AMSA, the Australian Maritime Safety Authority and regulator, has announced that from 1 July 2018 all domestic commercial vessels that are required to have a certificate of survey will need to be surveyed in accordance with the frequency and requirements in the new marine order 503, and Part 2 of the Marine Surveyor Manual. This includes ‘grandfathered’ vessels, which to date have been surveyed in accordance with the National Standards for the Administration of Marine Safety (NSAMS) 4, the USL Code, or other survey processes.
So what does this mean in practice?
These changes implement the outcomes of the Decision Regulation Impact Statement (RIS) under the National System for Domestic Commercial Vessels, which AMSA says better aligns the survey requirements for domestic commercial vessel with the risk of individual vessels.
All domestic commercial vessels are required to have a national law certificate of survey unless an exemption applies. It is claimed that the survey regime changes are designed to better align survey requirements with risk, so that safety is maintained, but compliance costs are reduced. Namely, the new survey scheme introduces changes to the previous survey requirements by:
– expanding the non-survey category (Exemption 02)
– expanding the Restricted C category (Exemption 40)
– reducing survey requirements a for vessels in survey (Marine Order 503)
– changing the requirements for unpowered barges (Exemption 41).
Anticipated benefits of the new survey regime
– Reduced periodic survey requirements for the majority of the fleet.
– More flexibility to move vessels into higher or lower survey frequency levels, depending on the performance of the individual vessel.
– Amending the survey modifiers (high-risk operations and other vessel attributes that change the survey requirements which would otherwise apply to the vessel) in order to remove safety gaps in the current arrangements and better align survey frequency to risk.
– Ensuring that those aspects of the vessel must be inspected at each survey reflect modern technology.
– Allowing greater flexibility in periodic survey timing to ensure that other vessel maintenance activities can be aligned with surveys. This provides a six-month window of up to three months prior to and three months after the due date – with no application required.
Other changes to marine order 503
– An additional ‘age’ modifier for vessels over 15 years old and not made of steel or aluminium — these vessels will be in medium frequency survey (at minimum).
– You can now renew your certificate of survey, rather than applying for a ‘new issue’, with a lower fee for this service where there have been no changes to your vessel or operation.
– Vessel owners will be required to notify AMSA of changes made to the vessel’s structure as a condition of the certificate survey.
– To be issued a certificate of survey, new vessels that are greater than or equal to 35 metres and at least 400 GT are required to provide evidence that the vessel meets the standards for construction and equipment as required by Annex I of MARPOL.
Changes to load line certificates
There have been minor changes to load line certificates (marine order 507) to allow vessels to comply with the Load Lines Convention or section 7 of the USL Code and to align with the new survey schedules.
Expanded non-survey vessel category (Exemption 02)
The length cut-off for non-survey will be extended from less than 7.5 metres to less than 12 metres.
– Less than 12 metre Class 2D and Class 2E non-survey vessels that carry up to 4 passengers are now eligible.
– Vessels involved in sporting or recreational activities and operating inshore, can be non-survey where they are affiliated with a body that AMSA determines has systems in place to effectively manage risk.
Expanded class C restricted category (Exemption 40)
The exemption for Class C Restricted offshore operations will be expanded so that the number of people that may be carried on board the vessel is increased from 3 persons (no passengers) to:
– 12 persons (no passengers) when within 5 nautical miles from a shore base within restricted C areas
– 6 persons (no passengers) when within 15 nautical miles from the shore within restricted C areas
– 3 persons (no passengers) otherwise when within restricted C areas.
Changes for unpowered barges (Exemption 41)
– Changes to Exemption 41 clarify the conditions for unpowered barges and make it clear that passenger (Class 1) unpowered barges are eligible for the exemption provided they are not being used for overnight accommodation.
– Unpowered barges only need to have ‘appropriate crew’ and are not required to meet core complement or minimum crewing requirements in marine order 504. Unpowered barges previously not permitted to access the crewing arrangements under Exemption 41 can now do so.
Future changes for vessels greater than 35 metres
From July 2020, the changes to class survey requirements recommended in the RIS will commence, which will allow vessels up to:
– 45 metres to undergo initial and periodic surveys by an Accredited Marine Surveyor
– 65 metres to undergo periodic surveys by an Accredited Marine Surveyor, provided that they have done their initial survey (and certification) via a Recognised Organisation.
IIMS has been in dialogue with AMSA about the implementation of this scheme following a number of serious concerns raised by surveyors and other interested parties in Australia. IIMS would welcome your view. Please email us your thoughts.
Click to read a candid feature article written by Stuart Ballantyne and published in Ausmarine on this subject entitled ‘Are the Swiss cheese holes aligning’?
Full details about the transition to a national system from 1 July can be found on the AMSA web site.