Background

This document provides a summary of responses to questions asked during the last public consultation on the proposed amendments to Marine order 505, which took place from 5 August – 29 September 2019.

Of the consultation questions, six were closed-ended questions, asking respondents to provide ‘yes/no’ answers. Another open-ended question allowed industry to provide feedback about any aspect of the proposed changes to Marine order 505.

AMSA received over 500 submissions, along with additional feedback and input from the 387 attendees at the information sessions facilitated at 14 locations across the country.

The feedback was diverse and, in many instances, revealed opposing views on a number of aspects in the draft marine order.

Proposed solutions arising from consideration of this feedback are the subject of the 2021 public consultation on Marine order 505.

Other responses received, along with a more detailed report on responses to Questions 1–6, will be made available in the final consultation feedback report when the new version of Marine order 505 comes into effect.

ferry operator
Responses to questions 1–6

The table below provides an overview of the quantitative response data for Questions 1 to 6.  From the data we can make the following key assumptions. 

  1. The majority of respondents understand the marine order.
  2. The majority of respondents are comfortable with providing a first aid certificate to obtain a certificate of competency.
  3. A higher portion of the respondents agree the proposed eligibility requirements and duties for a Coxswain Grade 3 are at the right level.
  4. A marginally higher proportion of the respondents agree a recreational boat licence is enough for a Coxswain Grade 3.  

Responses to question 4 suggested a large portion of respondents were confused by the question asked. As a result, AMSA is not able to effectively evaluate and draw assumptions from the feedback.  

Summary of responses to specific questions in the 2019 consultation

Question Is the draft Marine Order 505 easy to understand? Are there any sections that are not clear? Do you agree that an application for a new certificate of competency should include the requirement to hold a first-aid certificate? Do you think a medical fitness certificate for a new issue and self-declaration of medical fitness for renewal is appropriate for the lower grade certificates? Do you think the eligibility requirements and duties for a Coxswain grade 3 NC are appropriate? Do you think a recreational boat licence is sufficient for a Coxswain grade 3?
Response Yes No Yes No Yes No Yes No Yes No Yes No
Number of responses 246 57 133 174 195 72 134 170 163 127 175 153
Percentage 68.0% 15.7% 36.7% 48.1% 53.9% 19.9% 26.7% 33.9% 45.0% 35.1% 48.3% 42.3%
% number where the answer was indefinite or absent 16.3% 15.2% 26.2% 32.3% 19.9% 9.4%
Other responses

Some of the respondents opted only to provide general feedback, leaving questions 1–6 blank, while others provided feedback by alternate means, including via social media.

During the process of reviewing the feedback from industry, AMSA identified three key themes and worked closely with the Industry Reference Group (IRG), which was established specifically for this review, to find proposed solutions to the issues raised by industry. These three themes and proposed solutions are outlined  below.

Rough seas

To ensure the submissions raised during consultation were considered from a ‘whole-of-industry’ perspective, the IRG consists of representatives from across many of the diverse areas of our industry including:

  • ferries, sailing, tourism, and charter vessels
  • fishing and aquaculture
  • construction and towage
  • Australian Sailing
  • Maritime Industry Australia Limited
  • unions

A full feedback report will be provided when the marine order is finalised. For more information about all the proposed key amendments to the current qualification framework refer to the guidelines.

We will continue to work with industry representatives to ensure that Marine order 505 provides robust and consistent safety outcomes for the broad range of industry sectors operating domestic vessels.

Themes arising from feedback and proposed positions to industry concerns

Theme 1: General purpose hand near coastal certificate of competency—applying appropriate training and duties

Feedback summary:

  • Industry feedback indicated that the GPH training and duties are not fit for purpose across all sectors of the industry.

New proposed policy position:

General purpose hand NC—duties and functions:

Note: The terms deck work, direct supervision, engine work, and general supervision are defined in section 4.

  1. Assist with deck work on a vessel <100 m long and <3000 GT <EEZ under general supervision of the master of the vessel or an appropriately certificated crew member to whom the master delegates the supervision.
  2. Assist with engine work on a vessel with propulsion power <3000 kW <EEZ under general supervision of the chief engineer of the vessel or another appropriately certificated crew member to whom the chief engineer delegates the supervision 

Note This means that a person assisting with deck work or engine work under direct supervision rather than general supervision is not required to hold a certificate. 

Eligibility requirement: General purpose hand course at certificate 1 level 

Sea service requirement: At least 5 days qualifying sea service on a commercial vessel.

Please see the guidelines and draft Marine order 505 for more information.

Theme 2: A recreational boating licence issued by a state or territory as one of the training options for a coxswain grade 3 certificate.

Feedback summary:

  • The industry is split between an RBL being sufficient and insufficient as training for a Cox 3.

New policy position:

Coxswain Grade 3 NC—eligibility requirements

Any one of the following:

  1. Australian Sailing Powerboat Handling course
  2. RYA level 2 Powerboat course
  3. completion before [1 July 2022] of training and final practical assessment in accordance with Marine Safety (Low complexity duties) Exemption 2020 for the performance of low complexity duties (EX38)
  4. each of the following:
    1. a licence, issued by a state or territory, to operate a recreational vessel
    2. at least one day qualifying sea service on a commercial vessel
    3. a declaration on the approved form
  5. each of the following courses from the MAR Maritime Training Package, or a course developed as part of the MAR Maritime Training Package to cover the same skills:
    1. MARI003 Comply with regulations to ensure safe operation of a vessel up to 12 metres
    2. MARK007 Handle a vessel up to 12 metres
    3. MARN008 Apply seamanship skills aboard a vessel up to 12 metres.

Please see guidelines for more information.

Theme 3: Task books compulsory for completing sea service to obtain a CoC.

Feedback summary: 

  • Industry wants both options of providing sea service with and without a task book.

New policy position:

  • To provide both options of providing sea service with or without a task book.

Please see schedule 3 of the draft Marine order 505  for details.