Published on Australian Maritime Safety Authority (

Survey Matters—February 2020

16 February 2020

We welcome your feedback and input into this newsletter. In particular, let us know if you would like to know more about a particular topic or if you encounter issues out in the field that need clarification.

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Since the last edition

We have updated the way we manage enquiries received through the and inboxes.

This change is designed to provide us with greater traceability of the type of enquiries we receive and also provide you with a more detailed automatic reply email.

The automatic reply will now include a title, ID number and where applicable, also reference the vessel name and UVI.

This change does not affect where you direct your emails. Technical enquiries are still sent to while application related enquiries (including emailed survey reports) are still sent to

In this edition

The role of an AMSA accredited surveyor

It has come to the attention of AMSA that an Accredited Marine Surveyor may have made representation to a foreign vessel operator that the surveyor was accredited by AMSA to assist in preparing vessels for port State control (PSC) inspections. AMSA only accredits marine surveyors to carry out surveys of Australian Domestic Commercial Vessels (DCVs) under the National Law.

While AMSA accepts that some Accredited Marine Surveyors have the appropriate training, qualifications and experience to assist the operator of a vessel with preparing for a PSC or flag State control (FSC) inspection, it is misleading for a surveyor to make representations that they are accredited by AMSA to do so. Similarly, it is misleading for a surveyor to allow a vessel operator to assume that the surveyor’s AMSA accreditation was with respect to the survey or inspection of RAVs or foreign vessels. This type of misleading practice is inappropriate and future instances will be referred to the Australian Competition and Consumer Commission (ACCC) and surveyor professional associations for investigation. In addition, towards the end of last year we received two incident reports of verbal abuse being directed at AMSA staff by an accredited surveyor.

This type of behaviour is unacceptable and AMSA takes these reports seriously. Welcome to the latest edition of Survey Matters e-Newsletter. Survey Matters brings you the latest news and information for accredited surveyors in Australia.

Get on My Boat

If you need a simple guide to standards for new vessels, visit the My Boat app and find out how to prepare for survey.

My Boat includes standards tools such as the safety equipment list generator, navigation lights generator, propeller shaft calculator, F2 leisure craft, EX40 and EX02 non survey vessel requirements.

The details on (NSCV) level flotation

In 2016, AMSA ran an article entitled “Get the basics on flotation” in our Working Boats publication.

The article also included this helpful illustration which helps depict the difference level flotation can make if you get into trouble.

level flotation

Level flotation means that the boat will continue to float in a level position if swamped and will be prevented from capsizing in calm water.

This will allow you to remain in the boat and bail the vessel to remove the water.

basic flotation

Basic flotation means that the boat will float in some form if swamped. If the boat has capsized it will remain afloat for you to possibly cling to the upturned hull.

From a survey perspective, there is more we need to know about level flotation, because when it comes to meeting the criteria, it’s the details that matter. In particular, this article will explore maximum heel angle criteria– the details of which are specified in tables 33 to 35 of NSCV C6B:

In this criteria there is a requirement that the vessel not heel more than 10 degrees from the upright.

Geometrically, for this criteria to be safely met, it follows that flotation in the sides of the vessel should come into contact with the flooded waterline, before the 10 degrees heel criteria is failed.

As a starting point, the placement of foam required to ensure that it does come into contact with the flooded waterline can be calculated geometrically as a function of vessel breadth as follows:


This means that for a typical 2.4m wide runabout, foam should be placed less than 219mm above the design waterline (if we assume no righting moment is provided by deck buoyancy, for example on an open boat).

If foam is placed higher than this, there is a risk that criteria will not be met, as the vessel may heel beyond the 10 degree criteria, before the buoyancy comes into contact with water.


Note: In the case of a decked vessel, righting moment is provided by the enclosed under deck area and so foam can be placed higher. However, consideration should still be given to this geometric positioning and side foam should commence as low as possible.

The decked vessel case

In a decked vessel, any water mass that has a head above the waterline can be considered as added mass with a free surface. 

It is possible to draw some inferences about the effect this mass of water may have, by estimating the volume of this water. Consider the vessel shown in the image below in figure 1.

monohull section

Figure 1 - monohull section

If the water contained in the above the deck area is 420mm deep then the flooded area is approximately equal to the total buoyant area below the deck and it could be considered a significant volume of water.


Figure 2 - water in well equal to buoyant area below deck

As the water mass is located above the centre of buoyancy in this loading condition, there may not be sufficient righting moment to counter any upset to transverse centre of gravity (TCG), including waves, wind or even the buoyancy force of the below deck area. As a result, even small upsets to TCG, causing the water mass to shift to one side of the vessel, may result in dangerous list or capsize. You will also note that at this point, any foam flotation materials fitted high up under the gunwales will do nothing to increase the height of the centre of buoyancy and stability of the vessel, as the foam will not yet come into contact with the waterline, see Figure 3.

side foam high

Figure 3 - side foam positioned too high to have effect at equilibrium

For this foam to come into effect, the vessel needs to list significantly to one side. Failing the NSCV C6B criteria specified in tables 33 to 35. A foam installation giving consideration to these factors will start lower in the vessel and continue up the sides of the vessel (continuing up to account for the additional effect of deadweight loading).

figure 4

Figure 4 - side foam positioned lower in the vessel

In summary, relying on Annex D of NSCV C6B for the placement of foam buoyancy, without taking into consideration the arrangement of the vessel, does not guarantee that a vessel will meet the technical criteria of NSCV C6B 8.7.4. Consideration should be given to the arrangement of the vessel including decks. Geometric properties of the vessel should also be considered when assessing or specifying flotation positioning.

Use of previous state accepted arrangements or approaches

We are 18 months into AMSA providing service delivery and as all involved parties are becoming better versed in the use of MARS, the Surveyor Accreditation Guidance Manual (SAGM), and AMSA procedures and processes, it is a timely reminder to review the previous approach or arrangements that were in effect under state marine safety agencies.

Under the state model, individual agencies were able to approve Local Equivalent Solutions (LES), which other jurisdictions may not have agreed to or implemented.

Additionally, the local authorities had the ability to make policies regarding interpretations or arrangements for the application of the standards.

As a general rule these existing LES, policies, arrangements etc. are not applicable to new vessels or to vessels which have triggered transitional status, as they are not valid under the current Marine Order 503, nor were they previously nationally accepted. Here are three examples that AMSA has come across during assessments for a certificate of survey:

  1. Ferries in chains, or similar, being surveyed without lifesaving appliances required under NSCV C7A
  2. ‘B’ area vessels with no berthed accommodation
  3. ‘Well decked’ vessels fitted with level flotation utilising ‘Collared vessel’ criteria for intact stability (pictured below).

well decked

Although the application of these arrangements have been historically accepted, in some cases for many years (such as the interpretation that foam filled bulwarks on a well deck vessel meet the definition of ‘buoyant collars’ in C6A) they no longer have application under the National Law. If you are seeking a solution that differs from the standard, apply for an equivalent solution or specific exemption.

Recommending with conditions

Conditions recommended by accredited marine surveyors appear on the face of a certificate if they are considered suitable by the approving delegate at AMSA. Conditions are generally added to a certificate of survey after initial survey in order to ensure the vessel complies with the standards. It is rare that conditions are added to a Certificate of Survey as a result of a periodic or renewal survey unless the periodic surveyor considers something has been missed during the initial survey process.

Historically some state or territory agencies would write conditions on a certificate of survey that covered outstanding areas of initial or periodic survey that still needed to be addressed e.g. Compass must be swung within 3 months of the issue date of this certificate. This practice was acceptable when certificate durations were only for one year and/or the survey and compliance duties were covered by the same agency.

Under service delivered by AMSA, which incorporates accredited surveyors and compliance partners on a national scale, this approach is not correct and may conflict with National Law provisions including Marine Order 503. Under Marine Order 503 Section 11 (1) (b) it is a condition of a certificate of survey that any defect identified in any survey, including a periodic survey, must be rectified. In addition, under MO503 Section 9 (2) (a), one of the criterion for the issue of a certificate of survey is that the national regulator is satisfied that the vessel meets the standards mentioned in Marine Order 503.

To indicate that a defect be rectified as a condition listed on a certificate would be counter-intuitive to these requirements.

Examples of improper recommendations with conditions:

Examples of proper recommendations with conditions:

Documenting non-conformances

In response to the article published in the last edition Reporting deficiencies ‘as soon as practicable’, we were asked to expand further on the term ‘nonconformance,’ to assist a surveyor in utilising the AMSA586 form correctly.

The AMSA586 may be used by an accredited surveyor or recognised organisation to record non-conformances and corrective actions on a DCV, the form also enables the surveyor to communicate these matters to both the National Regulator and the vessel owner.

To try and define ‘non-conformance’ for the purpose of a survey is difficult. However, it’s basically a lack of conformity to the specified law or standard that the vessel is required to satisfy.

A surveyor’s role is to detail and document non-conformances using the AMSA586 so it’s unambiguous, defensible, clear and concise to all involved parties. A brief description of each non-conformance and the standard to which the non-conformance relates must be articulated on the form.

Below is an example of real life non-conformances and the related standards that have been submitted to MARS as part of a periodic survey process. As you will see, it’s clear and concise and allows all parties to understand what needs to occur.


AMSA’s approach to modular barges

We have received a number of enquiries about how AMSA deals with the survey and load line requirements for modular barges. Our approach to these vessels is outlined below:  A single certificate of survey will be issued listing all modules on the certificate.

Measured length is taken as the measured length of the longest proposed configuration.