Survey Matters—March 2021

In this edition we provide advice on how to send us large files, what to do if you receive a complaint about a survey, provide guidance on battery safety, and more.


Large file transfer

On occasion, we have previously received reports from accredited surveyors via a Dropbox or Google Drive link. Our IT department have advised us not to access these files for security reasons.

AMSA has a file transfer protocol (FTP) site available for use by accredited surveyors. If you need to send large files, please contact us via and we will provide you with temporary access to upload your files. 

What to do if you receive a complaint about a survey 

We recognise that conducting survey activities in the National System may not always be an easy task. Appeasing vessel owners, companies and insurers can be a tricky business, conflicts and complaints may arise.  

An accredited marine surveyor has obligations under section 34 of the regulations to notify the National Regulator about certain matters. You must notify AMSA within 5 business days of becoming aware of a written complaint about a survey. You can do this by emailing details of the complaint to  

AMSA considers each individual complaint and takes a pro-active approach to managing these issues. AMSA, however, does not get involved in complaints relating to insurance claims, consultancy work, pre-purchase surveys, commercial disputes, or financial matters. 

On all occasions, AMSA seeks that complaints are raised with the accredited surveyor first in hopes of a satisfactory resolution.

Since the beginning of the accreditation audit scheme, AMSA has conducted 28 complaint audits against 24 different accredited surveyors. During these audits, a total of 62 findings were sent to the respective surveyors for corrective actions for direct response.  

One surveyor had 19 findings against a single survey activity. The surveyor was found to have contravened section 32 of the regulations and received an official counselling letter.  

During another audit, it was revealed an accredited surveyor received an official complaint but failed to alert the National Regulator. The surveyor was found to have contravened section 34 of the regulations and received an official counselling letter.   

Owner’s responsibilities under Marine Order 503

Owners of domestic commercial vessels have responsibilities to ensure the conditions on a certificate of survey are being complied with at all times. This includes ensuring that the vessel completes periodic surveys in accordance with the frequency mentioned in schedule 3 of Marine Order 503 (MO503).  

Section 11 (1) (c) of MO503 requires the owner to ensure the National Regulator is provided a report setting out the condition of the vessel and the extent of its compliance following periodic surveys.

It has been brought to AMSA’s attention that not all owners are receiving clear communications from their accredited surveyor with respect to periodic and renewal survey activities. This may be because the surveyor directly uploads into MARS without providing the owner with any closure or report. It may also be due to the surveyors holding reports for a period of time for various reasons.  

AMSA recommends providing the owner with a copy of the AMSA901 (or surveyor’s equivalent) and AMSA586 forms following a survey. These forms enable the surveyor to communicate survey related matters to both the National Regulator and the vessel owner. This also ensures the owner holds evidence that they have complied with the requirements of MO503.

Fibreglass sheathing of timber vessels

We’ve recently received questions about fibreglass sheathing of timber vessels and the survey requirements for such vessels. AMSA considers sheathed timber vessels as being primarily of timber construction and as such, they must be surveyed by surveyors accredited to survey timber vessels.

AMSA does not recommend the sheathing of timber vessels due to the following:

  • The 10 yearly survey requirement of withdrawing sample fastenings still applies. This may require costly repairs.
  • During an out of water survey, the attending surveyor must be satisfied that the hull structure continues to meet the applicable standards. The FRP sheathing would limit the extent to which the hull may be inspected, and it could result in the surveyor not recommending the survey if they are not satisfied that the hull condition can be suitably verified.
  • FRP sheathing of old timber vessels must be done under very controlled conditions to ensure a watertight bond between the timber and the sheathing. Due to the nature of timber, the hull planking expands and contracts which is why seams are caulked. The FRP sheathing would not flex to the same extent as the timber. This may result in damage to the planking, or delamination of the sheathing from the timber which may then introduce moisture or rot that may not be readily seen.

Recommendations from the investigation into the loss of the passenger vessel Conception

DCV Safety Alert: 1/2021 is available on the AMSA website now. It aims to raise awareness of recommendations made by the United States National Transportation Safety Board (NTSB) following the investigation into the fire and subsequent loss of the passenger vessel Conception. The safety alert highlights, among other things, the need for suitable smoke and fire detection systems and the importance of emergency escape routes.

While this incident didn’t occur in Australia, the findings of the NTSB investigation provide our industry with an opportunity to learn from the unfortunate experience of others.

Battery safety

Batteries both portable and fixed, onboard vessels have the potential to cause harm. Lithium-ion battery installations, in particular, have additional requirements in AS/NZS 3004:2 that must be observed for new installations. 

This includes observing IP ratings, specified ventilation and temperature limits, battery monitoring systems, alarms, and automatic load disconnection. 

Further guidance and information about batteries is available at the weblinks below:

Material alert

DNV recently notified AMSA they have suspended two material certificates for grade VL5083 aluminium plates manufactured by Henan Mingtai Industry Co. Ltd. China (Mingtai).

The certificate numbers are AMMM0000053 Rev. 1 and AMMM00002RA. Further information on the suspended certificates is available on their website.

Have your say on the new standard for watertight and weathertight integrity

We have opened consultation on a new, more modern standard for watertight and weathertight integrity on domestic commercial vessels.

Consultation for NSCV C2: Watertight and weathertight integrity is open from 18 January to 28 March 2021.

This proposed change is likely to be of interest to boat designers, boat builders, naval architects, and industry groups. We encourage you to share this message with interested parties.

Why we need a new standard

The requirements for watertight and weathertight integrity for domestic commercial vessels are currently spread across three technical standards contained in the Uniform Shipping Laws (USL) Code that were developed more than 40 years ago. Section C2 is a long outstanding section of the NSCV that needs modernising.

This draft standard updates the requirements for watertight and weathertight integrity to reflect current technologies and to align with international standards and best practice. It has been co-designed with the guidance of a technical advisory panel comprising accredited marine surveyors, representatives of industry associations and educational institutions.

What we are proposing is a performance-based standard with multiple options to achieve compliance and address several safety issues with the current requirements, including over-loading.  

Find out more about the proposed changes and make a submission at You can also send submissions via email to

Last updated: 14 November 2023