Passenger safety on domestic commercial vessels

Marine order 504

We are running information sessions focussing on passenger safety and compliance with Marine Order 504. The sessions are open to all owners, operators and crew of domestic commercial vessels.

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While many operators have already implemented measures for passenger safety, these requirements are now compulsory under the Marine Order 504 (Certificates of operation and operation requirements – national law) Amendment 2020 (PDF 290 KB)

Do you have a question?

We encourage you to submit your question to us if you are unsure about how to implement the new measures.

Since 31 May 2020, passenger vessel operators must do the following:

  • Have a procedure in their safety management system (SMS) that provides an effective and verifiable means of passenger monitoring to ensure the master of the vessel is able to find out the number of passengers on board the vessel at any time.
  • Have an emergency procedure in their SMS for responding to a situation where a passenger is unaccounted for.
  • For certain types of operations, have a procedure for counting passengers at specified points to ensure an accurate number of passengers embarking and disembarking the vessel. This includes a count:
    • at or around the time passengers embark and disembark the vessel at the start and end of a voyage, or at an intermediate stop, and
    • before departing any point where passengers have disembarked for a water activity such as diving, snorkelling or swimming
  • Record passenger counts in the vessels logbook. 

There is a community expectation that the safety of passengers has been considered before they get on board your vessel. 


ven diagram

The flowchart below will assist in determining what your vessel is required to do in relation to passenger monitoring and counts.

504 ven diagram

Review your safety management system 

All commercial vessels, including passenger vessels, should already be operating under Marine Order 504. Your passenger vessel operation must:

  • Include a procedure for monitoring passengers so that the master of the vessel is able to find out the number of passengers on board at any time.
  • For certain types of operations, undertake a count of all passengers on board the vessel on embarkation and disembarkation.
  • Record all passenger counts in the vessel’s logbook.
  • Your SMS must include information on when passenger counts will be conducted, particularly when passengers join the vessel, the vessel stops for water activities such as snorkelling, diving and swimming, and at the end of a voyage

You may already do these things and have these measures in your SMS. If so, keep doing what you’re doing and review your Safety Management System periodically. If not, here’s some further advice on how to bring your SMS up to scratch.

1. Risk Assessment

Your risk assessment is a critical component of an effective SMS. This should be reviewed to identify risks to passengers on board, including the risks of persons overboard under various operating conditions.  Effective control measures should be identified to mitigate and manage these risks. This may mean alternative ways to monitor passenger movements such as increased monitoring or restricting access to areas that increase the risk of a person going overboard. 

Other important aspects to consider are:

  1. Passenger briefings and encouraging passengers to look out for fellow passengers.
  2. Wearing of lifejackets.
  3. The responsible service of alcohol.
  4. Crewing numbers for various operating scenarios—such as parties and other events.
  5. How passengers will embark and disembark at the start, finish, or during the voyage.

2. Emergency procedures

You must have a system in place to respond in the event of a missing passenger.  For example, you should identify how you will quickly muster and account for all persons on board and determine where and when the passenger went missing. This may include, for example, verifying that a passenger is in fact missing, by repeating a count, counting by a different method, making announcements, asking passengers to check on their companions.  It should also include what happens when it is more certain that someone is missing, for example, alerting rescue authorities, marking the last position, stopping the vessel or searching the water. 

Passengers should also know how to alert the crew if they believe someone has gone missing. 

Your SMS will also include emergency procedures for other situations:

  • a personal injury or other medical emergency
  • person overboard
  • adverse weather or water conditions
  • fire, collision, grounding, flooding, loss of steering or the master being incapacitated.

Assembly stations are also identified in the SMS, and information on emergency procedures is required to be displayed at assembly stations, in passenger cabins and other areas frequented by passengers.

Regular drills should be carried out to test the effectiveness of your emergency plans.

Knowing what you need to do in an emergency prevents confusion and makes a real difference in effectively dealing with a situation. Drills should be logged, and discussed with your crew to ensure ongoing learning, with any amendments recorded in your SMS.

3. Crewing assessment

Many vessels carry out a variety of passenger operations from regular sightseeing cruises, bespoke charters or tourism activities like fishing, snorkelling or whale watching. There is a community expectation that these events have been well planned, and the safety and wellbeing of passengers is considered. This includes having the appropriate number of qualified crew to ensure these events are both fun and safe. 

An appropriate crewing assessment is required as part of your SMS which considers each operational scenario. 

A multi-purpose operator will have different crewing requirements depending on the type of activity being carried out, for instance, sight-seeing versus conducting adventure events like diving or a private social function after dark where alcohol is served. 

Assess the risk of each scenario and indicate how many crew you require to keep passengers safe. Document this in your SMS.

In the event of an incident, your crewing assessment may be requested by AMSA and any other investigating regulator or law enforcement body.

4. Passenger count requirements

To implement the passenger count requirements, your SMS must include a procedure on the counts that will be done. Passenger counts must be recorded in the vessel’s logbook. This can be done manually or electronically. The logbook must be available on board the vessel.

In addition to passenger counts, you must also have a procedure that sets out how you will monitor passengers so that the master is able to find out at any time how many passengers are on the vessel.  There are many different ways (and combinations of ways) of achieving this, including:

  • electronic monitoring
  • CCTV 
  • electronic ticketing 
  • head counts

These processes must be documented in the Safety Management System, and crew trained and assessed as competent to complete these tasks.

Counting passengers ‘at or around the time of embarkation or disembarkation’ does not have to be done literally at the point a passenger crosses from vessel to wharf. For example, it could be done within the first or last few minutes of a voyage, or it could be done at a muster point on land just after passengers have disembarked.  The outcome must be an accurate record of the number of passengers embarking and disembarking the vessel. 

Think about what is practical and effective for your particular operation. For example, it’s not practical and effective to count passengers who have disembarked onto a busy multi-user wharf, and it would be more practical and effective to count them just before arrival.

5. General safety duties apply to passengers as well

Passengers are expected to comply with the vessel’s safe operating procedures and can be held accountable for any behaviour that jeopardises their or anyone else’s safety.  

Passengers have a responsibility to behave safely while on board. Effective signage is also an effective way to alert passengers of any risks on a vessel. You can get our passenger safety decal for your vessel from one of our regional shop fronts or order yours online.


Get information

Keep an eye on our website and or sign up to our AMSA update newsletter to get more information.

Last updated: 14 August 2023