AMSA have released their National Compliance Plan (NCP) for 2024-25, which details the focus areas for their compliance activities over the next 12 months.
Compliance focus areas for 2024-25 seek to improve compliance and maritime safety by analysing safety data to identify areas of concern. While these areas are AMSA’S primary focus, they may direct attention to other areas in response to new data and emerging trends.
There are four ‘Focus Areas’:
For our newsletter, we will be looking more closely at Focus 3 – Domestic commercial vessels.
Priorities relevant but not limited to domestic commercial vessels include:
• risk-based inspection targeting
• safe work practices
• lifejacket wear requirements
• carriage of dangerous goods
• safe vessel operations in the Torres Strait and Top End
• poorly implemented safety management systems
• pilot transfer operations
• MARPOL garbage requirements
AMSA will conduct at least 2,300 inspections of domestic commercial vessels based on vessel priority.
Marine Order 504 Phase 2 regulatory changes are linked to existing risk areas across the domestic commercial vessel fleet. Phase 2 is expected to focus on changes to safety management system provisions, including simpler systems for smaller vessels, covering the following:
Marine Order 504 Phase 2 is scheduled for implementation in late 2024. This will involve a range of new regulatory requirements, but with particular focus placed on the new simplified SMS requirements for small vessels and simple operations.
Please Note: we are unable to assist with enquiries regarding the inclusion/exclusion of Marine Order 504 Phase 2 at this stage and await further instructions from AMSA.
Three (3) Operational fatalities occurred in 2023 (1 hire & drive, 1 passenger, 1 crew on a class 3). All vessels were less than 7.5 metres in length, and all involved persons overboard.
The changes to Marine Order 504 in August 2023, included a procedure for lifejacket wear requirements. AMSA inspections following this, showed that 46% of the inspected vessels could not identify when lifejackets must be worn. 44% did not identify lifejacket wear other than in an emergency. WOW! That statistic is frightening.
AMSA have identified there is a real need for continued compliance focus on lifejacket wear and risk assessment requirements, so expect inspections for this and other issues will continue.
Carriage of dangerous goods is a high-risk activity for domestic commercial vessels. As such, it has been incorporated into the requirements of MO504 phase 2. This risk area will provide an opportunity to collaborate with State Work Health and Safety (WHS) regulators.
AMSA will publish safety information in collaboration with State WHS regulators focusing on the carriage of dangerous goods on domestic commercial vessels. We will keep our clients informed of these changes once Phase 2 is released.
AMSA will continue engagement with the Aboriginal and Torres Strait communities. As relationships are developed between AMSA and Aboriginal and Torres Strait Islander organisations, safety management system workshops will be offered to Indigenous stakeholder groups and vessel owner/operators.
This compliance priority is aligned with AMSA’s reconciliation vision and Reconciliation Action Plan.
AMSA will conduct safety management safety education with Aboriginal and Torres Strait Islander domestic commercial vessel owners and operators including providing guidance on changes to operational safety requirements, including the implementation of Marine Order 504 phase 2 requirements.
However, if you have any questions, here at Shorlink, we would be happy to discuss your SMS and/or training requirements to ensure safety and education is paramount to all.
Vessel operations represent a concerning proportion of serious and very serious marine incidents. A major contributing factor to these incidents is the quality of Safety Management System (SMS) implementation, including risk assessment, safety procedures, crew training and emergency drills.
Tracey in our office is often heard like a broken record, repeating over and over again on the phone to existing and potential clients, explaining the importance of not only have a compliant SMS, but ensuring that it is implemented. AND that the implementation to your crew is documented to ensure you and your business are covered legally!
AMSA have taken a focus once again or the poorly implemented safety management systems in our industry and will conduct operational monitoring on key areas of risk assessment, maintenance, crewing and emergency preparedness.
Whilst not affecting all of our clients, pilot transfer operations present a niche maritime risk that involves a high level of consequence and a high level of complexity in interacting between a domestic commercial vessel (pilot launch) and a vessel requiring a pilot.
AMSA will also be conducting operational monitoring on domestic commercial vessel pilot launch operations.
AMSA’s previous survey on DCV awareness and compliance with pollution prevention (garbage) requirements (MARPOL Annex V) highlighted a need to raise awareness of the regulations aimed at preventing both accidental pollution and pollution from vessel operations that apply to DCVs.
This includes placard display, garbage management plans, garbage record books, discharge rules and procedures. The 2024/25 focus will be on MARPOL Annex V and the prevention of pollution by garbage from domestic commercial vessels.
AMSA Inspection on vessels between 100-400 GT will also focus on MARPOL V compliance, including inspection of garbage record books and associated procedures.
As you can see, with Phase 2 coming into play shortly, we can envision heightened focus and attention on compliance within our industry.
AMSA release their National Compliance Plan to give regulated communities and compliance partners insight into the areas they will focus their efforts on during 2024-25. Outlining their priorities in advance allows the industry, including you, the opportunity to review your operations to ensure compliance.
Very Simple. If you are unsure about any of the above, please contact our office on (07) 4242 1412 or email here.
Also, if you can share this newsletters with those in our industry to ensure awareness and education for all.
