Survey Matter—September 2021

In this edition we explain about National Law audits,

In this edition

Audits and application assessments

AMSA audits recently accredited marine surveyors to ensure the correct 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. These audits identify issues that may arise in the early stages of a surveyor's activity.

Observations and non-conformances will be provided in writing to the surveyor for action.

Audits also occur because of complaints received or non-conformances detected during our assessment of survey applications. The three cases below are examples where major non-conformances were identified.

A certificate of survey application for a new build 2B vessel was refused when several major non-conformances were identified. The non-conformances 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 damaged stability did not comply with NSCV C6B
  • The vessel was fitted with a stepped collision bulkhead that does not comply 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. The vessel has since undergone modifications and a new application for a certificate of survey has been submitted.

An AMSA inspection identified a 3B vessel had undergone a major refit. The vessel had permanent ballast removed and major hull and structure replacements were carried out. Fish linings, tanks and freezers were also removed, and the vessel’s stability needed to be reassessed. The accredited surveyor made an error in assuming these works could be undertaken as a renewal survey instead of an initial survey to the transitional vessel standards.

The vessel’s certificate of survey was suspended without a show cause notice as there was clear intention to operate the vessel without a revised stability assessment. The vessel remains unable to operate without contravening S11(1) (h) of Marine Order 503, pending an initial survey.

The accredited surveyor was issued a notice of decision letter refusing a further time period to renew their accreditation under the National Law. The surveyor had failed to apply to renew their accreditation within the timeframes set out by the regulations. The surveyor is no longer accredited after they chose not to submit an initial application and undergo an interview.

AMSA conducted inspections on two 2C sister vessels after receiving a complaint. Major non-conformances were identified following a physical practical stability test of the vessels.

The surveyor had initial survey categories revoked following an audit and show cause process. The certificates of survey were revoked for both vessels, and the owner has settled a claim against the builder and surveyor involved.

Submission of survey reports

AMSA will stop receiving emailed survey reports from 1/12/2021. This means accredited marine surveyors and Recognised Organisation surveyors need to submit their reports and recommendations directly into MARS from this date. We are making this change so that our stakeholders (your clients) receive their certification as soon as possible. This change will increase the efficiency of certification processes.

To prepare for this change surveyors will need to ensure your MARS login details (username and password) are current. You will need to download the free ‘VIP Access’ app to your desktop or mobile device. Chapter 3 of the MARS user guide contains the steps to get set up and log in. The user guide is available on the AMSA website here. If you need help setting up, you can email for assistance.

You should review the rest of the user guide to ensure you are familiar with uploading survey reports directly into MARS. If you currently submit your reports via email, you now have almost three months to transition to lodging reports directly into MARS.

Please note the MARS user guide and associated web pages will be updated to reflect the change in process.

Can one of my employees access MARS and upload surveys on my behalf?

Yes, AMSA provides the option to set up company access so an administrative representative can claim and enter surveys on behalf of a surveyor. Send an email to if you would like to set up company access.

Does this apply to ALL survey reports?

There are some exceptions to the rule. AMSA will accept emailed submissions when:

  • A licensed electrical contractor, who isn’t an accredited marine surveyor, conducts an electrical survey.
  • A surveyor provides a recommendation in support of an EX02 application or as part of an engine change notification.
  • An accredited marine surveyor who doesn’t hold the required category to claim a code asks for the survey activity to be marked ‘not required’ (with sufficient justification).

What if I conduct an additional survey outside the vessel’s survey cycle?

If you conduct an additional survey that doesn’t align with a vessels survey cycle, for example a repair survey, you can email and ask for a code to be generated. This process also applies for surveys conducted on vessels that aren’t required to hold a certificate of survey, for example vessels operating under EX02 Division 5.

What about surveys for vessels greater than 35 metres?

There is no change to the process already in place. If an accredited surveyor conducts a survey on a vessel greater than 35 metres they must email and provide:

  • The vessel name and UVI
  • The survey code(s)
  • The reason a Recognised Organisation doesn’t need to survey the vessel (i.e. it is an existing vessel not in class at 01/07/2013)

Any questions about this update can be directed to

Structural fire protection

AMSA continues to receive recommendations from surveyors where non-compliant structural fire protection has been fitted to vessels. These non-conformances have significant impacts for builders, surveyors and vessel owners. AMSA recently refused an application for a certificate of survey for a new build vessel fitted with non-compliant structural fire protection, among other non-conformances.

We wrote about passive fire protection measures in the April 2020 edition of Survey Matters. The information is reproduced below to reiterate the importance of compliant structural fire protection.

Structural fire protection is installed on the vessel structure to contain or slow the spread of fire. It includes the installation of fire-resistant bulkheads, deck heads, decks and doors.

The primary aims of structural fire protection are:

  • Prevent or delay the spread of fire, smoke and heat within high-risk spaces.
  • Protect essential systems and spaces to enable evacuation from the immediate area. This also ensures persons on board can reach muster stations and then abandon ship, should the fire become unmanageable.
  • Provide redundancy and work alongside active fire protection systems. This avoids vulnerability arising from over-reliance on a single measure.

Passive structural fire protection works in four main ways:

1. Protects structural elements

Structural fire protection guards essential components and compartments against fire and thermal heat, to maintain structural integrity.

2. Compartmentation

Compartmentation includes fire-rated divisions or compartments, bulkheads, deck heads, and smoke barriers. It seeks to contain the spread of fire, thermal mass and smoke. Fire can be contained within the machinery space, for example, if the bulkheads and decks are sufficiently protected.

3. Opening Protection

Fire doors and fire-resistant penetrations installed in openings aim to maintain fire-resistance. They work together to form an effective smoke and fire barrier.

4. Fire stopping materials

These materials generally withstand temperatures exceeding 1200°C for extended time periods. This limits fire spread.

Note: It’s common to see a fire-rated division penetrated during modifications. Workers may leave hidden holes in the division as they perform maintenance and upgrades. Surveyors need to pay attention to fire-rated divisions and ensure they are maintained to the original approved specification. This includes paying close attention to cable and pipe penetrations.

The type and thickness of insulation depends on the material it is protecting. For example; steel begins to lose its design margin of safety at temperatures of around 550°C. For aluminium the temperature is much lower at around 150°C. At 275°C aluminium will lose around 50% of its yield strength. Composites soften as temperatures rise, resulting in reduced structural properties for a laminate. The glass transition temperature of the resin affects the amount of insulation required for a composite. Performance of cores & fibres across a range of temperatures also impacts the amount required.

The April 2020 edition of Survey Matters contains the basic principles and examples of data sheets and certificates of compliance for Aluminium - A30, Steel - A30, and Composite - A60 structural fire protection.

Key items a surveyor should verify

Installing protection under approved design and OEM guidelines is the only way to achieve the aims mentioned above. This includes:

  • Ensuring only appropriately tested solutions are used.
    • The requirements of the performance standards (Fire Test Procedures Code or the High Speed Craft Code) are specific. Products not designed and tested to meet these standards are not acceptable (see below).
    • Insulation requirements vary based on type and thickness of the material it is protecting. Requirements also vary depending on the area on the vessel and the time rating of the division. 
  • Having concise and accurate approved drawings, of the proposed arrangements. 
  • Verifying that materials and fittings are correctly installed by competent personnel, i.e. as stated in the approval documentation and/or the manufacturer’s instructions. For example, pins are fixed to the substrate correctly. Pins are sufficient in nature as per approval documentation and achieve required returns.
  • Verifying that the means of protection are inspected and tested at regular intervals. This includes prompt repair and renewal whenever necessary.
  • Checking the certification of the SFP, do not confuse non-combustible products, with those properly tested and certified as part of time rated fire-resisting divisions (structural fire protection).

Examples of unacceptable products

Pink batts are not acceptable. They are combustible above 350°C and are designed for comfort insulation and acoustic use only.

Intumescent paints and similar solutions do not meet the performance requirements for use. They are not approved for use as structural fire protection solutions.

A solution approved for use on steel, is not necessarily suitable for use on aluminium or fibreglass. Even if it is certified for a higher time rating than required. 

A solution approved for use in a land-based building is not approved for use on a vessel. The performance criteria are significantly different between vessels and buildings. The environment, firefighter response time and distance to safety or rescue if a fire breaks out differ.

Out of water survey requirements

AMSA has noticed there is some confusion about what items must be surveyed as part of a periodic out of water survey. The confusion stems from the out of water survey items section at the bottom of Table 9 in chapter 4 of SAGM Part 2.

The out of water survey items section is not an exhaustive list of items that must be surveyed as part of a periodic out of water survey. The whole of table 9 must be considered when conducting a periodic out of water survey and any item with a tick next to it must be surveyed.  

When you conduct a survey for an OWAT code, ensure all applicable items in Table 9 are examined, verified, tested or trialled, and documented on your reports.

Navigation light requirements

AMSA frequently receives enquiries from vessel owners and operators regarding the navigation light requirements for domestic commercial vessels. During audits we have also noticed that navigational light arrangement plans are commonly omitted, or these details aren’t reflected in the general arrangement plan as part of the initial survey documentation.

Does my vessel need a navigation light arrangement Plan?

For vessels which must comply with Pt. C of COLREGs, AMSA expects that a navigation light arrangement plan, approved by an AMS, is available on board. This plan may contain details regarding the different types of navigation light, minimum range of visibility, horizontal and vertical positioning and spacing of the lights etc.

Alternatively, for smaller vessels, these details can be provided on the general arrangement Plan.

A profile view and table of navigation lights on a ship over 50m is shown below for illustration purposes only (not to scale).

Boat dimensions

Item numberLightTypeSI numberRangeVisibilityColour
1Fore Masthead Light----225°6nmWhite
2Aft Masthead Light----225°6nmWhite

Can a vessel use LED navigation lights?

LED navigation lights can be installed, subject to several conditions listed in IMO resolution MSC.253 (83).

However, AMSA reminds all owners, operators and accredited surveyors that the luminous intensity of LEDs gradually decreases while the electricity consumption remains unchanged. The rate of decrease of luminous intensity depends on the output and temperature of the LEDs.

What are the additional requirements for LED navigation lights?

Marine Order 30 requires navigation lights, navigation light controllers and associated equipment, installed on DCVs after 30 November 2009 to conform to performance standards at least equal to those mentioned in the Annex to IMO Resolution MSC.253(83).

To prevent shortage of luminous intensity of LEDs, the following additional requirements have been specified in IMO Resolution MSC.253 (83): 

  1. An alarm function should be activated to notify the Officer of the Watch that the luminous intensity of the light reduces below the level required by COLREGs;


  1. LEDs should only be used within the lifespan (practical term of validity) specified by the manufacturer to maintain the necessary luminous intensity of LEDs. The lifespan of LEDs should be determined and clearly notified by the manufacturer based on the appropriate test results on the decrease of luminous intensity of the LEDs under various temperature conditions and on the temperature condition of LEDs in the light during operation, taking the appropriate margin into account.

What should an accredited surveyor check regarding LED Navigation Lights?

Accredited surveyors are encouraged to check the following documentation/marking checks in addition to the routine safety and operation checks;

  1. Valid type approval certificates for reference to IMO Resolution MSC.253 (83) and for special installation instructions.
  2. Check if the Navigation light controller is included in the type approval certificate and the controller is approved in accordance with MSC. 253 (83).
  3. Check the LED light or the manufacturer documentation for navigation light expiration dates.
  4. When completing the AMSA 901, specify LED for Navigation Lights as well as the expiration date.

If expiry dates aren’t specified by the manufacturer, check for alarm functions on the bridge for reduction in luminous intensity of LED Navigation Lights.

Lines plans/hull model requirements

The Surveyor Manual Part 2 Table 2 requires that a lines plan (or electronic 3D hull file) is provided when comprehensive stability criteria is used. This is expanded in NSCV C6C, clause A8.8.4 as part of the information supporting the inclining experiment.

This may elicit concern, as it is a valuable piece of intellectual property. AMSA appreciate that a lines plan represents sensitive proprietary hull design information often built up over many years. It can also represent a significant investment of time to model an existing vessel, providing a competitive advantage.

We understand and appreciate these concerns. AMSA has a comprehensive privacy policy on our website.

The rationale behind the requirement for lines plan data (either in the form of a drawing or a 3D hull model) is to permit audit in accordance with section 45 of the regulations.

Another reason for requiring a lines plan is to aid investigation in the event of an incident linked to the vessel stability. Should stability need to be assessed the provision of hull data allows for this to be undertaken.

Hence, when comprehensive stability is used on a vessel, either a lines plan containing the data listed in Table 2 of SAGM Part 2, or an electronic hull file, such as a Maxsurf hull file or *.iges is required in support of a recommendation for stability approval.

Autonomous vessels in Australia

AMSA has recently seen an increase in the use and application of autonomous vessels in Australia. AMSA has produced guidance material to assist operators of these vessels to comply with the national system. The guidance notice is now available on the AMSA website and helps improve our regulation of emerging technology in Australia.

Guidance Notice – Small unmanned autonomous vessels

Nitrogen oxide (NOx) emission requirements for marine diesel engines on DCVs

As a part of global measures to reduce harmful nitrogen oxide (NOx) emissions, marine diesel engines with an output above 130kW must now meet NOx emission requirements.
Globally, the shipping industry is reducing NOx emissions by requiring marine diesel engines with a power output of greater than 130kW to comply with NOx emission limits.  To confirm an engine is compliant, an Engine international air pollution prevention (EIAPP) certificate and a technical file must be carried on board for each engine.  
AMSA has introduced measures that will assist DCV owners and operators comply with the NOx emission requirements. Under Exemption 44, DCV owners and operators can hold specified alternative evidence that demonstrates engines are likely to meet the NOx emission limits.

Read more information about the requirements

The AMSA National Compliance Plan 2021-22 is now available

The National Compliance Plan 2021-22 provides practical guidance and a clear view of what AMSA will be looking for over the coming year to make it easier to comply with the national law.

Focus area 3 in the plan specifically addresses domestic commercial vessels. The importance of safety management systems, incident reporting, fatigue management, and compliance with the marine surveyors’ accreditation guidance manual are priority areas for AMSA’s compliance activities over the coming year.

Focus areas 4 and 5 are also targeted to domestic commercial vessels to increase beacon registration and prevent pollution from ships.

Please familiarise yourself with the priority areas and share this information with your clients as the opportunity arises.

We welcome your feedback

Is there a topic you’d like to see covered in a future edition of Survey Matters? Send an email to with any suggestions or feedback.

Last updated: 14 April 2022