

Understanding Transitional Vessels

Fixed fire systems are integral to the safety of commercial vessels. They are designed to suppress fires quickly and effectively, thereby reducing the risk of catastrophic damage or loss of life. For existing vessels, fixed fire systems are required to be maintained in good order in accordance with their original certification and service requirements. However, when a vessel transitions, existing systems must be examined to determine if they comply with the requirements of NSCV C4 - not just that they have been serviced.

NSCV C4 mandates that all fixed fire systems installed on commercial vessels must be designed, assessed, manufactured and installed in accordance with a standard mentioned in Table 14, where “assessed” is defined as:

Assessed: type assessed and verified as meeting the applicable standard or specification or test mentioned within this subsection, in a manner than complies with Chapter 18.

For a system to be accepted, each component, system or installation of active or passive fire protection measures must be tested and specifically listed for the purpose specified in NSCV C4 by

• Being tested and specifically listed as a fixed fire system by a NATA accredited laboratory, or a specialised laboratory such as the Scientific Service Laboratory (SSL);
• certified by a JAS-ANZ accredited product certification body;
• type approved by a recognised organisation; or
• certified by a Notified Body, recognised by the National Regulator, in accordance with the EU Marine Equipment Directive, Module B (MED-B).
• Evidence of this assessment is provided in the form of a type approval / listing certificate form the body that conducted the assessment.

A fire servicing agent or similar cannot provide this certification, they are not recognised as listing bodies by the NSCV.

Even if the fixed fire system has been in the vessel for a number of years, transition is a point in time where a surveyor is required to confirm that this system could be fitted to the vessel if it was now being built to contemporary standards.

Regardless of whether the system was previously accepted under a state scheme or previous standard, NSCV C4 requires that it has a current type approval / listing and could be accepted on a contemporary DCV today.

Service Certification vs. Type Approval: What’s the Difference?

Type assessment involves the certification of a product or component (in this case, a fixed fire system) by a recognized authority to confirm it meets the relevant standards. This process typically includes rigorous testing under controlled conditions to ensure the system’s effectiveness in a fire scenario. For transitional vessels, it is imperative to confirm that any installed fixed fire system holds a current type assessment with NSCV C4 specifications.

Service certification, on the other hand, is the ongoing verification that the installed system has been maintained. This includes regular maintenance checks, servicing, and testing, as well as compliance with installation standards. Service certification is crucial because even a type-assessed system can become ineffective if not correctly serviced and maintained, or if it has been modified without proper oversight.

Surveying Fixed Fire Systems on Transitional Vessels

Check Type Approval Documentation: Surveyors must request and review the type assessment documentation for the fixed fire system, which must clearly indicate that the system complies with the

relevant standards as outlined in NSCV C4.

This documentation can generally be obtained from the original equipment manufacturer.

What does this mean in practice?

In practice, this means that a system will need to be replaced if its type assessment certification has expired or been revoked - even if it has been in the vessel for several years.

AMSA is aware that there are several systems, previously acceptable under USL Code that do not have current listings and cannot be fitted onboard transitional or new DCV’s. This has occurred because:

• The system was listed / approved by a state marine safety agency and does not hold any national or internationally recognised listing.
• The listing for the system expired and has not been renewed by manufacturer. Expired listings/approvals are not valid.
• The extinguishing agent is environmentally damaging, and the manufacturer no longer maintains the approval.

If a fixed fire system on a transitional vessel does not hold current type assessment certification permitted under NSCV C4, it must be replaced with one that does.

Electrical issues able to be identified by non-electrical periodic surveyors

This topic raised at the recent Accredited Marine Surveyor Workshop generated considerable discussion:

Can a non-electrical accredited surveyor comment on potential electrical issues observed during a periodic survey?

An AMSA employee offered a helpful analogy: “Think of yourself as a GP. If you identify a potential issue, bring in the specialist—such as a licensed electrician or electrical surveyor.” This highlights that marine surveyors can and should note observations about electrical issues, even if they are not qualified to assess them fully.

There appears to be a misconception that surveyors cannot comment on electrical issues, which is incorrect. For instance if an electrical surveyor notices a cracked engine mount while inspecting generator mounts, they would be remiss not to include that observation in their report, even though don’t hold a machinery accreditation.

Similarly, if you observe clear examples of poor wiring, signs of overheating, damage to electrical enclosures, broken fittings or fixtures then these should be recorded as deficiencies requiring corrective action.

Following are examples of substandard wiring and electrical issues that would require rectification.

Unsecured and unprotected wiring and exposed conductive electrical components attached to an unsecured battery.

As above, an example of a very poorly installed electrical wiring installation

Poor battery maintenance. This white power is lead sulphate which is toxic to ingest and breathe. This can be prevented by keeping your battery dry and using a Dielectric grease on the terminals. Poor battery maintenance. This white power is lead sulphate which is toxic to ingest and breathe. This can be prevented by keeping your battery dry and using a Dielectric grease on the terminals.

AMSA is considering the development of an Instruction to Surveyors (ITS) to further assist the AMS be better equipped to identify and report these matters.

Timber boat surveying – with a focus on inspection of metallic fasteners

Surveying a timber boat is essential to ensure its safety, seaworthiness, and structural integrity. Timber boats, unlike those made of more modern materials like fiberglass or metal, require regular inspection and maintenance due to the natural properties of wood, which can be susceptible to issues such as rot, swelling, and pest damage. The main purposes of surveying a timber boat are to:

Identify structural weaknesses: Wood can deteriorate over time, so a survey helps identify issues such as rot, cracks, or damage from marine organisms. This is critical for the safety of the boat and its crew.

Evaluate repairs and maintenance needs: Regular surveys can pinpoint areas that need repair, maintenance, or replacement. This might include re-caulking seams, replacing damaged planks, or treating wood for pests.

Assess hull condition: The hull is especially vulnerable in timber boats. A survey can assess the condition of the hull, which is essential for water-tightness and overall buoyancy. Depending on the type of timber, the method of construction and the level of maintenance and protective coatings, timber boats take on or absorb water during their service life. This leads to increases in weight, rot or deterioration and can increase the likelihood of corrosion or damage to any metallic fasteners used in the construction of the vessel - especially for those vessels operating in salt water. Various metals are used are used in fasteners for timber vessel construction including galvanised mild steel, bronze, bronze alloys, stainless steel, and copper.

Ensure compliance with safety standards: AMSA requires commercial vessels including timber boats to undergo regular surveys to meet safety regulations. This is particularly important for boats used for passenger transport. By conducting a thorough survey, owners of timber boats can catch potential issues early, extend the life of the vessel, and ensure it remains safe and reliable on the water. Inspections should include:

• Internal Structure: Inspect frames, stringers, and other structural components, as well as any signs of rot, cracks, or separation.
• Deck and Cabin Inspection: Check for leaks, signs of water intrusion, and deteriorated joints in the deck, cabin, and other superstructures.
• Mechanical and Electrical Systems: Outline a basic inspection of these systems and their integration within a timber structure.
• Fasteners and Fittings: Examine metal fittings for corrosion and ensure bolts, screws, and other fasteners are intact.

Metallic fasteners and their modes of failure.

The failure of metallic fasteners in old timber boats is a common issue that can lead to significant structural deterioration and even compromise the safety and integrity of the vessel. The main causes and mechanisms behind this type of failure are outlined below.

Corrosion

Galvanic Corrosion: Different metals, when in contact with each other in a marine environment, can create an electrochemical reaction. For example, if iron fasteners are used alongside copper or bronze fittings, the iron can corrode quickly due to galvanic action.

Saltwater Exposure: Saltwater accelerates corrosion significantly. When metallic fasteners are exposed to seawater or even salt-laden air, they can corrode over time, weakening their ability to hold the timber planks together.

Crevice Corrosion: Areas where fasteners are embedded in the wood may trap water and other contaminants, creating an environment with limited oxygen that favours crevice corrosion. This localized attack can undermine the metal’s structural integrity from within and is a common failure with stainless steel fasteners.

Electrochemical reactions in wood

Acidity and Moisture in Wood: Wood itself contains organic acids and can absorb moisture from the surrounding environment, especially in bilge areas or hull regions below the waterline. These acidic conditions can lead to localized pitting or rusting of metallic fasteners, especially with iron or steel.

Galvanized Fastener Deterioration: In some cases, fasteners are galvanized or coated to resist corrosion. However, this coating can wear off over time, leaving the metal underneath exposed to further chemical degradation.

Mechanical stress and fatigue

Vibration and Load Cycles: The dynamic forces experienced by a boat, such as wave impact and load shifts, create repeated stress on the fasteners. Over decades, this can lead to metal fatigue, where micro-cracks develop in the fastener, eventually causing it to break.

Swelling and Shrinking of Wood: Wood naturally swells and shrinks due to changes in humidity and moisture. This movement places additional stress on the fasteners, causing wear and loosening over time.

Hidden deterioration

Embedment and Concealment: Many fasteners in timber boats are embedded within wooden joints or covered with plugs, making it challenging to inspect for signs of corrosion or wear. As a result, deterioration can remain unnoticed until it becomes severe.

Wood Rot and Structural Weakening: When rot sets into wood near metallic fasteners, it reduces the holding strength of the fastener in the timber and may lead to loosening or failure. Wood rot also creates an even more corrosive environment for metal components.

Preventive measures and remedies

Inspection and Replacement: Regular inspection of fasteners is crucial, especially in areas prone to high stress or saltwater exposure. For older boats, replacing corroded or fatigued fasteners with corrosion-resistant metals like silicon bronze or stainless steel can improve longevity.

Sealing and Isolation: Applying a protective sealant on metal fasteners or using non-metallic bushings can help isolate them from the wood and reduce galvanic reactions. Epoxy coatings or barrier paints on metal fasteners also help minimize corrosion.

Using Compatible Metals: When possible, using metals that are compatible with the surrounding materials can reduce galvanic corrosion. In many cases, using the same metal for all fasteners and fittings (like bronze) can prolong the structure's life.

Addressing these failure mechanisms early on is key to preserving the structural integrity of old timber boats and ensuring their continued use and safety.

Steps in surveying timber boats

Preliminary Inspection: Begin with an overview of the boat, looking for visible issues like:

Rust and Oxidation: Examine visible areas of fasteners for rust, which indicates potential corrosion.

Stainless steel or bronze fasteners should not rust in typical conditions, so any rusting indicates issues.

Loosening or Movement: Check if any fasteners are loose, as this could mean they have worn down or the wood around them has softened.

Discoloration in Wood: Dark staining around fasteners often indicates iron corrosion, which may signify weakening. Bronze can also leave green or blue stain, pointing to fastener degradation.

Rust streaks are often indicators of the type / material of fasteners and that corrosion or deterioration might require further inspection.

Inspection: Examine the hull below the waterline, checking for soft spots, seams, fasteners, and signs of rot.

Check caulked seams are consistently tight and compact. Use a sharpened awl to check for soft spots or rot in the timbers. Look for areas of blistered or raised paint that might indicate rot or swelling underneath. Consider removing selected pieces of copper sheathing (where fitted) to inspect / probe timbers underneath. Check major structural components around the shaft(s) and rudder post(s). Pay particular attention around hull penetrations - especially fresh water drains from galleys and bathrooms.

Once the underwater paint scheme has been stripped it may be easier to identify a random selection of fasteners for removal. These should include fasteners from the stem and stern post areas which will have been in place since the original construction of the vessel.

Non-destructive testing (NDT)

Ultrasonic Testing: Ultrasonic equipment can detect cracks or weak points in metal fasteners without removing them. This is particularly useful for inspecting fasteners embedded deep in the timber.

Magnetic Particle Inspection: This method can be used for ferrous fasteners to detect surface and slightly subsurface cracks.

Moisture Meters: Testing surrounding timber for moisture levels is essential, as wet wood accelerates corrosion and can rot around fasteners, causing loosening.

Removing sample fasteners

In some cases, removing a few fasteners for inspection can reveal hidden corrosion and deterioration patterns. This may be necessary if NDT is inconclusive or if the vessel shows signs of advanced corrosion.

SAGM Part 2 requires more in depth inspections at the 10 yearly or renewal survey interval and are reproduced below:

4.11 Scope and depth of a periodic or renewal survey

(1) A periodic or renewal survey must include the examinations, verifications, tests and trials of:

• the items specified in Table 9 relevant to the survey type unless otherwise approved in writing by the National Regulator; and
• as reasonably required by the surveyor in order to be satisfied that the vessel complies with the applicable legislation, exemptions and standards.

(2) In addition to the items specified in Table 9, the following inspections must be carried out on a vessel at every second renewal survey for the vessel, which should occur at intervals not exceeding 10 years and six months:

• ultrasonic thickness for vessels having metallic hull
• withdrawal of sample fastening for vessels having wooden hull
• hull in way of removable ballast
• verify internal foam buoyancy if not fully inspected during the five yearly in and out of water survey because of inaccessibility
• internal hull inspection if not fully inspected during the five yearly in and out of water survey because of inaccessibility;
• pressure test all sea water pipes
• internal fuel tank inspection of at least half the number of the tanks on board; and
• internal inspections of all other tanks not mentioned in Table 9.

Surveyors should use their observations of the hull and structure prior to the vessel being removed from the water to identify fasteners that are indicating signs of corrosion, wastage or failure. Depending on the fastener material, signs of corrosion or deterioration may not be clear or easy to identify. Surveyors should use their judgement and remove fasteners from high risk areas where fresh water, excessive moisture, poor ventilation, mould or rot are evident, or from areas where structural damage / previous repairs have been made for removal and inspection.

Typical keel to stem construction.

Typical keel to stern post construction.

Replacing corroded fasteners

Material Choice: Use corrosion-resistant materials like stainless steel or silicon bronze. Avoid mixing metals in close contact to reduce the risk of galvanic corrosion.

Protective Coatings: Consider using coatings or sealants around fasteners to minimize water ingress and slow corrosion.

Maintenance Best Practices: Offer tips on regular maintenance, such as sealing, painting, and antifouling treatments.

Protecting Against Moisture: Recommend preventative measures, including proper ventilation and regular cleaning.

Handling Repairs: Provide a basic guide on when to handle repairs and when to seek professional help, especially for issues like structural rot.

Conclusion

Routine inspections combined with preventative maintenance can help identify issues early and prolong the life of metallic fasteners in timber boats, preserving both safety and vessel longevity.

Upcoming peak period for Accreditation renewals

We have a large cohort of AMS who are coming up for accreditation renewal next year, to ensure applications are processed quickly please remember that a completed AMSA804 application must be received a minimum of three months before expiration of your accreditation.

What makes an AMSA804 application complete?

It must have:

• an updated photo for your new survey card,
• evidence of your professional membership including expiration date and
• evidence of continued professional development, either a statement and/or copies of certificates.

Be on the lookout for the reminder email. Toulla will send them out four months before your accreditation expiration date.

Float-free EPIRB maintenance: HRU and batteries

This is an important reminder to regularly review the hydrostatic release unit (HRU) and batteries on float-free Emergency Position Indicating Radio Beacons (EPIRBs) whilst undertaking surveys.

If a float-free EPIRB has been installed for 2 years or more, it’s time for owners and surveyors to give it the attention it deserves. Regular maintenance could make all the difference in an emergency.

Float-free EPIRBs are designed to automatically activate during emergencies. These water-activated distress EPIRBs are securely housed in a float-free bracket and deploy when a vessel capsizes at depths of 1–4 meters. Equipped with an HRU, the EPIRB floats to the water’s surface if unobstructed and immediately starts transmitting the distress signals.

For float-free EPIRB devices to work correctly, 2 critical components must be in top condition: the battery and the HRU. Batteries need regular checks due to their limited lifespan, and the HRU must be replaced every 2 years, unless the manufacturer specifies otherwise.

When conducting surveys, follow the manufacturer’s maintenance instructions, and inspect both battery and HRU as appropriate.

Find out more about HRU replacement

New builds – Duties of builders, designers and surveyors

General Safety Duties – Designers and builders

Designers and builders (amongst other persons) are required under Section 14 of the National Law to ensure that, as far as reasonably practicable, a vessel is safe if used for the purpose for which it was designed, commissioned and constructed. They shall carry out, or arrange the carrying out of such testing and examination as may be necessary to ensure the vessel is safe. A vessel that is found to be unsafe during builder trials which is subsequently allowed to enter service would be a breach of the general safety duties of the designer and builder.

Role of AMS in a new vessel build

Accredited Marine Surveyors (AMS) are tasked with assessing a vessel’s compliance with the applicable standards using the survey standards outlined in Marine Order 503 and the Marine Surveyors Accreditation Guidance Manual (SAGM). An AMS must not conduct a survey of a vessel while also acting in the capacity of an owner’s representative, as there may be a conflict of interest between the objectives of the owner and the AMS discharging their duties under the National Law. Similarly, the surveyor’s accreditation must not be used by the owner as a form of quality control over the builder to ensure that contractual requirements are met. This is usually the remit of the owner themselves, or an owner’s representative.

Vessel that is not fit for purpose

Criteria outlining a vessel’s fitness for purpose, and the metrics for establishing this, should be decided by the owner and builder and clearly outlined in the build contract. The owner may then wish to engage a competent third party as their representative to ensure that the builder fulfils their contractual obligations.

For example, a vessel meets all applicable standards and the initial surveys have been correctly completed, but its design is such that it does not meet the maximum laden speed specified in the contract. It is the remit of the designer and builder to ensure the problem is rectified – not the AMS, as it does not relate to safety.

Vessel that is unsafe

Section 6 of the National Law Act defines an unsafe vessel as one that is likely to endanger any persons for any reason. Clause 2.8 (5) of edition 3 of SAGM reinforces the requirement for a surveyor who identifies unsafe aspects of a vessel’s arrangement, construction, machinery, equipment or operational performance to report it to the National Regulator as soon as practicable. In addition, SAGM 3.11.2 outlines the various commissioning phase surveys and DCV-ITS-009 provides instructions for AMS undertaking these surveys.

The commissioning phase of initial survey should include vessel trials through which the propensity of a vessel to exhibit undesirable (unsafe) characteristics is checked. If the vessel is found to be unsafe during the course of a commissioning survey, the AMS must report the matter to AMSA, and work with the builder and/or designer to ensure such characteristics are rectified before recommending the survey.

For example, a DCV’s hullform and / or steering system performs dangerously whilst underway despite meeting the intact stability and engineering standards. Under the general safety duties, it is the remit of the persons responsible for the design, construction and testing of the vessel to ensure that these performance issues were identified and resolved. This ideally would be done by the builder prior to engaging an AMS to undertake the commissioning phase of initial survey. The commissioning AMS must not recommend the survey if the unsafe performance issues are not resolved.

AMS approving their own designs

It’s worth noting that an overlap exists between the general safety duties and accredited marine surveyors in instances where a person accredited in plan approval approves their own design and recommends it.  In these instances, the general safety duties would also apply to them in their capacity as a designer. Acting as the plan approval surveyor does not relieve a designer of their general safety duties and as such, they must ensure the vessel is safe if used for the purpose for which it was designed. This should include witnessing the vessel performance during commissioning trials, ensuring design speeds and displacements are not exceeded, and verifying that the lightship particulars and associated stability criteria have been met for all loading conditions.

Conclusion

AMSA recommends that AMS undertaking the plan approval or commissioning phases of initial survey clearly establish with the builder and the designer the duties applicable to each party under National Law. Each party should agree on the criteria for acceptance of the commissioning trials as they relate to the detection and rectification of unsafe vessel matters not covered under the applicable technical or survey standards.

Survey Matters suggestions

AMSA wants to make sure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels. 

We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications.

¹ Updated on 12 February 2025: This sentence has been updated since its original publication.

• Marine Surveyor Accreditation Guidance Manual – Part 22
• Case Study– Compliance action on an AMS’s accreditation
• Domestic Commercial Vessels - Decks
• Understanding Conflict of Interest Provisions for Accredited Surveyors under the National Law Regulations
• Temporary Operations Permits – Division 5 and 6 – Ongoing Issues
• Instructions to Surveyors (DCV-ITS-022)
• Surveyor Workshop – October 2024
• Alternate Survey Approvals - Surveyors must conduct surveys in accordance with prescribed standards
• Have your say on the new Accommodation, Arrangement & Personal Safety form
• Survey Matters suggestions

Marine Surveyor Accreditation Guidance Manual – Part 2

Edition 3 of the Marine Surveyor Accreditation Guidance Manual – Part 2 was approved by the National Regulator on 15 July 2024 and will commence on 1 January 2025. Key changes made to the manual include:

1. Increased Owner Control and Flexibility with Survey Cycles
   • Owners of high survey frequency vessels can now choose to conduct their out-of-water survey in either year 2 or year 3 of the survey cycle.
   • Owners of medium survey frequency vessels can choose to conduct their year 3 survey either in or out of the water.
2. Simplified Dual Class 2/4 Certification for Leisure Type Vessels
   • Class 2 vessels engaged in leisure type activities (up to C waters) can now use the same CE certification for structural verification as Class 4 vessels, reducing regulatory burden for skippered Class 4 operations.
3. Clearer Reporting Obligations for Repair and Damage Surveys
   • A definition has been added for "partial" surveys, along with a process described to allow reporting to AMSA.
4. Use of Own Forms
   • SAGM now allows any AMS to use their own survey reporting forms, provided these forms contain sufficient detail.
5. Easier Entry Survey for Class C Restricted Vessels
   • Design documentation requirements for restricted C class vessels have been made less burdensome.
6. Significant Detail Added to the Description of Each Survey Type
   • A significant increase in detail has been added to the descriptions of each survey type within Table 2 and Table 6.

The approved document will be published on the AMSA website towards the end of 2024 to provide surveyors with an opportunity to familiarise themselves with the final version before it comes into effect.

In the meantime, AMSA is currently reviewing survey forms, the MARS system, and internal assessment processes to allow implementation of Edition 3 of SAGM Pt 2, which commences on 1 January 2025.

Case Study– Compliance action on an AMS’s accreditation

AMSA field staff lodged a complaint in relation to an AMS after conducting inspections on multiple vessels. AMSA performed audits on periodic, out of water, shaft and lightship surveys performed by an Accredited Marine Surveyor (AMS) across multiple vessels. The audit identified several Major Non-conformances. On 25 May 2023, the AMS was invited to show cause why their accreditation should not be revoked due to the failure to comply with a condition of accreditation referred to in Division 3.3 (Sections 32 and 33) of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the Regulations) along with a request to provide corrective action to the audit findings. On 20 July 2023, after evaluating the responses from the AMS, the delegate of the National Regulator decided to revoke the accreditation of this AMS. Section 44(1) of the Regulations provides the power to the National Regulator to revoke accreditation if an Accredited Marine Surveyor contravenes a condition of accreditation referred to in Division 3.3).  

On 1 August 2023, the AMS applied to the National Regulator for internal review of the decision in accordance with Section 142 of the Marine Safety (Domestic Commercial Vessel) National Law Act 2012 and Section 48 of the Regulations. On 16 November 2023, after evaluating the submissions made, the new delegate of the National Regulator affirmed the decision to revoke the accreditation. 

Conditions Contravened 

The condition in section 32 of Division 3.3 of the Regulations requires an AMS to conduct a survey of a domestic commercial vessel in accordance with a standard prescribed by a Marine Order that relates to the survey of domestic commercial vessels. Section 5 of Marine Order 503 (Certificates of survey-national law) 2018 in turn prescribes Part 2 of the National Law – Marine Surveyors Accreditation Guidance Manual (SAGM) 2014 as the survey standard. 

The AMSA delegate formed the view that the AMS failed to comply with the requirements of Section 32, in Division 3.3 of the Regulations and Clause pts- 2.3, 2.8, 2.9.1, 2.9.2, 4.7, 4.8, 4.9 and 4.11 of SAGM Part 2 as the prescribed survey standard. 

Reasons for revocation 

1. The AMS did not perform a shaft survey on several vessels as required by table 9 of SAGM Part 2. 
2. The AMS did not perform a lightship survey on a Class 1 vessel as required by SAGM Part 2. 
3. Many of the defects identified during the AMSA inspection on some vessels were serious, long standing and indicative of inadequate scope and depth of survey conducted by the AMS. Surveys conducted were not in accordance with the requirements of SAGM, albeit conducted months earlier than the AMSA inspection. The AMS failed to identify these issues in their survey report, and further failed to report them to AMSA, breached the requirements of SAGM, and the conditions outlined in sections 32 and 33 of the Regulations. 
4. The AMS also did not take an approach of implementing corrective actions to their survey practices to perform the surveys in accordance with SAGM Part 2.

Below are some photographs of the vessel’s condition, as observed by AMSA Inspector, a few months after the AMS’s survey.

Figure 1: Defective, badly rusted fuel inlet pipe

Figure 2: Air vents rusted and holed

Figure 3: badly rusted bulwarks, with holes that could injure crew members

Figure 4: Doors not weathertight / watertight

Figure 5: Defective and inoperable Engine Room air intake

Figure 6: Damaged lifejackets onboard a Class 1 vessel.

Key takeaways for Accredited Surveyors

• Photographic evidence

Section 2.9.2 (3) of SAGM Part 2, regarding the documentation supporting recommendation is cited below.

3. All supporting documentation must be provided to the Natioanl Regulator with the recommendation. 
   
   Note Photographs are a good source of evidence and should be maintained by the surveyor and provided to the National Regulator on request

AMSA appreciates that some AMS are already taking a proactive approach of providing photographic evidence of the surveyed items as part of their recommendations in MARS. If the AMS uploads photographs of defective items in MARS, AMSA also expects AMS to provide the repaired/corrected photographs as well.

It is AMSA’s expectation that the AMS shall provide AMSA with the photographic evidence of the surveyed items (while responding to the audit commencement email for the Major audits or while responding to the findings report for a Complaint Audit). AMSA encourages all AMS to take adequate photographs with date stamps (as far as practicable) for the surveyed items, so that their recommendations to the National Regulator are defensible & auditable.

2. Corrective actions for non-conformances

AMSA has noticed that some of the AMS, while addressing corrective action for non-conformances identified during audits, are only focussed on correcting immediate issues to address the finding. AMSA encourages all AMS to also address any systemic issues in their survey practices/techniques/procedures to prevent re-occurrences of similar findings.

AMSA has identified that several AMS’s do not undertake corrective actions for audit findings in a timely manner. AMSA would like to remind AMS’s that failure to undertake appropriate corrective actions in a timely manner or the audits resulting in serious findings may result in Infringement Notices, show causes or compliance actions on the AMS’s accreditation.

Domestic Commercial Vessels - Decks

Types of Decks

Most commercial vessels have one or more open decks, and according to NSCV C1 definitions these can be categorised as three (3) different types.

Each deck must be categorised when applying NSCV C1 Chapter 6 Personnel Safety requirements. For a new design this may be straightforward but for exiting vessels that have made a transitional change under Schedule 1 of Marine Order 503, this can cause confusion. The use of the vessel and the deck configuration must be analysed with input from the owners and operators to determine the exact use of each deck.

NSCV C1 Chapter 6

When applying clause 6.4 Bulwarks and guardrail requirements, the deemed to satisfy solution in clause 6.12.3, the minimum height of bulwarks and guard rails depends on the deck categorisation. In Table 29 reduced heights are allowed for special purpose and special working decks, but with additional measures required as detailed in clause 6.12.4 which refers to Table 30. There are nine (9) measures listed, with their applicability varying for seagoing (Class A, B and C) and sheltered water (Class D and E) vessels. The minimum specifications are in clause 6.12.7 of the standard. 

When implementing, applicable additional safety measures must be expressly documented in the vessel’s safety management system as required by clause 6.12.4 (b).

Alternative way to accept

If it is not practical to apply these measures and the deck does not comply, risks may be reduced by limiting access, thus must however be realistic. For example, if crew cabins or toilets are to be accessed via this deck then access cannot be restricted as it is a basic need of the crew to always have access to these facilities. Access controls may be applied to decks that are used for a short duration, such as mooring decks and decks that are used only for maintenance.

How to report

During initials surveys, it is expected that these requirements are identified and assessed at the plan approval stage and documented in the plan approval letter. During commissioning a check must be carried out to ensure they are implemented. During periodic surveys a check must be carried to ensure they are in good order and reported correctly under the deck survey section of the AMSA 901 or surveyor’s equivalent.

Understanding Conflict of Interest Provisions for Accredited Surveyors under the National Law Regulations

As an accredited surveyor operating within Australia's domestic commercial vessel industry, you are entrusted with ensuring that vessels meet the safety standards under the National Law framework. Central to this role is your obligation to perform your duties impartially and without any conflict of interest.  

The National Law Regulations contain specific provisions aimed at preventing conflicts of interest, which are critical to maintaining the integrity and safety of maritime operations. This article outlines these conflict-of-interest provisions and provides example scenarios of conflicts that may arise during your work. 

Conflict of Interest Provisions: An Overview

Section 37 of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013, prohibits the conduct of a survey of a domestic commercial vessel in circumstances where there may be a conflict of interest.  Specifically, an accredited surveyor must not conduct a survey or make a recommendation if they have a direct or indirect interest that could conflict with the proper performance of their duties as an accredited surveyor.

Consistent with these provisions, AMSA reminds you of the importance of avoiding situations where your objectivity could be compromised, either by financial incentives, personal relationships, or other external pressures. The key is that your decisions must be based solely on whether a vessel meets the prescribed standards - not on any other interest.

Examples of Conflict of Interest

Conflicting duties as Accredited Surveyor and Owner’s representative

Scenario: You enter into an agreement with a vessel owner to act as their project manager and owners’ representative throughout a survey process for their vessel. The owner also asks you to also conduct the surveys of their vessel as an accredited surveyor.

If you had been engaged only in your capacity as an accredited surveyor, your duty would be to objectively assess the vessel's condition, document the construction process, identify any non-compliance issues, and communicate them to the owner. It would then be up to the owner or their representative to decide how to address the defects to meet the standards. This may include holding discussions with you in your capacity as a surveyor on possible ways forward.

Conflict: In this scenario, you have made a commitment and will receive financial consideration to provide a service to the vessel owner that may conflict with your duty as an accredited surveyor.

The agreement creates a duty to the owner to represent their interests throughout the process. An owner representative’s duty will generally include for example minimising the inconvenience and cost of the survey process. As an owner’s rep you may need to take on a role as advocate on behalf of the owner to seek exemptions from non-compliances and identified safety requirements. Your actions are aimed at securing a tailored boutique solution that would allow the vessel to be certified despite its non-compliance, rather than ensuring that the vessel meets the necessary safety standards.

This may conflict with your duty as a surveyor and your conditions of accreditation under the National Law to ensure the vessel meets the applicable standards and has been subject to the required surveys, regardless of cost and inconvenience.

This relationship might reasonably be seen to give rise to a conflict between your duties as a surveyor and your interests under the arrangement, including improperly influencing the performance of your duties and responsibilities as an accredited marine surveyor.  This could also extend to any financial interest or payment you receive for your services under the agreement.

Personal Relationships:

Scenario: A close friend or family member owns a vessel that requires surveying. They ask you to conduct the survey.

Conflict: Conducting a survey for a relative can give rise to a conflict of interest and is expressly precluded by section 37(1)(b) of the Regulation. In such cases, you should remove yourself and refer the survey to another accredited surveyor.

Consequences of Breaching Conflict of Interest Provisions

Breaching the conflict-of-interest provisions not only jeopardises maritime safety but also has significant legal and professional repercussions. If a surveyor is found to have acted in a way that constitutes a conflict of interest, their accreditation could be revoked or suspended under Division 3.4. Furthermore, such actions could lead to legal proceedings, damage to professional reputation and potentially severe financial penalties.

Upholding Professional Integrity

To avoid conflicts of interest, always ask yourself the following questions before undertaking a survey:

• Do I have any financial interest in the outcome of this survey?
• Could my relationship, including any other contractual relationships with the vessel owner or operator, influence or be perceived to influence my decisions?
• Have I made any promises to the owner that could affect my impartiality?

If the answer to any of these questions is "yes," it is crucial to remove yourself from the situation to maintain the integrity of your role. For example, by referring the owner to engage another impartial surveyor. By adhering to these conflict-of-interest provisions, you contribute to the safety and reliability of Australia's maritime industry.

Conclusion

As an accredited surveyor, your role is central to ensuring that vessels operating within Australian waters are safe and compliant with the survey requirements. The conflict-of-interest provisions set out in the National Law Regulations are designed to protect the integrity of this process.

If you encounter a situation where a conflict of interest might arise, seek guidance or pass the survey to another qualified surveyor to avoid any potential breaches.

Remember, your duty as an accredited surveyor is to comply with the requirements and conditions of accreditation under the National Law and ensure the safety and compliance of the vessel, not to fulfil commitments you have made to owners or family members.

Temporary Operations Permits – Division 5 and 6 – Ongoing Issues

In the August 2020 edition of Survey Matters, titled “Issuing temporary permits under divisions 3, 5 & 6 of exemption 7”, and the January 2023 edition, “Are you issuing temporary operations documents correctly?”, AMSA provided guidance and advice on the proper issuance of temporary operations exemptions. Recent audits undertaken by AMSA have shown that errors are still occurring in issuing temporary operations permits where the relevant criteria for issue was not satisfied.

The errors are mainly occurring on permits issued under division 5 and 6 of exemption 7 (EX07).

Under divisions 5 and 6 of EX07 an accredited surveyor may issue a temporary operation permit only where relevant criteria are satisfied. The criteria for issue generally includes relevant vessel surveys being carried out, and the person who conducted the surveys considering whether the vessel complies with the applicable standards specified for each division.

The criteria under division 5 of EX07 requires (among other things) that the vessel has completed a periodic survey. The criteria under division 6 of EX07 requires (among other things) that the vessel has completed a renewal survey. SAGM Part 2 defines a renewal survey as:

... 'surveys undertaken at the end of a survey cycle, while the vessel is out of the water, and while afloat, to determine if the safety systems and safety characteristics of a vessel at that point in time comply with the applicable legislation, exemptions and standards.'

Clause 4.11 of SAGM Part 2 sets out the scope and depth of a renewal survey. It requires that the survey must include the examinations, verifications, tests and trials of the items specified in Table 9 relevant to the survey type. Table 9 also requires shaft and lightship inspections to be completed as a part of a renewal survey.

Recent examples have again shown that temporary operations permits are being issued under division 6 when the renewal survey was incomplete. In one case only the in-water and lightship surveys had been completed and no application for renewal of the vessels certificate of survey had been made.

The criteria for issue under division 6 was not met, because the surveyor had not conducted the examinations required for a renewal survey. Note, it is not the signed document alone that exempts the vessel, it is the fact that the vessel complies with the conditions for the issuing of the documents. Getting this wrong, can have serious consequences for the vessel owner.

Division 7 of EX07 is available for a vessel to be operated after the certificate of survey has expired and only the in-water components of the renewal survey have been completed. An accredited marine surveyor cannot issue a temporary operations exemption under this division. It is the operator who must make an application using the AMSA 777 form if they wish to utilise Division 7.

Instruction to Surveyors DCV-ITS-002 provides detailed advice on the issue of temporary operations exemptions. Please review this instruction before issuing permits under division 5 & 6 of Exemption 7

Instructions to Surveyors (DCV-ITS-022)

The long awaited Instruction to Surveyors (ITS) for the inspection of foam buoyancy, hull voids and fuel tank compartments at 10 yearly surveys is now live on the AMSA Website; https://www.amsa.gov.au/vessels-operators/domestic-commercial-vessels/instructions-surveyors This ITS was created on the back on the discussions and ideas of accredited marine surveyors at the 2022 surveyor workshop. The initial draft was then released in survey matters and further refined based on feedback received. AMSA is very appreciative of the discussion and feedback provided by the surveyor community to create a useful tool for reference.

Surveyor judgment and experience on the ground is fundamental to the practical implementation of the ITS. Ultimately it is for the surveyor to provide technical justification of the approach taken to establish the condition of the items being surveyed. The ITS provides a defendable framework for establishing this justification.

Guidance is also provided for builders and plan approval surveyors for design details that should be included at the design and construction stage. This will facilitate the survey of the vessel in the future, without the need for costly and potentially destructive works in the future. These represent a very tangible and marketable saving in cost of ownership and require minimal additional effort at the design and construction stages.

We strive for continual improvement in the resources provided to surveyors and welcome any feedback or suggestions for this ITS, others already available or those to be created.

Surveyor Workshop – October 2024

AMSA are pleased to announce that we are planning another surveyor workshop in October. Drawing on the feedback we received from the workshop in May, we will continue our established online format of dedicating different days to initial, periodic, and electrical surveys. However, we are shortening the duration to just one and a half hours to fit the workshop into busy schedules more efficiently.

The agenda is currently in development and will be tailored to cover the most relevant topics for each survey type. We can assure you there will be varied content between the days. We also invite participants to share any additional subjects they would like us to explore in this or future workshops.

Finally, we are actively exploring other options to access the workshop recordings, as we recognise that the platform used for the May workshop was challenging to use.

We look forward to welcoming you to an informative workshop in October.

Alternate Survey Approvals - Surveyors must conduct surveys in accordance with prescribed standards

Accredited surveyors are required to conduct surveys in accordance with the survey standards prescribed under section 32 of the National Law Regulations. Marine Order 503 and the Surveyor Accreditation Guidance Manual (Part 2) provide that the Australian Maritime Safety Authority (AMSA) may approve an alternative standard for the performance of surveys.

Surveyors intending to deviate from the prescribed standards must obtain alternative survey process approval from AMSA before proceeding. Conducting a survey without approval is a breach of accreditation conditions and may result in compliance actions or refusal of applications.

Have your say on the new Accommodation, Arrangement & Personal Safety form

AMSA is currently seeking feedback on a new survey form titled “Accommodation, arrangement & personal safety".

Background

AMSA has developed a new form to complement the existing set of forms currently in use by industry. This new form was developed to assist surveyors ensure the vessels arrangement meets the requirements of NSCV Part C, Section 1.

The aim of this form is to assist a surveyor conducting construction and commissioning surveys of a new build vessel. The form outlines the key areas of NSCV Part C, Section 1, which should be confirmed onsite during the build phase of a vessel. This is an area not currently covered in the existing AMSA form set.

Consultation phase

AMSA are seeking feedback on the proposed form prior to circulation for use.
To enable this consultation, AMSA has prepared the following:

• Draft version of the form.
  • This draft form can be accessed here:
• Consultation survey form
  • A consultation survey has been prepared with some prompt questions to gather feedback on the new form
  • The questions cover all aspects of the form and its use.
  • The survey form can be accessed here.

The consultation phase is open for a period of two months. Final feedback is requested by the 25/10/2024. If you have any questions during the consultation phase, please send an email to dcvsurvey@amsa.gov.au

Next steps

Following the close of the consultation phase period, AMSA will gather all feedback and review. From this, AMSA will make changes where necessary, prepare the final version of the form and implement the processes required for submission of this form.

We encourage everyone to review the proposed form and provide feedback to AMSA.

10-year surveys must be completed

AMSA continues to receive Certificate of Survey (CoS) renewal submissions where the required 10-year survey items have not been completed. This oversight can lead to significant delays and possible rejection of applications.

To avoid these issues, AMSA reminds surveyors that when conducting a renewal survey, it is crucial to ensure that all 10-year survey items are completed as required.

Since the service delivery transition in 2018, AMSA’s policy has required 10-year surveys to be completed by the second renewal survey conducted after 2018, if not earlier. This requirement is also highlighted in the reminder letters sent to certificate holders.

For most vessels, the next renewal will be the second one due after 2018.
Surveyors can take the following steps to determine if 10-year surveys are due:

1. Review certificate: Check the conditions on the certificate of survey. AMSA includes notes on 10-year survey due dates on initial and transitional certificates of survey.
2. Check the vessel report: the reminder letter sent to the certificate holder includes a vessel report. When preparing for a survey, request the vessel report from the owner along with the relevant survey codes. Alternatively, download the vessel report from MARS by following the steps in Chapter 5 of the MARS User Guide.

Refer to the “notes/observations section for 10-year renewal survey items” section at the bottom of the vessel report. This section provides information on past surveys, including dates and types of inspections performed. Comments in this section are from previous surveyors and not AMSA. Review these comments as well to identify what has been conducted e.g. partial inspection only.

If there is no information or comments available for an applicable 10-year item, it will not appear on the vessel report.

3. Seek AMSA clarification: If you are uncertain after reviewing the certificate and vessel report, email DCVSurvey@amsa.gov.au for clarification before undertaking the survey.

The 10-year survey items are outlined in SAGM Part 2, Chapter 4.11(2), which states:

(2) In addition to the items specified in Table 9, the following inspections must be carried out on a vessel at every second renewal survey for the vessel, which should occur at intervals not exceeding 10 years and six months:

1. ultrasonic thickness for vessels having metallic hull;
2. withdrawal of sample fastening for vessels having wooden hull;
3. hull in way of removable ballast;
4. verify internal foam buoyancy if not fully inspected during the five yearly in and out of water survey because of inaccessibility;
5. internal hull inspection if not fully inspected during the five yearly in and out of water survey because of inaccessibility;
6. pressure test all sea water pipes;
7. internal fuel tank inspection of at least half the number of the tanks on board; and 
8. internal inspections of all other tanks not mentioned in Table 9.
   Example of other tanks sludge, sewage, drain tanks

Survey Matters suggestions

• AMSA wants to make sure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels.
• We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications.

• Surveyor Accreditation Guidance Manual 2 consultation closed
• Shaft surveys explained
• Frequently asked questions related to AMS Audits
• Focused Certification Campaigns
• Monitoring Conditions
• Lithium Batteries
• Surveyor workshop feedback
• Supporting AMSA’s ‘be electrically safe’ education campaign
• Invisible gases, real risks
• Survey Matters suggestions

Read past editions

Surveyor Accreditation Guidance Manual 2 consultation closed

The consultation for SAGM Part 2 was open for a period of 8 weeks between 1 February and 2 April 2024.

The draft and a summary of the proposed changes were published on our website and stakeholders were asked to submit feedback online, via email, or through AMSA Connect.

AMSA promoted the consultation via posts on our website and social media channels. It was also highlighted in the AMSA Update and Survey Matters newsletters which have a combined reach of over 22,000 people.

A public consultation webinar covering the key changes was held on 22 March 2024. The 21 attendees asked a range of questions during the webinar which were addressed at the time and are also included in the consultation results.

AMSA also raised awareness of the consultation process through its regular stakeholder engagement activities. This included the Regional and National Safety Committee forums.

AMSA received a total of 9 submissions during the consultation period. 7 submissions came via the online form, 2 came via email.

The submissions included a total of 92 comments. 12 comments from the webinar have also been considered.

Most respondents indicated that they supported the proposed amendments. A few submissions also provided recommendations for improvements to the draft order.

Accessing the report

Visit the consultation report webpage for a detailed review of the feedback and proposed amendments.

Shaft surveys explained

Shaft surveys play an important role ensuring the reliability of vessel propulsion, however not all vessels require a shaft survey. As the name suggests, a shaft survey is a survey on a propulsion shaft which transmits mechanical power from the prime mover to a propeller to generate thrust.

Which shafts need surveying?

Almost all the propulsion drive systems include a shaft of some form, but shaft surveys are required only for shafts that are not part of a proprietary propulsion devices such as stern drives, azimuthing propellers (Z drives, electric pods), water jets and outboard engines. The logic behind this is that shafts within such proprietary propulsion devices are covered by their maintenance, and usually sits within the vessel allowing routine inspections and maintenance.

Contrary to this, a traditional propeller shaft in a stern tube cannot be inspected or maintained when in water so requires special attention when out of water. This includes both propeller and intermediate shafts in a shaft line. Refer NSCV C5A, Chapter 3 for propulsion systems requirements.

For Classed vessels shaft surveys are as per the class rules and covered under the machinery survey.

When you need a shaft survey?

A shaft survey must be completed at the initial survey which has a 5-year validity unless a transitional assessment is triggered. It is important to identify vessels that have no surveyable shaft/s so the shaft surveys can be removed from the survey schedule.

At a transitional survey, a shaft survey is required only if the change affects the shaft, or the vessel wants to enter a new survey cycle with a 5-year validity.

Changes that may affect a shaft include, prime mover power increase invalidating original shaft size calculations, shortening or lengthening the shaft, repositioning of the shaft line or withdrawal of the shaft, even if it is to swap ends or a like for like replacement.

At the end of each 5-year renewal survey cycle, a shaft survey will be required to assess its condition.

What level of details are required?

Initial survey stage (new build or transitional), the survey must cover all three stages, plan approval, construction and commissioning as scoped in Chapter 3 of the Marine Surveyors Accreditation Guidance Manual Part 2.

Renewal survey, details as required in AMSA 638 Shaft Survey Report is the minimum expected as applicable to the arrangement and situation. The information AMSA expects to see in the Shaft Details section of the AMSA 638 form is shown in the image below.

A typical shaft survey would include a visual inspection followed by non destructive testing (NDT) such as dye penetrant or magnetic particle to detect hairline cracks in any suspicious areas around keyways etc. Precision measurement of diameter, taper and straightness will be required to detect excessive wear or deformation.

To determine allowable tolerances, industry best practices such as IACS Guidelines for Non-destructive Examination of Hull and Machinery Steel Forgings and standards such as ISO 4566 and ABYC P-6 can be referred to.

Bluing of tapers is compulsory if mating surfaces have changed due to either installation of a new shaft or propeller or both, swapped ends or rebuild.

Associated components of the shaft such as couplings, brackets, bearing clearance, propellers and safety guards must also be surveyed during this time. Survey of the stern tube and stern gland or seal will also be required to ensure the water and weather tight integrity of the vessel.

Finally, a running check of the shaft is recommended where possible. Excessive vibration, overheated bearing housings or leaking glands could be indicative of defects such as shaft misalignment or loose propeller.

Frequently asked questions related to AMS Audits

AMS has been receiving questions recently from some AMS regarding the audits performed in accordance with the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the Regulations).

Q: What are the main steps involved in the accredited marine surveyor audits?

A: The following steps outline the audit process.  

1. AMSA informs the AMS about the audit commencing. This includes details of the survey codes being audited.
2. The AMS provides AMSA with any additional documentation, if applicable, within the timeframe.
3. AMSA conducts the audit.
4. AMSA sends an audit findings report to the AMS.
5. AMS responds with a proposed corrective action plan (CAP) by deadline (where required).
6. AMSA assesses the CAP and either agrees to it or proposes alternative actions.
7. AMS implements CAP and provides a response back to AMSA within the required deadline.
8. AMSA evaluates corrective action and informs AMS about the audit outcome when the audit is closed.

Q: What types of findings can be made under audit?

A: There are five types of findings:

• Positive Observation
• Neutral Observation
• Negative Observation
• Minor Non-Conformance
• Major Non-conformance

Q:  Should I respond to all the findings?

A: You are only required to respond to non-conformances. In these instances, you must provide a corrective action plan for each non-conformance. You are not required to respond to observations.

Q: What is a corrective action plan?

A: The substance of the corrective action should be proportionate to the level of the non-conformity identified. A corrective action plan is a response that outlines the steps intended to resolve an issue.

A corrective action must:

• Correct any immediate issues specific to the vessel mentioned in the audit finding. For example, the owner must provide an extra five coastal lifejackets and a confirmation email with photographic evidence.
• Correct systemic issues (issues with your survey process), to prevent re-occurrence, for example by incorporating:
  • lessons learnt (e.g. vessels must carry life-saving equipment for 100% complement for all classes); or
  • improvements to survey techniques and procedures (e.g. add an additional step in my survey process – “Inspect survey documentation to verify the classes and complements indicated on the vessel’s certificate of survey”)

Q: How should I propose a corrective action for a non- conformance finding?

A: Your correction action response should include the following:

• The finding number.
• The planned/implemented corrective action specific to the vessel and survey in question.
• Improvements in survey practice to avoid repeating the non-conformance.
• Supporting documentation (if applicable)
• The anticipated completion date.

Q: What should I do if I notice some findings are not applicable or incorrect?

A: The findings are recorded based on the information available to AMSA at the time of the audit. AMSA acknowledges desktop audits don’t provide an opportunity for the auditor to discuss the finding directly with you. If you believe any finding is not applicable or incorrect, please provide sufficient justification including a written explanation of your interpretation of the requirement/s and supporting information. AMSA will assess this new information and may consider downgrading the findings.

Q: How would I know if the corrective action is accepted or not accepted?

A: AMSA will notify you once all the findings and the audit are closed. During this time, we may also inform you about any downgraded findings. In case any corrective actions are incomplete or not acceptable, AMSA will request further documentation or a different course of action.

Focused Certification Campaigns

AMSA is undertaking compliance assessments based on intelligence analysis in order to identify current and emerging compliance risks. 

AMSA is developing targeted strategies to effectively address safety and compliance priorities, using a planned approach with clear goals and using the full range of tools available. 

As published in November 2022 Survey Matters the top three causes for refusal of certificates of survey applications were:

1. Survey process breakdown
2. Incorrect intact stability
3. Fire safety non-compliance
    

Image description

AMSA selected items 1 Survey process and 3 Fire safety non-compliance to focus on in the 2023-2024 certification campaign to increase compliance and reduce refusals.

Results

Since July 2023, 21% or around 160 applications were unable to be quickly processed due to issues with the plan approval letter content and fire systems.

Plan approval affected around 120 applications this year.

This is consistent with the previous data AMSA had on refusals which indicates plan approval failure as the largest reason for refusal of an application.
 

In the 2023-2024 period to date two applications were refused as the vessels were either not fitted with structural fire protection or fitted with the incorrect type of structural fire protection.

One application was refused because the plan approval process had not been followed resulting in incorrect surveys being completed.

One application was refused because the stability assessment had not been correctly conducted.

The impact of delays must be considered alongside the impact of refusals, especially given the number of hours wasted on reworking plan approval letters and the reassessment of applications.

Fire safety concerns remain a serious issue and can lead to significant delays or application refusals. These problems are particularly challenging as they may require the replacement of fire safety systems or fittings.

Monitoring Conditions

Several accredited marine surveyors currently hold accreditation with monitoring conditions. Most of these conditions were applied in the early days of AMSA taking over delivery of the Surveyor Accreditation Scheme. A common example of a monitoring condition is provided below:

“Before undertaking the first 2 surveys in this category, the surveyor must provide the National Regulator with a survey plan and obtain approval. The surveyor must also enable a person nominated by the National Regulator to undertake monitoring of the surveyor for conduct of the first 2 surveys in this category”

AMSA may remove the conditions from your accreditation if you have fulfilled the requirements. 

What is the process?

Our accreditation team will email you the details of your monitoring conditions. If you would like them removed, you can provide AMSA with evidence that you have completed the surveys and fulfilled the requirements.

AMSA will review the reports and if satisfied:

• Initiate a variation of your accreditation to remove the condition(s). You will not need to apply and there is no fee.
• Issue you a notice of decision letter outlining the approved variation.
• Update MARS accordingly.
• Update the web list, where applicable, to remove the asterisk from your categories.

Note:  Conditions will be retained if AMSA isn’t satisfied the requirements have been fulfilled.

This process is only applicable for monitoring conditions. All other variations to accreditation require an application and payment prior to assessment.

Lithium-Ion batteries

The use of Lithium-Ion batteries in the marine environment is increasing as the battery chemistry has numerous advantages, these advantages also come with higher risks. Lithium-ion batteries are not a direct drop-in replacement for lead acid batteries. They must be treated as a system as they have a communication link, different charging requirements, higher fault currents, different venting hazards and may require additional fire protection and detection systems.

The term Drop-In replacement is not an accurate term due to the points raised below. The Drop-in replacement term is being used in the market referring to the physical size of the battery occupying the same area as a lead acid battery but does not refer to the compatibility with the vessels electrical system.

Regulatory Compliance

Standards and Certifications: In Australia, lithium batteries must be installed in accordance with AS/NZS 3004.2 – 2.9.3 – Additional requirements for Lithium-Ion batteries.

Safety Concerns

1. Fire and Explosion Risks: Lithium Batteries have the ability to enter a state known as thermal runaway, which can lead to fires or explosions. Once thermal runaway of a battery is reached there is no easy way to extinguish the ensuing fire. Batteries can enter thermal runaway due to internal failures such as internal short circuits caused by manufacturing faults or external failure caused by operating the battery outside of its operating envelope, e.g. over/under voltage, extreme temperatures.  The marine environment can also expose the batteries to vibration, moisture, and temperature variations which may fall outside of the battery operating envelope.
2. Installation and Maintenance: Proper installation and maintenance are crucial to avoid safety risks. Lithium batteries must be installed with appropriate ventilation, must use suitable chargers, and undertake regular inspections of battery health. 

Compatibility

1. System Integration: Lithium batteries must be compatible with existing marine electrical systems. This includes ensuring that the battery management system (BMS) integrates seamlessly with the boat’s power management system.
2. Charger Compatibility: Not all chargers are suitable for lithium batteries. Using an incompatible charger can lead to overcharging or undercharging, which can damage the battery and pose safety risks.
3. Additional passive and active fire safety requirements may be required.

Environmental Factors

Marine Environment Challenges: The harsh marine environment, characterized by high humidity, saltwater exposure, and varying temperatures, can affect the performance and longevity of lithium batteries. Batteries must be designed to withstand these conditions.

Conclusion

While drop-in lithium batteries offer significant advantages for marine applications, including higher energy density, longer lifespan, and better performance, they also present hazards. Ensuring regulatory compliance, addressing safety concerns and ensuring compatibility with existing systems are all critical for their use on Domestic Commercial Vessels.

Surveyor workshop feedback

Following on from the AMS workshop we are keen to receive any feedback from attendees. Feedback ensures that AMSA can create workshops that are tailored to the needs of the industry.

The feedback period will remain open until Friday 5th of July. Click here to complete the survey.

You can also view full recordings of all 3 days of the workshop here.

Supporting AMSA’s ‘be electrically safe’ education campaign

Commencing in May 2024, and in alignment with the 2023/4 National Compliance Plan, AMSA has begun a ‘be electrically safe’ education campaign, with a focus on electrical fault and fire prevention. This campaign is not related to new regulations, but rather the reality that electrical installations and test records are among the top deficiencies identified during DCV inspections.

The purpose of this campaign is to raise awareness and educate DCV owners, operators and crew about the risk of fire from batteries and electrical installations on board vessels, and the importance of mitigating against and managing this risk as part of a vessel’s safety management system. 

As part of this campaign, a new AMSA webpage provides guidance surrounding common electrical hazards and recommended best practices. The information shared covers lead-acid batteries, lithium-ion batteries, portable device charging and wiring. 

AMSA encourages accredited surveyors to share these safety recommendations with DCV owners, operators and crew during inspections when electrical issues are detected and or discussed. 

Your support will assist AMSA in improving awareness of the campaign’s key messages, which aim to provide implementable actions that help, where needed, change behaviour over time.

Invisible gases, real risks

Toxic, explosive and highly flammable, hazardous gases can quickly accumulate on board a vessel when sources are not appropriately monitored, maintained, or managed.

Incidents involving prolonged, confined or highly concentrated exposure to gases are a serious concern and can cause death in a matter of minutes.  

When undertaking a survey, ensure you check sources of hazardous gases are well maintained, compliant and correctly stored.  

Hazardous gases are produced through waste or a by-product of operations such as sewage systems (hydrogen sulphide), CO2 cylinders (carbon dioxide) or combustion of fuels (carbon monoxide).  

Know the risks 

Survey Matters suggestions

AMSA wants to make sure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels.

We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications.

In this edition

• Draft instruction to surveyors now available – Ultrasonic thickness measurement for metallic vessels
• Do you know all your transitional requirements?
• Have your say on the proposed changes to SAGM Pt 2
• Stability booklets – Required loading conditions
• Conditions of specific exemptions and how they relate to survey
• Survey Matters suggestions

Read past editions

Draft instruction to surveyors now available – Ultrasonic thickness measurement for metallic vessels

AMSA has developed a draft instruction to surveyors (ITS) which outlines the processes and acceptable options for ultrasonic thickness measurement of metallic hulls required by SAGM Part 2 for a 10-year renewal survey.

The instruction provides information on the rationale for UTM as well as information on how to conduct a thickness measurement survey and acceptance criteria.

As part of the ITS development, AMSA welcomes any feedback from accredited marine surveyors on the form and content of the attached draft.

Any comments and feedback can be directed to dcvsurvey@amsa.gov.au, with ‘DCV-ITS feedback’ in the subject line. This will ensure that all feedback can be easily collected and collated.

Click here to access the draft DCV-ITS-021 UTM for Metallic Vessels.

Do you know all your transitional requirements?

Marine Order 503, Section 11 (g) requires an owner to notify AMSA of any changes to the vessel structure, arrangements, material or scantlings, including changes not mentioned in Schedule 1. Marine Order 503 Section 11 (h) states that a vessel must not be operated if a change in Schedule 1 occurs, and a vessel may only recommence operations if a new certificate of survey has been issued after meeting the survey criteria of Section 9 (1).

If the vessel is an existing vessel, and a change under Schedule 1 occurs, the vessel becomes transitional and it must meet either the NSCV standards, or the transitional standards listed in Schedule 2.

Regardless of whether surveys are only required to address the extent of the change under Section 9 (1), all the transitional standards now apply and there are certain mandatory upgrades that must be made.

AMSA uses the opportunity at transition to require these upgrades to be made to ensure vessels and personnel safety levels are brought in line with the objectives of the National System and contemporary safety standards.

As a minimum, the following upgrades must be verified against the transitional standards, regardless of the changes that trigger the transition:

• Fixed fire extinguishing and detection system as required by NSCV C4 must be installed
• Residual current devices are to be fitted in accordance with AS/NZS 3000 Electrical installations (already required for all vessels under state and territory law)
• LPG appliances & engines must comply with NSCV C5C & C5D respectively
• Intact stability must be reassessed with the person weight updated to meet the NSCV Part C6 requirements, and intact stability re-approved
• Safety, communications and navigation equipment must meet NSCV C7A, C7B and C7C respectively.

If you are engaged by an owner to undertake the surveys required under MO 503 Section 9, you should inform them of these additional requirements, as compliance may require modifications and upgrades to the vessel.

The surveyor who conducts the commissioning survey must complete the checklist for transitional vessels renewal survey on page 5 of the AMSA 901 - Survey report and recommendation form (or surveyors equivalent) confirming compliance.

Note: If the vessel has been assessed as a transitional vessel previously but has triggered again due to another Schedule 1 change, this checklist should be completed again by the commissioning surveyor.

Useful resources:

AMSA 241 - Marine Order 503 – Existing Vessel Transitional Vessel Concept Flowchart

Have your say on the proposed changes to SAGM Pt 2

AMSA is currently seeking feedback on proposed changes to the Marine Surveyor’s Accreditation Guidance Manual, Part 2 (SAGM Pt 2).

Background

SAGM Pt 2 sets clear standards and criteria for Accredited Marine Surveyors and Recognised Organisations (class societies), outlining the procedures for surveying domestic commercial vessels to ensure compliance with safety regulations and standards.

SAGM Pt 2 came into force on 1 July 2018 and has been the prescribed survey standard for more than 5 years.

Since the introduction of the manual, we have gathered valuable learnings and feedback, which we have now applied to enhance its clarity and effectiveness through these proposed revisions.

Key Changes

The following summarises some of the key changes in the draft document:

• Class 2 vessels used only for leisure type purposes, will be allowed to use the same CE certification as Class 4 vessels for structural approval
• Owners of medium-frequency survey vessels will be provided the flexibility to complete a year 3 survey either in water or out of water, and owners of high-frequency vessels will have flexibility to swap their year 2 and 3 surveys
• Alignment of construction documentation requirements for restricted C (EX40) vessels with risk levels, reducing the necessary documentation
• Clarification that Accredited Marine Surveyors may use their own reporting forms, provided these have the required level of detail 
• Inclusion of reporting obligations for repair and damage surveys
• Survey tables expanded to remove ambiguity and improve consistency and reliability in the survey processes 
• Various other minor changes

Further information

The below link takes you to the consultation page. On this page, you can find more information about the proposed changes including the draft standard and a summary of all the proposed changes.

An online information session is scheduled for Friday the 22nd of March. You can register your interest in attending at the link below.

Feedback is sought on the proposed changes. This link can also be used to provide your feedback using an online form. The consultation process closes at midnight on the 2nd of April 2024. Please ensure all feedback is provided by this date.

Click here to access the consultation hub.

We encourage everyone to review the proposed changes, attend the information session and provide us your feedback.

Stability booklets – Required loading conditions

AMSA audits accredited marine surveyors to ensure the correct procedures and protocols set out in the National Law - Marine Surveyors Accreditation Guidance Manual (SAGM) and the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the regulations) are being implemented.

AMSA regularly performs audits related to stability approvals from accredited marine surveyors (AMS). Most of the submissions from accredited surveyors are found to be compliant and many positive observations are noted.

However, during recent audits, findings regarding the extent of loading conditions presented in stability booklets have become common. Rather than just demonstrating compliance with the applicable stability criteria, AMS are encouraged to focus on providing clear guidance to an operator for them to be able to operate the vessel within the allowable limits. Below is some guidance on how to identify what loading conditions to include in stability documentation.

NSCV requirements

It is a required outcome of NSCV C6A for the intact stability to be safe over the range of foreseeable conditions of loading. Clause 2.2 states:

Note 1 clarifies the extent of the term “foreseeable conditions”.

Requirements for the form and content of a stability booklet are found in the National Standards for Commercial Vessels (NSCV), Section C6C, Annex F. This annex details all the information required to be included in the stability book and is a normative (compulsory) part of the standard (see also December 2019 edition of Survey Matters).

Clause F5 / Table F1 of Annex F outlines the required contents of a stability book and points to clause F9 for the loading conditions. Clause F9 stipulates that a range of loading conditions be presented in the stability book and highlights the need to include any loading conditions that may have marginal stability characteristics (worst case scenarios). It also includes an important note about consulting with the operator to ensure the loading conditions of all intended operations have been assessed. Table F.3 outlines the standard departure and arrival loading conditions applicable to all vessels, and Table F.4 includes the minimum vessel-specific loading conditions to be included in a stability book. It is important to note that Table F.4 requires all vessels to include a lightship condition.

Importance

Vessels may vary significantly in design and operation and there may be additional conditions over and above the minimum requirements that must be analysed to ensure all limiting conditions have been identified. For certain vessels the limiting conditions may be readily identifiable, however, they may not be so clear for other vessels that, for example, are variably loaded (vertically, longitudinally and transversely); have movable ballast; have lifting and grounding effects; have multiple consumables tanks; or have tracked or wheeled plant loaded from the shore.

By analysing the full range of loading conditions and looking in detail at activities that can impose additional heeling moments on the vessel, all potential operating profiles are analysed prior to the vessel entering service. Worst-case loading conditions (limiting conditions) must be identified by the surveyor (preferably in collaboration with the operator) and guidance addressing these conditions must be included in the stability book in accordance with clause F9.

Conditions of specific exemptions and how they relate to survey

Specific exemptions (SPEXs) may have conditions imposed to ensure the safety of the vessel or its occupants. These conditions can relate to the operation of the vessel, its equipment, or its design. The legal onus to ensure these conditions are met is placed on the owner, the master or both. This is due to the way the National Law is written whereby it is a strict liability offence for an owner or master to breach a condition of an exemption (Sections 144 and 145). For many smaller vessels the owner is also the master, but this is not always the case – particularly for larger fleet vessels.

Surveyor’s obligations during survey

In accordance with SAGM, a surveyor is required to verify that a vessel complies with applicable legislation, exemptions, and standards. This means that as part of any survey (initial or periodic), if a SPEX has been granted to the vessel, there may be certain conditions that must be verified by a surveyor as part of the survey process.

Surveyors should ascertain whether a vessel is subject to a SPEX and consider whether any conditions listed on the SPEX must be considered as part of the survey process. If the vessel has a SPEX and is undergoing periodic or renewal survey there will be a note on the face of the CoS and the SPEX will also be indicated in the Vessel Report. The owner is required to keep a copy of the SPEX with the Certificate of Survey.

Conditions relating plan approval

If the vessel is undergoing plan approval and a CoS is yet to be issued, the surveyor should consult the owner for a copy of any SPEXs granted by AMSA.

Conditions relating to vessel design will generally be directed to the owner but will require that certain things be verified by a surveyor on the owner’s behalf during the plan approval phase. Examples of conditions pertaining to vessel design are as follows:

• The owner must ensure that the vessel’s structure meets the requirements of ISO12215 for an ISO category B vessel.
• The owner must ensure the vessel complies with single compartment subdivision with the collision bulkhead damaged.

Conditions relating to construction surveys

Some SPEXs contain conditions that must be verified by a surveyor during initial construction survey but would not require ongoing verification once the CoS is issued. The conditions will generally be directed to the owner and require verification by a surveyor on their behalf. Examples of conditions pertaining to vessel construction are as follows:

• The owner must ensure the minimum height of the bulwarks/guardrails is 850mm
• The owner must ensure the power of the propulsion engine does not exceed 450kw
• The owner must ensure that the width of the crew stairs between the main deck and wheelhouse is no less than 585mm.

Conditions relating to commissioning and periodic surveys

If the vessel is undergoing commissioning survey and a CoS is yet to be issued, the AMS should consult the owner for a copy of any SPEXs granted by AMSA. If the vessel has a SPEX and is undergoing periodic or renewal survey there will be a note on the face of the CoS and the SPEX will also be indicated in the vessel report. The owner is required to keep a copy of the SPEX with the certificate of survey. These conditions will either be directed to the owner, or to both the owner and master.

Examples of conditions pertaining to commissioning and periodic surveys are as follows:

• The owner and master must ensure that an additional 4.5kg ABE fire extinguisher is carried.
• The owner and master must ensure that an additional portable powered 11kL/hr bilge pump with wandering hose is provided onboard.
• The owner must ensure that signage is provided on either side of the watertight door stating “MUST BE CLOSED AT SEA”.

Reporting

Surveyors can make a comment on the AMSA901 form (or equivalent) listing the items relating to a condition of a SPEX that have been verified as part of their survey. Alternately a separate report can be compiled, listed as supporting documentation on the AMSA901 (or equivalent), and uploaded into MARS. The benefit of a separate report is that photographic evidence can be provided which is encouraged by AMSA for transparency (SAGM 2.6), and we recommend this in particular for initial commissioning surveys.

Survey Matters suggestions

AMSA wants to make sure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels. 

We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications.

In this edition

• Audits and application assessments
• Compass adjustment requirements
• Uncrewed barges
• Electrical components must be approved for use in Australia
• Electrical plan approval
• Operational policy for large commercial yachts operating under the National Law
• Specific exemptions
• Important notice regarding 10-year surveys for accredited marine surveyors
• AMSA586 Survey activity report and temporary operations
• Photographs provided as supporting documentation
• Season's Greetings

Audits and application assessments

Summary of audits 2022-23

Sec 45 of the Marine Safety (Domestic Commercial Vessel) National Law Act 2012 provides that AMSA as the National Regulator can conduct audits on the recommendations made by an accredited surveyor; the survey process followed by the surveyor; the conduct of surveys; and the records kept in accordance with Section 40.

In the 2022-23, financial year AMSA carried out scheduled audits on 162 survey recommendations covering 20 accredited marine surveyors (AMSs) under the Major Audit Program. The surveyors were selected for audit from AMSA’s Surveyor Risk rating tool. Of these, 10 surveyors were audited on initial surveys (mainly on plan approval stability approval and initial commissioning surveys), and 10 were audited on periodic surveys (periodic surveys, out of water surveys, shaft surveys and periodic load line surveys). 18 of these audits resulted in the AMS initiating corrective actions on their survey practices and / or on the vessels in question. One surveyor was required to show cause as to why their accreditation shouldn’t be suspended.

AMSA also conducted 37 complaint audits regarding 23 surveyors. The audits were based on complaints received from a member of the public or an AMSA port marine surveyor / marine safety inspector. These audits resulted in 3 surveyors being issued with formal caution or counselling letters; a surveyor’s accreditation varied to impose conditions for stricter survey reporting requirements; and a surveyor’s accreditation being revoked by the National Regulator.

On-site monitoring surveys were also successfully performed for 2 surveyors.

Audit findings

Major audits have resulted in 342 findings, of which 31 (22%) of them were non-conformances requiring corrective actions. AMSA also noted positive findings for several surveyors. The below pie chart shows the percentage distribution of the findings for the major audits.

Complaint audits have resulted in 73 findings of which 44 (60 %) were non-conformances The pie chart below shows the percentage-wise distribution of the findings for the complaint audits.

Common findings in periodic / renewal survey audits 2022-23

Following are the common findings identified during the periodic / renewal survey audits.

1. Vessels with several serious deficiencies were recommended for temporary operations following a renewal survey (e.g. structural fire protection material damaged).
2. Vessels were recommended with inadequate communication equipment onboard. (e.g. vessel trading outside LCS coverage areas without an H.F radio or satellite phone).
3. Vessels were recommended with incorrect lifesaving appliances. (missing life rafts, lifejackets etc.)
4. Class 1 vessels over 12 meters were recommended without performing a lightship verification and a declaration signed by the owner or master was provided instead. SAGM Sect 4.9 (6) limits lightship declarations on Class 1 Vessels to those less than 12m.
5. Incorrect lightship particulars were recommended when the correct lightship particulars would have triggered transitional surveys.
6. Temporary operations permits had been issued for several vessels despite the conditions of Div. 5 or 6 of AMSA EX07 (Marine safety temporary operations) Exemption not being met.
7. Third party service reports referenced in the form AMSA 901 Survey report and recommendation were not provided in the recommendation.
8. Megger testing and RCD testing were not carried out in the specified intervals.
9. Ultrasonic thickness measurement not carried out for metallic vessels during the 10-year renewal survey.
10. Other 10-year renewal survey checks were not carried out.

Compass adjustment requirements

Ensuring the accuracy of a vessel's magnetic compass is crucial for safe navigation at sea. Marine Order 504 (Certificates of operation and operation requirements) mandates a systematic approach to vessel and equipment maintenance. The magnetic compass is one such piece of equipment. Vessel owners are required to establish a regular inspection and maintenance program, recording details of each inspection and addressing identified deficiencies. These records may be maintained in the vessel's logbook.

For transitional and new vessels NSCV Part C Section 7C specifies that the master must document any observed deviations in compass readings during the vessel’s operation. Section 7C also specifies situations in which compass adjustment is mandatory. These include when deviations exceed 5 degrees, after vessel repairs or alterations, or when the vessel has not previously operated from any port or place in Australia.

The adjustment should be carried out by individuals possessing the necessary knowledge and skills obtained through experience, training or qualification.  A qualified compass adjuster for Marine Order 27 (Safety of navigation and radio equipment) 2016 meets the training and qualification requirements of NSCV C7C Clause A4.3.

Furthermore, any changes to the magnetic compass including alterations to magnet positions or soft iron correctors must be recorded by the compass adjuster and the record kept onboard. This rigorous adherence to compass adjustment requirements ensures the reliability of navigation systems and promotes maritime safety and compliance.

Existing vessels must comply with the requirements that applied to them at the introduction of the National System - generally the USL Code Section 13 Appendix B. The requirements of the USL Code for compasses are largely consistent with those of the NSCV. 

Uncrewed barges

AMSA has received enquiries about uncrewed barges being transferred into domestic commercial vessel survey while carrying people onboard. Uncrewed and unpowered barges certified under the International Convention on Load Lines 1966 (ICLL) may have a 25% reduction in their assigned summer freeboard, as per Regulation 27(14)(c) ICLL.

This reduction applies specifically to uncrewed, unpowered barges with small access openings sealed by watertight gasketed covers of steel or equivalent on the freeboard deck. (most commonly flat-topped barges). ICLL Regulation 27(14)(b) exempts these barges from complying with Regulations 25, 26(3), 26(4), and 39.

Similar requirements under ICLL Regulations are outlined in:

• USL Code Section 7 Clauses 23, 42, 46.4.
• NSCV C2 Chapter 3 for Class 1 and 2 vessels with a load line length of 24 m or more in offshore waters.

As per GES 2022/01, a domestic commercial vessel with a load line length of 24m or more can adhere to either USL Code Section 7 or NSCV C2. For an unpowered barge initially certified to ICLL as uncrewed but intended for operation with people on board, additional freeboard assignment and possible extra markings are required.

Specific load line requirements for sheltered waters operations, as outlined in USL Code Section 7 Part 11 or NSCV C2 Chapter 5, may be applicable based on the intended operation of the vessel.

Electrical components must be approved for use in Australia

An enquiry has been received in relation to vessels being built overseas that intended to include electrical components such as circuit breakers and RCBO units that were not approved by Australian Standards.

Electrical contractors must not install Type AC RCDs after 30 April 2023.

In accordance with AS3000 amendment 2, Type AC RCDs are not to be installed in Australia after 30 April 2023. Type AC Residual Current Devices (RCDs) have been widely used and are effective for tripping sinusoidal alternating currents. However, due to the growing use of electronics, renewable energy, and other technologies, there's a rise in direct current (DC) waveforms appearing on the alternating current (AC) supply.

To address this, AS/NZS 3000:2018 Amendment 2 requires the use of Type A RCDs. These devices can trip both sinusoidal alternating currents and pulsating direct currents.

Amendment 2 also mandates that RCDs placed next to or built into a socket-outlet must interrupt all live (active and neutral) conductors.

Surveyors must be aware that all electrical components need to be approved for use in Australia.

Electrical plan approval

AMSA has recently received several applications featuring solar charging and/or lithium-ion battery ELV installations. These installations are deemed to be “complex ELV systems” under SAGM Table 2 and require additional consideration than standard ELV installations.

The schematics for complex ELV installations require plan approval by a recognised organisation (RO) or an AMS accredited for electrical plan approval.

Solar array installation requires additional licensing for land-based installations. In the absence of an equivalent accreditation category for DCV installations, AMSA requires owners or builders to engage the services of a solar array installer who is licensed in the state or territory where the vessel is located. The attending AMS must obtain an installation certificate from the installer to be used as 3rd party documentation to support their recommendation for survey. The installer must declare that the installation has been carried out in accordance with the approved schematics.

Installations incorporating lithium-ion batteries must be verified against the approved schematics by the attending AMS. The AMS must consider the location of lithium batteries to ensure that in the event of a thermal runaway there are no additional risks to onboard safety.

Operational policy for large commercial yachts operating under the National Law

AMSA receives numerous exemption applications for yachts originally built to foreign flag requirements and now seeking domestic certification within Australia. To assist industry in these circumstances AMSA would like to clarify its specific exemption assessment policy for yachts.

AMSA will consider issuing a specific exemption (from the vessel and equipment standards mentioned in Marine Order 503 (Certificates of survey - national law) 2018)) for yachts which are intended for operation as domestic commercial vessels under the National Law. Generally, such an exemption will be conditional upon the surveyor of the vessel confirming the vessel and its equipment, meet the standards set forth within Marine Order 52 (Yachts and training vessels) 2022. These standards currently being the Red Ensign Code (the Code) and Australian National Annex to the code.

The Red Ensign Code and Australian Annex are internationally recognised standards for yacht safety. This approach ensures that the vessels maintain a high level of safety while also considering the unique needs of yachts in comparison to other commercial vessels.

The policy not only ensures that safety remains a top priority but also simplifies the regulatory process, allowing for a smoother transition for those wishing to operate their yachts as domestic commercial vessels.

Will AMSA consider other approaches?

All specific exemption applications are considered on a case-by-case basis, considering policies that are relevant to the decision, as well as the specific circumstances of an application.

Does AMSA accept foreign flag state / historical certification?

The National Law requires that recommendations be provided by an accredited marine surveyor (AMS) or recognised organisation (RO). The AMS or RO are responsible for assessing the vessel and ensuing it complies with the applicable standards. Previous class certification and or foreign flag certificates do not constitute a recommendation in and of themselves.

Does the yacht need to be classed?

For Yachts under 35 metres, surveys do not have to be conducted by a recognised organisation, and a certificate of class is not required. This policy is intended to reduce the regulatory burden on owners of smaller yachts while still ensuring that they operate safely in Australian waters.

Specific exemptions

AMSA has been receiving requests for exemption from certain areas of the standards that have not been substantiated in accordance with the exemption policy. The exemption policy states that cost or inconvenience is not a legitimate reason to grant an exemption.

It appears that a culture is emerging where, if an owner is reluctant to undertake modifications to their vessel to achieve compliance with the applicable standards, the AMS is encouraging them to apply for exemption. Many of these exemption applications do not meet the exemption policy and are being refused, resulting in administrative costs and time delays to the initial survey process.

• Following are some examples of exemption refusals in 2023:
• Non-compliant fuel tank plating thickness.
• Non-compliant bilge piping in an engine space.
• Non-compliant railings on a houseboat.
• Requirement for fixed fire detection and extinguishing systems.
• Shared fuel tank vents.
• ELV pump in petrol tank cofferdam.
• Structural fire protection in-way-of vehicle deck on Ro-Pax ferry
• Requirement for a vessel to be classed.
• Application of transitional standards for a vessel out of survey for more than 2 years.
• Structural Fire Protection of fuel tanks in an engine space.
• Lightship check / Stability review of a Class 1 vessel Lm>12m.
• Use of Structural Fire Protection in applications not covered by its type approval.
• We strongly encourage AMS’s to strive for compliance with the standards in the first instance, and to inform owners that cost or inconvenience is not an acceptable reason to apply for exemption.

Important notice regarding 10-year surveys for accredited marine surveyors

AMSA has received numerous enquiries from accredited marine surveyors seeking assistance to determine whether vessels are due for their 10-year surveys. In response, AMSA recommends obtaining the vessel report either directly from the client or by downloading it from MARS.

To identify if a vessel has undergone 10-year renewal surveys or partially conducted 10-yearly surveys, please refer to the "Notes/Observations from 10-year renewal survey items" section at the bottom of the vessel report. This section will display relevant information, including the date/s of survey reports and the type of survey conducted.

If the vessel has not completed 10-year survey components, the vessel report will not contain any information in these fields, and hence will not be included. Below is a screen shot of what will appear on a vessel report when a 10 yearly survey has been performed.

Notes / observations from 10 Year renewal survey

AMSA586 Survey activity report and temporary operations

AMSA has been receiving AMSA586 survey activity reports where the use of the temporary operations provision under Exemption 7 Division 6 has been incorrectly applied by the accredited surveyor.

Some examples of erroneous 586 forms include reports where the temporary operations sections are incomplete; not all surveys have been completed; or the reports have been submitted more than 90 days after expiry of the Certificate of Survey. This exposes owners and operators to potential compliance action.

Exemption 07 Division 6 can only be applied when the following conditions are met:

The vessel has held the CoS previously and not been suspended or revoked, and

An application has been made to renew the CoS 180 days before, or up to 90 days after its expiry, and

All renewal surveys (OWAT / PRDC / LTE / SHAFT) have been conducted within 180 days before, or 90 days after CoS expiry, and

The vessel only has minor non-conformances and the accredited marine surveyor issues a signed 586 form to the operator and AMSA stating what the non-compliances are, and the associated standards that apply.

When all of the above conditions are met an owner or operator can operate under Exemption 7 Division 6 as per below:

The exemption begins when the AMS gives the signed 586 report to the owner and AMSA, and

Ends 120 days after the CoS initially expires or when AMSA issues the CoS, and

The owner must keep a copy of the AMSA586 on the vessel.

Photographs provided as supporting documentation

SAGM 2.9.2 encourages AMS’s to use photographs as supporting documentation for their surveys. We see good use of this from many surveyors, however, some MARS assessments have multiple single photos uploaded without a naming convention.

We encourage you to seek software that combines multiple photos into a single pdf so that only one file is uploaded (provided it is less than 20Mb in size). We also encourage you to get in the habit of taking a macro photo showing the overall location of an item to compliment a detailed photo of the item you wish to highlight. Ideally these photos would be annotated with a description.

Season's Greetings

The AMSA team would like to wish all our readers a Merry Christmas.

Thank you for your valued relationships and collaboration. We hope everyone has a safe and peaceful Christmas and new year period.

The DCV Applications team remain on deck to process temporary operation applications lodged between Christmas and the New Year. Normal services will return on the 2nd of January 2024.

In this edition

• Focused certification campaign 2023-24
• Guidance for recognised organisations making initial survey recommendations
• Electrical matters
• Updates to Exemption 44 
• NTSB Report – doubler-plated hull repairs
• Changes to operational safety requirements

Focused certification campaign 2023-24

AMSA will conduct a focused certification campaign for the 2023-24 financial year, focusing on plan approval documentation and fire safety.

As mentioned in the November 2022 edition of Survey Matters, incomplete survey process and fire safety non-compliance are two significant reasons for refusal of certificate of survey applications.

The campaign will see AMSA conduct focused assessments on high-risk vessels, to confirm structural fire protection (SFP) and fixed firefighting systems are compliant, as well as reviewing plan approval letters in greater detail.

Plan approval letter content

The saying "failing to plan is planning to fail," rings true in the context of design appraisal in the maritime industry. As stipulated by the Surveyor Manual (SAGM Part 2), plan approval letters play a pivotal role in maintaining safety, compliance, and transparency throughout the survey process. For new construction and modification projects, these documents facilitate a smooth and streamlined process. 

Despite their significance, AMSA frequently receives plan approval recommendations that lack the necessary plan approval letters or inadequately describe the applied standards or survey processes. This causes delay in application processing, adversely affecting your customers.  

Plan approval letter(s) must comprehensively describe the process applied to the vessel, including the applicable standards, examined drawings, scope of your plan appraisal, comments, and outcomes. For transitional vessels, please specify the vessel changes that invoke the transitional standards. The SAGM Part 2 clause 3.9.2. provides the requirements for plan approval documentation.

Before submitting your plan approval letters, ask yourself: Could a third party with no background knowledge of the vessel comprehend the entire process you have applied? Or would they conclude that only a partial survey, such as an NSCV C3 or machinery NSCV C5A review, has been conducted? 

Ensure your plan approval letters are clear and thorough. This reduces the likelihood of an incomplete survey process and enhances the vessel certification process.

Fire safety items

Fire is a serious issue that can lead to catastrophic results. In 2021 the US passenger vessel Conception caught fire resulting in the total loss of the vessel and the loss of 34 lives.

Design controls such as fire detection, alarm, fire protection and escape and evacuation routes may have prevented this tragedy. An investigation of the event found that the escape and evacuation routes and alarm systems did not enable persons to escape from their sleeping quarters before the fire developed.

Similarly in Australia, significant fires have occurred in the last 5 years which resulted in total vessel loss. For example, the catamaran vessel 1770 was a total loss after an engine room fire. Investigations concluded that incorrect fitment of structural fire protection allowed the fire to spread through the vessel’s tunnel to an adjacent space. Whilst this event did not result in the loss of lives, 19 persons were hospitalised.

The April 2020 and September 2021 editions of Survey Matters provided a detailed analysis of AMSA’s requirements for structural fire protection onboard vessels of steel, aluminium, and composite construction, as well as the expected documentation to support recommendations.

In addition to the provision of structural fire protection, many vessels are required to be fitted with fixed fire-extinguishing systems. As part of the focused certification campaign, AMSA will be expecting confirmation that the fixed fire-extinguishing systems conform to the acceptable standards outlined in Table 14 of NSCV Part C Section 4.

Guidance for recognised organisations making initial survey recommendations

When a vessel is classed with a registered organisation (RO) and intends to operate as a domestic commercial vessel (DCV), an application for a certificate of survey is required. The operator will be sent a letter containing a list of surveys which are to be completed and recommended by an Accredited Marine Surveyor (AMS) or an RO surveyor.

While documentation that shows a vessel was built in accordance with class rules demonstrates compliance with some aspects of the National Law, it does not cover all the requirements. The owner must ensure the aspects that are not covered by its certificate of class are surveyed. An owner can employ an independent AMS to survey those aspects on vessels less than 35m long, however it is common for the RO to complete all the initial surveys for a vessel.

Further information and detailed instructions can be found in Chapters 3 and 5 of the Marine Surveyor’s Accreditation Guidance Manual (SAGM) Part 2 or via the initial certificate of survey applications page on the AMSA website.

What is covered by a certificate of class?

A certificate of class is accepted by AMSA as evidence that the vessel complies with the following aspects of initial survey:

• Hull structure (NSCV Part C3)
• Machinery (NSCV Parts C5A, and C5C*)
• Electrical (NSCV Part C5B*)
• Anchoring (NSCV Part C7D)

*There are state laws relating to electrical and LPG systems that apply to domestic commercial vessels. For some installations a state certificate of compliance is required. It is therefore recommended to have electrical installations (LV and above) and LPG installations inspected by a suitably qualified and licensed technician within Australia, and to submit any reports and certificates as part of the initial survey application.

What is not covered by a certificate of class?

The following parts of the NSCV need to be specifically addressed as they apply to the vessel for plan approval, construction, and commissioning phases of initial survey, in addition to the classification component above.

• Arrangement, accommodation, and personal safety (NSCV C1)

The requirements of NSCV C1 are often missed by ROs in the plan approval survey, as they are not covered by a certificate of classification. NSCV C1 includes requirements for bridge visibility, navigation lights, passenger and crew accommodation, stairways and ladders, escape and evacuation routes, and personal protection, amongst other things. It reflects statutory requirements drawn from a number of international conventions and other legislation and forms an essential part of the NSCV.

The initial plan approval (PLAN) survey will need to address NSCV C1 requirements. The general arrangement, navigation light, fire & safety, and other arrangement drawings should be assessed by a plan approval surveyor for compliance. Reference to the C1 standard must be included in the plan approval letter submitted with approved copies of the drawings as per SAGM Part 2 Chapter 3.9.2.

• Watertight and weathertight integrity (NSCV C2)

NSCV C2 (Watertight and Weathertight Integrity) came into force on 01 January 2023, however there will be a transitional period of 3 years allowing initial survey vessels to comply with either NSCV C2 or the USL Code sections 5C, 5D and 7. The initial watertight and weathertight integrity (IWWI) survey will need to address NSCV C2 or equivalent requirements.

For vessels ≥ 24 metres that would otherwise be subject to the requirements of the International Convention on Load Lines, AMSA will accept a previous international load line certificate or a document of compliance as evidence that the vessel complies with the domestic standard. In such cases, a copy of the certificate or document of compliance, and a copy of the record of conditions of assignment should be submitted as supporting documentation.

• Fire safety (NSCV C4)

While class rules may address fire safety, and form part of any new construction or transfer of class surveys, a certificate of class is not accepted by AMSA as evidence that the vessel complies with NSCV C4 (or the relevant marine order, dependent on vessel size). The initial plan approval (PLAN) and initial fire (IFIR) surveys will need to address NSCV C4 requirements for passive and active fire protection, additional measures relating to machinery, accommodation, galley, control, cargo, ro-ro, and helideck spaces, and dangerous goods (as applicable).

Particular attention should be paid to structural fire protection requirements, as these may differ to other national or international standards. The vessel’s structural fire protection and fire & safety drawings should be assessed by a plan approval surveyor for compliance with the standard. Reference to the standard must be included in the plan approval letter submitted with approved copies of the drawings as per SAGM Part 2 Chapter 3.9.2.

• Stability (NSCV C6A, C6B and C6C)

As with fire safety, class rules may have requirements relating to stability that form part of the new construction or transfer of class surveys, however a class-approved stability book is not automatically accepted by AMSA as evidence that the vessel complies with the three parts of NSCV C6. The requirements for intact stability (C6A) and damaged stability (C6B) differ from those of the Intact Stability (IS) Code and other conventions that relate to intact and damaged stability. For this reason, the vessel’s stability characteristics should be assessed by a plan approval surveyor for compliance with the NSCV, and reference to the standards included in a plan approval letter submitted with a copy of the approved stability book.

• Safety, navigation, and communication equipment (NSCV C7A, C7B and C7C)

The installation of safety, navigation and communications equipment as required in the NSCV (or the relevant marine order, dependent on vessel size) is usually confirmed by the attending surveyor when undertaking the commissioning survey (COMM). The equipment to be carried will depend on the number of persons onboard and the operational area of the vessel and may differ to international convention requirements. Please note that the maximum number of persons that can be carried onboard (as shown on the certificate of survey) and the area of operation may be limited by the provision of equipment, therefore it is important that the surveyor who completes and recommends the commissioning survey understands what the proposed domestic operations are.

What documentation to submit to AMSA?

The Marine Surveyor’s Accreditation Guidance Manual (SAGM) Part 2 Chapter 5.4 gives a list of documents to be submitted by an RO to cover those aspects for which classification is accepted, i.e., hull structure, machinery, electrical, and anchoring.

For aspects that are not covered by classification, the list of plans and supporting documents given in Chapter 3.9.2 and Table 2 can be used as a guide. A plan approval letter that addresses the parts of NSCV C1, C2, C4, and C6 that apply to the vessel, and referring to the relevant vessel plans, must be submitted with copies of the approved plans and documents.

Which AMSA forms to complete?

AMSA has produced forms that relate to each survey code to enable easier reporting of surveys. Annex 1 of SAGM Part 2 gives a reference table of forms that relate to each survey code. The forms can be downloaded from the AMSA website here.

Surveyors may also make their recommendations on their own equivalent forms if all the same information is provided.

How to submit?

Surveyors from recognised organisations can arrange for access to the MARS online system by contacting OSS@amsa.gov.au. MARS enables surveyors to upload survey reports and supporting documents directly to AMSA resulting in applications being processed faster.

AMSA no longer uploads reports on behalf of surveyors, other than for electrical surveys. If the RO is submitting electrical survey reports on behalf of a licensed electrician, these can be emailed directly to dcvapplications@amsa.gov.au.

Electrical matters

Vessel explosion 

In December 2022 an explosion occurred on the vessel pictured below while at anchor. The explosion may have been caused by lithium-ion batteries reaching thermal runaway within an enclosed space.

Fortunately, no one was onboard at the time and no injuries were reported.

You can read more about lithium batteries and the associated hazards in the January 2020 edition of Survey Matters.

Overcharged lead acid batteries 

The batteries pictured below were recently removed from a sailing catamaran after the owner noticed strange things happening with the vessel’s power.

The electrical surveyor reported that an incorrect charger was being used and the batteries were constantly left on charge.

As well as the batteries being replaced, the charger was replaced with one suited for maintenance charging.

Extra low voltage solar photovoltaic (PV) systems

WorkSafe QLD recently published an article about the risks of working on solar PV systems following the electrocution of a person modifying solar panels on an off-grid system.

Read the eSAFE article on the WorkSafe QLD website for more information and issues to consider.

UK Maritime and Coastguard Agency guidance – Small electric powered craft on yachts

Following an increase in fires on yachts, The United Kingdom Maritime and Coastguard Agency has published a guidance notice regarding fire safety and storage of small electric powered craft on yachts.

The guidance is available on the UK MCA website here.

Updates to Exemption 44 

A revised Exemption 44 – Marine Safety (Domestic commercial vessels – EIAPP Certificate) 2023 (EX44) has been published. 

EX44 exempts DCVs from the requirement in Marine Order 503 to hold an Engine International Air Pollution Prevention (EIAPP) Certificate to be issued a certificate of survey. 

It is important though to note that EIAPP certificate requirements still apply to some DCVs through Marine Order 97 (MO97). MO97 requires DCVs to have on board an EIAPP certificate and associated Technical File for each marine diesel engine over 130kW that is installed or that undergo a major conversion after 31 December 2022. However, this requirement is not linked to the criteria for a DCV to be issued with a certificate of survey. 

AMSA is writing to Australian marine diesel engine suppliers to strongly urge them to secure the required certification prior to the importation of engines to Australia, where relevant, and otherwise at the time the engine is tested by the manufacturer for NOx compliance. This will help avoid unnecessary delays and costs. 

NTSB Report – doubler-plated hull repairs

The United States National Transportation Safety Board (NTSB) recently released its report into the loss of the fishing vessel Grace Marie in July 2022. The report focuses on the failure of the doubler-plated hull under the engine room as the likely cause of the incident. The 7 crew members on board were rescued and no injuries were reported; however, the total loss was valued at $650,000. 

The full report is available via the NTSB website. 

Changes to operational safety requirements

On 1 August 2023, a series of changes to Marine Order 504 (Certificates of operation and operation requirements) came into force which follow extensive consultation with industry to improve operational safety outcomes.  

The changes broadly relate to risk assessment – in particular, the wearing of lifejackets, crewing and safety management system requirements under Marine Order 504.  

While these changes won’t impact the important work of accredited marine surveyors, they may come up in conversation with domestic commercial vessel owners and operators.  

As such, please encourage vessel owners and operators to seek guidance from AMSA’s information hub.  

Below is a summary of the changes:  

• Crewing provisions will better align with the certificate of competency arrangements in the revised Marine Order 505 (Certificates of competency) which came into force on 1 January 2023. The minimum crewing requirements table in Marine Order 504 has also been simplified.  
• Sufficient rest (a minimum of 10 hours in every 24-hour period) must be adequately addressed when determining risk-based crewing levels.  
• Risk assessment (including the appropriate crewing determination) must be accessible to the master, crew and marine safety inspectors.  
• The master and crew (if applicable) must be consulted on the development of the vessel’s risk assessment.  
• A copy of the vessel’s safety management system must be kept onboard (if practical) and with onshore personnel.  
• Additional onboard training and drills will become a requirement for emergency procedures which must be addressed in the vessel’s safety management system, and associated record-keeping must be undertaken.  
• There must be clear and direct reporting pathways for the escalation of issues to the designated person, these must be understood by crew and master and incorporated into the safety management system, which must be working as intended.  
• Lifejacket wear must be addressed in the vessel’s risk assessment and a written procedure must be included in the safety management system.  

Vessel owners and operators should be encouraged to review and reassess their safety management system, crewing determination, and risk assessment to ensure they meet the new requirements.  

Please refer vessel owners and operators to the information hub on AMSA’s website where they can find examples, checklists and step-by-step guidance.