Survey Matters – November 2022

In this edition we look at the most common reasons for certificate of survey refusal.

In this edition

Audits and application assessments 

AMSA audits accredited marine surveyors to ensure the processes set out in the National Law – Marine Surveyors Accreditation Guidance Manual (SAGM), Marine Order 503 and the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013 (the Regulations) are followed correctly.  

For example: 

  • The assessment of certificate of survey applications identified major non-conformances in the plan and commissioning survey for two passenger vessels. These included: 
  • Required plans not submitted. 
  • Plans approved but indicated that parts of the vessels were non-compliant with the relevant standards. 
  • No evidence of required inspections being conducted throughout the survey process. 
  • Inability to demonstrate that the vessels complied with the NSCV stability or fire safety requirements. 

Both survey applications were refused and AMSA formed the view that the surveyor had contravened sections 32 and 36 of the Regulations.  

Following a show cause process, the surveyor had conditions placed on categories a, g, h, and k of their accreditation. The conditions limit the type and complexity of vessels for which the surveyor can now undertake initial survey. The surveyor is prevented from undertaking surveys on more complex vessels that require greater proficiency in passive and active fire protection measures; watertight and weathertight standards; and propulsion and engineering systems. 

Another surveyor had their accreditation varied following complaints raised by regional AMSA staff. Desktop audits of various survey activities identified that the surveyor often failed to submit survey recommendations to AMSA until several months after the completion of the surveys.   

Incident investigations undertaken on some of these vessels identified further non-conformances and AMSA formed the view the surveyor had contravened sections 32, 33 and 36 of the regulations.  

Following a show cause process, the surveyor had conditions imposed on their periodic survey accreditation. The conditions require the surveyor to provide AMSA with additional evidence of certain survey items, along with their survey reports, within 10 days of the survey date. 

Certificate of survey refusal reasons 

AMSA approves around 97% of Certificate of Survey (CoS) applications. This means around 3% of CoS applications are refused, which is an undesirable outcome that can occur for several reasons.  

Reasons for CoS refusals

Below is a breakdown of why initial CoS applications were refused in 2021-2022.

Pie chart showing the reasons for CoS refusal

  • Engineering/Machinery (C5A): 14%
  • Watertight weathertight integrity (USL): 8%
  • Fire safety (C4): 16%
  • Intact astability (C6A): 22%
  • Survey process (SAGM): 24%
  • Structure (C3): 11%
  • Damage stability (C6B): 5%

SAGM specifies survey requirements for vessels by prescribing a consistent process for accredited marine surveyors (AMS) to follow. The National Law requires an AMS to apply the process set out within SAGM to ensure nationally consistent survey outcomes and safe vessels.  

Failure to follow the SAGM process can result in the refusal of an application. In fact, this is the most frequent reason for refusal of an initial CoS application. Moreover, failure to implement SAGM removes a layer of assurance which can result in non-compliant vessels. 

Compliant survey vessels are the result of three overlapping parties working together to produce quality outcomes:  

  • designers,  
  • builders, and  
  • surveyors.  

Designers and builders have general safety duties to ensure a vessel is designed, constructed, and subjected to tests and trials as required, to guarantee it meets the relevant standards. Survey assurance is a critical control to validate the quality systems within the design and construction process and independently verify a vessel meets the standards expected by the Australian public.  

It is not a surveyor’s sole responsibility to ensure a vessel complies with the applicable standards. Rather, surveyors ensure a designer and builder’s quality systems are being implemented and document the applied process. Surveyors are critically important and responsible for third party assurance of the design and construction process, on behalf of AMSA.  

When AMSA identifies non-conformances, we prefer to work collaboratively with the surveyors. AMSA identifies opportunities for improvement in the survey process and assists an AMS to implement corrective actions. This ensures the same non-compliance does not reoccur on future vessels. AMSA does this primarily in two ways:  

  • by providing an opportunity for additional information to be provided before we decide an application
  • through our formal audit program.  

These interactions with AMSA are opportunities for surveyors to correct an immediate issue and improve their survey process to avoid repetition. The result of improved processes is a higher standard of surveying, a rise in the quality of the vessels built, and a reduction in AMSA intervention.  

Surveyors are subject to conditions of accreditation and a failure to conduct surveys in accordance with an applicable standard is a breach of these conditions. This may result in AMSA taking compliance action against a surveyor, such as formal warnings, infringements, variation, suspension, or revocation of accreditation.  

Understanding the surveys required notice letter 

A recent update in MARS now allows AMSA to modify the survey activities listed in the Surveys Required Notice Letter prior to it being sent to the applicant.  

This update was implemented following feedback that letters were generic and contained survey activities that weren’t required for an application, for example where a vessel has undergone modification. This change has been well received.  

However, AMSA has also received applications for new certificates of survey where the full extent of modifications weren’t included. In these instances, the Surveys Required Notice Letter generated without all of the required survey activities being listed. 

This has resulted in submissions that do not cover all the survey activities necessary to meet the requirements of Marine Order 503 and/or Marine Order 507 for the issue of certificate(s). This has delayed the issue of certificates until additional surveys were undertaken and the required submissions were assessed.  

The excerpt below from the Surveys Required Notice Letter addresses the issue of additional surveys: 

Will any other surveys be required for my application? 

The survey activity codes listed above have been generated based on AMSA's understanding of the facts and circumstances presented in your application. 

However, the surveys necessary for your vessel to meet the requirements of Marine Order 503 and/ or Marine Order 507 and be granted a certificate(s) may differ from the survey activity codes above. 

You should seek advice from your surveyor(s) to determine if additional surveys are required for your vessel, particularly if your vessel has been modified. Please have your surveyor contact if additional activity codes are required. 

Surveyors may also mark a code as "not required" if, in accordance with the above Marine Orders and the National Law— Marine Surveyors Accreditation Guidance Manual 2014 (the SAGM), a survey listed above is not required.  

Note: Failure to complete the surveys required by the above Marine Order(s) and the SAGM may result in delay or refusal of your application. 

Accredited marine surveyors are reminded to address such situations with the applicant, conduct the required surveys and make the appropriate submissions.   

How to apply for a periodic survey extension 

Marine Order 503 allows for periodic surveys to be conducted within the three months before or after the due date. A vessel can continue to be operated without seeking any extensions during this six-month period. 

  • Example – if a vessel is due for periodic survey on 1st October, the vessel can be surveyed between 1st July and 1st January. 

If the survey can’t be completed within the six-month window provided by Marine Order 503, an extension can be requested as follows: 

Exemption 6 – this exemption can only be used to apply for an extension for up to 90 days after the period provided by Marine Order 503. 

  • Example – A vessel’s six-month window runs from 1st July until 1st January – exemption 6 can only be used to apply for an extension until 1st April.  

Exemption 7 - this exemption can be used to apply for an extension for a periodic survey by using the ‘another temporary use’ option (Division 2). This would allow for an application to be made outside the timeframes provided for in both Marine Order 503 and Exemption 6.  

  • Example – A vessel’s six-month window runs from 1st July until 1st January and the period for an exemption 6 application has passed (1st April). If you need to apply for a further extension to complete the periodic survey, an exemption 7 application is required. 

Applying for an extension to conduct year 5 surveys for EX40 vessels 

Exemption 40 allows for year 5 in and out of water surveys to be conducted within the three months before or after the due date. The vessel can continue operating without seeking any extensions during this six-month period. 

  • Example – if a vessel’s due date is 1st October, the vessel can be surveyed between 1st July and 1st January. 

If the year 5 surveys for an EX40 vessel can’t be completed within the six-month window an extension can be requested under Exemption 7 Division 2 - using the ‘another temporary use’ option.  

  • Example – if a vessels six-month window runs from 1st July until 1st January and you need to apply for a further extension, an exemption 7 application is required. 

Navigation light supply 

AMSA understands there is a conflict between NSCV C5B and AS/NZS 3004.2 with regards to navigation light supply.  

NSCV C5B states:

5.3.2 Navigation lights 

Each light must be wired by a separate circuit to a:  

  1. discrete section of a distribution board; or  
  2. panel dedicated to navigation lights.  

The use of junction boxes in navigation light circuits must be limited to those needed to connect the navigation lights to fixed wiring. Navigation light circuits must not share wiring enclosures or junction boxes with other circuits.  

Each light must be:  

  1. individually controlled; and  
  2. protected in each active pole by a fuse or a circuit breaker, mounted on the navigation light distribution board or panel.  

AS/NZS 3004.2 states: 

2.14 Navigation lights supply  

All boats are required to comply with the Internal Regulations for Preventing Collisions at Sea 1972, as amended.  The construction and installation of navigation lights shall be to the satisfaction of the appropriate authority.  

When a boat 24m in length overall or less uses electric lights -  

  1. one operation, such as one switch or one position of a switch, shall display the complete navigation light configuration as required for the boat while underway;  
  2. another switch or switch position shall display the anchor light only; and 
  3. switch functions shall be appropriately labelled.  

EXCEPTION: Sailboats may use additional switches to satisfy underway conditions for both sail and power.  

If a boat is longer than 24m, the supply to each navigation light shall be provided in its insulated phase or pole with a switch and fuse or alternatively by a circuit-breaker fitted on the navigation light distribution board.  

AMSA will accept either method for compliance. However, if using AS/NS 3004.2 AMSA still requires each light to be protected in each active pole by a fuse or a circuit breaker, mounted on the navigation light distribution board or panel.  

Novel vessel policy 

AMSA’s Novel vessel policy statement is now available on the AMSA website. The policy statement identifies the types of vessels that AMSA considers to be ‘novel’ and clarifies what standards vessels must comply with for design approval. It also provides additional pathway information for novel vessels to gain certification. 

The policy is available on the National Standard for Commercial Vessels webpage under Section F3: Novel vessels. 

Anyone planning to design or build a ‘novel’ vessel can email for further advice on classification and certification. 

Relevant reading 

Planned Maintenance on DCVs - Safety Alert 

AMSA has issued a safety alert highlighting the importance of planned maintenance on DCVs.  

Recent incidents involving engine and machinery failure demonstrate how important maintenance is in preventing breakdowns and serious risks to safety.  

Arc flash safety  

WorkSafe QLD have published information on arc flash and how to manage the associated risks. There is also a short arc flash safety film available on their website. 

Report into the fire on board ‘MS Brim’ 

The Norwegian Safety Investigation Authority (NSIA) has produced a report on the fire on board the battery powered ferry MS Brim which occurred in March 2021. 

Last updated: 2 February 2023