News and information for accredited surveyors in Australia.

Survey Matters—March 2020

In this edition we talk about survey procedures to verify radio installations on some vessels, we give tips for conducting a load line renewal survey, talk about simple exemptions and more.
20 March 2020
In this edition we talk about survey procedures to verify radio installations on some vessels, we give tips for conducting a load line renewal survey, talk about simple exemptions and more.
Last updated: 24 April 2020

Survey Matters—January 2020

In this edition we explain what is meant by reporting deficiencies ‘as soon as practicable’; we talk about exemption 40 stability documentation, describe and explain different types of lithium battery and more.
15 January 2020
In this edition we explain what is meant by reporting deficiencies ‘as soon as practicable’; we talk about exemption 40 stability documentation, describe and explain different types of lithium battery and more.
Last updated: 24 April 2020

Survey Matters—December 2019

In this issue we bring you information about a new electrical standard, welding requirements for some vessels, how many watertight doors the NSCV allows and more.
14 December 2020
In this issue we bring you information about a new electrical standard, welding requirements for some vessels, how many watertight doors the NSCV allows and more.
Last updated: 24 April 2020

Survey Matters—August 2020

In this edition we explain the criteria for issuing temporary permits under exemption 7, we give details of the reports that are needed when a regulated Australian vessel becomes a domestic commercial vessel, we give you a handy tour of the AMSA organisation, and more.
11 August 2020
In this edition we explain the criteria for issuing temporary permits under exemption 7, we give details of the reports that are needed when a regulated Australian vessel becomes a domestic commercial vessel, we give you a handy tour of the AMSA organisation, and more.
Last updated: 14 November 2023

Survey Matters—April 2020

In the April edition we tell you what we are doing to support our industry during the COVID-19 period, we provide information about passive fire safety measures, give guidance on inspecting internal buoyancy or sealed internal hull voids, and more.
28 April 2020
In the April edition we tell you what we are doing to support our industry during the COVID-19 period, we provide information about passive fire safety measures, give guidance on inspecting internal buoyancy or sealed internal hull voids, and more.
Last updated: 14 November 2023

Survey Matter—September 2021

In this edition

Audits and application assessments

AMSA audits recently 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 followed. These audits identify issues that may arise in the early stages of a surveyor's activity.

Observations and non-conformances will be provided in writing to the surveyor for action.

Audits also occur because of complaints received or non-conformances detected during our assessment of survey applications. The three cases below are examples where major non-conformances were identified.

A certificate of survey application for a new build 2B vessel was refused when several major non-conformances were identified. The non-conformances included, but were not limited to:

  • The vessel was fitted with non-compliant structural fire protection material
  • The fuel tank did not comply with NSCV C5A 
  • The damaged stability did not comply with NSCV C6B
  • The vessel was fitted with a stepped collision bulkhead that does not comply with NSCV C6B 7.3.6
  • The stability documentation was missing critical detail and did not comply with NSCV C6C.

The surveyors involved were counselled for contravention of conditions of accreditation. The vessel has since undergone modifications and a new application for a certificate of survey has been submitted.

An AMSA inspection identified a 3B vessel had undergone a major refit. The vessel had permanent ballast removed and major hull and structure replacements were carried out. Fish linings, tanks and freezers were also removed, and the vessel’s stability needed to be reassessed. The accredited surveyor made an error in assuming these works could be undertaken as a renewal survey instead of an initial survey to the transitional vessel standards.

The vessel’s certificate of survey was suspended without a show cause notice as there was clear intention to operate the vessel without a revised stability assessment. The vessel remains unable to operate without contravening S11(1) (h) of Marine Order 503, pending an initial survey.

The accredited surveyor was issued a notice of decision letter refusing a further time period to renew their accreditation under the National Law. The surveyor had failed to apply to renew their accreditation within the timeframes set out by the regulations. The surveyor is no longer accredited after they chose not to submit an initial application and undergo an interview.

AMSA conducted inspections on two 2C sister vessels after receiving a complaint. Major non-conformances were identified following a physical practical stability test of the vessels.

The surveyor had initial survey categories revoked following an audit and show cause process. The certificates of survey were revoked for both vessels, and the owner has settled a claim against the builder and surveyor involved.

Submission of survey reports

AMSA will stop receiving emailed survey reports from 1/12/2021. This means accredited marine surveyors and Recognised Organisation surveyors need to submit their reports and recommendations directly into MARS from this date. We are making this change so that our stakeholders (your clients) receive their certification as soon as possible. This change will increase the efficiency of certification processes.

To prepare for this change surveyors will need to ensure your MARS login details (username and password) are current. You will need to download the free ‘VIP Access’ app to your desktop or mobile device. Chapter 3 of the MARS user guide contains the steps to get set up and log in. The user guide is available on the AMSA website here. If you need help setting up, you can email mars.support@amsa.gov.au for assistance.

You should review the rest of the user guide to ensure you are familiar with uploading survey reports directly into MARS. If you currently submit your reports via email, you now have almost three months to transition to lodging reports directly into MARS.

Please note the MARS user guide and associated web pages will be updated to reflect the change in process.

Can one of my employees access MARS and upload surveys on my behalf?

Yes, AMSA provides the option to set up company access so an administrative representative can claim and enter surveys on behalf of a surveyor. Send an email to DCVSurvey@amsa.gov.au if you would like to set up company access.

Does this apply to ALL survey reports?

There are some exceptions to the rule. AMSA will accept emailed submissions when:

  • A licensed electrical contractor, who isn’t an accredited marine surveyor, conducts an electrical survey.
  • A surveyor provides a recommendation in support of an EX02 application or as part of an engine change notification.
  • An accredited marine surveyor who doesn’t hold the required category to claim a code asks for the survey activity to be marked ‘not required’ (with sufficient justification).

What if I conduct an additional survey outside the vessel’s survey cycle?

If you conduct an additional survey that doesn’t align with a vessels survey cycle, for example a repair survey, you can email DCVApplications@amsa.gov.au and ask for a code to be generated. This process also applies for surveys conducted on vessels that aren’t required to hold a certificate of survey, for example vessels operating under EX02 Division 5.

What about surveys for vessels greater than 35 metres?

There is no change to the process already in place. If an accredited surveyor conducts a survey on a vessel greater than 35 metres they must email DCVSurvey@amsa.gov.au and provide:

  • The vessel name and UVI
  • The survey code(s)
  • The reason a Recognised Organisation doesn’t need to survey the vessel (i.e. it is an existing vessel not in class at 01/07/2013)

Any questions about this update can be directed to DCVSurvey@amsa.gov.au

Structural fire protection

AMSA continues to receive recommendations from surveyors where non-compliant structural fire protection has been fitted to vessels. These non-conformances have significant impacts for builders, surveyors and vessel owners. AMSA recently refused an application for a certificate of survey for a new build vessel fitted with non-compliant structural fire protection, among other non-conformances.

We wrote about passive fire protection measures in the April 2020 edition of Survey Matters. The information is reproduced below to reiterate the importance of compliant structural fire protection.

Structural fire protection is installed on the vessel structure to contain or slow the spread of fire. It includes the installation of fire-resistant bulkheads, deck heads, decks and doors.

The primary aims of structural fire protection are:

  • Prevent or delay the spread of fire, smoke and heat within high-risk spaces.
  • Protect essential systems and spaces to enable evacuation from the immediate area. This also ensures persons on board can reach muster stations and then abandon ship, should the fire become unmanageable.
  • Provide redundancy and work alongside active fire protection systems. This avoids vulnerability arising from over-reliance on a single measure.

Passive structural fire protection works in four main ways:

1. Protects structural elements

Structural fire protection guards essential components and compartments against fire and thermal heat, to maintain structural integrity.

2. Compartmentation

Compartmentation includes fire-rated divisions or compartments, bulkheads, deck heads, and smoke barriers. It seeks to contain the spread of fire, thermal mass and smoke. Fire can be contained within the machinery space, for example, if the bulkheads and decks are sufficiently protected.

3. Opening Protection

Fire doors and fire-resistant penetrations installed in openings aim to maintain fire-resistance. They work together to form an effective smoke and fire barrier.

4. Fire stopping materials

These materials generally withstand temperatures exceeding 1200°C for extended time periods. This limits fire spread.

Note: It’s common to see a fire-rated division penetrated during modifications. Workers may leave hidden holes in the division as they perform maintenance and upgrades. Surveyors need to pay attention to fire-rated divisions and ensure they are maintained to the original approved specification. This includes paying close attention to cable and pipe penetrations.

The type and thickness of insulation depends on the material it is protecting. For example; steel begins to lose its design margin of safety at temperatures of around 550°C. For aluminium the temperature is much lower at around 150°C. At 275°C aluminium will lose around 50% of its yield strength. Composites soften as temperatures rise, resulting in reduced structural properties for a laminate. The glass transition temperature of the resin affects the amount of insulation required for a composite. Performance of cores & fibres across a range of temperatures also impacts the amount required.

The April 2020 edition of Survey Matters contains the basic principles and examples of data sheets and certificates of compliance for Aluminium - A30, Steel - A30, and Composite - A60 structural fire protection.

Key items a surveyor should verify

Installing protection under approved design and OEM guidelines is the only way to achieve the aims mentioned above. This includes:

  • Ensuring only appropriately tested solutions are used.
    • The requirements of the performance standards (Fire Test Procedures Code or the High Speed Craft Code) are specific. Products not designed and tested to meet these standards are not acceptable (see below).
    • Insulation requirements vary based on type and thickness of the material it is protecting. Requirements also vary depending on the area on the vessel and the time rating of the division. 
  • Having concise and accurate approved drawings, of the proposed arrangements. 
  • Verifying that materials and fittings are correctly installed by competent personnel, i.e. as stated in the approval documentation and/or the manufacturer’s instructions. For example, pins are fixed to the substrate correctly. Pins are sufficient in nature as per approval documentation and achieve required returns.
  • Verifying that the means of protection are inspected and tested at regular intervals. This includes prompt repair and renewal whenever necessary.
  • Checking the certification of the SFP, do not confuse non-combustible products, with those properly tested and certified as part of time rated fire-resisting divisions (structural fire protection).

Examples of unacceptable products

Pink batts are not acceptable. They are combustible above 350°C and are designed for comfort insulation and acoustic use only.

Intumescent paints and similar solutions do not meet the performance requirements for use. They are not approved for use as structural fire protection solutions.

A solution approved for use on steel, is not necessarily suitable for use on aluminium or fibreglass. Even if it is certified for a higher time rating than required. 

A solution approved for use in a land-based building is not approved for use on a vessel. The performance criteria are significantly different between vessels and buildings. The environment, firefighter response time and distance to safety or rescue if a fire breaks out differ.

Out of water survey requirements

AMSA has noticed there is some confusion about what items must be surveyed as part of a periodic out of water survey. The confusion stems from the out of water survey items section at the bottom of Table 9 in chapter 4 of SAGM Part 2.

The out of water survey items section is not an exhaustive list of items that must be surveyed as part of a periodic out of water survey. The whole of table 9 must be considered when conducting a periodic out of water survey and any item with a tick next to it must be surveyed.  

When you conduct a survey for an OWAT code, ensure all applicable items in Table 9 are examined, verified, tested or trialled, and documented on your reports.

Navigation light requirements

AMSA frequently receives enquiries from vessel owners and operators regarding the navigation light requirements for domestic commercial vessels. During audits we have also noticed that navigational light arrangement plans are commonly omitted, or these details aren’t reflected in the general arrangement plan as part of the initial survey documentation.

Does my vessel need a navigation light arrangement Plan?

For vessels which must comply with Pt. C of COLREGs, AMSA expects that a navigation light arrangement plan, approved by an AMS, is available on board. This plan may contain details regarding the different types of navigation light, minimum range of visibility, horizontal and vertical positioning and spacing of the lights etc.

Alternatively, for smaller vessels, these details can be provided on the general arrangement Plan.

A profile view and table of navigation lights on a ship over 50m is shown below for illustration purposes only (not to scale).

Boat dimensions

Item numberLightTypeSI numberRangeVisibilityColour
1Fore Masthead Light----225°6nmWhite
2Aft Masthead Light----225°6nmWhite
3-----------------

Can a vessel use LED navigation lights?

LED navigation lights can be installed, subject to several conditions listed in IMO resolution MSC.253 (83).

However, AMSA reminds all owners, operators and accredited surveyors that the luminous intensity of LEDs gradually decreases while the electricity consumption remains unchanged. The rate of decrease of luminous intensity depends on the output and temperature of the LEDs.

What are the additional requirements for LED navigation lights?

Marine Order 30 requires navigation lights, navigation light controllers and associated equipment, installed on DCVs after 30 November 2009 to conform to performance standards at least equal to those mentioned in the Annex to IMO Resolution MSC.253(83).

To prevent shortage of luminous intensity of LEDs, the following additional requirements have been specified in IMO Resolution MSC.253 (83): 

  1. An alarm function should be activated to notify the Officer of the Watch that the luminous intensity of the light reduces below the level required by COLREGs;

or

  1. LEDs should only be used within the lifespan (practical term of validity) specified by the manufacturer to maintain the necessary luminous intensity of LEDs. The lifespan of LEDs should be determined and clearly notified by the manufacturer based on the appropriate test results on the decrease of luminous intensity of the LEDs under various temperature conditions and on the temperature condition of LEDs in the light during operation, taking the appropriate margin into account.

What should an accredited surveyor check regarding LED Navigation Lights?

Accredited surveyors are encouraged to check the following documentation/marking checks in addition to the routine safety and operation checks;

  1. Valid type approval certificates for reference to IMO Resolution MSC.253 (83) and for special installation instructions.
  2. Check if the Navigation light controller is included in the type approval certificate and the controller is approved in accordance with MSC. 253 (83).
  3. Check the LED light or the manufacturer documentation for navigation light expiration dates.
  4. When completing the AMSA 901, specify LED for Navigation Lights as well as the expiration date.

If expiry dates aren’t specified by the manufacturer, check for alarm functions on the bridge for reduction in luminous intensity of LED Navigation Lights.

Lines plans/hull model requirements

The Surveyor Manual Part 2 Table 2 requires that a lines plan (or electronic 3D hull file) is provided when comprehensive stability criteria is used. This is expanded in NSCV C6C, clause A8.8.4 as part of the information supporting the inclining experiment.

This may elicit concern, as it is a valuable piece of intellectual property. AMSA appreciate that a lines plan represents sensitive proprietary hull design information often built up over many years. It can also represent a significant investment of time to model an existing vessel, providing a competitive advantage.

We understand and appreciate these concerns. AMSA has a comprehensive privacy policy on our website.

The rationale behind the requirement for lines plan data (either in the form of a drawing or a 3D hull model) is to permit audit in accordance with section 45 of the regulations.

Another reason for requiring a lines plan is to aid investigation in the event of an incident linked to the vessel stability. Should stability need to be assessed the provision of hull data allows for this to be undertaken.

Hence, when comprehensive stability is used on a vessel, either a lines plan containing the data listed in Table 2 of SAGM Part 2, or an electronic hull file, such as a Maxsurf hull file or *.iges is required in support of a recommendation for stability approval.

Autonomous vessels in Australia

AMSA has recently seen an increase in the use and application of autonomous vessels in Australia. AMSA has produced guidance material to assist operators of these vessels to comply with the national system. The guidance notice is now available on the AMSA website and helps improve our regulation of emerging technology in Australia.

Guidance Notice – Small uncrewed autonomous vessels

Nitrogen oxide (NOx) emission requirements for marine diesel engines on DCVs

As a part of global measures to reduce harmful nitrogen oxide (NOx) emissions, marine diesel engines with an output above 130kW must now meet NOx emission requirements.
 
Globally, the shipping industry is reducing NOx emissions by requiring marine diesel engines with a power output of greater than 130kW to comply with NOx emission limits.  To confirm an engine is compliant, an Engine international air pollution prevention (EIAPP) certificate and a technical file must be carried on board for each engine.  
 
AMSA has introduced measures that will assist DCV owners and operators comply with the NOx emission requirements. Under Exemption 44, DCV owners and operators can hold specified alternative evidence that demonstrates engines are likely to meet the NOx emission limits.

Read more information about the requirements

The AMSA National Compliance Plan 2021-22 is now available

The National Compliance Plan 2021-22 provides practical guidance and a clear view of what AMSA will be looking for over the coming year to make it easier to comply with the national law.

Focus area 3 in the plan specifically addresses domestic commercial vessels. The importance of safety management systems, incident reporting, fatigue management, and compliance with the marine surveyors’ accreditation guidance manual are priority areas for AMSA’s compliance activities over the coming year.

Focus areas 4 and 5 are also targeted to domestic commercial vessels to increase beacon registration and prevent pollution from ships.

Please familiarise yourself with the priority areas and share this information with your clients as the opportunity arises.

We welcome your feedback

Is there a topic you’d like to see covered in a future edition of Survey Matters? Send an email to DCVSurvey@amsa.gov.au with any suggestions or feedback.

Category

Survey Matter—December 2021

Merry Christmas and Happy New Year

In this edition

Season's Greetings

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

Tis the season to be jolly, to prosper, and to carry good tidings of this year into the next. Thank you for your partnership and for our valued relationship with you. May you and your family have a wonderful Christmas and may you experience great success this coming New Year. Merry Christmas to you and your family.

The DCV Applications team remain on deck to process temporary operation approvals lodged between Christmas and the New Year.

Recent surveyor audit findings

Since the last edition AMSA has conducted over 30 Accredited Marine Surveyor Audits, most of which covered several surveys.
 
Many audits were positive, with findings mainly observations or minor non-conformances, however four major non-conformances were issued.

Two major non-conformances were issued to one surveyor because stability books, substantially not meeting the requirements of the NSCV, had been approved. In one case this resulted in AMSA downgrading the previously issued Certificate of Survey. For the repeated breach, the accredited marine surveyor was issued a $2,664 infringement (fine), for not complying with the conditions of their accreditation.

A major non-conformance was issued because an accredited surveyor had completed and recommended a renewal survey for a class 1 vessel > 12 m, accepting the owner’s declaration for the lightship check (instead of a lightship measurement). The accredited marine surveyor implemented corrective actions to ensure the issue was rectified and ensure it would not occur again. A counselling letter for a breach of conditions of accreditation was issued.

A major non-conformance was issued because the requirements of NSCV C7A had been improperly applied during a survey, this resulted in a Class 2C vessel not being provided with a liferaft.

What is corrective action?

AMSA conducts regular audits of the survey records and recommendations made by Accredited Marine Surveyors (AMS).  The purpose of these audits is to monitor the quality of the surveys conducted, ideally promoting, and assisting with continuous improvement.

AMSA categorise findings from audits as follows:

  • Observations (these can be positive, neutral, or negative) - these are for the information of the AMS and require no response to be provided to AMSA.
  • Minor non-conformances and Major non-conformances – these require a corrective action to be provided to AMSA.

What does a corrective action need to achieve?

A corrective action needs to:

  • Correct any immediate issues, if required, to make the problem right; and
  • Correct systemic issues (issues in your survey system), to prevent re-occurrence, for example by incorporating:
  • lessons learnt; or
    • improvements to survey techniques and procedures.
    • The substance of the corrective action should be proportionate to the level of the Non-Conformity identified. 

Examples

Non-ConformityExample of Corrective ActionGood or Bad?
Minor Non-Conformity – Form 638 for SHAFT survey does not indicate that a dimensional check was conducted and no supporting documentation supplied in this respect.
 
“Dimensional check was done; shafts are in good condition.”Bad -
No Immediate or Preventative Corrective Action
“Please find attached a revised form supplemented by copies of my field notes.  Going forward more attention will be paid to providing the correct information in recommendations for shaft surveys, evidenced by supporting documentation, if required.”Good –
Correct Form supplied with supporting documentation and measures to prevent re-occurrence (lessons learnt).
Major Non-Conformity – Temporary Operations Permit was issued to the vessel following Renewal Survey when major deficiencies remained not rectified.“I’ve known this operator for years and he is very trustworthy.  I had every confidence that he would rectify the items before operating, therefore I issued a Temporary Operations Permit with these items outstanding.  There was no risk to safety.  Everything has now been repaired and the vessel is in good condition. “Bad – No preventative corrective action
“I have followed up with the owner who confirms that all of the major deficiencies have now been rectified. I have reviewed Exemption 07 and now better understand the conditions under which I have the delegation to issue a Temporary Operations Permit. I have updated my survey procedures accordingly.”Good – Immediate corrective Action (follow up) and Preventative Corrective Action (lessons learnt, procedures updated).

The purpose of the audit process is to assist surveyors to identify areas of improvement in their survey process. AMSA and accredited surveyors must work together to build trust with customers, by improving the professionalism, accuracy and consistency of surveys conducted around Australia.

Condition of tailshaft, survey recommended by Surveyor

During the desktop audit of a periodic shaft survey recommended by an accredited surveyor it became apparent that the surveyor recommended a periodic shaft survey of a water lubricated shaft, in the condition shown below, for a 1C passenger vessel. Despite noticing significant surface corrosion/pitting and excessive wear on the shaft, the accredited marine surveyor recommended the shaft survey without performing adequate tests (e.g.: NDT, dimension/trueness check etc.) to determine the suitability of shaft for the next 5 years. AMSA seeks your view whether you would recommend shaft surveys for this tailshaft without performing any additional checks or remedial action.

Water lubricated shaft

Water lubricated shaft

Stability audits – common findings

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 has performed over 300 audits related to Stability approvals from accredited marine surveyors (AMS), with the assistance of Transport of New South Wales. Most of the submissions from accredited surveyors were found to be compliant and several positive observations noted. However, some of the audits identified several serious findings and the vessels failed to meet criteria. Below are some of the most common non-conformances identified:

1. Maximum allowable angle of Static Heel

In most cases, the AMS determined the heel consequence of the vessel as low and applied the allowable single and combined angles of static heel as 14 and 18 degrees respectively. However, during the audits, it was noted that several vessels did not meet the conditions of application of low heel consequence level. Several of these vessels failed to meet the comprehensive stability criteria for angle of heel when heel consequence of the vessel was determined as Moderate or High. AMSA encourages AMS approving Stability Booklets to ensure that the conditions of application for appropriate heel consequence level are met for each vessel. These conditions ensure that the vessel has adequate capacity to control the risks as the static heel angle increases. NSCV Part C Section 6 Subsection 6A Ch.3.8 Table-4, cited below, addresses these requirements: 

able 4 - Maximum allowable angles of static heel

2. Allowable loss of freeboard calculation using alternate simplified criteria.

In several cases, the type of vessel (cockpit vessels and well deck vessels) was identified incorrectly by the surveyor, which leads to application of incorrect simplified stability criteria for calculation of the allowable loss of freeboard. In several cases, it was noted that the accredited surveyors used the allowable loss of freeboard criteria for cockpit vessels, instead of using well deck vessel criteria. AMSA identified, during the audits, that these vessels failed to meet the well deck criteria. Definition of the type of vessel can be found in NSCV Part C Section 6 Subsection 6A Ch.1.7 and Fig-2. The relevant simplified stability criteria for measurement of inclined freeboard can be found in NSCV Part C Section 6 Subsection 6A Ch.7.4.5. We have summarised the definition and requirements in the below table for the ease of reference.

Vessel types

3. Wind pressures in bare poles condition for sailing yachts.

For sailing yachts, surveyors have applied wind speed restrictions for operations during bare poles to satisfy the criteria for wind heeling angles, in some cases. Surveyors should consider not applying a restriction in wind speed, while calculating the wind heeling moments in bare poles condition.

AMSA considers application of a restriction on wind speed as failing the criteria for wind heeling angles for the area of operation. The minimum wind pressure to be used in the wind heeling moment calculation is specified in NSCV Part C Section 6 Subsection 6A Annex B 3.1 Table 41, as cited below:

Wind pressure

Maintaining professional competence

Section 28 of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the regulations) requires an accredited marine surveyor to maintain professional competence in the categories of surveying in which they are accredited.

AMSA expects an accredited surveyor to:

1. Maintain their professional competence in marine surveying.

As a guide AMSA generally expects every accredited surveyor to spend at least 45 hours over a 3-year period maintaining professional competence on items directly related to the role of a surveyor. The table below should be used as a guide.

2. Fulfill the Continuous Professional Development (CPD) requirements of their professional association, to maintain membership. 

This varies from association to association and the scope can be broad.  Associations would normally consider crediting professional competence items mentioned above against their CPD requirements. Associations typically require 105-150 hours of CPD over a 3-year period.

If an accredited surveyor takes a break from surveying, AMSA does not generally expect them to maintain their professional competence during this period. However, if an accredited surveyor re-commences surveying, AMSA expects them to be able to demonstrate they have spent a suitable amount of time fulfilling the requirements above and may request evidence that their professional competence is up to date.

If an accredited surveyor takes a break from surveying, AMSA does not generally expect them to maintain their professional competence during this period. However, if an accredited surveyor re-commences surveying, AMSA expects them to be able to demonstrate they have spent a suitable amount of time fulfilling the requirements above and may request evidence that their professional competence is up to date.

ActivityMaximum number of hours to count per 3-year periodExamples
Keeping up to date with changes to the National Law and AMSA processes20 Hours (mandatory)This includes the reading of ‘AMSA Survey Matters’, familiarisation with changes to SAGM, Marine Orders and Exemptions.
Workshops and technical meetings20 HoursTechnical meetings, including AMSA workshops and relevant professional association meetings.
Courses25 HoursTertiary or short courses in Law, Naval Architecture, Marine Engineering, Electrical Engineering, Fire, Risk Management, Working at Heights, Confined Space Entry.
Practical training15 HoursTraining with a more experienced AMS or an AMS with a different skill set.
Private study which extends relevant knowledge and skills.5 HoursPrivate study includes the reading of books, journals, transactions, technical content on the internet etc.
Any other structured activities that meet the purpose maintaining professional competence.Unlimited, but to be balanced with some other professional competence activities listed above. 

Marine Safety Incident – POB

A private charter cruise vessel had an incident when a guest with a toddler walking from aft deck to the swim platform fell overboard. The master had seen the guest with the toddler a few seconds earlier on the CCTV but no one saw them fall. A few seconds later the master noticed that the double gate was wide open and he could not see passengers on the swim platform. The persons overboard were spotted about 80-100m astern and before they could be reached, there were screams and yells from the toddler’s mother who jumped into the water to rescue. The POB were retrieved successfully and bought on board – shaken but no injuries.

Why this happened?

  • The guest is assumed to have leant against the gate which opened under the pressure of his body weight.
  • The double gate had not been properly secured shut with the locking bolt at some stage prior to departure.
  • The gate was only held shut by a “flap” cover that did not fully prevent opening under pressure.
  • The gate can open both inwards and outwards with no ‘stop’ preventer either way.

Marine safety incident - POB

AMSA has conducted a review of the vessel’s safety management system and identified deficiencies relating to risk assessments and passenger verification procedure. The operator has engaged a fabricator to redesign gates and to prevent them from opening outwards.

Safe design is a better control than administrative measures such as the safety management system
It is requested that surveyors inspect the opening and gates in bulwarks and railings for securing devices and bring any safety concerns to the attention of the owner and Master.

Harmonisation of shaft surveys with renewal surveys

Sometimes owners voluntarily draw shafts outside a vessel’s renewal survey window, perhaps if there is an issue with the bearings/sealing arrangements or if the shafts require renewal.

The SAGM requires that shafts be withdrawn and a SHAFT Survey conducted as part of a renewal survey. If a shaft has been previously withdrawn, just outside the renewal survey window, owners can obviously be reluctant to do this again.

Therefore, if a SHAFT survey is done outside the Renewal Survey window the best option (as the vessel will be out of the water) is to conduct a full Renewal Survey early to set the vessel up for the next 5 year cycle.

If this is not possible, owners have the option to apply for a Specific Exemption (SPEX) to allow the likes of a new shaft to be exempt from the requirement to be withdrawn at the next Renewal Survey. Such exemptions would only be granted in exceptional circumstances. Factors considered would be the time between shaft surveys being requested, the age of the shaft, the number of shafts the vessel has, envisaged running hours, the type of shaft material used, the type of bearing lubrication, whether the vessel is left in the water for prolonged periods without the shaft turning, duration of repair facility (slip) availability etc...

Previous State Authority practices of allowing shafts to be withdrawn at periodic out of water surveys are no longer considered.

Initial survey of sister vessels

For AMSA to issue a certificate of survey, an application must be supported by the required survey reports and recommendations.

For the initial survey of a sister vessel, clause 3.9.5 of Part 2 of SAGM provides that, in lieu of full plan approval, the basis vessels approved plans are able to be submitted, and they need to be accompanied by a statement from an accredited marine surveyor with category ‘a’ (plan approval) accreditation (as per clause 3.9.1) as well as a lightship comparison report of the basis and sister vessel.

Depending on the type of sister vessel, the accompanying statement would need to confirm the basis and sister vessels’ service categories, crew, special personnel and passenger numbers, and maximum speeds.

Construction and commissioning phases of initial survey are to be conducted as per any other new vessel construction, in accordance with Part 2 of SAGM.

If you do not currently hold copies of the basis vessels plans and/or stability documentation, you may be able to request copies of the basis vessels records, however intellectual property considerations may apply.

Please see the AMSA website for instructions on how to request vessel records. 

Weld defects and NDT examination 

Weld defects may have serious consequences if not identified and properly repaired. Different types of weld defects cause different effects on the ships structure. 

Cracks, lack of fusion and incomplete joint penetration can create notch effects. Discontinuities such porosity and slag inclusions amplify stresses by reducing the weld area.

Cracks – are the most serious type of welding defect because of their tendency to propagate under certain levels of stresses. They are the primary cause of structural failure. Cracks act as stress concentrators and are not acceptable for ship hull welds, regardless of their size. They must be repaired immediately. 

Lack of fusion – is a failure of the welding process, fusion failed to occur between the base metal and the weld metal, caused by improper welding techniques, preparation of the material for welding, incorrect joint design.  

Lack of penetration – This is a root condition in which the weld bead does not penetrate the entire thickness of the base plate or when two opposing beads do not interpenetrate. This will cause weld failure if the weld is subjected to tension or bending stresses. 

Undercut is a groove melted into the base metal adjacent to the weld toe or weld root and left unfilled by weld metal. Concavity is a weld discontinuity in which the maximum distance from the face of a concave weld perpendicular to a line joining the weld toes is insufficient. 

Inclusions are entrapped foreign solid material, such as slag, flux, or oxide.

Porosity occurs because of weld metal contamination. Gas is entrapped in solidifying weld metal. It is generally spherical but may also be elongated. Excessive hydrogen is one of the main causes of porosity and moisture is a major source of hydrogen. 

Overlap - is an excess of weld metal covering the parent metal but not fused to it. Incorrect welding procedures, inappropriate selection of welding material, insufficient travel speed are some of the typical causes of overlap. This is one of the serious welding defects on ships and should be avoided.  

Misalignment occurs in plates in the perpendicular direction to the plate surface and weld axis. 
The non destructive test (NDT) methods used for detection of weld surface imperfections are visual testing, liquid penetrant testing and magnetic particle testing. 

Ultrasonic testing and radiographic testing are NDT methods used for weld internal imperfections. 
The acceptance criteria, defined by recognised organization or Australian Standards, can be used for the assessment of the results of different NDT methods. 

For more information on welding inspection refer to instruction to surveyors DCV-ITS08.

NSCV C6B review project commencing 

AMSA has commenced a review of NSCV C6B (Stability and buoyancy after flooding). The project seeks to make amendments to NSCV C6B based on issues and feedback supplied by accredited marine surveyors. 

Specifically, the project will: 

  • review and validate the flotation and foam requirements of Annex C, D and F
  • develop a new alternative simplified level flotation annex for low complexity vessels 
  • review and validate the raking damaged requirements for inflated collar vessels 
  • review the number of watertight doors per hull and the type of door 
  • develop guidance to assist with implementation and compliance 

AMSA will be developing a Technical Advisory Panel (TAP) for this project. Interested industry stakeholders should complete the TAP nomination form available on the We welcome your feedback

Is there a topic you’d like to see covered in a future edition of Survey Matters? Send an email to DCVSurvey@amsa.gov.au with any suggestions or feedback.

Category

Survey Matters—May 2021

Renewing your accreditation

The Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the regulations) require an accredited marine surveyor to submit an application to renew accreditation on the AMSA 804 form, and pay the required fee, no less than three (3) months prior to the expiry of accreditation. 

AMSA requires the full three months to process a renewal application and ensure:

  • The surveyor has maintained their professional competence in the categories of surveying in which they are accredited.
  • The surveyor’s work has been found, during any audits, to be satisfactory.
  • Complete administrative and card processing work. 

If there is an extraordinary reason as to why you were unable to submit your application three months prior to your accreditation expiring, AMSA may consider allowing a further period of time. Please be aware that requests to allow a further period must be in writing to AMSA from the accredited surveyor and may not be approved without extenuating reasons.

Since the start of 2021, AMSA has issued show cause notices to two accredited surveyors who failed to apply within the prescribed period. Subsequently Notices of Decision to refuse a further period of time were issued.
Are there consequences? 

Yes. If your accreditation expires, a new application for accreditation, including payment of the initial fees and interview for the categories of accreditation is required.

Changes to identity cards

Accredited marine surveyor identity cards underwent a change in December 2020. Cards no longer list a surveyor identification number; instead, they list your unique AMSA ID number which will never change. This change effects all cards issued after December 2020.

Using existing surveyor ID

You can use your existing surveyor ID number, however we recommend that you transition to the AMSA ID. 

Using existing surveyor ID card that does not have an AMSA ID

Your card is valid until you submit a new or renewal application and receive an updated card.

Surveyor ID on the AMSA form 

Existing AMSA forms require you to fill in the ‘Surveyor ID’ field. You can populate either your Surveyor ID or AMSA ID in this field.

Updates coming to MARS

MARS updates, focused on increasing the efficiency of certification, are in the pipeline.

The updates include changes to the management of supporting documents in MARS, and updates to the way ‘surveys required’ letters are generated. 

Changes to the supporting document

MARS activities currently have a general file upload button.

After the update, each survey activity will have its own specific survey documentation upload buttons. For example, the hull survey activity will have a specific place to upload the expected hull survey report. 

If a user chooses not to upload an expected document, a warning message will appear when the recommendation is made in MARS. 

A user may still proceed without uploading the document, however this will cause delay or may ultimately result in a refusal of the application.   

Reason for the changes 

The most common reason applications are delayed or refused is because they are incomplete. 

These changes aim to improve submission quality, allowing AMSA to complete applications with less manual checks, and provide faster outcomes for you and your clients.

The ‘surveys required’ letter changes

Currently ‘surveys required’ letters are automatically generated by the MARS system, containing a comprehensive list of survey codes. 

This update will allow AMSA to check and customise survey codes on these letters before they are sent to the applicant. 

Reason for the changes 

These changes allow AMSA to communicate survey requirements more clearly to applicants and reduce the administrative burden for survey.

Expected date of updates 

These system updates are currently undergoing initial testing by the system developer. 

We will let you know when the changes take effect.

AMSA application review process 

To ensure AMSA is providing a high level of service and meeting stakeholder expectations, AMSA has internal service guidelines.   

In most cases, AMSA will consider an application within 10 business days of completion. 

The maximum period allowed for AMSA to consider and decide most applications is 90 days. This maximum time frame is provided to ensure AMSA considers and decides applications within a reasonable period.  That is, AMSA must decide to approve or refuse the application within the time frames prescribed in Marine Order 501.

In cases where there is insufficient information to approve an application, AMSA delegates will request additional information from the applicant.

About the process

AMSA will review the application and if necessary information is available, make a decision on the application. 

However, if additional information is required, AMSA will send the applicant a request for further information, usually by email.  

AMSA will allow a reasonable period for the applicant to obtain and supply the requested information. 

After the request period has passed, AMSA will consider and decide the application based on the information available to us.  

Questions and answers

What if I don’t think the information AMSA requested is necessary or reasonable? 

Answer: You should review the applicable Marine Orders and the Surveyor Manual. An applicant can choose to omit the information, AMSA has requested. At the end of the request period AMSA will consider the application based on the available information. If the requested information has not been provided, it is possible AMSA may refuse the application.  

What if I don’t believe the period for the request is reasonable? 

Answer: Just ask to extend the time period and AMSA may extend if there is sufficient reason. Please note a reasonable period will be set for the requested information as required by Marine Order 501, after which a decision will be made. 

What can I do if the application is refused? 

Answer: If an application is refused on the basis of insufficient information, just apply again when the information is available.

Alternatively, a refusal decision made by AMSA may be reviewable. This means certain rights of review may arise for the applicant. Further information regarding these rights will be provided at the same time the applicant is given a written notice of the decision. 

Completing the AMSA 638 shaft survey report

We have found significant variation in the quantity and quality of information provided on the AMSA 638 form in the Shaft details section.

The information AMSA expects to see in the Shaft Details section of the AMSA 638 form is detailed in the image below. We understand there are times when some of this information isn’t available to the surveyor, nonetheless the provision of this information is considered appropriate and should be sourced wherever possible.

shaft survey diagramLoad line survey frequency for vessels operating under Exemption 2 Division 5  

Vessels operating under Exemption 2 Division 5 which are required to hold a load line certificate must undergo load line surveys in accordance with the Marine Surveyors Accreditation Guidance Manual (SAGM).  

Chapter 6.3.2 (1) of SAGM refers to Marine Order 507 for periodic survey frequency requirements. 

Division 2(7)(f) of MO507 states: 

“if a vessel does not have a certificate of survey, the periodic survey mentioned in paragraph (d) must occur according to the frequency that a periodic survey would be required for a certificate of survey under Marine Order 503 if the vessel was required to have a certificate of survey;”

Periodic load line surveys must be completed within the 3 months before, or 3 months after the due date listed in the survey schedule on page 2 of the load line certificate.

Working with the Fire Protection Industry Board to protect the environment, property and lives

Written by the Fire Protection Industry (ODS & SGG) Board.

By working with the Fire Protection Industry (ODS & SGG) Board (FPIB), accredited marine surveyors can help protect the environment, the safety of vessels, and the lives of those onboard. 

The FPIB administers the fire protection industry permit scheme on behalf of the Australian Government. The permit scheme aims to reduce unnecessary emissions of extinguishing agents that are ozone depleting substances (ODS) and synthetic greenhouse gases (SGG), known as scheduled extinguishing agents.

Surveyors can minimise the risk of accidental discharges of scheduled extinguishing agents by ensuring that fire suppression systems and portable fire extinguishers on domestic commercial vessels are installed, maintained, tested and decommissioned in line with the permit scheme.

Scheduled extinguishing agents are harmful if discharged into the atmosphere. Depending on the type, these substances can either damage the earth’s ozone layer and/or contribute to global warming. The most common scheduled extinguishing agents found in vessels are FM-200, NAF-SIII and FE-227.

Vessel owners or operators should only use licenced technicians as they are suitably qualified and skilled. Using unlicensed technicians is potentially damaging for the environment. It also puts at risk the safety of vessels and the lives of those onboard.

It is an offence under the Ozone Protection and Synthetic Greenhouse Gas Management Regulations 1995 to handle scheduled extinguishing agents without an appropriate fire protection industry permit. It is also an offence to breach any conditions of that permit.

Surveyors can assist the FPIB with a few simple measures:

  • When work on a fire suppression system or a portable fire extinguisher is needed, encourage the vessel’s owner to confirm that the technician holds a valid fire protection industry permit by contacting the FPIB on 1300 731 922 or by email.  
  • If a technician has already been engaged and has performed the work, check the maintenance logbooks. You may contact the FPIB to confirm they hold a valid fire protection industry permit. 
  • If a scheduled extinguishing agent has been discharged from a fixed fire suppression system or portable extinguisher, please report this to the FPIB via their short online discharge notification form. Note, it is an offence under the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 to discharge a scheduled extinguishing agent outside of the Regulations. 

For further information on scheduled extinguishing agents in the marine industry, see the FPIB’s factsheet.

The importance of terminal covers

The incident below occurred in 2020 and highlights the importance of insulating bare conductors and terminals. 

The incident demonstrates the benefits of conducting regular maintenance on electrical systems, particularly ensuring all components are secured.  

This 4.35m vessel suffered a short circuit, as a result of a hinge pin working loose, causing the battery switch panel to drop onto the aluminium hull (see pictures below). 

The high current flow through a short circuit generates heat that can cause a fire. Isolating the battery is the only way to stop the high current flow in the engine start circuit. In this instance the throttle cables, ignition system and outboard components melted and generated smoke. 

Fortunately, the operator wasn’t far from the boat ramp and was able to make shore. The consequences could have been worse if they were operating further seaward and unable to identify the cause.

terminal

terminal

Ultrasonic thickness measurements 

The Marine Surveyor Accreditation Guidance Manual (SAGM) provides limited guidance on Ultrasonic Thickness Measurements (UTM) required as part of 10-yearly renewal survey.

SAGM 2.7(2)(d) and Example 2 contain reference to UTM but do not provide details about the requirements and conduct of the UTM itself. Neither the NSCV nor the USL Code provide information nor was there a uniform approach adopted by the state authorities.

AMSA plans to address this gap and is currently developing guidance material in the form of an Instruction to Surveyors. The instruction will be based around the existing IACS recommendations (Z7 and Z7.1) adapted for domestic vessels less than 35m. Note: Vessels maintained in class must continue to follow the requirements of their recognised organisation for renewal surveys.

The intention of the instruction is to provide guidance to accredited marine surveyors in the following areas:

  • General Requirements – such as access arrangements and cleaning requirements.
  • Conduct of the Survey – requirements of the surveyor and the UTM company and the execution of the survey onboard the vessel.
  • Extent of Survey - what is required at each 10, 20 and 30+ year renewal surveys.
  • Reporting - the what and the how of reporting.
  • Acceptance criteria – for the different type and measured length of vessel and for different material types.

The purpose of the UTM is to ensure that wastage affecting the vessel’s structural, or weathertight/watertight integrity is identified and repaired to the surveyor’s satisfaction.

We will contact accredited marine surveyors for feedback when the draft instruction is available. 

Upcoming certificate of survey renewals 

In NSW, a large number of certificates of survey will be due for renewal in the next 6 months, you can expect an increase in renewal survey requests. 

A number of vessels in NSW that have certificates of survey were not previously subject to ongoing periodic (or renewal) surveys. Due to changes to the law in 2018, those vessels are now required to undergo survey in order to renew their certificates of survey.

Renewal surveys can be conducted anytime in the six months prior to the expiry date of the current certificate. We encourage you to upload the surveyor reports directly to AMSA systems—to reduce processing times. 

Simplified equipment lists for small fishing vessel operations  

Two simplified equipment lists are now available for certain non-survey vessels less than 12 metres long, working close to land.  

The equipment requirements depend on where and how far from land a vessel operates. 

  • Fishing vessels working in warm waters and operating within 2 nautical miles of land 
  • Beach fishery vessels operating within 200 metres of land, anywhere in Australia. 

Eligible vessels must be operating under Exemption 2 (certificates of survey) or Exemption 40 (class C restricted operations). 

No application is required to use the equipment lists for vessels operating under these conditions. Operators must simply ensure they carry all the required safety equipment. 

These changes to safety equipment requirements have taken shape through collaboration and consultation with industry. You can read more about the equipment lists on the AMSA website. The consultation feedback report is also available.

Category

Survey Matters—March 2022

In this edition

Correct and incorrect use of conditions

Conditions are used to impose additional requirements on duty holders.  They cannot be used to avoid compliance with a requirement of the law. This is only permitted by exemption.   

Correct use of conditions  

Conditions can be used to require a duty holder to do additional things.  For example, AMSA could impose a condition requiring a master to check engine oil each morning (if we believed it was necessary and correct to do so).   

Checking the oil is not a “standard” requirement of the law. Marine Order 503 and the standards do not explicitly require the master to check the engine oil each morning. Nonetheless, if a condition is imposed on the certificate, the master would be required to meet this condition (see section 38 of the National Law).   

Incorrect use of conditions  

A condition on a certificate cannot be used to “overrule” or contradict the requirements and conditions set out in the National Law.   

For example, the National Law Marine Orders may require a vessel to carry a life raft. A condition cannot be used to overrule this requirement. A condition such as "life raft not required to be onboard provided master only operates in D waters” would not have the desired effect. It is not an exemption.  

Examples of correct conditions  

  • Opening between engine room and steering compartment at Frame 37 to be closed watertight during 1D operations 
  • Recommended Condition: Vessel operations limited to within 30NM radius of safe haven and able to return to safe haven from any point in 2 hours. Reason: Vessel fitted with single anchoring system.  

Examples of incorrect conditions  

  • Vessel to operate in 1D until in service life raft returned to vessel  
  • Vessel to carry life-saving equipment (Life jackets and life buoys) appropriate to the number of crew onboard.  
  • Fuel tank to be removed and inspected at or before next renewal survey in September 2023  

If you come across a vessel that does not comply with the law, for example because the life raft is not onboard or because they have not completed the surveys required by the Law; then your duties as a surveyor are to communicate the deficiencies to the owner on an AMSA 586, and work with the owner to ensure the issue is rectified. If the owner needs to operate with exemptions, flexibility is provided through Exemption 6 and Exemption 7. Where appropriate, the owner may also apply for a specific exemption

Inclining experiment methods 

The National Law permits the use of equivalent and alternate solutions for meeting the standards. This may permit use of alternate incline methods, on a case-by-case basis. AMSA has for example allowed some smaller vessels to apply the ASTM F3052-14 and SNAME Technical Bulletin 9-1 methods for air inclinings. 

An article entitled Scaling the Wall: Inclining Experiment Analysis on Vessels with Chines, Hull Discontinuities or Asymmetry was recently published by Richard Dunworth, Naval Architect, Department of Defence, in the November 2021 issue of The Australian Naval Architect.  

This article introduces and discusses the merits of a KN based inclining method that may deliver more accurate inclining results for asymmetrical hull forms and vessels where waterplane area changes during inclining, such as RIB’s. 

Surveyors who wish to apply this method for vessels, that are difficult to incline in a traditional manner, or any other non-conventional method, such as air inclining, can apply for an equivalent means of compliance using AMSA form 649

If you are considering applying for an equivalent solution, please ensure you are familiar with the method you intend to apply and can demonstrate the method will be at least as effective as the solution it replaces. For example, with the KN method: 

  • KN values must be available and accurate for small intervals of heel. 5-degree intervals such as traditionally used in a stability assessment are not sufficient.  
  • Procedures must ensure the vessel is free to heel and will not hang on lines, touch bottom or similar. Noting the method does not appear to have a mechanism to identify these types of issues, particularly because results may be non-linear as waterplane area changes.  

NSCV C7A safety equipment requirements 

Marine Order 503 requires all vessels to comply with NSCV C7A for safety equipment. This means new, existing and transitional vessels. 

The latest amendment of NSCV C7A commenced on 1 January 2018 and includes Annex I which outlines the phased arrangements for existing vessels to meet with regards to updating safety equipment. Annex I includes timeframes starting from the next periodic or renewal survey after 1 January 2018, during which time the update in specific equipment must be carried out. There are also deadline dates should no periodic or renewal surveys occur beforehand. 

At the time of writing this article, all deadline dates have now passed, except for the requirements for stowage of liferafts (within 12 months of the next out of water survey or 1 January 2023). The following is a summary of some of the major items that surveyors must be looking for during periodic and renewal surveys. The list below is not exhaustive, and AMSA recommends surveyors familiarise themselves with all the requirements of NSCV C7A if they haven’t done so already. NSCV C7 Equipment guidance notices are also available on the AMSA website. 

IMPORTANT: Only lifesaving equipment that falls under NSCV C7A requires updating. Anchoring, navigation, and communication equipment are not required to be updated to the NSCV standards on existing vessels. 

NSCV C7A Clause Description Requirement 
4.3.1.3 Signage Stowage locations for safety equipment shall be marked. The signage shall indicate the type of equipment and the quantity if more than one unit is stowed there. The signage should use symbols conforming to IMO Res A.760(18).  
4.5.3 Liferaft stowage For Class 1 vessels only - Means shall be provided to ensure that the stowage positions of liferafts, the launching devices (where fixed launching devices are used), and the areas of water into which the liferafts will be deployed shall be sufficiently illuminated 
4.5.4 Liferaft signage Posters, signs, or operating instructions shall be provided on, or in the vicinity of liferafts and their launching controls and shall— 
a) illustrate the purpose of controls and the procedures for operating the appliance and give relevant instructions or warnings; and 
b) be easily seen under emergency lighting conditions. 
NOTE: Symbols used should conform to IMO Resolution A.760(18) Symbols Related to Life-saving Appliances and Arrangements. 
4.6.4 Illumination of dinghy stowage and launching areas Means shall be provided to ensure that the stowage positions of dinghies and the areas of water into which the dinghies will be deployed shall be sufficiently illuminated 
4.7.3 Illumination of buoyant appliance stowage areas Means shall be provided to ensure that the stowage positions of buoyant appliances are sufficiently illuminated. 
4.8.2 Lifebuoy stowage 

A lifebuoy shall be stowed so that it— 
a) is not permanently secured; 

b) is readily accessible to crew or passengers; and 
c) can be easily deployed. 
Where two (2) lifebuoys with self-igniting lights and smoke signals are required, they shall be stowed to allow for immediate access and rapid deployment from the operating position. 

4.9.2 Lifejacket stowage Lifejackets shall be stowed in clearly marked, easily located, and readily accessible stowage areas. The stowage areas shall be dry and protected from weather and excessive heat. 
4.9.3 Lifejacket signage Written and pictorial instructions to be provided adjacent to lifejacket stowage area 
4.10.1 Pyrotechnic stowage Pyrotechnic and smoke signals shall be stowed in a buoyant watertight container, fitted with a handle or lanyard. The container shall be clearly and permanently marked as to its contents. On Class 1 and Class 2 vessels the container shall be readily accessible to the crew. On Class 3 vessels the container shall be mounted in a float free position and be readily accessible. 
5.3, tables 2, 3 and 4 Dinghy replacement 

Except for certain Class 3C vessels, a dinghy is not permitted to be used as an alternative to an inflatable liferaft.  

For Class 3C vessels <25m, a dinghy may continue to be used as an alternative to an inflatable liferaft provided it meets the requirements of NSCV C7A Annex C within 12 months from next periodic or renewal survey, or within 24 months from 1 January 2018, whichever occurs first. Where the existing dinghy being used in place of a liferaft is due for replacement, it shall be replaced by an inflatable liferaft. 

5.3 table 2 Open reversible liferafts Class 1 vessels that carry buoyant appliances (Carley Floats) and operate in areas where it may be unsafe for persons to be immersed in water (e.g., Water temperatures below 15 deg or dangerous wildlife) must replace their Carley floats with Open Reversible Liferafts (ORLs). Vessels that opt to carry buoyant appliances must have a risk assessment included in their SMS that justifies the use of buoyant appliances in lieu of ORLs. 
5.3 table 2 Buoyant appliances and lifebuoys A vessel shall carry the kind and quantity of buoyant appliances and lifebuoys mentioned in Table 2 
5.3, tables 2, 3 and 4 Number of lifejackets A vessel must carry lifejackets for 100% complement. In particular, 1E vessels that were permitted to carry fewer lifejackets under the USL Code must now carry 100% complement. 
F2.6 Painter on Carley floats A buoyant appliance shall be fitted with a painter that shall be of sufficient length to allow deployment of the buoyant appliance from its maximum possible height and have a breaking strength of 10 kN. 
H3.2 Medical equipment and supplies Equipment supplies shall be in accordance with H3.2. NOTE: This includes the kind, quantity, scale and standard of medical equipment and supplies. NOTE: GES 2015/01 may also apply for C, D and E water vessels where the owner/master has done a risk assessment. 

LPG Installation case study 

In June last year an explosion occurred on board a houseboat when the owner attempted to light a gas-powered stove via a piezo ignition switch. The explosion caused catastrophic damage to the vessel structure & fittings and both people on board were hospitalised with burn related injuries. 

AMSA inspected the 9.9m vessel following the incident and found that major structural damage had occurred to the superstructure, windows, doors, hatches, compartments, fittings and fixtures. The join of fibreglass between the hull and superstructure was cracked and had delaminated away from the hull in the area surrounding the lower cabin. The carpet and curtains were singed, whilst the galley and dining area floor had delaminated. The dining table had also been flipped upside down. 

gas explosion

The vessel had a fixed gas system installed which was certified to supply a cooktop, refrigerator, and instantaneous hot water system. Two 8.5kg LPG cylinders were located on the upper deck during inspection, one was connected to the fixed gas system. 

Two gas connections were located in the galley during inspection. One supplied the gas cooktop while the other was not connected to an appliance. There was no gas fuelled refrigerator on the vessel. The hot water system was connected to one of the LPG cylinders on the upper deck and was not supplied by the fixed gas system. A valve and connection linked to the fixed gas system was also located externally aft of the vessel, but it was not connected to a hot water system. 

Following the incident AMSA engaged a gasfitter to inspect the fixed gas system. At the time of inspection, the gasfitter found the system was not compliant with the requirements of Gas Supply (Consumer Safety) Regulation 2012 because: 

  • Gas appliances as indicated on the compliance plate were not installed 
  • Where appliances weren’t fitted, the connection points were not sufficiently capped to prevent a gas leak 
  • A gas detector was not on board 

Following a pressure test of the system, the unused gas connection in the galley was found to be leaking when tested in the off position. The connection and valve located externally was also found to be leaking. The components of the external connection were made from a half-inch kinko nut and olive compression fitting. These fittings are manufactured for use in water copper pipe systems and are not compliant with gas system requirements.  

The gasfitters report stated that it is likely the LPG leak from the disconnected gas fridge isolation valve in the galley would have contributed to the presence and accumulation of explosive vapour within the vessel. 

AMSA concluded that: 

  • Propane gas was most likely the cause of a flammable gas air mixture within the vessel 
  • A faulty gas isolation valve leaking through an open outlet within the kitchen cabinetry was likely the source of uncontrolled gas escape 
  • The source of ignition was almost certain to be the piezo ignition switch on the gas cooktop which was operated by the owner in the moment before the explosion 

AMSA reminds surveyors of the periodic survey requirements listed in Table 9 of SAGM Part 2. Surveyors should look for signs of alterations, modifications, deterioration and disconnections when inspecting the condition of LPG systems. Verification of compliance certificates/plates for installed gas equipment is also required under Table 9. In accordance with section 6 of the National Law, gas systems must also comply with the applicable state or territory gas safety regulator requirements. A licensed gasfitter should inspect the system if there are any concerns.  

B extended operations 

NSCV Part B defines B extended operations as: 

...for use beyond 200 nm from the baseline of any of the following but in waters to the outer limit of the EEZ:  

(I) the Australian mainland; 

(ii) the Tasmanian mainland; 

(iii) a recognized island 

Additionally, the definitions of 1B extended, 2B extended and 3B extended state that the vessel must comply with the NSCV requirements for use in operational area unlimited domestic operations

The phrase operational area unlimited domestic operations is of crucial importance as this is the definition used for Operational Area Category A. 

What are the implications? 

A vessel that is used for operations in B extended area is required to meet the NSCV requirements for class 1A, 2A or 3A vessels as applicable where specific B extended requirements are not defined. 

The NSCV contains several significant changes between Operational Area Category B and Operational Area Category A. 

A summary of the changes that may need to be addressed is given in the table below (current for NSCV as at March 2022) 

NSCV Part Application for Operational Area B extended vessels 
C1 

The accommodation level must be AL72+ 

Some changes apply in Chapter 6 requirements may apply 

C3 Vessel must comply with robust operation and LR SSC G5 service area restriction, this may require reassessment of the vessels structure. 
C4 

Some class 1 vessels will have an increase in fire risk category: 

e.g., Class 1 vessels with 13 – 36 berthed passengers and Class 1 vessels with 37 – 200 day passengers will increase from FRCIII to FRCIV 

C5A 

Class 1 vessels must comply with Marine Order MO12 irrespective of length. 

Class 2 vessels greater than 35m and 500GT must comply with MO12 

Bilge pump requirements change. 

C5B The capacity of emergency power supply in class 2 and 3 vessels increases from 2 to 12 hours 
C5C No changes 
C5D No changes 
C6A 

5B stability criteria is not applicable to catamarans 

All vessels must apply the severe wind and weather criteria in Annex H 

C6B Class 1 vessels must meet SOLAS Chapter II-1 
C6C No changes 
C7A Vessels must comply with Marine Order MO25 and Marine Order MO11 
C7B Vessels must comply with Marine Order MO27 
C7C Vessels >24m must comply with Marine Order MO27 
C7D No changes 

These changes are applicable for new vessels. Some, if not all, will apply to transitional vessels. It is strongly recommended that a gap analysis is carried out early in the process to identify any areas that require upgrading when any vessel is considering operating in operational area B extended. 

N & C flag requirements

Recently AMSA has become aware of some confusion surrounding the requirements for the provision of signal flags under the NSCV. 

The requirement for signal flags is enlivened under NSCV C7B section 4.7 and table 3 (see below) 

N and C flag requirements

Signal lights, lamps and flagsl

There is no requirement in table 3 to carry a full set of international code flags for vessels in operational areas C, D and E. Section 4.7 only requires carriage of the specific flags which are appropriate to maintain safe operations (which is upon the operator to decide based on their operational risk assessments in the vessel SMS). The example given being the “A” flag for diving operations or the “H” flag for pilotage operations   

It is often thought that the “N” & “C” flags are required as part of section 4.7. There is no direct requirement under the NSCV for the carriage of these flags. The USL code Section 13 did require the “N” & “C” flags for vessels in service category class 1C and 2C and all vessels in service areas A & B. The NSCV does not require the carriage of the “N” & “C” flags for vessels in C, D or E service areas. 

Testing and servicing of fire suppression equipment  

Written by the Fire Protection Industry (ODS & SGG) Board 

The Fire Protection Industry (ODS & SGG) Board (FPIB) is encouraging domestic commercial vessel owners and operators to prioritise the regular testing and servicing of fixed fire suppression equipment, irrespective of when a vessel is due to be surveyed under Marine Order 503. 

For owners and operators of vessels in low or medium survey frequency it might seem convenient or cost-effective to coordinate testing or servicing of fire suppression equipment when the vessel is due to be surveyed.  

However, these owners and operators should not take unnecessary risks by putting off routine testing and servicing of fixed fire suppression systems and/or portable extinguishers as these are safety-critical devices and it is vital they function properly in the event of a fire to preserve both life and property. 

While some vessel owners and operators may view this maintenance as an unnecessary expense because they consider the possibility of a fire to be low, a lack of testing and servicing can lead to much higher costs down the track. 

Owners and operators may not be aware that the chemical agent inside the fire suppression system on their vessel has a higher chance of unintentionally discharging the longer it goes untested or serviced. In some cases, this inaction can result in the fire suppression system or portable extinguisher not operating at all. 

In terms of costs, a gas cylinder installed in a fire suppression system on an average size marine vessel typically contains around 13 kilograms of scheduled extinguishing agent, costing the vessel owner roughly $2,500. If this system discharges due to a lack of adequate maintenance over time, not only does the vessel owner have to pay for a replacement cylinder with new chemical agent, but they must also pay an installation cost – which should be carried out by a licensed fire technician. In simple terms, overhauling an entire fire suppression system far outweighs the cost of having an existing system tested or serviced. 

Vessel owners and operators should aim to have their fixed fire suppression system serviced every 12 months, and portable extinguishers every 6 months. These are the recommended timeframes as stated in Australian Standard 1851 – Routine Service of Fire Protection Systems and Equipment. 

Vessel owners and operators should also have their fixed fire suppression systems and portable extinguishers undergo pressure testing every five years to ensure there are no leaks to the gas cylinder, and that it will work correctly if required.  

Owners and operators should be aware that when gas cylinders become low on pressure, they have a higher chance of discharging chemicals into the atmosphere which can cause depletion to the earth’s ozone layer or contribute to global warming depending on the substance.  

The FPIB would encourage all accredited marine surveyors to take a proactive approach in educating vessel owners and operators around the importance of testing and servicing fire suppression equipment on a regular basis. This might be as simple as a two-minute conversation at the conclusion of a survey. 

We would recommend that if you are a surveyor and have relationships with owners or operators of vessels belonging to the low or medium risk class, that you please raise the testing and servicing guidelines outlined above. Doing so could save lives, as well as save the owner or operator thousands of dollars if they have to replace a fire suppression system unnecessarily. 

Without even realising it, marine vessel owners and operators can actively help to preserve the natural environment by reducing the risk of their fire suppression system equipment unintentionally discharging. 

For any concerns or queries, please reach out via ozone@fpib.com.au 

Have your say: NSCV C1 consultation 

AMSA is now inviting feedback on proposed changes to NSCV Part C1, which contains standards for wheelhouse visibility, escape, accommodation, and personal safety.  

The proposed changes include:  

  • meeting disability accessibility standards   
  • improved standards for escape routes, escape lighting and signage  
  • clarified definitions of ‘special working decks’ and ‘working decks’  
  • further risk management associated with a person falling overboard and the recovery of persons overboard, by improving technology requirements and inclusion of a ‘no-climb’ zone  
  • a minor relaxation of when toilet and ship sanitation facilities must be fitted  
  • improved ventilation requirements   
  • improved safety requirements for pilot vessels  
  • changes to gangway requirements  
  • alignment of some requirements with already adopted national and international legislation and standards.  

It is proposed that the amended NSCV Part C1 will only apply to newly constructed vessels and vessels that undergo modifications to the arrangement, accommodation, and personal safety aspects of the vessel. 

Following consultation, we propose that the new standard will come into effect on 1 January 2023 with a transition period of two years. 

Consultation is open until 24 April 2022. 

Learn more and submit your feedback 

National Law review 

The Australian government has commissioned an independent review of Australia’s Domestic Commercial Vessel safety legislation and associated costs and charging arrangements. 

The review will be undertaken by an independent expert panel, supported by the Department of Infrastructure, Transport, Regional Development and Communications. AMSA is a stakeholder in this review. 

The review will be conducted in two phases, with the first to focus on the National Law framework (Phase 1) and the second to consider national system delivery costs and future funding options (Phase 2). 

Submissions for phase 1 of the review are being accepted until 30 March 2022. You can visit the Department of Infrastructure, Transport, Regional Development and Communications ‘have your say’ webpage to make a submission. You can also email submissions to dcvsafetyreview@infratsructure.gov.au.  

Discussion of the National Law review has also been added as an agenda topic for the upcoming surveyor workshops. This is so we can hear your view, but note this is not an AMSA review, you need to make comment directly to the Department. 

Construction barge safety campaign 

AMSA has launched a new safety campaign focusing on the importance of regularly reviewing risks to protect lives on construction barges. 

A dedicated campaign website is now available to support owners, operators and individual workers and we encourage you to share the campaign information and advice with your clients. 

A series of free workshops covering risk assessment will also be delivered by AMSA, in partnership with state and territory WHS agencies. 

The first workshop will be presented in partnership with WorkSafe NSW on 29 March in Drummoyne, Sydney. More workshops in other locations will be announced. 

Please recommend this workshop to your clients in the greater Sydney area. For more information and to register online click here

Exemption 6 has been updated 

AMSA has recently updated Exemption 6 Marine Safety (Periodic survey, equipment certification, compass adjustment and liferaft servicing). The new amendments provide greater flexibility for operators when liferafts are being serviced, repaired, or replaced. 

DCVs can now operate when a liferaft is out of action, provided there are enough liferafts to accommodate all persons onboard the voyage. 

Read more about the update here

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