Advisory note—Vessels registered in Queensland before 1 July 2013—replacement of safety equipment to meet NSCV C7A requirements
Topic: Vessels registered in Queensland before 1 July 2013 - replacement of safety equipment to meet NSCV C7A requirements.
Issue: At the start of the National System, vessels registered in Queensland were mid-way through a transition to full compliance with the safety equipment requirements of the National Standard for Commercial Vessels C7A. That transition was due to be completed by 30 June 2014.
Marine Order 503 (Certificates of Survey) outlines at s8(b)(ii) that a vessel in existence on 30 June 2013 remains subject to the equipment standards that applied to that vessel on that date.
For the purposes of interpreting MO503, s8(b)(ii), the National Regulator considers the equipment standard in place in Queensland on 30 June, 2013 was full compliance with the equipment requirements of NSCV C7A by 30 June, 2014. As a result, there is a potential for inconsistency in the regulatory treatment of vessels now operating under the National Law. AMSA has considered the matter and provides the following advice:
Advice: Queensland vessels that were otherwise required to have transitioned to full compliance with NSCV Part C7A by June 30, 2014, are required to do so:
- as a vessel’s equipment reaches its scheduled replacement date; or
- when that equipment, through damage or other circumstance, is no longer capable of performing its intended safety function, whichever the earlier of the two. This recognises the serviceable lifespan of safety equipment, and the compliance cost to ship owners and operators.