• Large file transfer
• What to do if you recieve a complaint about a survey
• Owner’s responsibilities under Marine Order 503
• Fibreglass sheathing of timber vessels
• Recommendations from the investigation into the loss of the passenger vessel Conception
• Battery safety
• Material alert
• Have your say on the new standard for watertight and weathertight integrity

Large file transfer

On occasion, we have previously received reports from accredited surveyors via a Dropbox or Google Drive link. Our IT department have advised us not to access these files for security reasons.

AMSA has a file transfer protocol (FTP) site available for use by accredited surveyors. If you need to send large files, please contact us via DCVSurvey@amsa.gov.au and we will provide you with temporary access to upload your files. 

What to do if you receive a complaint about a survey 

We recognise that conducting survey activities in the National System may not always be an easy task. Appeasing vessel owners, companies and insurers can be a tricky business, conflicts and complaints may arise.  

An accredited marine surveyor has obligations under section 34 of the regulations to notify the National Regulator about certain matters. You must notify AMSA within 5 business days of becoming aware of a written complaint about a survey. You can do this by emailing details of the complaint to DCVSurvey@amsa.gov.au.  

AMSA considers each individual complaint and takes a pro-active approach to managing these issues. AMSA, however, does not get involved in complaints relating to insurance claims, consultancy work, pre-purchase surveys, commercial disputes, or financial matters. 

On all occasions, AMSA seeks that complaints are raised with the accredited surveyor first in hopes of a satisfactory resolution.

Since the beginning of the accreditation audit scheme, AMSA has conducted 28 complaint audits against 24 different accredited surveyors. During these audits, a total of 62 findings were sent to the respective surveyors for corrective actions for direct response.  

One surveyor had 19 findings against a single survey activity. The surveyor was found to have contravened section 32 of the regulations and received an official counselling letter.  

During another audit, it was revealed an accredited surveyor received an official complaint but failed to alert the National Regulator. The surveyor was found to have contravened section 34 of the regulations and received an official counselling letter.   

Owner’s responsibilities under Marine Order 503

Owners of domestic commercial vessels have responsibilities to ensure the conditions on a certificate of survey are being complied with at all times. This includes ensuring that the vessel completes periodic surveys in accordance with the frequency mentioned in schedule 3 of Marine Order 503 (MO503).  

Section 11 (1) (c) of MO503 requires the owner to ensure the National Regulator is provided a report setting out the condition of the vessel and the extent of its compliance following periodic surveys.

It has been brought to AMSA’s attention that not all owners are receiving clear communications from their accredited surveyor with respect to periodic and renewal survey activities. This may be because the surveyor directly uploads into MARS without providing the owner with any closure or report. It may also be due to the surveyors holding reports for a period of time for various reasons.  

AMSA recommends providing the owner with a copy of the AMSA901 (or surveyor’s equivalent) and AMSA586 forms following a survey. These forms enable the surveyor to communicate survey related matters to both the National Regulator and the vessel owner. This also ensures the owner holds evidence that they have complied with the requirements of MO503.

Fibreglass sheathing of timber vessels

We’ve recently received questions about fibreglass sheathing of timber vessels and the survey requirements for such vessels. AMSA considers sheathed timber vessels as being primarily of timber construction and as such, they must be surveyed by surveyors accredited to survey timber vessels.

AMSA does not recommend the sheathing of timber vessels due to the following:

• The 10 yearly survey requirement of withdrawing sample fastenings still applies. This may require costly repairs.
• During an out of water survey, the attending surveyor must be satisfied that the hull structure continues to meet the applicable standards. The FRP sheathing would limit the extent to which the hull may be inspected, and it could result in the surveyor not recommending the survey if they are not satisfied that the hull condition can be suitably verified.
• FRP sheathing of old timber vessels must be done under very controlled conditions to ensure a watertight bond between the timber and the sheathing. Due to the nature of timber, the hull planking expands and contracts which is why seams are caulked. The FRP sheathing would not flex to the same extent as the timber. This may result in damage to the planking, or delamination of the sheathing from the timber which may then introduce moisture or rot that may not be readily seen.

Recommendations from the investigation into the loss of the passenger vessel Conception

DCV Safety Alert: 1/2021 is available on the AMSA website now. It aims to raise awareness of recommendations made by the United States National Transportation Safety Board (NTSB) following the investigation into the fire and subsequent loss of the passenger vessel Conception. The safety alert highlights, among other things, the need for suitable smoke and fire detection systems and the importance of emergency escape routes.

While this incident didn’t occur in Australia, the findings of the NTSB investigation provide our industry with an opportunity to learn from the unfortunate experience of others.

Battery safety

Batteries both portable and fixed, onboard vessels have the potential to cause harm. Lithium-ion battery installations, in particular, have additional requirements in AS/NZS 3004:2 that must be observed for new installations. 

This includes observing IP ratings, specified ventilation and temperature limits, battery monitoring systems, alarms, and automatic load disconnection. 

Further guidance and information about batteries is available at the weblinks below:

• Western Australia Department of Mines, Industry Regulation and Safety—Lithium-ion battery safety
• Maritime & Coastguard Agency UK - Electrical Installations—Guidance for Safe Design, Installation and Operation of Lithium-ion Batteries

Material alert

DNV recently notified AMSA they have suspended two material certificates for grade VL5083 aluminium plates manufactured by Henan Mingtai Industry Co. Ltd. China (Mingtai).

The certificate numbers are AMMM0000053 Rev. 1 and AMMM00002RA. Further information on the suspended certificates is available on their website.

Have your say on the new standard for watertight and weathertight integrity

We have opened consultation on a new, more modern standard for watertight and weathertight integrity on domestic commercial vessels.

Consultation for NSCV C2: Watertight and weathertight integrity is open from 18 January to 28 March 2021.

This proposed change is likely to be of interest to boat designers, boat builders, naval architects, and industry groups. We encourage you to share this message with interested parties.

Why we need a new standard

The requirements for watertight and weathertight integrity for domestic commercial vessels are currently spread across three technical standards contained in the Uniform Shipping Laws (USL) Code that were developed more than 40 years ago. Section C2 is a long outstanding section of the NSCV that needs modernising.

This draft standard updates the requirements for watertight and weathertight integrity to reflect current technologies and to align with international standards and best practice. It has been co-designed with the guidance of a technical advisory panel comprising accredited marine surveyors, representatives of industry associations and educational institutions.

What we are proposing is a performance-based standard with multiple options to achieve compliance and address several safety issues with the current requirements, including over-loading.  

Find out more about the proposed changes and make a submission at www.amsa.gov.au/watertight-weathertight. You can also send submissions via email to consultation@amsa.gov.au

• Application form updates
• Initial survey applications
• Surveying vessels >35m
• Incomplete recommendations
• Transitional survey requirements and certification
• Electrical plan approval requirements

Application form updates

The online forms for certificate of survey and certificate of operation have been updated.

AMSA 576 form used to renew a certificate of survey, is redundant. The AMSA 521 form now allows users to apply for a new certificate of survey or renew a certificate.

AMSA 549 form, used to vary a certificate of operation, is redundant. Its contents have been combined into the AMSA 504 form.

Please ensure your clients are aware of these updates.

Initial survey applications

To manage workload effectively AMSA has updated the process for assessing initial survey applications (SAPP).

Previously, an assessor was assigned upon receipt of an application. Survey codes and the assessor contact details were provided by email to the applicant.

Now we assign the assessor to an application only when all survey assessment codes are ready for review. An email is still sent to the applicant providing survey codes and confirming receipt of application. Any request for a status update can be sent to DCVApplications@amsa.gov.au.

If you have a technical question relating to survey of the vessel, quote the SAPP number in your email to DCVSurvey@amsa.gov.au.  The SAPP will be assigned to an assessor at this stage to answer the query.

This change will help us better manage applications, provide faster processing and better support for industry. 

Surveying vessels >35m 

Marine Order 503 (certificates of survey – national law) 2018 (MO503) requires a Recognised Organisation (RO) to survey vessels over 35m, unless:

• it is an existing vessel that was not required to be surveyed by a RO before 1 July 2013, or; 
• the vessel holds an exemption from the requirement to be surveyed by a RO.  

If unable to claim a survey on a vessel >35 meters length, please email DCVsurvey@amsa.gov.au and provide: 

• vessel name and UVI
• survey code(s) 
• the reason a RO doesn’t need to survey the vessel 

 The accreditation team will provide information on how to claim and/or recommend the survey. 

Incomplete recommendations

Surveys must be conducted and documented in accordance with the requirements of the Marine Surveyors Accreditation Guidance Manual (SAGM) Part 2.

MO503 contains the applicable standards that survey recommendations and supporting documentation must cover. Despite these requirements, we have noticed survey recommendations often overlook the aspects below.

NSCV C1—Arrangements accommodation and personal safety

• Requirements for nominated special purpose and special working decks.
• Passengers accommodation, access, escape and evacuation requirements 

USL Code 5C & 5D—Watertight subdivisions

• Height of hatch coamings and sills

NSCV F1—Fast craft requirements  

• Navigation and Collision avoidance equipment requirements

Transitional vessels standards (Schedule 2 Table 1 MO503) 

• NSCV C4 compliance for fixed fire system installation
• NSCV C1, as applicable

NSCV Part B—General requirements

• Measured length - for vessels previously certified as Regulated Australian Vessels

Ensure you cover these items as part of your recommendations. We will continue to use Survey Matters to highlight trends when they arise.

Transitional survey requirements and certification

The transitional vessel requirements under MO503 are now well known. This article provides guidance on managing some of the changes mentioned in Schedule 1 of MO503 citing some recent examples.

Addition of active fin stabilisers

MO503 Schedule 1 Clause 7 Change to vessel structure and watertight integrity

Vessels that undergo a Schedule 1 clause 7 change must complete an initial survey. This type of change requires application for a new certificate of survey which generates a full set of survey codes.

The intent of this requirement is for the vessel to undergo initial survey to the transitional vessel standards. However, you may apply for an alternate survey process if you believe the requirements specified in MO503 Schedule 2 can’t practically be applied. For example, if the changes to the watertight envelop or structure are minor and localised, you may be able to propose an alternate process to meet the requirements.

Recently, for the addition of active fin stabilisers, an initial survey to the extent of the change and renewal survey for the rest of the vessel was approved. This was due to the design basis of the vessel being well documented and no other changes taking place. 

Submit any alternate survey applications before making changes. This allows us to confirm the approved form of survey beforehand. It also ensures the correct surveys are undertaken before, during and when commissioning the change. 

Installation of hydraulic knuckle crane

MO503 Schedule 1 clause 6 (f) – Removing repositioning, installing, cranes, net reels, tanks etc

This clause requires vessels to complete an initial survey for the areas affected by the change and a renewal survey for the rest of the vessel. Again, these changes require an application for a new certificate of survey, to capture the vessel changes in the MARS certification system. 

This type of change doesn’t require an alternate survey approval. Assess the scope of the change to vessel structure and systems and undertake initial survey as required. On completion of surveys, submit the applicable documents with your recommendations. Forms may be annotated to indicate the extent of the change if required.

Ensure you provide justification for any surveys you mark as not required. A detailed justification allows the assessor to understand the rationale for the recommendation. Areas of the vessel not subject to initial survey must undergo renewal survey confirming compliance with the transitional vessel standards in Schedule 2.

Lightship changes

MO503 Schedule 1 Clause 6 (c) and/or (d) – Variation to displacement of at least 4% and/or LCG by at least 2%.

Unlike the examples mentioned above, lightship variations don’t necessarily need an application for a new certificate of survey. This is because Section 9 (d) of MO503 requires only renewal type surveys for this change. 

Follow the process below during renewal survey when a vessel becomes transitional due to lightship changes only.

Inform the owner that the vessels lightship particulars have changed, and the vessel is now considered transitional. The vessel must be surveyed to the transitional standards mentioned in Schedule 2 of MO503. Explain that the change requires the vessel to undergo further surveys. The vessel will need to undergo a new stability assessment to the transitional standards. This may result in a change to the number of persons permitted on board the vessel. 

Email DCVApplications@amsa.gov.au to notify us of the change, including evidence you’ve been engaged to conduct the survey(s). If the owner has applied to renew the certificate of survey, we will add a stability assessment to the application in MARS and provide you with the code. Let us know if you need any further codes created.

Submit your survey reports and recommendations as normal when the additional survey activities are complete. You must also provide AMSA with a list of the applicable transitional standards the vessel has been surveyed against. Note: the AMSA 901 form contains a checklist for transitional vessel renewal surveys.

AMSA will assess the renewal application once we receive all the transitional survey reports. During assessment we will make any updates or changes to the person numbers from the new stability assessment. We will record the transitional standards that apply to the vessel in MARS. This will display on the certificate and future vessel reports.

General requirements and reminders

All activities must be marked either recommended, recommended with conditions, not recommended or not required for the application to progress to assessment. An application will not progress if survey activities remain as ready for assessment or assessment in progress. You must provide a reason for surveys marked not required. 

Chapter 2.9 of SAGM Part 2 also requires justification for any conditions proposed when recommending with conditions.  

You must notify the operator if their vessel becomes transitional and inform them of their obligation to notify AMSA. The vessel may require a temporary operations permission to continue operating. 

A lightship declaration is not an acceptable form of lightship survey for initial surveys. 

Progress

Over 400 vessels completed transitional vessel survey in the last financial year, in addition to newly constructed vessels entering service.  At this rate, it is estimated that 80% of the surveyed fleet will comply with either the transitional vessel standards or the NSCV standards in full, by 2029.

Electrical plan approval requirements

The requirements for plan approval are found in the Surveyor Manual SAGM Part 2. The manual states electrical plan approval is required for vessels with installations greater than 32V and vessels with complex extra low voltage electrical systems. 

Design and installation of electrical systems on DCVs must meet the requirements of:

• National Standard of Commercial Vessels, Section C5B - Design and Construction - Electrical.
• AS/NZS 3004.2014 Electrical Installations, Marinas and Boats, Part 2 – Boat installations.
• AS/NZS 3000:2018 Electrical Installations, also known as the Wiring Rules. 
• AS/NZS 3008:2017 Electrical Installations, Selection of Cables and Voltage Drop.

Accredited surveyors must be familiar with SAGM, however other bodies involved in DCV construction may not be so familiar. The following information aims to streamline the electrical plan approval process.

Note: this is a guide only and shouldn’t be considered a definitive checklist. Not all items listed will apply to all vessels.

SAGM doesn’t currently contain definitions for basic or complex electrical systems. However, as a guide, a basic electrical system could be considered to comprise:

• One battery (no dual battery system, no trolling motor or anchor winch batteries).
• Minimal navigation lights (Port, Starboard, Stern, Masthead, Anchor, Compass light).
• Minimal electrical equipment (One sounder, one bilge pump, one high level alarm).
• Only one engine with electric start.
• An engine that provides basic charging of one start battery.
• No solar, wind or shore power facility to charge battery.
• No inverter or DC-DC converter/charger.

Anything more advanced than a basic system should be considered complex.

Electrical plans should include:

• Whole of vessel single line and/or full line diagrams.
• System used for earthing.
• Charger/Inverter description or data sheet including any solar systems.
• Load and voltage calculations.
• Cable data sheet. 

Drawings must be clearly labelled with a version and date. They must be comprehensive and easy to read. There are no direct rules for how they must be drawn, but they should be:

• In English, using standard electrical symbols and drawing conventions e.g. AS/NZS 3000 Appendix J.
• Drawn on A4 paper at a minimum and clearly labelled. Particularly when systems are on multiple pages.
• Clearly indexed to link with adjacent drawings.

Drawings for Low Voltage (LV) and complex Extra Low Voltage (ELV) systems shall include the items below, where applicable:

• Voltage for each circuit.
• Battery Ah or CCA capacity.
• Type of battery- e.g. Lead acid, AGM, Li Ion.
• Battery isolation provisions – e.g. double pole if the system is isolated from Earth.
• Hull bonding details if applicable.
• Switch/circuit breaker sizes.
• Battery protection, i.e. fuses or circuit breakers and sizes.
• Cable sizes.
• Blocking diodes, if used.
• Dedicated radio and emergency batteries.
• Paralleling and change over switches.
• Solar panels and their detailed connection into the system.
• Any notes concerning the location of a battery and ventilation installed including chargers.

Components used in DC systems must be suitable and rated for use in those systems. In an AC electrical circuit, the voltage is zero twice in each cycle. This allows the arc formed whilst switching to extinguish. In a DC system the voltage is constant. Once an arc is formed it continues to grow as the gap widens and is only extinguished when the air ionisation and air currents formed reach their limit.

As well as the details listed above, LV drawings should also include the information below for each system.

Generators:

• Type and Data sheet.
• Capacity – kVA or KW.
• Voltage, phases and frequency.
• Protection circuits, control and metering instrumentation.

Shore power arrangements:

• Polarity test and interlocking facilities.
• Detection of phase sequence and phase reversal facilities, if fitted.
• The ship/shore supply change over switch operating in all live conductors including the neutral 

Distribution system:

• Separation of LV and ELV.
• Cable size.
• Circuit protection.
• RCDs, RCBOs.
• AC - Main switchboard and sub-boards.
• DC – Sub boards, radio and navigation light boards.
• Emergency supply, if an emergency generator is installed

Other details to provide:

• The earthing system, including the earth plate on vessels with a non-metal hull, equipotential bonding and the MEN point at the generators and inverters, as appropriate.
• The lightning protection system on vessels with non-metal hull/superstructure – AS/NZS 1768.
• Load details of motors and other equipment.
• Cable data sheets with current capacity for all the cable sizes.
• Control circuits, e.g. remote shut down of engine room fans and pumps.
• Any other information pertinent to the electrical design of the vessel e.g. manufacturers data sheets.

Further information on ELV electrical systems is available in the instruction to surveyors DCV-ITS-015.

Season's greetings

The AMSA team would like to wish all our readers a very merry festive season.

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

In this edition

• Audits and application assessments
• Certificate of survey refusal reasons
• Understanding the surveys required notice letter
• How to apply for a periodic survey extension
• Navigation light supply
• Novel vessel policy
• Relevant reading

Audits and application assessments 

AMSA audits accredited marine surveyors to ensure the processes set out in the National Law – Marine Surveyors Accreditation Guidance Manual (SAGM), Marine Order 503 and the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the Regulations) are followed correctly.  

For example: 

• The assessment of certificate of survey applications identified major non-conformances in the plan and commissioning survey for two passenger vessels. These included: 
• Required plans not submitted. 
• Plans approved but indicated that parts of the vessels were non-compliant with the relevant standards. 
• No evidence of required inspections being conducted throughout the survey process. 
• Inability to demonstrate that the vessels complied with the NSCV stability or fire safety requirements. 

Both survey applications were refused and AMSA formed the view that the surveyor had contravened sections 32 and 36 of the Regulations.  

Following a show cause process, the surveyor had conditions placed on categories a, g, h, and k of their accreditation. The conditions limit the type and complexity of vessels for which the surveyor can now undertake initial survey. The surveyor is prevented from undertaking surveys on more complex vessels that require greater proficiency in passive and active fire protection measures; watertight and weathertight standards; and propulsion and engineering systems. 

Another surveyor had their accreditation varied following complaints raised by regional AMSA staff. Desktop audits of various survey activities identified that the surveyor often failed to submit survey recommendations to AMSA until several months after the completion of the surveys.   

Incident investigations undertaken on some of these vessels identified further non-conformances and AMSA formed the view the surveyor had contravened sections 32, 33 and 36 of the regulations.  

Following a show cause process, the surveyor had conditions imposed on their periodic survey accreditation. The conditions require the surveyor to provide AMSA with additional evidence of certain survey items, along with their survey reports, within 10 days of the survey date. 

Certificate of survey refusal reasons 

AMSA approves around 97% of Certificate of Survey (CoS) applications. This means around 3% of CoS applications are refused, which is an undesirable outcome that can occur for several reasons.  

Reasons for CoS refusals

Below is a breakdown of why initial CoS applications were refused in 2021-2022.

• Engineering/Machinery (C5A): 14%
• Watertight weathertight integrity (USL): 8%
• Fire safety (C4): 16%
• Intact astability (C6A): 22%
• Survey process (SAGM): 24%
• Structure (C3): 11%
• Damage stability (C6B): 5%

SAGM specifies survey requirements for vessels by prescribing a consistent process for accredited marine surveyors (AMS) to follow. The National Law requires an AMS to apply the process set out within SAGM to ensure nationally consistent survey outcomes and safe vessels.  

Failure to follow the SAGM process can result in the refusal of an application. In fact, this is the most frequent reason for refusal of an initial CoS application. Moreover, failure to implement SAGM removes a layer of assurance which can result in non-compliant vessels. 

Compliant survey vessels are the result of three overlapping parties working together to produce quality outcomes:  

• designers,  
• builders, and  
• surveyors.  

Designers and builders have general safety duties to ensure a vessel is designed, constructed, and subjected to tests and trials as required, to guarantee it meets the relevant standards. Survey assurance is a critical control to validate the quality systems within the design and construction process and independently verify a vessel meets the standards expected by the Australian public.  

It is not a surveyor’s sole responsibility to ensure a vessel complies with the applicable standards. Rather, surveyors ensure a designer and builder’s quality systems are being implemented and document the applied process. Surveyors are critically important and responsible for third party assurance of the design and construction process, on behalf of AMSA.  

When AMSA identifies non-conformances, we prefer to work collaboratively with the surveyors. AMSA identifies opportunities for improvement in the survey process and assists an AMS to implement corrective actions. This ensures the same non-compliance does not reoccur on future vessels. AMSA does this primarily in two ways:  

• by providing an opportunity for additional information to be provided before we decide an application
• through our formal audit program.  

These interactions with AMSA are opportunities for surveyors to correct an immediate issue and improve their survey process to avoid repetition. The result of improved processes is a higher standard of surveying, a rise in the quality of the vessels built, and a reduction in AMSA intervention.  

Surveyors are subject to conditions of accreditation and a failure to conduct surveys in accordance with an applicable standard is a breach of these conditions. This may result in AMSA taking compliance action against a surveyor, such as formal warnings, infringements, variation, suspension, or revocation of accreditation.  

Understanding the surveys required notice letter 

A recent update in MARS now allows AMSA to modify the survey activities listed in the Surveys Required Notice Letter prior to it being sent to the applicant.  

This update was implemented following feedback that letters were generic and contained survey activities that weren’t required for an application, for example where a vessel has undergone modification. This change has been well received.  

However, AMSA has also received applications for new certificates of survey where the full extent of modifications weren’t included. In these instances, the Surveys Required Notice Letter generated without all of the required survey activities being listed. 

This has resulted in submissions that do not cover all the survey activities necessary to meet the requirements of Marine Order 503 and/or Marine Order 507 for the issue of certificate(s). This has delayed the issue of certificates until additional surveys were undertaken and the required submissions were assessed.  

The excerpt below from the Surveys Required Notice Letter addresses the issue of additional surveys: 

Will any other surveys be required for my application? 

The survey activity codes listed above have been generated based on AMSA's understanding of the facts and circumstances presented in your application. 

However, the surveys necessary for your vessel to meet the requirements of Marine Order 503 and/ or Marine Order 507 and be granted a certificate(s) may differ from the survey activity codes above. 

You should seek advice from your surveyor(s) to determine if additional surveys are required for your vessel, particularly if your vessel has been modified. Please have your surveyor contact dcvapplications@amsa.gov.au if additional activity codes are required. 

Surveyors may also mark a code as "not required" if, in accordance with the above Marine Orders and the National Law— Marine Surveyors Accreditation Guidance Manual 2014 (the SAGM), a survey listed above is not required.  

Note: Failure to complete the surveys required by the above Marine Order(s) and the SAGM may result in delay or refusal of your application. 

Accredited marine surveyors are reminded to address such situations with the applicant, conduct the required surveys and make the appropriate submissions.   

How to apply for a periodic survey extension 

Marine Order 503 allows for periodic surveys to be conducted within the three months before or after the due date. A vessel can continue to be operated without seeking any extensions during this six-month period. 

• Example – if a vessel is due for periodic survey on 1st October, the vessel can be surveyed between 1st July and 1st January. 

If the survey can’t be completed within the six-month window provided by Marine Order 503, an extension can be requested as follows: 

Exemption 6 – this exemption can only be used to apply for an extension for up to 90 days after the period provided by Marine Order 503. 

• Example – A vessel’s six-month window runs from 1st July until 1st January – exemption 6 can only be used to apply for an extension until 1st April.  

Exemption 7 - this exemption can be used to apply for an extension for a periodic survey by using the ‘another temporary use’ option (Division 2). This would allow for an application to be made outside the timeframes provided for in both Marine Order 503 and Exemption 6.  

• Example – A vessel’s six-month window runs from 1st July until 1st January and the period for an exemption 6 application has passed (1st April). If you need to apply for a further extension to complete the periodic survey, an exemption 7 application is required. 

Applying for an extension to conduct year 5 surveys for EX40 vessels 

Exemption 40 allows for year 5 in and out of water surveys to be conducted within the three months before or after the due date. The vessel can continue operating without seeking any extensions during this six-month period. 

• Example – if a vessel’s due date is 1st October, the vessel can be surveyed between 1st July and 1st January. 

If the year 5 surveys for an EX40 vessel can’t be completed within the six-month window an extension can be requested under Exemption 7 Division 2 - using the ‘another temporary use’ option.  

• Example – if a vessels six-month window runs from 1st July until 1st January and you need to apply for a further extension, an exemption 7 application is required. 

Navigation light supply 

AMSA understands there is a conflict between NSCV C5B and AS/NZS 3004.2 with regards to navigation light supply.  

NSCV C5B states:

5.3.2 Navigation lights 

Each light must be wired by a separate circuit to a:  

1. discrete section of a distribution board; or  
2. panel dedicated to navigation lights.  

The use of junction boxes in navigation light circuits must be limited to those needed to connect the navigation lights to fixed wiring. Navigation light circuits must not share wiring enclosures or junction boxes with other circuits.  

Each light must be:  

1. individually controlled; and  
2. protected in each active pole by a fuse or a circuit breaker, mounted on the navigation light distribution board or panel.  

AS/NZS 3004.2 states: 

2.14 Navigation lights supply  

All boats are required to comply with the Internal Regulations for Preventing Collisions at Sea 1972, as amended.  The construction and installation of navigation lights shall be to the satisfaction of the appropriate authority.  

When a boat 24m in length overall or less uses electric lights -  

1. one operation, such as one switch or one position of a switch, shall display the complete navigation light configuration as required for the boat while underway;  
2. another switch or switch position shall display the anchor light only; and 
3. switch functions shall be appropriately labelled.  

EXCEPTION: Sailboats may use additional switches to satisfy underway conditions for both sail and power.  

If a boat is longer than 24m, the supply to each navigation light shall be provided in its insulated phase or pole with a switch and fuse or alternatively by a circuit-breaker fitted on the navigation light distribution board.  

AMSA will accept either method for compliance. However, if using AS/NS 3004.2 AMSA still requires each light to be protected in each active pole by a fuse or a circuit breaker, mounted on the navigation light distribution board or panel.  

Novel vessel policy 

AMSA’s Novel vessel policy statement is now available on the AMSA website. The policy statement identifies the types of vessels that AMSA considers to be ‘novel’ and clarifies what standards vessels must comply with for design approval. It also provides additional pathway information for novel vessels to gain certification. 

The policy is available on the National Standard for Commercial Vessels webpage under Section F3: Novel vessels. 

Anyone planning to design or build a ‘novel’ vessel can email nscvfeedback@amsa.gov.au for further advice on classification and certification. 

Relevant reading 

Planned Maintenance on DCVs - Safety Alert 

AMSA has issued a safety alert highlighting the importance of planned maintenance on DCVs.  

Recent incidents involving engine and machinery failure demonstrate how important maintenance is in preventing breakdowns and serious risks to safety.  

Arc flash safety  

WorkSafe QLD have published information on arc flash and how to manage the associated risks. There is also a short arc flash safety film available on their website. 

Report into the fire on board ‘MS Brim’ 

The Norwegian Safety Investigation Authority (NSIA) has produced a report on the fire on board the battery powered ferry MS Brim which occurred in March 2021. 

In this edition

• Commencement of National Standard for Commercial Vessels (NSCV) C2 – Watertight and Weathertight Integrity
• MARS updates - survey reminder letters
• Administration of fees for specific exemption and equivalence applications
• Temporary operations documents
• How AMSA aligned certificates of survey to state issued certificates when Marine Order 503 was updated
• New regulations relating to air pollution from vessels
• Ensuring correct installation of float free EPIRBs

Commencement of NSCV C2 – Watertight and Weathertight Integrity

NSCV C2 came into effect on 1 January 2023 for new vessels. The new standard replaces USL Code Sections 5C, 5D and 7.

NSCV C2 reflects current technology, international standards, and best practice. It also addresses safety risks highlighted by several fatal and serious incidents over the last four decades. These incidents have highlighted the importance of:

• the effectiveness of watertight and weathertight components such as hatches, doors, and through-hull fittings 
• rapid drainage of water from decks 
• reserve buoyancy 
• not overloading. 

NSCV C2 commenced on 1 January 2023 and a generic equivalent solution (GES) has been issued which allows voluntary compliance with either USL or C2 until 1 January 2025. 

MARS updates - survey reminder letters

AMSA is currently working on a MARS update to provide additional survey reminder letters for vessel owners.

Currently, letters are sent to owners for certificate of survey and EX40 vessels;

• at the time of application
• three months before periodic and renewal surveys are due.

The update will see additional reminder letters generated for survey and EX40 applications that remain open for more than three months. These letters will continue to generate every three months until all surveys are completed, or the applicant opts out of receiving the reminders.

An overdue letter will also now generate for periodic surveys which remain open three months past their due date. Only one reminder letter will be sent for overdue periodic surveys.

The reminder and overdue letters will list surveys that have been submitted including the name of the surveyor who has submitted the work and list the incomplete surveys. Additionally, a survey that has been claimed but not completed will show as incomplete with the surveyor listed. 

Example extract from letter

The table below shows the surveys required to be submitted to AMSA for this application and their current status:

The update is currently undergoing final testing by the system developer. We will let you know when the change takes effect.

The additional reminders will provide applicants with greater visibility of their application status. 

Administration of fees for specific exemption and equivalence applications

The fee generated by AMSA when submitting a specific exemption (SPEX) or equivalence (EMOC) application is based on 1½ hours of processing and assessment time. 

It is AMSA’s experience that defensible and well documented SPEX and EMOC applications can be processed within this time  period. However, complex applications may take longer or cannot be assessed due to a lack of information.  

AMSA can provide additional assessment for applicants in these circumstances. However, as a fee for service agency, AMSA is required to charge for assessment of SPEX and EMOC applications on an hourly basis. 

Please be aware that moving forwards, in circumstances where the initial 1½ hour assessment time is exhausted, AMSA may send an updated estimate of the total number of assessment hours and the associated fee payable. An applicant can decide if they would like to pay the additional fee to continue their application or close their application. 

As specified in Section 51(6) of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013, this fee must be paid in advance and AMSA is not required to continue to assess the application until the amount specified in the notice is paid.  
If the cost of providing the assessment ends up being less than the estimated fee amount, AMSA will refund an amount equal to the difference between the estimate and the cost of providing the assessment.  

Are you issuing temporary operations documents correctly?

Recently we have seen some accredited surveyors complete the temporary operations section of the AMSA 586 form where the relevant criteria for issue was not satisfied.  

It’s important to know that it is not the issue of the signed document alone that exempts the vessel and allows for temporary operations (under Division 5 or 6 of EX07). The vessel must also comply with all the conditions and criteria for the issue of the document. Getting this wrong has serious consequences for the vessel owner, and subsequently for the surveyor issuing the signed document. It may result in contravention of National Law requirements for vessel certification and affect conditions of the vessel’s insurance coverage.

Under divisions 5 and 6 of EX07 an accredited surveyor or recognised organisation may issue a temporary operations document only when all the relevant criteria are satisfied. The criteria for issue generally includes all the relevant vessel surveys being carried out, and the person who conducted the surveys considering whether the vessel complies with the applicable standards for each division.  

Completion of all the surveys is not the only criteria – for example division 6 requires the surveys to be completed and an application for renewal of the certificate to be submitted within a specified timeframe.  For more information see the instruction to surveyors DCV-ITS-002. Please review this instruction before issuing temporary operations documents under division 5 or 6 of Exemption 7. Note – this instruction also includes information about sea trials documents (division 3).

Examples of incorrect and/or erroneous completion of the temporary operations section of the AMSA 586 form

In July 2022, an AMSA 586 form was erroneously completed by a surveyor for a 31.5m class 2B vessel. The form indicated that only the in-water component of the renewal survey had been completed. The surveyor also incorrectly filled in the division 5 temporary operation section (for periodic surveys) with the intention of giving the vessel an extension of time to complete the renewal surveys. Not only had the vessel not completed all the renewal surveys, but division 5 only applies to periodic surveys (not renewal). 

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. The operator must make an application using the AMSA 777 form if they wish to utilise Division 7. 

In May 2022 AMSA identified a class 1 vessel that didn’t hold a certificate of survey when it was involved in an incident. Prior to the incident a surveyor completed an AMSA 586 and issued it to the owner with the division 6 temporary operation section completed. 

Despite the surveyor completing the AMSA 586, the criteria for temporary operations under division 6 was not met because a renewal application had not been submitted for the certificate of survey.
For clarity, division 6 also requires the renewal survey to be completed. 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.

How AMSA aligned certificates of survey to state issued certificates when Marine Order 503 was updated

All National Law certificates are subject to statutory conditions prescribed by Marine Orders. The statutory conditions mentioned in Marine Order 503 (Certificates of survey – national law) were updated in 2018. 

The effect of those changes was that all domestic commercial vessels with a valid certificate of survey were moved into one of three new survey frequency categories - high, medium, or low (which replaced the previous NSAMS survey levels).

The new statutory conditions relating to survey regimes came into force on 1 July 2018 and apply to the vessel from that date. 

The new survey regimes were assigned to vessels and aligned to the survey due dates on each vessel’s previous state issued certificates.

AMSA re-issued certificates with the updated survey levels and due dates (including updated expiry dates) to assist certificate holders in understanding how the new regimes applied to their vessel and make it easier for them to meet the new statutory conditions in Marine Order 503. 

How did AMSA align certificates to the previously recorded survey dates on state issued certificates?

Chapter 4.11 (and table 9) of SAGM Part 2 requires shaft and / or out of water surveys to be undertaken as part of the renewal surveys.

Using the state data that was available to AMSA at the time, the new survey regimes and expiry dates were based on a combination of the vessels previous survey due dates and expiry dates. 

Those changes along with a copy of the re-issued certificate that showed the updated survey regime, survey and expiry dates were communicated via letter to each certificate holder in July 2018. Reminder letters are posted to advise of both periodic and renewal survey due dates. Certificate holders were also advised to check the updated certificate and contact the Data Verification team (Dataverification@amsa.gov.au) if the updated certificate did not appear to align with the state issued certificate. 

New regulations relating to air pollution from vessels

Marine Order 97 (MO97) deals with the prevention of air pollution from vessels and gives effect to the MARPOL Regulations for the Prevention of Air Pollution from ships (Annex VI). MO97 applies to regulated Australian vessels, domestic commercial vessels, recreational vessels, and foreign vessels.

MO97 has been re-issued and came into effect on 1 January 2023. It implements a new short-term measure adopted by the International Maritime Organization (IMO) to reduce the carbon intensity of international shipping by 40% by 2030. The short-term measure applies to certain types of foreign-flagged and commercial Australian vessels that undertake international voyages. 

MO97 also requires that all marine diesel engines with a power output of more than 130 kW installed on a domestic commercial vessel from 1 January 2023—or that undergo a major conversion from that date—must have on board an EIAPP certificate and associated technical file.    

Any existing diesel engines installed before 1 January 2023 will not require an EIAPP certificate or associated technical file unless the engine undergoes a major conversion or the vessel undertakes an overseas voyage (for example, to undertake maintenance or for delivery).   

Learn more about the new air pollution regulations from 1 January 2023.

Ensuring correct installation of float free EPIRBs

AMSA is urging owners of vessels with float-free EPIRBs onboard to make sure these devices are correctly installed. 

In 2021, there were nearly 50 inadvertent activations of float-free EPIRBs which were the result of incorrect installation.

EPIRBs removed from their float-free housing by vessel owners and replaced incorrectly accounted for numerous inadvertent activations. Incorrect re-installation often resulted in a misalignment between the magnet inside the housing and the reed switch on the EPIRB itself. 

If the magnet and reed switch aren’t aligned exactly as per the manufacturer’s guideline, the EPIRB water sensor can activate when exposed to moisture while still inside the housing – like during a squall or hosing of the vessel. 

With proper installation, float-free EPIRBs are designed to activate only when two things occur:

• the whole device is submerged, and the pressure underwater causes the hydrostatic release unit (HRU) inside the housing to release the EPIRB
• when water activates the sensor on that EPIRB. 

At that point, the EPIRB should float free of the vessel and be actively signalling for help. 

Correct installation of float-free EPIRBs will ensure they function as intended, and that search and rescue resources are not occupied by inadvertent activations.

Keeping beacon registration details up to date also helps search and rescue officers contact beacon owners when their beacons are detected – including for inadvertent activations.  

Please ensure your clients are aware of the manufacturer’s guidelines and AMSA’s beacon registration requirements.

In this edition

• Careers at AMSA
• Audits and application assessments
• Draft Instruction to Surveyors now available - 10 yearly internal inspections
• Periodic lightship check - comparison of departure conditions is not acceptable
• Vessel repairs
• Polyurethane sealant in timber vessels
• Load line conditions of assignment
• Minor fixes can save major costs later

Careers at AMSA

AMSA is looking for individuals who are passionate about helping us achieve our vision of safe and clean seas, saving lives. It’s important and rewarding work and you can join us to play your part.

Click here to see a list of current vacancies, including two Senior Naval Architect positions. 

You can also subscribe for AMSA job alerts by clicking here. 

Audits and application assessments

AMSA audits accredited marine surveyors to ensure the processes set out in the National Law–Marine Surveyors Accreditation Guidance Manual (SAGM), Marine Order 503 and the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the Regulations) are followed correctly.

In December 2022, AMSA received a complaint from the owner of a 1D vessel regarding deficiencies identified during an out of water survey.

AMSA commenced an audit and requested a list of pending deficiencies from the surveyor, as well as the applicable standards and rules related to the deficiencies.

AMSA found the standards applied for the deficiencies were not applicable for the vessel as per Section 7 of Marine Order 503. The surveyor also failed to follow the relevant process for disputed deficiencies as outlined in SAGM Part 2 Chapter 2.9.4.

The surveyor was issued a counselling letter for contravention of conditions of accreditation.

Draft Instruction to Surveyors now available - 10 yearly internal inspections

AMSA has developed a draft Instruction to Surveyors (ITS) which outlines the processes and acceptable options for internal hull, fuel tank cofferdam, and foam buoyancy inspections required by SAGM Part 2 for a 10-year renewal survey.

Several surveyors have rightly asserted that under the strictest interpretation of 10-year survey requirements, DCVs (particularly smaller vessels) with sealed underdeck spaces, may require extensive and destructive works to permit inspection. This would ultimately lead to greater damage to the vessel and a lower safety outcome than leaving these spaces intact.

As part of the ITS development, AMSA welcomes any feedback from accredited marine surveyors on the form and content of the attached draft. AMSA is particularly interested in the processes that surveyors may already have in place for the inspection of sealed underdeck spaces and foam buoyancy materials, and the condition of these spaces on older vessels undergoing survey.

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 PDF203.32 KB to access the draft ITS.

Periodic lightship check - comparison of departure conditions is not acceptable

Recently, an accredited surveyor recommended a periodic lightship check after measuring the vessel’s departure condition and comparing this with the departure values shown in the stability book.

The surveyor concluded there had been no (0%) change in vessel lightship from this measurement and recommended the vessel’s certificate be renewed.

AMSA identified this during assessment of the application and required a lightship measurement to be conducted on the vessel.

The lightship comparison correctly identified that the vessel’s lightship displacement had, in fact, changed by almost 8 tonnes. The vessel was re-inclined, and the VCG had increased significantly.

Comparison of departure conditions is not an acceptable method to assess a vessel’s lightship displacement or determine if any modifications have occurred.

As shown by this case, a comparison of departure condition does not provide evidence that a vessel has not been modified. Whilst a vessel’s loaded displacement may remain constant, other changes may still have occurred, such as replacement of lead ballast with additional tanks, awnings, etc.

For example, in the case of the Returner, the coroner’s report states:  

 103. The AMSA/DoT investigators concluded that if the vessel’s weight (checked through the freeboard) was the sole or deciding factor used to determine whether further testing of stability was required, a false conclusion may have been reached. It appears that this is what did occur. 

Applications recommended with this kind of method may be refused by an AMSA delegate and lead to investigation by AMSA’s surveyor audit team.

Vessel repairs

AMSA recently became aware of several new vessels of a similar design displaying advanced pin hole corrosion in sections of buoyancy tube plating. The vessels were relatively new, undergoing their first renewal surveys when the corrosion was detected.

The severity of the corrosion ranged from relatively minor pitting to larger pits, which a tool could be easily passed through. The range of corrosion identified provides an excellent case study into repair practices and the accredited surveyors’ role in reporting and overseeing the repair process.

Show all / Hide all

Minor repairs

One of the vessels in question had only very minor pitting that was just beginning to show on the outer parts of the hull. The vessel owners wanted to know if a surveyor was required to review, inspect, and approve the repairs. Below are two sections of the solid buoyancy tube requiring repair.

Guidance notice AMSA 830 Are you altering or maintaining a vessel? gives some advice on the difference between vessel alterations and general maintenance. In this case, these are small make good repairs. As per the definition provided:

small ‘make good’ type repairs to existing parts of the vessel (steel, timber, plywood, fibreglass, etc.) provided the area being repaired does not interfere with, compromise, or alter watertight integrity and/or subdivision on the vessel.

Furthermore, the vessel owner had consulted with the builder as to the best course of action. In this instance, they had a repair plan for similar corrosion that had been approved by an accredited surveyor. In other instances, the repairs could be made by a suitably competent person and not specifically overseen by an accredited surveyor, as these are small ‘make good’ repairs.

If an accredited surveyor is unsure as to the severity of the repair and if it requires approval and inspection, they can refer to Marine Order 503 Schedule 1 and AMSA 830 or contact DCVSurvey@amsa.gov.au for further guidance. However, if you are asking the question, it’s probably not minor maintenance and, therefore, worth conducting an approval and inspection. There is no harm in this course of action.

Major repairs & accredited surveyor approval

A major repair that would require accredited surveyor approval is typically when the watertight integrity of the hull or a subdivision on the vessel will be affected. Examples of this could include cropping and replacing large sections of bottom plating, repair of a watertight bulkhead due to collision or other damage.

During this process, if the alterations occur that are listed in Marine Order 503 Schedule 1, an initial survey and application is required.

AMSA can generate ad hoc survey codes for repair surveys where an initial survey and application isn’t required. Email DCVApplications@amsa.gov.au to have an ad hoc survey code issued.

Repair standards

The underlying principle is that the repair will be as strong as the original structure. If modifications are made to improve the structure, such as removal of stress concentrations, additional bracketing, or other items, so much the better.

With respect to welding of aluminium, AMSA provides guidance in DCV-ITS-008 for welder qualifications, as well as guidance on defects and repairs. Additional information can be found in WTIA Technical Note 2.

In terms of the conduct of repairs, AMSA does not have a specified repair standard, only that the repair has the same integrity as the original structure. AMSA does suggest referring to a standard to give an auditable and justifiable rationale to approved repairs.

Principles

Generally speaking, welding of pin hole/pitting in aluminium is not acceptable (as per the definition in Guidance Notice AMSA 830), however, for highly localised repairs in low-risk plating, this could be accepted. The key here is identifying the risk of the defect, the repair and if a systemic problem is present. The consequence of continued failure must also be considered, i.e. there is a lower risk in an aluminium tube (of a solid collar RHIB) than the hull bottom plating. Flooding of the watertight envelope, particularly in the case of a vessel that is not foam filled, is a comparatively higher risk for flooding.

A leak in a tube (particularly if foam filled) is not ideal but most likely won’t directly lead to the vessel taking on large amount of water and/or foundering, compared to a leak in the hull bottom plating in a vessel without buoyancy foam, which could have this outcome.

Ultimately, it is the surveyor’s judgement as to the final repair plan and their satisfaction in the completed repair. In the event of a disagreement with the vessel owner, there is the avenue to submit a disputed deficiency. Refer to SAGM Section 2.9.4 for this process. Note there is a requirement that the details of the dispute are submitted in writing to AMSA, as per SAGM Section 2.9.4 (b)(i).

The presence of corrosion in a relatively new vessel is also a reminder to check items on a vessel regardless of age rather than to assume compliance. It also shows the value of identifying trends in vessels, by type, operations, age, or any other metric.

Furthermore, if in doubt about the level of repair required or to record the results of a minor repair, please don’t hesitate to contact AMSA for guidance.

Polyurethane sealant in timber vessels

AMSA inspectors have noticed an increase in the number of timber vessels with polyurethane sealants used in the underwater plank seams instead of the usual seam putty. Inspectors have identified that these sealants have been coming away from the seams, exposing the caulking and contributing to water leaks and moisture issues on vessels.

AMSA does not recommend the use of polyurethane sealants, because they do not work well in these underwater seams and fall out over time.

AMSA encourages the following best practice recommended by experienced shipwrights:

1. Clean out the seam thoroughly.
2. Paint underwater primer on timber planks.
3. Hammer oakum or cotton caulking.
4. Prime again.
5. Linseed putty with antifoul mixed in (for the putty worm).
6. Prime again.
7. Paint / antifoul.

Load line conditions of assignment

Load line certificates are issued subject to the conditions mentioned in Section 7 of Marine Order 507.

Marine order 507 Section 7 (1) (a) states:

the master must ensure that the conditions of assignment of load lines in the approved form are kept on board the vessel or, where it is impractical to keep the documents on board due to the structure of the vessel, made available on request of a marine safety inspector or the National Regulator.

The load line conditions of assignment must be met before the freeboard is assigned to a ship and a load line certificate is issued.

The conditions of assignment are also referenced during periodic load line surveys to determine if the vessel has been modified and whether guardrails, freeing ports, means of access for the crew, and appliances for the protection of openings are maintained effectively.

AMSA understands for some vessels built and certified before 2013, initial load line survey reports may not be available in records or on-board vessels.

For such vessels, details regarding freeing ports, guardrails, and means of protection and closure of openings (such as hatchways, doorways, ventilation, air pipes, etc) must be recorded during the load line renewal survey.

Accredited surveyors can submit the AMSA 555 Conditions of assignment report together with the AMSA 139 Load line survey report to support the renewal of a load line certificate.

Minor fixes can save major costs later

Updated guidance and templates are now available to help small domestic commercial vessel owners and operators develop and implement a maintenance plan for their operation.

An analysis of 117 reported marine incidents involving DCVs since 2020 found that maintenance failures were a factor in almost one-third. Common deficiencies identified by AMSA relate to the condition of safety equipment and validity of certification associated with these vessel operations, including overdue periodic surveys.

There is more to maintenance than just main engine servicing.

Developing and implementing a maintenance plan, and logging work undertaken, may help prevent a more serious underlying issue from turning into a breakdown, which puts a vessel out of the water and people out of business.

In this edition

• Audits and application assessments
• Monitoring conditions on accreditation
• Recognised Organisation surveys and submissions – common findings
• Simplified stability criteria / stability proof tests on Class 1 vessels over 12 metres
• Vessels permanently connected to shore
• Engine changes
• Alternate survey processes

Audits and application assessments

AMSA conducts audits of accredited marine surveyors to ensure the 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 correctly.

The cases below contain examples of major non-conformances.

A certificate of survey application for a new build 2B extended vessel was refused when several major non-conformances were identified. These 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 damage stability did not comply with NSCV C6B
• The vessel was fitted with a stepped collision bulkhead not complying 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.

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Alterations were made to a Catamaran which saw the vessel’s measured length increase by more than six metres.

As part of an application for a new certificate of survey, the plan approval activity was recommended listing the original measured length prior to the alterations. No compelling justification for the initial measurement being maintained was provided by the plan approval surveyor following requests for information. The measured length of the vessel had not been calculated in accordance with NSCV Part B and this had substantial implications for the certification and operation of the vessel.

The Plan approval surveyor was issued a counselling notice for contravention of conditions of accreditation.

The surveyor who conducted the Commissioning, Initial Hull Structure, and Initial Fire Systems & Fitout surveys failed to notify AMSA of the incorrect measured length despite the extension being in the survey scope. The surveyor was sent a notice of assessment finding letter and educated with regards to their regulatory responsibilities.

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A surveyor failed to conduct a periodic lightship verification during the renewal survey of a 12.65m class 1 vessel. Instead, the surveyor recommended the periodic lightship check with a declaration signed by the vessel owner.

The surveyor undertook a lightship check as a corrective action following an audit. However, AMSA noted the lightship report did not conform to the requirements of SAGM part 2 Chapter 4.9 for the following reasons:
 

• Lightship details were marked as not applicable with the comment – No hydrostatic data
• The percentage difference in change in displacement and LCG were not determined

Based on the failure to establish the variation in displacement and LCG, follow up action was required by the local AMSA office with the vessel owner to demonstrate that the vessel’s stability remains adequate for the intended operations.

The surveyor was issued a counselling letter for contravention of conditions of accreditation.

Monitoring conditions on accreditation

There are some accredited surveyors with monitoring conditions placed on their accreditation.

Surveyors should check their current notice of decision letter and follow the process below if there is a monitoring condition imposed.

I have a monitoring condition on my accreditation, what do I need to do?

• advise the accreditation team by email to dcvsurvey@amsa.gov.au well in advance of undertaking a survey related to the monitoring condition
• when advising the accreditation team, ensure you provide full details of the survey you intend to undertake (i.e., date, time, vessel name, UVI, hull material, length, vessel class and type, location, type of survey, survey codes and owner’s details)

What happens after I have notified the accreditation team of an upcoming vessel survey and details?

An AMSA representative will communicate with you and arrange to either:

• meet you at the vessel location; or
• may discuss the survey plan and later review and countersign the survey report.

What happens after the survey has been completed and monitored by an AMSA representative?

• upon completion of the monitoring survey the AMSA representative will contact you and provide a signed report of the outcome.
• once all monitoring conditions have been completed, AMSA will vary your accreditation to remove the conditions from your accreditation.
• you will receive a new notice of decision letter and our records will be amended accordingly

Your accreditation is subject to the conditions in Division 3.3 of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013. A failure to comply with these conditions of your accreditation, may lead to a variety of compliance measures in accordance with AMSA’s Compliance and Enforcement Policy.

It is in your best interests to notify AMSA of your intention to undertake a monitoring survey so we can assist you with having the conditions removed.

Recognised Organisation surveys and submissions – common findings

While acknowledging the high quality of surveys performed by most of the Recognised Organisations (ROs) on DCVs, AMSA has also noticed several inconsistencies and deficiencies related to some vessels surveyed and recommended by RO surveyors. AMSA has invested significant time assessing these applications. On numerous occasions, AMSA has identified gaps in submissions from requirements of the National Law and incomplete responses to requests for information. This has led to delays of several months in some instances.

Below is a list of common findings identified in the past few months. AMSA encourages all RO surveyors to consider these items prior to making a recommendation to avoid delays, refusals, and compliance action on vessels.

1. Several vessels were recommended for B waters operations without being fitted with adequate communication equipment required by NSCV C7B. (e.g. a vessel was fitted with VHF only and not fitted with HF Radio or satellite phone, as required for B waters).
2. Several vessels were noted to be recommended without assessment or approving documents for NSCV C1 requirements in relation to accommodation arrangements. (e.g. accommodation level assigned for vessels does not comply to NSCV C1 4.2).
3. Several vessels were noted to be non-compliant with additional stability requirements of NSCV C6A. (e.g., Tugs not complying with the towing stability criteria as per NSCV or alternate criteria specified as per GES 2015/03).
4. Several vessels were not assessed and recommended appropriately for the relevant Flooding Risk Category as per NSCV C6B. (e.g., confirmation not provided for compliance to Flooding Risk Category).
5. Where vessels changed flag from a foreign flag to become a DCV, some vessels were recommended with Conditions of Class relating to serious deficiencies (both class and statutory items) without prior approval from AMSA. (e.g., Main/Emergency Air Receiver found pitted and holed at bottom was accepted with temporary repairs and a Condition of Class imposed without prior approval from AMSA).
6. Several vessels were noted to have Conditions of Class related to serious statutory deficiencies, without raising them in AMSA 586 and obtaining prior approval (e.g., Conditions of Class on damaged fire main, magnetic compass, fire door etc.). As ROs do not have the authorisation to issue certification under the National Law, RO’s should not issue conditions related to statutory items for DCV’s.
7. Several vessels have been recommended using the Initial Fire Systems and Fitout Materials Survey (IFIR) code in MARS with a Class Certificate. AMSA Form 575 or an equivalent checklist developed by the RO must be provided.  A Class Certificate is not evidence of fire safety compliance.
8. Recent AMSA inspections of vessels within a week of RO surveys have identified several detainable deficiencies. (e.g., Fire detection and alarm system not operational, fixed fire extinguishing system in engine room not ready for use in an emergency, HF equipment defective).

Simplified stability criteria / stability proof tests on Class 1 vessels over 12 metres

Stability assessments may be conducted to simplified stability criteria in NSCV C6A Chapter 7 through the application of a stability proof test. This provides a simpler method of intact stability assessment, without the need to determine lightship particulars, loading conditions, KN data and hydrostatic data. Vessel hydrostatic data may still be required for verifying damage stability compliance.

SAGM Part 2 Chapter 4.9 requires vessels to periodically verify lightship particulars to confirm the vessel stability compliance remains valid. Class 1 vessels up to 12 metres in length and class 2 and 3 vessels can use the lightship declaration method. However, class 1 vessels over 12 meters cannot use a lightship declaration and must verify their lightship displacement at 5 yearly intervals.

Generally, this can be achieved through repeating the stability proof test or through confirming drafts or freeboards against a known load condition when the vessel stability compliance was first established (some stability assessments do use simplified stability criteria combined with hydrostatic data and a numerical analysis, these vessels can conduct a lightship assessment per NSCV C6C).

To allow comparison to a known loading condition at renewal survey it is recommended that freeboards are documented for a “near lightship condition” in the vessel stability compliance report (noting the NSCV C6A 8.6.5.1 requirement, lightship with incline weights onboard to represent full tanks may be the easiest to reproduce periodically). The stability compliance report should also include the precise locations for taking freeboards, in the form of sketches or annotated photos to reduce sources of error.

As most vessels assessed to simplified stability criteria don’t have hydrostatic data to quantify changes in lightship displacement, AMSA has determined that an accredited surveyor must verify that there has been no significant change in the vessel freeboards or drafts from those recorded at its initial certification in a known load condition. AMSA acknowledge that no significant change is not quantified, however it is expected a surveyor will be able to justify their recommendation with respect to any observed variation and the NSCV criteria at audit.

Where significant change in freeboards or drafts are identified the surveyor should conduct a new stability proof test to ensure compliance with the selected stability criteria.

If stability compliance reports do not include a known load condition, that can be accurately reproduced to identify any change in lightship particulars, then AMSA will require the vessel to undergo a new stability proof test to demonstrate compliance with a deemed to satisfy solution.

Where a vessels stability has been assessed to comprehensive stability criteria, the surveyor must conduct a lightship check in accordance with NSCV C6C.

Vessels permanently connected to shore

AMSA has recently been asked for clarification of the requirements for a floating structure to be considered as permanently connected to shore.

AMSA as the National Regulator cannot provide legal advice on such matters and each case would need to be considered on its unique circumstances. AMSA suggests take the characteristics below should be considered when determining whether a floating structure is permanently connected to shore:

• The floating structure has no propulsion or steering capacity
• The structure has a permanent and secure attachment to shore
• Permanent pedestrian access is provided to the structure
• Power and sewerage connections are in place between the floating structure and shore as applicable
• The floating structure remains in place permanently
• Evidence of a lease or permit for the structure to be in place as appropriate

This is to be considered as general advice only. Operators and Surveyors should seek their own legal advice as and where necessary.

Engine changes

Recently AMSA has fielded enquiries regarding the notification requirements when a vessel undergoes an engine change.

As mentioned in the November 2019 edition of Survey Matters, an AMSA 1847 form with supporting documentation must be submitted for engine changes on EX40 and certificate of survey vessels.

Under Marine Order 503 Schedule 1 clause (6)(b) – an increase in propulsion power for an existing vessel, that invalidates the assumptions and calculations used for structural or stability assessment, triggers the transitional vessel requirements.

EIAPP certification, issued in accordance with MARPOL Annex VI is required for vessels fitted with a new diesel engine after 30 June 2018, that has a propulsion power >130 kw, unless covered by Exemption 44.

Under Marine Safety (Domestic commercial vessels-EIAPP certificate) Exemption 2021 (Exemption 44), DCV owners and operators are exempt from holding an EIAPP certificate provided they hold acceptable alternative documents stating or showing that each installed engine is likely to comply with the applicable emission limits or tiers that apply to it under regulation 13 of Annex VI. Acceptable alternative documents are:

• a product manual from the engine manufacturer
• correspondence from the engine manufacturer
• emission certification issued by or for an International Maritime Organization member state
• a statement of compliance issued by a recognised organisation

Alternate survey processes

There are many vessels, which for varied reasons cannot follow the phases of initial survey set out in SAGM Part 2 Chapter 3.8. A common example is a vessel which has triggered full initial survey and must undertake an initial hull survey. For any number of reasons this might not be possible or appropriate.

As a result, the alternate survey process exists to allow for approved deviations from the survey process prescribed by SAGM and Marine Order 503. SAGM Part 2 Chapter 3.8 (2) states:
 

The key being ‘…approved otherwise in writing.’ All deviations from the survey process require this written approval from AMSA.

The AMSA 1854 form shall be completed and emailed to dcvsurvey@amsa.gov.au along with supporting information. It is important that the application explains why the defined process cannot be followed and proposes an alternate process.

To take the example from above, think of an aluminium fishing vessel currently in survey with a geographic restriction to South Australia. Full initial survey is required to remove this restriction. In this example the hull hasn’t been altered, the vessel has a current certificate of survey and has been maintained in survey for the vessel’s life. To perform an initial hull survey would be challenging. It could be proposed on the AMSA 1854 form to perform a 10 yearly hull inspection in lieu of the initial hull survey.

There are any number of different cases in this instance, but it is critical that the approval is made in writing from the national regulator. This saves time and gives greater certainty when submitting survey recommendations for a vessel that is slightly out of the ordinary.