Overview
Operators of small uncrewed autonomous vessels under 12m must apply for AMSA for specific exemption from a certificate of survey.
This guidance outlines AMSA's compliance approach to considering these applications. Our approach is based on the Exemption 02 and Exemption 40 frameworks currently applied to conventional vessels operating out to C water limits. This will help designers, builders and owners prepare an exemption application and provide supporting documentation.
Your exemption application should consider the matters outlined in this guidance. It is a guide and does not limit or replace a decision maker's discretion to grant, refuse or impose conditions on an exempion under s 143 of the National Law.
Scope
This guidance applied to autonomous vessels which are:
- less than 12 metres long
- non-passenger vessels (Class 2 vessel) or fishing vessels (Class 3 vessel) under the National Standards for Commercial Vessels (NSCV) Part B, and
- only operational in the following areas:
- operational area C
- operational area D, or
- operational area E.
This guidance does not apply to autonomous vessels that:
- carry any persons whilst underway
- carry dangerous goods
- engage in vessel towage operations and are not set up for this purpose
- have an inboard engine which operates on fuel that has a flashpoint of less than 60°C, or
- operate at greater than 10 knots.
It is also generally expected vessels following this guidance will be supported by a rescue vessel, capable of assisting, reporting on or recovering the vessel within 6 hours.
Note vessels ≥ 12 metres in length, operating within ‘B’ waters or that do not fall within the parameters listed above are generally considered to be survey type vessels. Survey vessels are expected to be certified under the survey framework and to do so will either need to comply with the deemed to satisfy solutions or be assessed against the required outcomes of the NSCV in support of an equivalent solution. After which a certificate of survey may be sought. In extraordinary situations AMSA may consider exemptions from some survey requirements.
Definitions
Accredited Marine Surveyor - means a surveyor who is accredited in accordance with Part 3 of the Marine Safety (Domestic Commercial Vessel) National Law Regulation 2013.
Exemption - means an exemption from a requirement of the National Law granted under section 143 of the National Law.
Certificate of Survey - means a certificate issued under section 38 of the National Law.
Competent person - means a person who has acquired through training, qualification/s or experience the knowledge and skills to carry out specific inspection tasks.
Conventional solution - a deemed to satisfy solution that meets required outcomes of the standards – see NSCV Part B. A conventional solution may vary depending on vessel use, operational area, speed and other performance factors considered by the standards.
Conventional vessel - a vessel that meets the requirements of the law (the NSCV required outcomes), by generally complying with the deemed to satisfy solutions. A conventional vessel’s design and arrangement of systems will vary depending on use, operational area, speed and other performance factors considered by the standards.
Equivalent means of compliance – means a proposed solution that is ‘at least as effective’ as compliance with the survey requirements or standards that apply to the vessel. Equivalent means of compliance are approved under Marine Order 503.
Recognised Organisation – means an organisation specified in schedule 1 of Marine Order 1 (Administration) 2013.
Uncrewed Autonomous Vessel - a vessel that conducts autonomous operations without any persons on board in operation.
Crewed Autonomous Vessel - a vessel that conducts autonomous operations with persons on board in operation, either in full or partial autonomy.
Guidance for uncrewed autonomous Vessels under 12m long in C, D and E waters
This table sets out recommended areas of consideration for a specific exemption application. The extent and complexity of the application submitted may vary depending on the size, type, service category, operation and complexity of the uncrewed autonomous vessel. Similar solutions providing an acceptable safety outcome may also be considered.
| Area of consideration | Guidance |
|---|---|
| Design and construction | The design and construction of an autonomous vessel is to be fit for purpose, for the intended operation. |
| Vessel flotation | An autonomous vessel is to be arranged with a combination of watertight compartments or low-density flotation materials so that it is incapable of sinking, if the single largest compartment becomes damaged. |
| Stability | An autonomous vessel, in all loading conditions, is to have stability characteristics fit for the purpose for which the vessel is intended by the owner. |
| Machinery - fuel tanks, pipes, etc | If there is an underdeck fuel tank on-board the autonomous vessel, it is expected to comply with clause 4.7 of NSCV Subsection C5A. Fuel piping for any non-portable fuel tank is generally expected to be of seamless, heavy gauge metal. However, a flexible fuel line may be used in accordance with clause 4.7.1.5 of NSCV Subsection C5A; and between the fuel shut-off valve or cock and the main engine. If a flexible fuel line is used, it is expected to comply with:
However, a flexible fuel line from the fuel filter to the outboard engine supplied by the engine manufacturer is not expected to comply with the standards mentioned above. A remote fuel shutoff of a failsafe close type is expected, as close to the tank as practicable. A fuel filter is expected, positioned after the shutoff valve mentioned above. If shafting is fitted, then it is expected to comply with either of the following standards; or with another standard approved by the National Regulator:
|
| Electrical | Other than the requirement to have an emergency power supply located above the weather deck, an autonomous vessel is expected comply with NSCV Subsection C5B. |
| Vision, communication and navigational systems | The owner is to appoint a competent person, to be responsible for the control and operation of an autonomous vessel when it operates. An autonomous vessel is to be arranged to ensure that the competent person responsible for control and operation of the vessel has sufficient information to identify navigational hazards, assess the risks and take appropriate measures to control the risks in both normal and abnormal conditions of operation. An autonomous vessel is to be arranged to enable the competent person responsible for control and operation of the vessel to comply at all times with the person’s obligations under the International Regulations for Preventing Collisions at Sea (COLREGS). An autonomous vessel is to be arranged to eliminate or reduce to acceptable levels the risk of operator error, fatigue or system errors arising due to the design and arrangement of the vessel’s operational systems. An autonomous vessel is to have means to inform other vessels of its location, nature, size, course and status, to help avoid collision or contact. |
| Watertight and weather tight integrity | An autonomous vessel is to be designed and constructed to prevent, or limit to an acceptable level, the likelihood of progressive flooding, disabling of essential or emergency systems and excessive heel and/or trim, in all reasonably foreseeable weather conditions. An autonomous vessel is to be provided with a means to monitor bilge levels in any propulsion machinery space, and in all other compartments that contain seawater pumping systems. |
| Steering systems | The autonomous vessel’s steering equipment is to be fit for the purpose for which the vessel is intended by the owner, the person who conducts the inspection and drafts the report must be satisfied that sufficient inspection, testing, trialling or evidence has been supplied. |
| Failure Mode and Effect Analysis (FMEA) | An autonomous vessel is to be subject to a failure mode and effect analysis of the following systems; and any other system affected by automation:
Note 1: Examples and procedure for failure mode and effect analysis are specified in Annex C of NSCV F1C and High-Speed Craft Code Annex 4. Note 2: Engineered solutions for controlling risk are preferred over operational solutions. |
| Provision of essential safety information | An autonomous vessel is to have a vessel operating manual which contains at least the following information (as applicable):
|
| Maintenance and servicing manual | An autonomous vessel is to be supplied with a maintenance and servicing manual containing at least the following information:
|
| Fire equipment | An autonomous vessel with a main engine that has an engine power of >120 kw, located in an enclosed space, is to have a means of smothering fire in the space. |
| Other equipment | To be specified by the applicant within their application as necessary. |
General notes
AMSA may impose condition on an exemption and may request additional information about the design documents, systems assumptions, and inspections carried out on an uncrewed autonomous vessel.
For vessels operating in C waters, the person carrying out the review and inspection of an autonomous vessel should be an Accredited Marine Surveyor or Recognised Organisation.
In D or E waters, AMSA may accept submission from a competent person.
How to submit your application
To apply for specific exemption please complete the online AMSA form 547.
Your application will be assessed against the national law criteria, the AMSA policy for exemptions, and the requirements outlined in this guidance document.
AMSA may enforce conditions on the exemption, including requirements for periodic inspection.
In general, AMSA may require an initial inspection, and an in- and out-of water periodic inspection, conducted within the three months before or the three months after each five-year anniversary of the vessel’s approval.
- For a vessel operating in C waters, the inspection should be done by an Accredited Marine Surveyor or recognised organisation.
- For a vessel operating only in D or E waters, AMSA may allow the inspection to be done by a competent person, or authorised person.
- The inspection will generally include:
- a physical inspection of the vessel
- verification of the ‘failure mode’ and ‘effect analysis’, operating manual, and maintenance and servicing manual, and
- testing of the vessel or its equipment, unless the competent person considers it appropriate to rely instead upon third party documentation.
Note: Examples of third-party documentation includes CE certification for structural components and expert reports from automation system designers and manufacturers.
More information
Read more information about the operational requirements that apply to under the National Law Act.