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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


 

Accreditation matters

Here is a look at the first six months of 2020 within the accreditation space. 

Accreditation renewals

The first accreditation renewals fell due in February this year. So far, we have received 72 applications for renewal with 53 approved and 19 still in progress.

We find many applications are incomplete or contain illegible documents, which causes delay. When submitting an application please ensure:

  • All necessary fields are completed in full.
  • Your signature remains strictly within the box provided. This ensures we can crop it correctly for your ID card.
  • Your photo is 45mm x 45mm on a white background, facing forward from the neck upwards. If possible, this should be scanned at 300dpi. 
  • You supply current evidence of professional association membership. If you are submitting a receipt of membership you must advise the renewal and expiry date.
  • You supply evidence of continued professional development. Submit copies of certificates from training courses, workshops or additional qualifications. If you don’t have certificates tell us in the box and supply dates. Provide the date of subscription and name of any publications you subscribe to. Provide dates and names of any technical meetings or conferences you have attended. If you mentor, tell us who, what the subject is and any dates. 
  • You submit a copy of your electrical license if you are accredited in categories e, f or m.
  • Payment is made quoting the transaction reference number (TRN) shown in the top right corner of the application form. If you make a mistake on the application and print another one, a new TRN will generate. You must advise us which TRN you made payment against.

You are reminded to submit renewal applications three months ahead of your accreditation expiry date. The renewal application is available on the AMSA website here. Due to COVID-19, all applications including supporting documentation must be emailed until further notice.

Audit outcomes

Renewals haven’t been our only focus this year. Since January we have sent nine letters to surveyors asking the recipients to show cause as to why we should not take action to revoke, suspend or vary their accreditation. These show cause processes have resulted in AMSA suspending the accreditation of three surveyors and varying the accreditation of another.  

Audit outcomes have seen letters sent to ten surveyors, requiring a corrective action response. We have sent counselling letters to six surveyors for contravening the conditions of their accreditation, as set out in the Regulations.

Examples of contraventions included:

  • Performing surveys outside of accreditation category. In this instance a surveyor provided a recommendation for a fuel tank construction survey, despite their accreditation not including an initial construction category.
  • Failing to conduct renewal surveys to the scope required by the surveyor manual. A complaint emanated due to the surveyor’s recommendations for a fleet of vessels omitting key safety information. The AMSA 901 forms did not contain adequate information for an AMSA delegate to renew the vessel’s certificates of survey. AMSA formed the view that the surveyor contravened section 32 of the regulations, after considering the missing details, indicated duration for each survey, the absence of details for the location and date of the surveys, and reports showing the hulls with heavy marine growth. 
  • Failing to conduct renewal surveys to the scope required by the surveyor manual. In this example a surveyor submitted a completed AMSA901 form recommending the survey. A subsequent AMSA inspection found the vessel was still under repair, with sections of the timber deck, exhaust pipework and insulation and weathertight hatches still to be fitted.
  • Failing to notify AMSA that a written complaint was made against a surveyor. Although the survey in this instance was a ‘risk evaluation’ survey for a prospective buyer, the regulations do not distinguish between the purposes of a survey. The vessel was a commercial vessel and the surveyor was accredited. 
  • Failing to provide information requested by the National Regulator under Section 35 of the regulations.

An educative approach through counselling was the preferable compliance and enforcement action in these examples. However, surveyors should be aware that contravention of the conditions of accreditation may result in a different outcome. This includes infringement notices and/or variation, suspension or revocation of accreditation. The minimum infringement for any act or omission that contravenes a condition prescribed by the regulations is 60 penalty units ($12,600.00 at time of writing) and is a strict liability offence. 

MARS matters

Claiming codes for vessels >35m

Following recent updates to MARS, you may see an error message stating that you do not have the appropriate accreditation to claim or recommend a survey for a vessel that is over 35m in length. This change has been brought in to satisfy Marine Order 503, whereby vessels over 35m must be surveyed by a Recognised Organisation (RO), 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. 

This message may appear if the material or required category of accreditation for the survey type does not match your profile in MARS. 

If you come across this message, please contact the accreditation team at dcvsurvey@amsa.gov.au. When emailing, please provide the vessel name, UVI, and survey code. If the vessel is over 35m, provide the reason it is not required to be surveyed by a RO. We will determine the cause for the error message and contact you about how to claim and/or recommend the survey.

Marking survey codes as not required

There are times when some survey codes are not required. You can mark them as such, provided you state the reason. However, do not mark surveys as not required in the following circumstances:

  • The vessel has been sold. The survey activities in MARS are linked to the certificate not to the holder of a certificate. The survey codes can be used by the new owner. If the vessel is sold and no longer operates as a DCV, the certificate holder can revoke the associated certificates. They can do this via the AMSA 600 form, which will ensure they don’t receive future reminder letters.
  • You believe the vessel is a non-survey vessel. Please send an email to DCVApplications@amsa.gov.au if you believe the vessel is a non-survey vessel. Closing the survey activity will not correct any permissions in our system and reminder letters will still generate. It also doesn’t enable AMSA to review the matter and, where applicable, issue a non-survey permission. 

Documentation supporting recommendations 

There have been recent examples of periodic and renewal survey codes having been recommended without any supporting documentation. 

Under SAGM Part 2 chapter 2.9.1 a surveyor who makes a recommendation using MARS, with appropriate supporting documents attached, is not required to use the AMSA's survey forms. This does not mean that no survey documents are required. If you are making recommendations directly in MARS, you must still upload appropriate supporting documentation. If your supporting documents do not contain sufficient detail, the application cannot be processed, which will result in delays for your customer receiving their certificate.

All National Law exemptions extended

AMSA has extended all existing National Law general exemptions until 30 June 2025.

You can read about the full list of exemptions and any changes that were made.

Changes to EPIRB requirements 

Changes to EPIRB requirements come into effect on 1 January 2021. AMSA has prepared guidance materials to help industry understand the new float-free EPIRB arrangements.

Your clients can download the brochure and flowchart, and read up on what they need to install on their vessels before the deadline.

Issuing temporary permits under divisions 3, 5 & 6 of exemption 7

Recently we have seen examples of temporary operations permits, where the relevant criteria for issue was not satisfied. 

Under divisions 3, 5 and 6 of EX07 an accredited surveyor may issue a temporary operation permit only when relevant criteria are satisfied. The criteria for issue generally includes relevant vessel surveys being carried out, and the person who conducted the surveys considering whether the vessel complies with the applicable standards specified for each division. 

As an example, in September 2019, a 19.9m 2B vessel was issued with a temporary operating permit under division 6 of EX07. A surveyor used the same division in February this year to issue a permit to a 24.85m class 1 vessel. On both occasions, only the in-water component of the renewal survey had been completed. 

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

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

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

The surveyor provided signed documents to AMSA and the vessel owners in both instances. However, the criteria for issue was not met, because the surveyor had not conducted the examinations required for a renewal survey. Note, it is not the signed document alone that exempts the vessel, it is the fact that the vessel complies with the conditions for the issuing of the documents. Getting this wrong, has serious consequences for the vessel owner.

Division 3 of EX07 allows a surveyor to issue a temporary permit for sea trials only. You cannot issue a temporary permit for general operations following initial survey. It is important that you send a copy of the AMSA 592 sea trial document to us so that we can review the conditions of the trial. It will also notify AMSA that the vessel’s surveys are complete. You can do this by emailing the permit to dcvapplications@amsa.gov.au.

For more information see the instruction to surveyors DCV-ITS-002. Please review this instruction before issuing permits under division 3, 5 & 6 of Exemption 7.

Regulated Australian and foreign flagged vessels becoming domestic commercial vessels 

Chapter 8 of SAGM Part 2 applies to Regulated Australian (RAV) and Foreign Flagged (FFV) vessels applying to become domestic commercial vessels under the national law.

Clauses 8.2 (f) and 8.3(g) of this Chapter require applications to be “supported by survey reports as necessary”.

This article discusses the types of reports AMSA considers necessary for RAVs and FFVs seeking DCV status for the first time.  

RAVs previously issued with a certificate of survey or load line certificate under the Navigation Act

RAVs, applying for DCV status, are considered existing vessels under Marine Order 503 if they were permitted to operate prior to the commencement of the National Law.  

Maintained in Class 

The below applies to a regulated vessel maintained in Class; at the time an application is made for National Law certificates.

AMSA expects the application to be accompanied by a declaration that the vessel complies with the applicable legislation, exemptions and standards. This will be supported by: 

  • A copy of the current survey status from class; and 
  • Confirmation from class that all overdue surveys and all overdue recommendations/conditions of class previously issued against the subject vessel, have been rectified.

Accredited Surveyor Survey 

This applies to RAVs withdrawing class at the time the application is made for National Law certificates.

AMSA expects the application to be accompanied by a declaration that the vessel complies with the applicable legislation, exemptions and standards under MO503. This will be supported by:  

  • A copy of the current survey status from class; and either 
    • Confirmation from class that all overdue surveys and all overdue recommendations/conditions of class, have been rectified; or 
    • Survey reports completed by the accredited surveyor, which demonstrate the vessel has no overdue issues for any elements of survey. 

Foreign Flagged Vessels

Foreign Flagged vessels (FFVs), applying for DCV status for the first time are considered new vessels under MO503 and must be surveyed for compliance against the applicable national standards.  

Maintained in Class 

This applies to FFVs maintained in class, when the application is made for National Law certification. 

AMSA expects the application to be accompanied by a declaration that the vessel complies with the applicable legislation, exemptions and standards. This will be supported by:

  • A copy of the current survey status from class; and 
  • Confirmation from class that all overdue surveys and all overdue recommendations/conditions of class have been rectified. 
  • Plan approval and survey reports for the national law statutory elements (NSCV Parts C1, C2, C4, C5B, C6, C7)
    • Accommodation e.g. stairways, door widths, escapes, landings, berths, railings etc.
    • Fire e.g. structural fire protection, detection, fixed fire systems etc. 
    • Watertight integrity e.g. vent heights, air pipes, hatches, 
    • Electrical 
    • Equipment e.g. safety equipment, navigation equipment, communications equipment 
  • Stability approval against NSCV stability criteria.

Accredited Surveyor Survey 

The below applies to FFVs withdrawing class at the time the application is made for domestic certificates. 

AMSA expects the application to be accompanied by a declaration that the vessel complies with the applicable legislation, exemptions and standards; supported by: 

  • A copy of the current survey status from class; and 
  • Either 
    • Confirmation from class that all overdue surveys and all overdue recommendations/conditions of class have been rectified; or 
    • Survey reports completed by the accredited surveyor, which demonstrate the vessel has no overdue issues for any elements of hull and machinery survey. 
  • Plan approval and survey reports for the national law statutory elements  (NSCV Parts C1, C2, C4, C5B, C6, C7)
    • Accommodation e.g. stairways, door widths, escapes, landings, berths, railings etc 
    • Fire e.g. structural fire protection, detection, fixed fire systems etc 
    • Watertight integrity e.g. vent heights, air pipes, hatches,  
    • Electrical
    • Equipment e.g. safety equipment, navigation equipment, communications equipment 
  • Stability approval against NSCV stability criteria.

General arrangement plans

Lately we are being asked if AMSA requires general arrangement plans to be approved as part of the design phase of initial survey.  

In some cases, general arrangement plans are used to display the general aesthetic of a vessel during initial design.  

In other cases, general arrangement plans can provide sufficient detail to enable assessment against the standards, for areas of the vessel. Such areas may include, but are not limited to: 

NSCV C1: 

  • Seating 
  • Deck areas and deck heights 
  • Bulwarks, railings, boarding, re-boarding from the water 
  • Escape and evacuation 
  • Aisle widths, hatch and door geometry 
  • Stairs and ladders 
  • Operating compartment design 
  • Berths, WC’s, basins 
  • Disabled access 
  • COLREGS including vision from helm and navigation light / shape arrangements. 

NSCV C7A: 

  • Location and launching of lifeboats, rescue boats, dinghies, liferafts and buoyant appliances. 
  • Location of assembly stations and associated stowage of lifejackets. 
  • Means of embarkation of survival craft. 

USL Code 5C and 5D: 

  • Freeing ports, scuppers, hatches, sills, coamings, vents, air pipes. 

AMSA recommends the use of detailed general arrangement plans to demonstrate compliance with applicable areas of the standards. This helps to avoid potentially costly modifications during the construction or commissioning phases. If you are using a general arrangement plan to demonstrate an area of compliance with the standards that is not addressed by other plans, it must be stamped as approved. Refer to the surveyor manual Table 2 for guidance.

Documents listed on the AMSA 575 form: Fire training manual and Fire safety operational booklet

In April’s edition of Survey Matters we discussed ‘what is a Fire Control Plan’ and some of the survey detail required to populate the AMSA 575 form. Let’s look at other fire safety preparedness documentation such as the fire training manual and the fire safety operational booklet. These are also both listed on the AMSA575 form.  

Chapter 6 of NSCV C4 requires a vessel specified in table 29 to be provided with a fire control plan, a fire training manual and a fire safety operational booklet.

These three documents provide vital information for an operator to comply with Marine Order 504 and to prepare crew for a fire emergency. A vessel may also be obliged to carry fire safety information under relevant State/Territory WHS legislation, in addition to the survey requirement under Marine Order 503.  

When you conduct a fire safety survey and you review the fire training manual and fire operational booklet, ensure you reference NSCV C4, 6.3, 6.3.2, 6.4 and 6.4.2. 

Key requirements of the Fire Training Manual

The manual must explain the following detail, using easily understood terms and illustration wherever possible:

a) general fire safety practice and precautions related to the dangers of smoking, electrical hazards, flammable liquids, dangerous goods and similar common shipboard hazards
b) general instructions on fire-fighting activities and fire-fighting procedures including procedures for notification of a fire and use of manually operated call points
c) meanings of the vessel’s alarms
d) operation and use of fire equipment
e) operation and use of fire doors
f) operation and use of ventilation shutdowns, fire flaps, smoke flaps, fire dampers and fuel shut-offs and
g) escape systems and appliances.

An example of an easily understood illustration within the manual may be a section explaining the colour coding of fire extinguishers. A simple table illustrating the colours and type is more easily understood by the crew than detailed written explanations. The manual may be in the form of an electronic document with added benefits of training videos or demonstrations the crew can access. 

fire extinguisher colour code table
Example of a simple fire extinguishing colour code table

Key requirements of the Fire Safety Operational Booklet

The booklet must contain necessary information and instructions for the safe operation of the vessel and cargo handling operations with respect to fire safety. It may be combined with the fire training manual. 

The booklet must contain information concerning:
a) the crew’s responsibilities for the general fire safety of the vessel while loading and discharging cargo and while underway.
b) an explanation of necessary fire safety precautions for handling general cargoes.
c) for vessels carrying dangerous goods, relevant stowage and segregation information for the dangerous goods to be carried.
d) for vessels carrying dangerous goods, the applicable references to the pertinent firefighting and emergency cargo handling instructions contained in the IMSBC Code and IMDG Code as appropriate. 

The fire training manual and fire safety operational booklet must be readily available to the crew and located in areas of immediate crew access, like the wheelhouse, crew cabins, and mess room. 

The purpose of this documentation is to directly benefit the master and crew. If they understand and work towards fire preparedness and avoidance of fire, this will help to avoid having to fight a fire onboard. Hence, a fire preparedness survey executed as per the standard in NSCV C4 is of importance. 

Electrical documentation requirements 

A lack of electrical documentation is still causing delays to some applications. Let’s have a look at what you need to submit to AMSA.

We require an AMSA 563 and/or AMSA 564 (or surveyors own equivalent report) for electrical installations on all Certificate of Survey and EX40 applications. 

A state electrical regulator certificate of compliance is required for vessels with a low voltage electrical installation for: 

  • initial survey; and 
  • major work carried out on the electrical system

A surveyor may request a certificate of compliance if they identify deficiencies with the electrical system.

State and territory electrical regulators have requirements to provide documentation detailing any low voltage electrical work that has been carried out on an installation. The purpose of the certificate is to assure the customer that the work is installed and tested to the appropriate Australian Standard.

The following links will take you to the state and territory specific certificates and provide further details on how to submit these documents:

Submit these documents along with your survey reports.

Electrical plans

Approved electrical plans must be provided:

  • Prior to installation; and
  • if any major work is carried out on a vessels low voltage electrical system.  

Major work includes upgrading the electrical supplies and replacing the shore power connection (unless it is like for like). A suitably qualified electrical surveyor with accreditation in category a must approve the plans.

Poor installation examples

Below are some photos of a poor extra low voltage installation. You don’t need to be an electrical surveyor to bring these issues to the attention of the vessel owner. You can request a report from an electrical surveyor or a suitably qualified electrician if you are in any doubt.

example

Issues include:

  • Incorrect use of red cable for a negative terminal. This can lead to confusion and possibly damage electrical equipment and cause a fire. 
  • Inadequate size of the black wire on the top battery. Noting the sizes of the other battery cables the smaller wire is too small for the current provided by the battery. This can cause overheating and lead to a fire.
  • The batteries do not appear to be secured.

example

Issues include:

  • Severe corrosion of the terminal on the right. This will cause a hot joint and increase the resistance of the cable/terminal which can lead to a fire.  
  • Use of mixed cable colours (both red and black) on the left hand connection.

example

Issues include:

  • No cable gland on the bulkhead penetrations. The cable must be protected from damage from the penetration, and the bulkhead integrity for watertightness and fire safety must be maintained.

Fast craft documentation

NSCV F1 contains requirements for Fast Craft. In order to provide safety for these vessels, it is essential to manage risk via:

  • Accommodation design
  • Active safety systems
  • Restricted operation
  • Quality management
  • Human factor engineering

Under the NSCV, risk factors associated with category F1 Fast Craft are comparable to those of category A and B Craft, and Cargo Craft included in the High Speed Craft (HSC) Code. The HSC Code provides a balance between technical and operational controls to address risks on these vessels.

A key risk parameter matrix approach was adopted for category F2 Fast Craft to establish equivalent safety outcomes to those contained in the HSC Code.

Category F2 Fast Craft must be supplied with two pieces of essential safety information:

  1. Craft operating manual; and
  2. Maintenance and servicing manual

The craft operating manual must take into account items listed in NSCV F1C 3.10.1 including:

  • the results of any failure mode and effect analysis (FMEA) reports developed during the craft design; and 
  • safe use limits for identified critical items for safety, established under the initial survey process. 

Navigating the AMSA organisation—who to contact and when

Our organisation is made up of the AMSA Board, the Executive team and four operational and service areas; Operations, Standards, Response, and Corporate Services. Below is a brief overview of each division and some of the teams you may need to contact. AMSA’s organisational structure is also available. 

Operations

Operations is responsible for ensuring that domestic and international shipping in Australia is operating in accordance with the regulatory framework administered by AMSA. Operations provide services under the Domestic Commercial Vessel National Law Act 2012 and Navigation Act 2012. 

Vessel Safety Unit (VSU)

The Vessel Safety Unit is the focal point for technical enquiries related to new domestic vessel construction, assessment of national law exemptions and decisions relating to the issue of initial certificates of survey. The Surveyor Accreditation Scheme is also administered by VSU, while the certification team are responsible for the administrative data entry of all DCV applications. 

VSU collaborates with Standards Division to assist with the review and development of Marine Orders, general exemptions and technical standards.

DCVSurvey@amsa.gov.au – For interpretations of standards, enquiries regarding surveyor accreditation, and requests for alternate survey process and vessel determinations. 

DCVApplications@amsa.gov.au – For submission of survey reports via email, survey code requests, status updates for vessel related applications, and requests for copies of AMSA issued certificates.

Vessel Operations (VO)

The Vessel Operations team is responsible for the implementation, monitoring and educational activities associated with safe vessel operations, seafarer safety and seafarer welfare. 

For DCVs VO provides subject matter expertise on certificates of operation, safety management systems, safe crewing, exemptions and educational activities aimed at improving safety outcomes. 

VOGeneralQueries@amsa.gov.au – General operations related enquiries including Marine Order 504, general exemptions and safety management systems.

Reports@amsa.gov.au – Incident reporting

Ship Inspection and Registration (SI&R)

The Ship Inspection and Registration team administers Flag State control inspections to ensure ships under AMSA’s jurisdiction are being properly maintained between scheduled surveys. SI&R are also responsible for Port State control inspections carried out on foreign flag ships. The Shipping Registration Office manages the Australian register of ships, delivering ship registration services for the commercial shipping, fishing and boating sectors.  

Regionally based operations staff carry out the FSC/PSC inspections, assess certificate of operation, temporary operating permits and renewal of certificate of survey applications.

FSC@amsa.gov.au – Flag state enquiries and applications for Navigation Act exemptions, equivalences, waivers and determinations.

SRO@amsa.gov.au – Shipping registration enquiries and applications.

Business Planning and Support (BPS)

The business Planning and Support team coordinates and provides system support services for all AMSA and external users. BPS also coordinate business planning, management system support, and finance and personnel matters for the Operations division.

MARS.Support@amsa.gov.au – MARS access issues or password expiry.

National System Transition Program (NST)

DCV.Records@amsa.gov.au - Requests for historic vessel records and certificates

DataVerification@amsa.gov.au - Information discrepancies between AMSA certificates and state issued certificates. Migration of state issued vessel permissions into AMSA’s system.

Standards

Standards maintains the regulatory framework and standards for maritime safety, navigation and marine environment protection for all vessels in Australian waters.

Maritime Regulation (MR)

The Maritime Regulation team is responsible for the day to day management of the regulatory framework for domestic commercial vessels, ensuring that the regulatory framework is appropriately risked balanced. MR also provides a range of legislative drafting and associated services to AMSA including drafting Marine Orders, general exemptions, AMSA's delegations and authorisation instruments and other non-legislative (administrative) instruments.

Enquiries regarding overarching policy of DCV legislation. General exemption expiry and continuation questions.

Vessel Standards (VS)

The vessel Standards team deal with a broad range of policy and technical matters for international, regional and national standards for vessels. VS focus on national stakeholder consultation and international engagement as part of their work to identify and develop necessary standards whilst also looking at the appropriateness of existing standards. 

Enquiries regarding standards development and guidance material such as vessel equipment lists.

Response

Response provides national search and rescue services to the maritime and aviation sectors. The division also works to prevent ship-sourced pollution in the marine environment and provide infrastructure to support safety of navigation in Australian waters.

Corporate Services

Corporate Services provides common support services to the organisation. Corporate Services also manages our corporate communication and stakeholder engagement, including media liaison, ministerial, parliamentary and government liaison, and web, publishing, and multimedia. Contact AMSA Connect on 1800 627 484 or AMSAConnect@amsa.gov.au 

Safety alerts and other newsletters

In 2020 we have issued safety alerts regarding:

Read our safety alerts and other newsletters.

Last Updated: 

15 September 2020