Survey Matters—November 2019
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Since the last edition
We have updated the surveyor audience page on the AMSA website, including creation of a new area to host MARS guidance materials. This area now contains the MARS user guide and guidance on AMSA expectations for initial survey submissions, including an example of AMSA’s checklist for new build submissions.
VSU have visited yards in NSW, Queensland and Tasmania to talk to boat builders with the aim to improve understanding of DCV requirements at the source. The focus is on timely submission of approved plans and survey reports prior to delivery to avoid unnecessary delay in the certification process. We have focused on consistent approaches and outcomes for alternate initial survey proposals submitted under SAGM 3.8 (2).
Some notable submissions regarding certificate of survey applications stood out. In particular an application which was assessed in less than 90 minutes due to the detailed and complete submission from the AMS. The certificate was issued to the applicant within 3 hours of the final survey report being recommended in MARS.
In the month of October, VSU’s application processing team received 740 applications across all online application types.
In this edition
- Accreditation matters
- Certificate matters
- Drafting errors in NSCV C4
- To What extent do you survey a vessel’s propulsion system?
- Requirements for fitting Fixed Firefighting Equipment
- Lead acid battery composition and the associated hazards
- Load line aspects to be considered for unpowered RAV barges applying to become a DCV for the first time
- Engine Changes
The first renewals of accreditation are due in February 2020. An application for renewal should be submitted to AMSA at least three months ahead of the expiry date of your accreditation. AMSA will be writing to all surveyors ahead of their renewal, reminding them to apply.
The renewal application can be found on the AMSA website. AMSA has recently revoked the initial survey accreditation for a surveyor, after a recurrence of undertaking surveys and submitting recommendations without approved vessel plans. The initial occurrence resulted in a variation of the accreditation, on the second occasion the accreditation was revoked.
The initial survey accreditation for another surveyor has ben suspended for not adequately surveying a vessel to determine that it met required standards. In this example, the surveyor was unable to provide sufficient information supporting their recommendation to the National Regulator. An inspection of the vessel found major non compliances with the required standards and the application for a certificate of survey was refused.
A further six suspensions of accreditation were initated due to surveyors not holding PI cover, and two variations of accreditation occurred. Prior to making a decision to vary, suspend or revoke an accreditation a show cause letter is sent to the surveyor. This letter sets out the intended action, the supporting reasons for the action and invites a response as to why the action should not be taken Two counselling letters have also been sent to surveyors who undertook surveys outside of their accreditation, while six investigations have arisen from complaints or inspections in this time.
In the lead up to the renewals of accreditation, audit activity and associated requests for information will be increasing.
When an application for a new or transitional certificate of survey is received by AMSA, survey codes are created and an AMSA assessor is allocated. The customer receives an email advising of the process, who their allocated assessor is and a copy of their surveys required letter.
If you have any questions in relation to the assessment of the application or the surveys that have been created in MARS, these can be directed to the allocated assessor. Your client will be notified of who the assessor is. Technical questions can be emailed to DCVapplications@amsa.gov.au marking it to the attention of the allocated assessor.
Drafting errors in NSCV C4
In the re-drafting of NSCV C4, alterations were made to definitions in order to accommodate the new structure of the standard. AMSA is now aware of two issues as a result of this re-drafting. AMSA Standards Division will amend these issues at the first available opportunity.
In the meantime:
Clause 5.4.1 / Table 13
Specifies that an aqueous system is required on class 1 vessels with more than 200 day passengers or 36 berthed passengers. This provision should only apply to vessels of fire risk category IV (as previously specified in C4).
If you find yourself considering plans or fire systems on a vessel carrying more than 200 day or 36 berthed passengers, then please contact the vessel safety unit team for more information.
Moderate risk fire spaces
The current version of NSCV C4 includes a definition of a small machinery space, being a space containing particular equipment, with volume less than 10m3 . Small machinery spaces are then listed as a specific example of a type of moderate risk space within table 3. However, Table 3 does not mention large spaces containing the same kind of equipment.
Nonetheless, spaces greater than 10m3, containing combustion machinery or electrical equipment with aggregate power of 30 KVA or more are moderate risk.
This is because as specified in table 3, they are spaces that:
(a) contain potentially dangerous quantities of flammable liquids but where the sources of ignition have relatively low frequency; or
(b) contain heat sources or other sources of ignition but where the quantity or nature of material within the space to fuel a fire is such that the risk is significantly reduced.
Do not classify these spaces as minor risk.
Note 3.2 (2) and 3.3 of NSCV C4 provide rules for classifying spaces.
3.2 Categories of spaces
(2) Where there is any doubt as to the category of a space, the space is to be assigned and meet the higher space category standards.
3.3 Spaces of multiple classification
Where it is possible to assign two or more classifications to a space, it is to be provided with active and passive fire protection measures that satisfy the more stringent of the requirements specified for each applicable classification.
To what extent do you survey a vessel’s propulsion system?
SAGM defines the purpose of conducting a survey is to;
(a) Confirm the vessel and its equipment comply with, or continue to comply with, the requirements of the applicable legislation, exemptions and standards; and
(b) Identify deterioration, wear or damage to the vessel that may interfere with the ability of the vessel and its equipment to comply with (a).
SAGM does not identify individual components in this definition - it refers to the entire vessel and all the equipment. For example a vessels certificate renewal where the AMS is required to survey the propulsion system in its entirety.
In this instance AMSA requests a shaft survey report (AMSA638) be provided. However, the extent of the survey is far greater than just the shaft report. The shaft report gives AMSA a snapshot of one item in the propulsion system survey. It is not the beginning and end of the propulsion system survey.
The propulsion system may comprise many elements such as flexible couplings, bobbin spacer, coupling, keys, coupling retaining nut, stern tube seal, shaft, bearings, P, V or I bracket, rope cutter, propeller, propeller retaining nut etc. There are numerous variations of propulsion systems and the surveyor needs to examine each component individually to satisfy items (a) and (b) of the SAGM definition mentioned above.
Many vessels have systems which include equipment supplied by an Original Equipment Manufacturer (OEM). The surveyor may not be familiar with this piece of equipment and it may not have a specific deemed to satisfy solution in the NSCV however, the surveyor still needs to ensure the component is suitable for its role and is compatible with interacting system elements. Again, using a propulsion system as an example, for a boat driven by a waterjet the surveyor should refresh their memory of the required outcomes for propulsion systems (NSCV C5A chapter 3.3 to 3.5) and assure themselves;
(a) The waterjet unit is securely fastened to the hull structure,
(b) The connection to the hull is watertight (no evidence of leaks),
(c) The surrounding hull structure is not cracked or distorted,
(d) There is no corrosion at the interface of the waterjet and hull structure due to dissimilar metals etc.,
(e) There are no waterjet defects apparent from an external examination,
(f) The surveyor should question the vessel owner / operator about the service history of the waterjet unit. Has it been maintained and serviced in accordance with the manufacturer’s recommendations?
Additionally, the torque transmitted to the waterjet coupling is transmitted by a driveshaft which allows for variations in alignment and distance. Part C of the NSCV does not have a deemed to satisfy solution for drive shafts. The modern driveshaft is an OEM supplied piece of equipment. The surveyor should ensure;
(a) The rotating driveshaft is covered by a safety guard,
(b) There is no slack in the universal joints, cracks or signs of wear,
(c) The shaft is not damaged or bent,
(d) There is no excessive slack in the slip spline,
(e) The surveyor should question the vessel operator about vibrations or noises that could emanate from the driveshaft. Vibrations can be caused by worn universal joints or slip splines, yokes out of phase or misaligned angles.
(f) The surveyor should question the vessel owner / operator about the service history of the driveshaft. Has it been maintained and serviced in accordance with the manufacturer’s recommendations?
(g) The surveyor should take photos and keep notes in relation to OEM inspections.
The survey process is best viewed as surveying an entire system rather than individual components. This approach is applicable to all of the vessels components, such as structural systems, lifesaving equipment systems, propulsion systems, navigation systems, electrical systems etc. The AMS should take photos and keep notes for all system surveys including those with OEM inspections.
Requirements for fitting Fixed Firefighting Equipment (FFE)
For vessels other than class 4 vessels or fast craft, fitting fixed firefighting equipment, fixed fire detection and extinguishing system must be compliant with the requirements specified in NSCV Part C4.
NSCV C4 fixed fire detection
NSCV Part C4 Chapter 5.1 defines the requirements for vessel fixed fire detection systems. When undertaking surveys of fire detection systems an Accredited Marine Surveyor must establish that the system is compliant with one of the following standards:
- FSS Code - Chapter 9; or
- HSC Code, clause 7.7; or
- AS 1603.
Significantly NSCV C4 Chapter 5 requires:
- Spaces are to be fitted with fire detection capability in accordance with NSCV C4 Table 10 including all vessels to have a fixed fire detection system fitted to a Machinery Space, and,
- Fire alarms must be located so that they can be monitored from the operating compartment and in such other places to ensure a responsible member of the crew hears them when the operating compartment is unmanned, and,
- For Class 1 vessels of Fire Risk Category II, III or IV, the fixed fire detection and fire alarm system must be of the self-monitored type, and,
- Manual call points to be located within 20m of any point; and integrated into a fixed fire detection and fire alarm system for RoRo vessels and Accommodation & Control station spaces of fire risk category II (+200 pax), III and IV.
- Vessel accommodation spaces that carry more than 36 Pax or have berthed accommodation and are not required by NSCV C4 5.1.1 to be fitted with a fixed fire detection and fire alarm system must be provided with self-contained photoelectric smoke alarms complying with AS 3786.
Fixed fire-extinguishing systems
NSCV Part C4 Chapter 5.4 defines the requirements for vessel fixed fireextinguishing systems.
When conducting a survey of fire-extinguishing systems an Accredited Marine Surveyor must establish that the system is compliant with one of the standards listed in NSCV C4 Chapter 5.4.3 and Table 14.
NSCV C4 Chapter 5.4.3 requires the fixed fire-extinguishing system must be of a type designed, assessed, manufactured, installed and tested in accordance with a standard listed in Table 14 or another standard determined by the national regulator.
Note the system must be confirmed to have been assessed.
The requirement assessed is defined in NSCV C4 Chapter 18 and requires the system to be confirmed as Type or Class approved.
AMSA has recently identified cases where the fixed fire-extinguishing system was recommended as compliant with the NSCV C4 requirements however when the Accredited Marine Surveyor was requested to demonstrate the basis for this recommendation there was no supporting evidence of compliance. It should also be noted that in some cases the standard may have changed since the system was originally installed so the original certification may no longer be compliant.
Fixed fire detection and fixed fire-extinguishing compliance with the requirements can be determined by surveying the system against the applicable standards or obtaining a report from a competent third party fire systems technician in accordance with SAGM Pt 2, 2.7(3) confirming the systems complies with applicable standards listed in NSCV C4 and discussed above.
Lead acid battery composition and the associated hazards
A lead acid battery produces hydrogen and oxygen whilst being operated and charged. These gasses fill the void in the headspace above the electrolyte and if they aren’t vented correctly or are exposed to a source of ignition, the battery can explode. Sources of ignition can be either external to the battery or come from within.
Causes of lead acid battery explosion:
Overcharging, faulty systems and normal operation
Overcharging due to a faulty charging system will produce hydrogen and oxygen that will increase the risk of explosion. Overcharging also increases the rate of grid corrosion of the internal battery plates and separators that can lead to the possibility of a short circuit and explosion.
A flooded lead acid battery used under normal operating circumstances can produce hydrogen and oxygen at the level where an explosion may occur.
External sources of ignition
External sources of ignition shall not be in the vicinity of these battery installations, they include: static sparks, naked flames, electrical switching equipment, battery chargers, invertors, loose connections, poorly maintained electrical wiring and shorting of electrical terminals due to exposed conductors. All of these examples have the ability to ignite the flammable gasses generated by lead acid batteries.
An engine start is when a battery is exposed to its maximum drawing current in normal operation. If there is an underlying mechanical problem with the battery it may cause an explosion and the risk is higher if the battery is nearing its end of life. Internal plate corrosion and a manufacturing fault both increase the risk of a short circuit. This risk is increased if the electrolyte level is low and the potential short is in the head space above the electrolyte.
Poorly maintained batteries
Batteries that have been poorly maintained for extended periods of time can lead to an increased possibility of explosion. Regular battery care and maintenance can help reduce the risk of battery explosion. The operating and maintenance instructions provided from the battery manufacturer and supplier should always be followed. Batteries will last longer and the risk of explosion will be reduced.
When undertaking surveys on vessels that aren’t existing vessels, ensure that batteries are stored, charged and ventilated in accordance with the requirements of NSCV C5B Chapter 3.
Although these issues are taken into account in the development of NSCV C5B and AS/NZS 3004.2 which have mitigated the risks to users, vessel owners should be made aware of the hazards posed by batteries.
Photos: Examples of sealed lead acid batteries where an incident occurred at start up
Load line aspects to be considered for unpowered RAV barges applying to become a DCV for the first time
A domestic commercial vessel to which Marine Order 507 (Load Line Certificates - National Law) applies must comply with the requirements of the International Convention on Load Lines (ILLC) or USL Code Section 7.
Many unpowered barges certified with international load line certificates issued under the Navigation Act which are applying for DCV status for the first time, have only been certified for un-manned, deck cargo operations. However, if the intended domestic operation is with persons on board, or with plant and machinery these issues must be considered before a National Law load line certificate can be issued.
In order for a DCV load line certificate to be issued, some aspects regarding the freeboard assignment process that need to be considered, include:
- Protection of the crew requirements (USL Code Section 7 Clause 23/ Regulation 25 ILLC)
- Additional operation, if applicable (as new crane operation), under the vessel’s stability assessment
- USL Code Section 7, Part 11 compliance, specifically regarding manned operations and minimum bow height requirements, noting that:
- 1. The minimum bow height requirements of Clause 42/Regulation 39 are not applicable to unmanned barges (USL Code Section 7 Clause 42.10/Regulation 27 ILLC).
- 2. Unmanned barges which have on the freeboard deck only small openings closed by watertight gasketed covers of steel or equivalent material may be assigned a summer freeboard reduced by 25%, according to USL Code Section 7 Clause 46.4 and ILLC regulation 27 (14) (c)
The AMSA 1847 form is now available on the AMSA website for notification of changes of engines on EX40 and certificate of survey vessels. Non-survey approval holders should continue to notify AMSA of engine changes via the AMSA 566 form.
The AMSA 1847 checklist requires supporting documentation confirming the details of the new engines as well as a recommendation from an accredited surveyor for engine changes that aren’t like for like. There is also a tick box regarding EIAPP certificates.
As mentioned in the August edition of Survey Matters, Marine Order 503 requires vessels fitted with a new engine after 30 June 2018, that is a Marine diesel engine with propulsion power >130 kW to have an EIAPP certificate or engine international air pollution prevention certificate issued in accordance with Annex VI of MARPOL.
DCVs operating under an exemption from the requirement to have a certificate of survey (for example, division 5 of Exemption 02) are not required to provide the certificate to AMSA, because the vessel is not required to have a National Law certificate of survey, however the provisions of MO97 apply and the engine must be supplied with EIAPP certification even if there is no certificate of survey.
Many of the major engine manufacturers have had parent engine testing conducted and type approval completed to MARPOL Annex VI tier II requirements; especially for series produced engines, with one supplier advising that 95% of their engine models are Tier II compliant. However some issues may arise with much older engine models as emission testing may never have been undertaken for those engines.