Tag Archive for: AMSA

What you need to know in relation to Marine Orders 504 and 505 which were released this January 2023 and how they may impact your operations.

We’ve had detailed discussions with AMSA and the bottom line is if you operate a DCV where you have a crew member stand watch, referred to as a deck or navigation watch you will be required to have a second Mater onboard.

That’s right, if you normally appoint a watchkeeper so as you can rest, sleep or do other work you’ll need to have another Master with the appropriate ticket onboard.

For example if you have a 23mtr vessel you’ll need two (2) Masters onboard who hold a current Master <24 m NC ticket.

Here is what’s required

Marine Order 504 Schedule 1 Clause (17) specifies that a deck/navigation watchkeeper must be qualified in accordance with Clause 7.3 of Subsection 7B of the NSCV Part C. The requirement is for the watchkeeper to hold a Long Range Operator Certificate of Proficiency (or higher).

To download Marine Order 504 click on this link : Marine order 504—Certificates of operation and operation requirements—national law (amsa.gov.au)

Download a copy of NSCV C7B by clicking on this link : NSCV C7B – Communications equipment (amsa.gov.au)

Marine Order 505 Schedule 1 Duties and functions for which a certificate of competency is required is where you’ll find what their duties are limited too.

To download Marine Order 505 click on this link : Marine order 505—Certificates of competency—national law (amsa.gov.au)

In Marine Order 505 Schedule 3 Eligibility and sea service requirements identifies what courses are required to attain specific certificates of competency.

Marine Order 505 also specifies that to undertake a Navigational Watch or be a deck watchkeeper the following applies (see below for definitions):

For inshore waters: Coxswain Grade 1 NC.

For offshore operations: Master <24 m NC. This enables the holder to act as a deck watchkeeper on vessels <100 m and <3000 GT <EEZ

Inshore Waters means non-tidal waters

Offshore Operations means vessel operations that are:

  • within 200 nm seaward of the baseline of:
  • the Australian mainland; or
  • the Tasmanian mainland; or
  • a recognised island; and
  • in waters to the outer limits of the EEZ.

Here is the wording direct from AMSA identifying who is not permitted to be in charge of a navigational watch.

A person is not in charge of a navigational watch when working:

  • as a general-purpose hand (this means a deckhand, certified as a GPH or not)
  • as a navigational watch rating
  • under training
  • to assist a master
  • under the direct supervision of the person in charge of the vessel

You can read it yourself by clicking on this link : Qualifying near coastal sea service (amsa.gov.au) and scrolling down to In Charge of  a Navigational Watch.

I’ve had, and still having ongoing discussions with AMSA in relation to this highlighting the:

  1. lack of suitably qualified Masters’ with experience in the required areas of operation;
  2. impracticality of dual Masters’ on DCV’s, especially in vessels up to 40mtrs;
  3. economic/financial impact on operators;
  4. added stress and anxiety this is going to cause owners and operators;
  5. potential for depression and potential suicide; and
  6. applying of “big ship” operational procedures to DCV’s.

Here’s two of the responses I got from AMSA:

  1. “you’ll just have to employee another Master”; and
  2. “in the consultation process many owners agreed to this along with insurance companies”

The bottom line is that for many your SMS may have to be updated along with the Appropriate Crewing Calculator to reflect these changes.

We would be more than happy to hear your response to these changes. Please email your comments to wayne@shorlink.com as he is keen to hear them.


Our primary recommendation is consider your operations and how these impacts on them both operationally and financially. You then have to implement changes in crewing and/or how you operate.



If you need help with any of the new laws, please contact our office as these changes can have a major impact on your business both operationally and financially.

Did you know that AMSA made an amendment to Marine Order 504 in relation to vessels carrying passengers that commenced on the 31 May 2020.

For Class 1 and Class 2 vessels that are permitted to carry passengers you will be required to have an effective and verifiable means of passenger monitoring to ensure the master is able to find out the number of passengers onboard at any time.


Operators will be required to undertake a passenger count at the time of embarkation and disembarking for vessels that are:

  • a Class 2 vessel permitted to carry passengers or a Class 1 vessel that is permitted to carry no more than 75 passengers; and
  • is on a voyage of at least 30 minutes and no more than 12 hours scheduled duration and the vessel is not scheduled to stop for embarkation or disembarkation in the first 30 minutes; and
  • is operating in B, C or D waters at any time of E waters outside of daylight hours.

For operators who transport passengers to a water-based activity the passenger count:

  • must include an additional count before the vessel departs from the site; and
  • is not required to be conducted when a vessel is stopped for a water-based activity and a passenger enters or leaves:
  1. the water; or
  2. another vessel used in conjunction with the activity

This means if you’re operating a ferry service or water taxi which has voyages of less than 30 minutes this amendment does not apply.

For most operators who carry passengers on voyages of 30 minutes or more and less than 12 hours you will need to update your Safety Management System (SMS) to incorporate the changes.

Shorlink’s Recommendation

We strongly recommend you review your SMS now and work out what changes are going to be required to ensure you meet the new requirements.  Feel free to utilise our free SMS Assessment Service – just email us a copy of your SMS, and our Principal Consultant will review and let you know of any changes may be required.


If you’re having trouble working out what’s required or how to incorporate the changes into your SMS then give us a call and we’ll help get you compliant with the changes.