Survey Matters - September 2025

In this edition:

• Correct use of the AMSA 586 form following a survey
• Draft standards on marina and boat electrical installations – open for comment
• ISO 12215 GES is now approved
• Time to check your branding
• Use of Starlink satellite system as a communications system on domestic commercial vessels.
• Portable fire extinguishers for DCVs
• When to Use Lightship Declarations: Guidance from AMSA
• Audit matters
• Survey Matters suggestions

Correct use of the AMSA 586 form following a survey

Following on from the recent AMS workshop, it is clear there is confusion about use of the AMSA 586 form (survey activity report).  

Used correctly, the 586 form provides a clear, auditable record of non-conformances and supports the safe, permitted operation of domestic commercial vessels. 

Purpose of the AMSA 586 form

The 586 form has two functions as the prescribed mechanism for surveyors to: 

• Record and communicate deficiencies and non-conformances identified during a survey (periodic or renewal), to both the vessel owner and the National Regulator. This is a condition of accreditation under the National Law regulations Section 33. 

33 Reports to the National Regulator about certain matters 

1.  If, in conducting a survey of a domestic commercial vessel, an accredited marine surveyor becomes aware of a matter mentioned in subsection (2), the surveyor must report the matter, in writing, to the National Regulator as soon as practicable after becoming aware of the matter.
2. The matters are the following:
   1. corrective action is required to the vessel, or a thing on the vessel, due to a defect or non‑conformity in the vessel or thing.
   2. a matter, or an aspect of a matter, being surveyed is complex or novel, and is not covered by a standard or code mentioned in section 32.

• Facilitate temporary operations under Divisions 5 and 6 of the Marine Safety (Temporary Operations) Exemption 2020 (EX07) where only minor deficiencies are present (EX07 Div 5 and 6).

Use of the AMSA 586 form 

1. Recording non-conformances

Surveyors must describe each non-conformance and identify the applicable standard. Each entry must specify the means by which compliance will be demonstrated: 

• Inspection (I) – rectification confirmed during follow-up inspection.
• Proof (P) – documentary or certification evidence provided.
• Declaration (D) – statement of compliance from the vessel owner/master. 

The vessel owner or agent must acknowledge receipt by signing the form, ensuring accountability for corrective action. The form must be supplied to AMSA to report non-conformances. This must be done as soon as practicable after identifying such non-conformance.

2. Temporary operations

While Exemption EX07 is issued by AMSA, its application in certain cases relies on the action of accredited surveyors. The surveyor must determine whether the vessel’s non-conformances fall within the criteria set by EX07 and complete and issue the approved 586 form to the owner. 

Surveyors carry the responsibility for bringing EX07 into effect where it relates to operation with minor non-conformances after survey. Failure to complete this step correctly exposes owners and masters to legal risk, including operating without approval.
 
The need for a temporary permit arises from the requirements of Marine Order 503 (Certificates of Survey — National Law) 2018, Section 11, which places conditions on certificates of survey. Items (1)(b) and (f) specifically pertain to defects and non-conformances: 

• MO503 Section 11(1)(b) requires that any non-conformance identified in a survey, including a periodic survey, must be rectified. The 586 form allows this to be communicated to AMSA. Once cleared, the form can be marked as cleared, or the non-conformances entered into MARS are closed out there.
• MO503 Section 11(1)(f) requires that a vessel continue to meet the standards that apply to it. In practice, this means that once a non-conformance exists, the vessel does not meet the standards, and if the vessel were to be operated, the owner and master would be in breach of the conditions of the certificate (sections 45 and 46 of the National Law Act). 

In the event of a minor non-conformance being identified during a survey, the secondary function of the 586 form is to fulfil the requirements of EX07 Division 5 and 6. In this case the surveyor must record the non-conformances,  confirm that it is minor and does not jeopardise the safety of the vessel or the people onboard. 

• Periodic survey (EX07 Division 5): exemption from certain Marine Order 503 requirements for up to 90 days, provided the vessel’s certificate of survey remains in force. Refer to Section 11(2)(b) & (c).
• Renewal survey (EX07 Division 6): exemption for up to 120 days after expiry of the certificate, provided the vessel continues to comply with its former certificate conditions. Refer to Division 6 Section (e)(i)(B) & (ii). 

It is a condition of EX07 that the signed 586 form is kept on board at all times during the exemption period. As discussed in the AMS workshop, this requires that Sections D and E of the form be completed. 

If the 586 form is not to be used as a temporary permit (for example, where deficiencies are not minor and the vessel must not operate), this must also be indicated in Sections D and E. 

Sometimes a renewal survey may find no deficiencies. Even then, the 586 form may still be needed if the vessel’s certificate of survey is close to expiry. In this instance:  

• Section D would be marked as Yes given a permit will be required, and the division indicated (Division 6 of EX07 for renewal).  
• Section E the bottom box would be checked.
• Section B would remain blank; this would still be a valid completion of the form indicating that there are no deficiencies.

3. Surveyor’s declaration 

By completing Section E of the 586 form, the surveyor declares that: 

• The survey has been conducted in accordance with the National Law and Marine Orders.
• Any identified non-conformances do not jeopardise the safety of the vessel or persons on board; or
• Identified non-conformances would breach the conditions of Marine Order 503 and the vessel is not to be operated. In this instance, the matter should be directly conveyed to AMSA as soon as practicable, consistent with SAGM Section 2.8(2) & the National Law Regulations Section 33.
• The National Regulator may request supporting information or documentation. 

The critical point is that Sections D and E cannot be left blank. The surveyor is required to indicate if the document is used to support a permit, or if the vessel is not permitted to operate.

Record-keeping requirements 

In line with Surveyors Accreditation Guidance Manual (Part 2 – Survey of Vessels), surveyors must retain survey documentation for seven years. This includes photographs, approvals, technical evaluations, and calculations that support the findings recorded on the 586 form. 

Key compliance points 

• Always use AMSA 586 form to document non-conformances following a survey.
• Ensure owners acknowledge receipt of the 586 form and understand rectification obligations for any deficiencies.
• Complete the EX07 temporary operations section where applicable, and strike through unused options for clarity.
• Inform the owner of the requirement for the form to be kept onboard.
• Retain complete records for audit purposes.
• Report directly to the National Regulator either by phone or direct email to dcvsurvey@amsa.gov.au if a vessel is unsafe and should not be operated, in addition to completing the form. 

Correct use of 586 form is essential for surveyors to meet their obligations under section 33 of the National Law Regulations and to activate temporary operating approval under EX07. When used properly, it ensures that both AMSA and vessel owners are aware of defects, sets a clear rectification period, and provides permission for continued operation while those defects are corrected. 

Incorrect use of 586 form may place surveyors in breach of their accreditation conditions. It may also result in owners and masters operating without valid approval (sections 43 to 46 of the National Law Act), exposing them to compliance or enforcement action, and potentially affecting other matters such as insurance cover. 

Draft standards on marina and boat electrical installations – open for comment

Two draft standards on electrical installations in marinas and boats are now open for public comment through Standards Australia.  

Log in or create an account with Standards Australia to view the drafts and submit feedback:

• DR AS/NZS 3004.1:2025 Electrical installations – Marinas and boats, Part 1: Marinas 
• DR AS/NZS 3004.2:2025 Electrical installations – Marinas and boats, Part 2: Boat installations  

Developed by Committee EL-057 Boating and Boating Marinas Installations, these drafts are open for comment from 15 September to 17 November 2025.  
 
Have your say today to help shape the future of electrical safety in marinas and on boats.  

ISO 12215 GES is now approved

The Generic Equivalent Solution (GES) permitting the use of ISO 12215 for scantling determination of vessels 24m or less in measured length has been published. It is now listed on AMSA GES webpage as GES 2025/01.  PDF179.33 KB

Vessels 24m and less in measured length expecting to operate in NSCV operational area category C, D or E can now use this GES subject to the exclusions and conditions listed on the GES.
 
Note that this GES applies only to the use of ISO 12215 for determining scantlings. All other aspects of the vessel—including items such as fuel tanks—must comply with the applicable National Standard for Commercial Vessels (NSCV) requirements. 

Time to check your branding

Correct use of symbols, such as the AMSA logo and Commonwealth Coat of Arms, protects the integrity of the accreditation scheme and reduces confusion for vessel owners and operations.

Please take a few minutes to review your branding to ensure you are using AMSA and Commonwealth materials correctly.  

While material presented in the Marine Surveyors Accreditation Guidance Manual (SAGM) is shared under a Creative Commons Attribution 4.0 International licence, the AMSA logo and the Commonwealth Coat of Arms are excluded.
 
This means the AMSA logo and Commonwealth Coat of Arms cannot be used on your website, email signatures, templates, reports, or any promotional materials. Misuse can create confusion by suggesting a surveyor is officially representing AMSA when they are not and may be a criminal offence. 

What you can do 

While you cannot use the AMSA logo or Commonwealth Coat of Arms, you can reference your accreditation in a professional way, including: 

• stating you are an Accredited Marine Surveyor
• listing your accreditation number
• outlining your categories of accreditation (e.g. plan approval, periodic survey, commissioning surveys)
• detail any conditions or limits, such as the types of materials or maximum hull lengths you are accredited to survey.  

This approach provides clarity to vessel owners and demonstrates your professional credentials without misusing AMSA branding.  

Key points to keep in mind

• Do not use the AMSA logo or Commonwealth Coat of Arms in personal or business materials. 
• Creative commons applies to most AMSA materials. Most AMSA guidance, forms and checklists can be copied, shared, or adapted, provided the source (AMSA) is clearly attributed. 
• Attribution is simple. Include the following: Source: Australian Maritime Safety Authority or © Australian Maritime Safety Authority  
• Clarity matters. Avoid presenting materials in a way that could be mistaken for AMSA official or endorsed documents. 

Use of Starlink satellite system as a communications system on domestic commercial vessels

VSU has received a number of enquiries regarding the use of the Starlink Satellite Systems as a communications system onboard DCV’s in lieu of MF / HF radio installations. 

VSU advises that if the vessel is not fitted with HF installations and is using a satellite telephone as a means of communication to comply with NSCV C7B, the satellite telephone must meet the requirements of NSCV C7B Annex D and the information in the key and notes in Table 2 must be taken into account.  

Any non-GMDSS satellite systems used onboard as a means of communication to comply with NSCV C7B must meet the requirements of NSCV C7B Annex C. 

At the time of writing the Starlink satellite system has not been confirmed as meeting the required outcomes of NSCV C7B and the requirements of Annex C / Annex D as appropriate and therefore cannot be used as a primary communications system.

AMSA will advise the Australian maritime safety community if this position changes, including details of the change and any actions that vessel owners, operators or surveyors may need to take as a result.

Portable fire extinguishers for DCVs

Under the National Standard for Commercial Vessels (NSCV), portable fire extinguishers are classified as an active fire protection measure. The specific requirements for their carriage are determined by the level of fire risk associated with the vessel and its operations. 

Minimum requirements for portable fire extinguishers are outlined in the applicable NSCV standard or exemption document.

Standards 

Only portable fire extinguishers that comply with relevant Australian Standards are permitted for use on domestic commercial vessels. The following standards are referenced in NSCV. 

Type, rating, size and quantity

In NSCV there are four parameters that are used to specify a portable fire extinguisher. 

The specifications label shown here is for a dry powder fire extinguisher. The fire test rating 3A:40B:E indicates the extinguisher is suitable for Class A (solids like wood), Class B (flammable liquids), and Class E (electrically energised equipment) fires. A 3A rating means the extinguisher can handle a moderate solid fuel fire, while 40B signifies effectiveness against a large flammable liquid fire and E class confirms it is safe for use on electrical fires.

Fire extinguisher ratings are important because extinguishers of the same type and size can vary in performance. For example, extinguishers designed for vehicles or caravans might not meet the minimum required rating for use on a vessel.

Size also plays a crucial role. Replacing one large extinguisher with multiple smaller ones may seem equivalent, but it can reduce effectiveness. The pause between using extinguishers can allow the fire to reignite. 

PFAS free

As of July 2025, the use of firefighting foams containing PFAS—commonly referred to as “forever chemicals”—is banned nationwide, including in existing installations. PFAS is mostly found in firefighting agents used in fixed fire suppression systems, such as AFFF, however, it is important to check your portable fire extinguishers as well. Extinguishers with fluorine free foams are PFAS free. 

Lithium-ion battery fires 

A new generation of portable fire extinguishers is now available, specifically designed for lithium-ion battery fires. These are specialised water-based extinguishers that comply with AS/NZS 1841.2 and have been tested for this application. If lithium-ion batteries are installed onboard, it is recommended to consult a qualified fire service provider to ensure appropriate protection is in place. 

When to Use Lightship Declarations: Guidance from AMSA

When it comes to a vessel’s stability, accuracy in weight data underpins safety. There are two methods that AMSA accept to verify the vessels weight characteristics. These two methods include: 

• Lightship declarations
• Lightship measurement reports 

While lightship measurement reports are the most accurate method for determining lightship particulars, they are not always necessary—or even practical. In some cases, a Lightship Declaration provides an efficient and acceptable alternative.

This article explains what lightship declarations are, when AMSA will accept them, and when a full inclining experiment is still required.

What is a lightship declaration?

A lightship declaration is a formal statement made by a person who operates the vessel (such as the owner or master) confirming that no changes have been made to the vessel or that any changes made, do not alter a vessel’s lightship displacement and longitudinal centre of gravity (LCG) outside the allowable limits of 4% and 2% respectively. The declaration combined with an examination of the vessel by a surveyor forms part of the lightship verification process required by SAGM. 

This process provides a cost-effective way to determine lightship changes without the expense and operational downtime of a full lightship measurement test. 

When AMSA accepts a lightship declaration 

Under the Surveyor Accreditation Guidance Manual (SAGM) Part 2, Clause 4.9, AMSA only allows the use of a Lightship Declaration for the following vessels: 

• Class 1 vessels less than 12 metres in length (measured)
• Class 2 vessels
• Class 3 vessels
• Class 4 vessels 

The lightship declaration can only be used for eligible vessel types at renewal surveys. AMSA does not accept lightship declarations at initial surveys or transitional surveys. 

When a vessel becomes transitional, AMSA requires it to undergo an initial survey to the transitional standards listed in Marine Order 503. These standards have been set to bring transitional vessels up to a baseline standard. AMSA requires all vessels to conduct a full lightship measurement during initial survey to ensure the weight and stability data available for the vessel is accurate. This is required for all transitional vessels, regardless of the transitional trigger or changes being made. 

At renewal or within a period not exceeding 5 years, a lightship declaration (where permitted) may be used when: 

• The vessel has not made any changes that would cause the vessel to become transitional (refer to Marine Order 503, schedule 1 for a list of transitional vessel changes)
• The vessel has not undergone major modifications or changes that would significantly alter weight distribution.
• There is no evidence of weight creep or changes that could affect stability.
• Existing stability data remains valid and reliable. 

It is important to note that a person (vessel owner or master) might commit an offence under section 137.1 of the Criminal Code Act 1995 if the person gives information to AMSA knowing that the information is false or misleading or omits any detail without which the information is misleading. 

Falsely signing a lightship declaration could also have serious consequences to the vessel’s safety. Undeclared changes to the vessel could result in loading conditions that have not been considered in stability calculations. This could lead to the loss of the vessel or loss of life. 

Best practice for using lightship declarations

For a lightship declaration to be accepted by AMSA, it should: 

• Be backed by thorough inspection—checking against design drawings or general arrangement shown in the stability book (where available), weight records, and the vessel’s condition by an accredited marine surveyor.
• Be signed by the Owner or Master of the vessel who can determine if any changes have been made to the vessel since the last renewal survey.
• Include supporting evidence to demonstrate accuracy and compliance with National Law requirements. 

These requirements are outlined in SAGM Pt 2, Clause 4.9. 

Lightship declarations and surveyor inspections provide an efficient method of verifying that a vessel has not been significantly modified since its last stability approval or since was last issued a certificate of survey. AMSA permits their use only for Class 1 vessels under 12 m, and Class 2, 3 and 4 vessels. 

They are not suitable for initial or transitional surveys, or where a vessel has undergone significant modifications. In these cases, a full inclining experiment or practical stability test remains essential to ensure the vessel meets the applicable stability standards.  

Audit matters

Field audits 

As part of improving survey practices and ongoing continuous improvement of survey practices, AMSA will run a pilot field audit program during the 2025-26 financial year.  

The pilot program will involve AMSA visiting accredited surveyors either: 

• In-office – focusing on the survey process and record keeping that supports recommendations.
• In field audits – AMSA will shadow the surveyor during the survey. These will focus on the surveyor’s process only, not vessel defects.  

AMSA will contact a small number of surveyors to take part and seek their willingness to participate prior to conducting these audits.  

The audit pilot program is not intended to impose any additional regulatory burden on the surveyors. It is intended to assist AMSA in the development of audit processes and procedures for the field audits program. 

Audits will be conducted in a constructive way, with the aim of supporting surveyors, not as a fault-finding exercise.

Surveyors who would like to take part voluntarily can contact dcvsurvey@amsa.gov.au.

Audit compliance matters – 10 yearly fuel tank inspection  

Recently an accredited surveyor conducted 10 yearly renewal surveys on an aluminium hulled vessel. A few weeks later, the vessels fuel tank exploded resulting in serious injuries to 3 crew members.

An AMSA inspection that followed identified several long-standing deficiencies in the fuel tanks. These defects indicated that the surveyor’s out of water survey had not been carried out with enough scope or depth.

AMSA subsequently conducted an audit on the accredited surveyor. This audit found: 

• a major non-conformance - inadequate depth and scope of 10 yearly fuel tank surveys.
• a minor non-conformance - related to electrical installations.  

After evaluating the surveyor’s responses, the National Regulator concluded that the surveyor had breached the conditions of accreditation.

A breach report was raised, and the surveyor was issued an advisory notice. 

The suspected breach related to Section 32 (c) and (d) of Division 3.3 of Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013. These provisions require Surveyors to carry out surveys in accordance with the requirements of Surveyor Accreditation Guidance Manual (SAGM), which replaces the National Standard of the Administration of Marine Safety (NSAMS) which is no longer in force.

Section 5(2) of Marine Order 503 confirms that SAGM is the Survey Standard for renewal Surveys. A breach under Section 32 may give rise to potential offence provisions under Section 161 of the National Law. 

SAGM requirements of fuel tank inspections during 10-yearly renewal surveys are cited below. 

When a surveyor recommends a 10-year out-of-water survey, AMSA expects this to mean that the internal inspection of the fuel tanks has been carried out and found to be satisfactory. If a surveyor has any difficulty in meeting this requirement, they should contact dcvsurvey@amsa.gov.au.

Survey Matters suggestions

AMSA wants to ensure Survey Matters is relevant and useful for accredited marine surveyors, boat builders, class societies, and others involved in the survey of domestic commercial vessels.  

We encourage our readers to submit subject requests or ideas to DCVSurvey@amsa.gov.au for articles that would be of assistance to industry in future publications