Following on from our newsletter last week, we acknowledge as an industry whether recreational or commercial – that as Summer approaches, we encounter our busiest time of the year both on and off the water.
Compliance is a topic that most operators and Master’s don’t want to deal with in many cases but…
…it can be a major issue in the event of an incident or even an inspection by AMSA!
Remaining compliant is vital to your operations and more so for your business! All too often when undertaking safety reviews or onboard training we identify non-compliance in many cases.
The non-compliance issues we uncover vary from minor (but still a potential problem) to serious which can cause serious issues in many ways.
Here’s a list of the more common non-compliance items:
Section 11 Documentation in MO 504 specifies what details are required in your log book. There is also a requirement for the Master to sign off each day.
Section 6 in MO 504 states that all new crew members must be inducted prior to going to work. Inductions must be recorded either in your log book or preferably in a specific form that identifies what areas new crew have been inducted in. This should be signed by the new crew member and counter signed by the person providing the induction.
Section 11 Documentation in MO 504 specifies that all crew members details must be documented and kept up to date.
Section 6 Resources and Personnel in MO 504 specifies the requirements for training which must be followed. Note that apart from “initial” training there is now no specified period for drills to be undertaken. Previously it was monthly but it’s now up to the owner or Master to ensure regular drills are undertaken. Be careful not to let your period between drills draw out otherwise you may end up with a problem in the event of an incident.
whilst undertaking regular drills recording them is equally important because if you fail to record them legally they didn’t happen! Take note that each person taking part in the drills must sign the form and the Master must counter sign as well.
Section 7 Procedures for onboard operations and Section 8 Emergency Preparedness in MO 504 require procedures to be developed and documented. If any changes are made to existing procedures they must be updated accordingly.
Section 2 Risk Assessment in MO 504 allows you to have a Risk Register rather than completing individual Risk Assessments. No matter if you use a Risk Register or Risk Assessments they must be updated if there is a change in the level of risk involved with a particular task. Where a new task has been added this must also be assessed and recorded appropriately.
Section 9 Follow-up on hazardous occurrences and non-conformities in MO 504 states that you are required to document all incidents including each hazardous occurrence and non-conformance. You also need to record each investigation into all incidents and any corrective action taken to prevent it happening again.
Section 12 Verification, review and evaluation in Section 12 in MO 504 specifies that both revisions and reviews be recorded in an appropriate form. A review of the SMS is required to be undertaken annually. Revisions and reviews to be recorded and include:
Our most important recommendation is to ensure all your documentation is completed and up to date at all times. A failure to keep it up to date can cause serious issues and potential financial losses if involved in an incident.
The best tip for you if you’re an owner is to check all documentation has been completed correctly and is up to date. If you’re a Master ensure you keep all relevant documentation up to date at all times.
To ensure your log book is up to date fill it out as things happen or as soon as possible thereafter, not the next day, week or month.
The same goes for incident reports, do then as soon as is reasonably practicable after the event.
