Changes to Marine Order 504

Table of contents

Do you know about the proposed changes?

You may or may not have known that AMSA are proposing changes to Marine Order 504 (MO504) and from Shorlink’s side we believe AMSA are catching up to us!

The good news is that the bulk of the “proposed” changes are already in the SMS manuals Shorlink develops which means we’re continually way in advance of most manuals developed by others.

In essence, we only have to add a couple of items to comply with the proposed changes; one of which is a Fatigue Risk Management Plan. AMSA are making this compulsory for all DCVs with the exception of the new simplified SMS requirements for vessels under 7.5 metres.

Yes, that’s right! AMSA have proposed a simplified SMS structure for most vessels under 7.5 metres which we believe is a great thing. This is something that we’ve been proposing for some time so it’s great to see it finally coming in.

Here’s a brief outline of the proposed changes that may affect you!
  • Fatigue Risk Management Plan (FRMP): This is going to be a requirement for ALL DCV’s. While Shorlink already has a Fatigue Management procedure in our manuals we will have to develop a FRMP for ALL vessels.
  • Drug & Alcohol Policy: Again all DCV’s will be required to have this. Note that Shorlink includes an Alcohol Policy and a Drug Policy as separate policies as we go deeper into the drug area.
  • Designated Person (DP) statement: Required for all DCV’s. Shorlink already has this in the manuals we develop.
  • Master’s Statement: Again required for all DCVs and another one that Shorlink already includes.
  • Oil or fuel spill procedure: This is a requirement for all DCV’s. Shorlink already has an oil/fuel spill response in our Bunkering procedure but will need to identify this in Emergency Preparedness.
  • Stability to be identified in the Risk Register: Again, for all DCV’s. We have this as a procedure already but will have to add this to our Risk Register’s. there’s also a requirement to ensure the Master and all crew have been advised of any changes to stability requirements.
  • Change to CoO: This will make it easier if you want to change the operational area of your vessel from say a C (Restricted offshore operations) down to a D (Partially Smooth Water Operations)

Fatigue Risk Management

AMSA are specifying that all crew including Master’s have 10 hours rest in every 24 hours. The good news is that it is not a continuous 10 hours it is cumulative which means your 10 hours may be 4 hours followed by 2 hours then another 4 hours provided that those hours are in the same 24-hour period.

One question that has been raised – does the hours travelling to and from work come into fatigue management and… yes it does! AND should be taken into account when undertaking a fatigue risk assessment.

Rest defined

So, as you can better understand what rest in relation to fatigue is in simple terms it means…
“Time away from any and all duties/tasks onboard except for emergency situations”.
This means you do not undertake any duties whatsoever including watchkeeping or supervising other crew members.

Simplified SMS Manuals

It’s good news for most operators with vessels under 7.5mtr as there is going to be a simplified format for your SMS which is great news. We’ll have details on the new simplified format available shortly and be able to start developing manuals accordingly.

Commencement Date

AMSA are going to have the final version out late this year (2024) with the actual commencement date being mid-2025. This is to give everyone time to become compliant with the changes.

Shorlink’s Recommendation

We recommend getting on top of any changes before the commencement date but in most cases not until the final version has been released later this year.

The Fatigue Risk Management Plan (FRMP) would be one thing you should be looking at carefully right and start developing your FRMP NOW!

If you require assistance developing yours, then please do not hesitate to contact us to ensure you cover all the requirements and stay compliant.


Top tip is to get on top of fatigue management!

This is going to be a key point AMSA will be looking at with all operators, not just fleet operators.

If you would like to know more about fatigue risk assessment or have Shorlink complete a fatigue risk assessment on any or all of your crew don’t hesitate to contact our office as we’re here to help.

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