
Are you ready for changes to Marine Order 504?
All Australian domestic commercial vessels (DCVs) are required to implement a safety management system (SMS) which complies with Marine Order 504 (MO504). Following public consultations on proposed changes, the Australian Maritime Safety Authority (AMSA) will implement final revised changes to MO504 aimed at enhancing safety outcomes and making SMS requirements clearer, more practical, and better suited to the diverse range of DCVs in Australia.
The proposed changes will take effect on 1 June 2025, and will apply to all owners, operators, masters, and crew of DCVs. There is sufficient time before implementation for DCVs to update their SMS and implement necessary adjustments to comply with the new AMSA standards.
Summary of Proposed Changes
- Simplified SMS Requirements for Smaller, Less Complex Vessels
From 1 June 2025, Class 2, 3, and 4 vessels1 under 7.5m in length will be eligible for simplified SMS requirements, provided none of the following applies:
- Class 2 vessels do not carry more than 4 day passengers.
- The vessel does not carry dangerous goods.
- The vessel does not have features such as cranes, lifting devices, or deck loads impacting stability.
- The vessel does not have an inboard petrol engine, berthed accommodation, or towage setups.
- The vessel is not deemed unsuitable by AMSA for simplified SMS.
Key features of the simplified SMS system are:
- Designated person responsibility statements are no longer required if the owner is also the designated person.
- If the owner is the master, a master’s responsibility and authority statement is no longer required.
- A risk assessment is no longer required to identify key daily tasks performed by the master and crew.
- Owners are not required to specify assembly stations as part of their emergency plan.
- Mandatory details for the crew list have been reduced.
- Strengthening Fatigue Management
It is well known that seafaring can be a physically and mentally demanding occupation, and that poor fatigue management presents one of the most significant risks to vessels, those on board and the marine environment.
The amendments to MO504 will apply to Class 1, 2, and 3 vessels, including those eligible for simplified SMS. These changes will bolster the requirements for identification and management of master and crew fatigue in the SMS. Importantly, the SMS fatigue risk management plan will need to consider factors beyond work and rest hours, such as night work, sleeping environments, and task demands to ensure a robust approach to fatigue management, in line with AMSA’s Fatigue Guidelines.2
Under the new requirements, owners will need to ensure risk assessment for the vessel addresses master and crew fatigue and how these risks will be managed as part of the fatigue management plan. Owners will also need to consider whether the identified fatigue risks require other parts of the SMS to be updated, for example:
- Appropriate crewing for watchkeeping and lookout duties.
- Employee induction.
- Procedures for breaks and adequate sleeping opportunities.
- Maintaining a healthy shipboard environment.
- Training on recognising and managing fatigue risks.
- Enhancing Management of Drug and Alcohol Risks
All DCV operators must include a drug and alcohol policy in the SMS. Like most aspects of the SMS, the relevant policy can be tailored in line with the size and complexity of a vessel’s operations. Operators that already have a drug and alcohol policy will need to make sure that the policy is included in the vessel’s SMS, that familiarisation with the policy is included as part of crew/staff induction, and that crew/staff are appropriately trained on the reasons for having the policy and the risks associated with non-compliance.
Drug and alcohol policies should address risk management and “fit for duty” assessments for all masters, crew, and special personnel. Passenger-carrying vessel operators must also consider passenger-related risks. In particular, it is important that all officers and crew are familiar with the vessel’s drug and alcohol policy and ensure that they are not impaired by drugs or alcohol at any stage during vessel operations.
The changes will impact different classes of vessels. For Class 1, 2, and 3 vessels, owners will need to consider:
- Alcohol and drug-related induction and emergency training.
- Operational procedures on alcohol and drug use (e.g., zero-tolerance or limited ingestion).
- Fit-for-duty standards and disclosure procedures for prescribed medications.
- Denial of boarding for impaired individuals.
For Class 4 vessels, owners will need to consider:
- Induction training on drug and alcohol use, including handling impaired hirers/participants.
- Expectations for acceptable use by staff, hirers, and participants.
- Pre-departure testing and denial of boarding for impaired individuals.
- Guidelines for onboard consumption by hirers/participants (if allowed).
- Changes to Operational and Emergency Procedures
Class 1, 2 and 3 vessels, including those eligible for simplified SMS, will need to include in the SMS procedures for important vessel operations outlining how high risk operations will be managed. Specifically, the SMS will need to address risks relating to:
- Vessel start up and shutdown.
- Vessel mooring and berthing.
- Vessel bunkering and refuelling.
- Vessel access (embarking/disembarking).
- Preparation and use of passage plans.
- For a vessel with a confined space – confined space entry.
- Where relevant, cargo operations including the carriage of dangerous goods as cargo.
Operators who identify risks in relation to the above areas will need to develop procedures relating to these risks and include them in the SMS. The extent of procedures required to manage the relevant risks will need to take into account the size and complexity of the vessel’s operation.
- Clarifying Roles and Responsibilities for Vessel Operations
Operators must ensure clarity in roles and responsibilities of owners, masters and designated persons. These requirements will mean that operators need to:
- Implement a Designated Person’s Responsibility Statement
- All vessels, including those eligible for simplified SMS, must include a statement outlining the designated person’s identity, contact details, and responsibilities.
- However, this is not required if the owner is also the designated person and their vessel qualifies for simplified SMS.
- Master’s Responsibility and Authority Statement
- Class 1, 2, and 3 vessels will need to clarify the master’s authority in ensuring vessel, environmental, and personal safety.
- However, this is also not needed if the owner is also the master and the vessel qualifies for simplified SMS.
- Updating Assembly Station Requirements
Class 1, 2, and 3 vessels that are not eligible for simplified SMS will need to review and update assembly station requirements in the SMS.
The key change for affected vessels is that alternative assembly station requirements are no longer dependent on the number of persons carried on board. Instead, alternative assembly stations will now be required where it is practical based on the vessel’s layout, characteristics and risk assessment.
Owners will need to consider:3
- Updating risk assessments and emergency plans to identify primary and alternative assembly stations (if practical).
- Include crew assignments, passenger safety procedures, and emergency drill schedules.
- Managing Risks to Vessel Stability
AMSA refers to vessel stability as “ability of a vessel to return to its upright position after being heeled over by wind, waves, or other forces. A vessel that does not have sufficient stability is at risk of capsizing“.
The updates to MO504 will require operators, other than those eligible for simplified SMS, to identify and manage risks to vessel stability within the SMS, in order to reduce the risk of the vessel capsizing. Such risks might include modifications to the vessel, overloading, accidental flooding or adverse weather conditions.
Operators of Class 1, 2, and 3 vessels, including eligible for simplified SMS, will need to record any structural or operational modifications affecting vessel stability and ensure documentation of these changes are accessible.
Next Steps
DCV owners and operators should:
- Assess eligibility for simplified SMS.
- Update SMS to address new requirements and consider how these new requirements might impact existing aspects of the SMS.
- Ensure compliance with the updated MO504 standards by 1 June 2025.
Practical guidance on how to implement these changes can be found on AMSA’s website at https://www.amsa.gov.au/changes-safety-management-system-requirements-1-june-2025.
Should you require legal advice on preparing for these changes, or concerning the application of the changes to your vessel, please contact Gavin Vallely or Andrew Shinnick.
Whilst every care has been taken to ensure the accuracy of this information at the time of publication, the information is intended as guidance only. It should not be considered as legal advice.
Footnotes
- DCV’s are separated into 4 classes as follows: Class 1: Passenger Vessel (13 or more passengers); Class 2: Non-passenger vessels (up to 12 passengers); Class 3: Fishing Vessel; Class 4: Hire and drive vessels used by the hirer only for recreational purposes.
- A copy of the Guidelines can be accessed at the following link: https://www.amsa.gov.au/sites/default/files/amsa-fatigue-guidelines-web.pdf
- Specific guidance for operators impacted by the changes to assembly station requirements can be found on the AMSA website at the following link: https://www.amsa.gov.au/sites/default/files/2024-12/assembly-station-guidance-mo504-changes_0.pdf