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Appropriate crewing for your operation under Marine Order 504
Consultation on the proposed changes to certificates of operation (Marine Order 504) has now closed.
We consulted on two options for changing crewing requirements to focus on empowering the operator to determine the appropriate crew for their vessel.
Option 1 would allow you to operate a vessel with the minimum crewing specified in Marine Order 504 if you determined that it would be safe to do so, having conducted and documented appropriate crewing evaluation.
Option 2 would allow you to operate a vessel with the minimum crewing specified in Marine Order 504 if all of the following criteria are met—smooth waters, no passengers, voyage <12 hours—and you determined that it would be safe to do so having conducted and documented appropriate crewing evaluation.
It is important to note that under both Option 1 and Option 2, the focus must be on putting the appropriate crewing evaluation first and foremost.
The proposed changes would only apply to new vessels. Vessels operating under grandfathered crewing arrangements may choose to continue to operate with the same amount of crew they currently do. Temporary crewing permits will also be available on application.
We are grateful to everyone who took the time to make a submission. Most submissions favoured Option 1 on the basis that it provided operators with the flexibility to determine appropriate crewing. In line with our efforts to move towards performance based rather than prescriptive regulation, we will implement Option 1.
We will be developing new guidance on how to work out your appropriate crewing and to support you in making sure you have the right people on board to manage your risks. We are also updating guidance on safety management systems and preparing to run safety management system workshops in the near future.
We anticipate the new Marine Order 504 will commence on 1 July 2018.