Tell us what you think: Proposed changes to operational safety requirements

About Marine Order 504

We are seeking feedback on proposed changes to Marine Order 504. The proposed changes relate to crewing requirements and the introduction of minimum lifejacket wear requirements through the vessel’s risk assessment and safety management systems.

Marine Order 504 (Certificates of operation and operation safety requirements – national law) 2018 (MO504) contains crewing requirements for vessels, including minimum and appropriate crewing, and associated requirements linked to risk assessment of vessel operations, such as operation-specific training requirements.  

MO504 should be read alongside Marine Order 505 (Certificates of competency – national law) (MO505).  

MO504 refers to competency requirements—i.e. qualifications for different categories of crew—which are contained within MO505. Amendments to MO504 will ensure that crewing arrangements and crew competencies operate as intended and are aligned with those within MO505. 


Key dates

14 November 2022

  • consultation opens

22 January 2023

  • consultation closed

March 2023

  • Marine Order 504 made available to industry


  • new requirements come into effect
What changes are we seeking feedback on?

Amending the crewing provisions to ensure alignment with the certificate of competency arrangements in the new MO505 and simplifying the minimum crewing requirements table format.


Emphasising the need for fatigue to be adequately considered when determining risk-based crewing levels.


Streamlining the crewing requirements process for autonomous or remotely operated vessels ≤3m in length.


Ensuring that the risk assessment (including the appropriate crewing determination) is accessible to the master, crew and enforcement personnel.

The proposed changes to MO504 focus on:

Requiring owners to consult with the master and crew in the development of risk assessments.


Adding prescription around onboard training and drill requirements for emergency procedures and associated record-keeping requirements.


Strengthening the designated person provision to ensure clear and direct reporting pathways for the escalation of issues.


Clarifying the requirement for lifejacket wear to be addressed in the vessel’s risk assessment and written procedure in the safety management system.  Read more about our consultation on lifejacket policy, industry feedback and how we have used this feedback to shape the proposed new policy on the AMSA website.