NEWS

This week AMSA has consulted with key stakeholders from industry including the AIMS to provide immediate clarification on the proposed reforms to NSCV C7A. It is hoped that interim measures will  avoid confusion and provide industry with clarification on the compliance requirements before the holiday season kicks in.

Industry has requested flexibility and streamlining of C7A and AMSA has responded quickly to ensure that operators are clear on the requirements prior to a full review of the regulations next year.

To date, operators have been unsure of how to apply the rules on life rafts when they are out for repairs, replacement, or maintenance or when operating conditions have changed.

The proposed reforms include the flexibility for operators to adapt the number of liferafts on board to the number of persons on board. While this may seem like a reduction of safety to some the proposed reforms are a sensible approach and allow operators to reduce the number of passengers or crew when liferafts are out.

Most industry operators are keen to comply with safety requirements but find there is no flexibility to operate effectively when life rafts are out for servicing. Current rules mean that these vessels cannot operate without the required number of liferafts for the operational requirements regardless of the number of people on board.

The proposed changes will allow operators to reduce the number of liferafts however they must ensure that the number of liferafts are sufficient for the number of persons (including crew) on board for each operation or journey. This approach  allows operators to rotate the servicing of liferafts and reduce the number of persons on board to suit rather than to cease operations.

Likely reforms include ensuring that life raft certification is kept on board at all times, date and evidence of removal of liferafts is recorded in the log book as well as the SMS and / or risk register and that details of pre-operational checks are recorded before setting sail.

Industry welcomed AMSA’s swift response to concerns and look forward to the release of the interim arrangements. 

AMSA is due to release the full details of the interim arrangements before Christmas and a full review is expected in the first quarter of 2022. Marine Order 25 will also be included in the review and interim arrangements.

 

The final edition for 2021 of our Shipshape Newsletter is out now. Find out all the latest news from our brand new Executive team, as well as some highly informative articles.

Engaging a Marine Surveyor within the recreational market for the first time can feel like rolling the dice.  There is limited reliable information for consumers to enable them to make an informed choice, know their rights and understand what the responsibilities of the marine surveyor are. Coupled with this is the many separate disciplines within marine surveying, making it difficult to establish what standard of service should be expected.  

For too long consumers, and marine surveyors themselves, have been baffled with the structure of the profession and with what constitutes a ‘professional’ marine surveyor.  The Australasian Institute of Marine Surveyors (AIMS), the peak industry body for marine surveyors in Australasia, recognised a need for change.  A need for consumers to be equipped with the right information to give them clarity in their choice of surveyor.  A need for an improvement in the standards and professional practices by marine surveyors across all sectors.

In 2018 AIMS answered the call for change, taking on the challenge of Certifying surveyors who are experienced and qualified in their field and conduct their business and practice to the standards expected of a ‘professional’.

AIMS already had tiers of membership and a rigorous application process in place for their 400 plus members.  Taking membership to the next level by offering Certification gave an opportunity for applying members to stand out in a class of their own.   

To date AIMS has almost 100 members who have successfully achieved Certification with many more working through the requirements to reach this elite level.  It is a huge win for the marine survey industry to have so many surveyors committing to raising and maintaining the level of professionalism amongst marine surveyors. 

What does Certification mean to a marine surveyor?

Certification is an optional application process; a quality system where surveyors and surveying organisations undertaken yearly auditing and verification of their professional experience and qualifications, insurance coverage and business management systems and processes.  If they pass, surveyors are awarded with Certification as a Certified Commercial Marine Surveyor™, an accreditation recognised and respected within the industry.

What does Certification mean to a consumer?

By choosing an AIMS Certified Commercial Marine Surveyor™, consumers can have confidence that their surveyor holds sufficient qualification and experience to undertake the marine survey tasks advertised, maintain their business practices to a minimum ISO 9001 accredited quality industry standard, and hold adequate insurance coverage in case something doesn’t go to plan.  

How do you know if you surveyor is AIMS Certified?

Certified Commercial Marine Surveyors™ are exclusively eligible to advertise their Certification with the CCMS logo.  This logo is a stamp of quality, if your surveyor is displaying this logo, you know you have made a great choice.  If you can’t find a local Certified surveyor, AIMS can help.  All Certified surveyors are advertised on their website www.aimsurveyors.com.au or give them a call and they can assist you in the process 02 6232 6555.

In the event you are not happy with your survey experience, you can provide feedback directly to AIMS via these channels also. The goal of Certification is to raise and uphold the standards of the marine survey industry.  If a Certified Surveyor has not provided the quality service expected, AIMS would like to know.

AIMS has answered the call and risen to the challenge; a solid certification platform has emerged.  In moving a traditional industry sector into a more contemporary model AIMS is working to protect consumers through higher quality and improved standards from marine surveyors who are clearly in a class of their own.  

After surveying cargo holds for the carriage of alumina for almost 20 years, I believe I have earned the right to express an opinion on this vexatious subject. Of course, there are many other cargoes that require similar cargo hold cleanliness inspection; nonetheless, all such inspections require the same courage and conviction to achieve the appropriate outcome.

For the sake of this article, I will first address “official hold cleanliness inspections”, not the variously named pre-cargo, advisory or whatever that have become commonplace in today’s shipping industry. I will burst this festering sore at the end of the article.

COURAGE noun: the ability to do something that frightens one; bravery.

In the context of cargo hold cleanliness inspection, I believe that courage means ‘strength in the face of a challenge’. The challenge to which I refer is that of doing the job properly weighed against the pressures placed upon the surveyor, by not only the numerous concerned parties, but the overall gravity of the situation. I hear many of our more experienced members scoff, however, if hold cleanliness inspection standards are to be maintained, we must educate those coming through the ranks about how their decisions will impact affected parties, and how to remain objective and ethical. We should not underestimate the myriad pressures experienced by surveyors when faced with these decisions.

Naturally, there are many situations where cargo holds are clearly suitable or unsuitable – these are probably the easier jobs. There is little question over the condition or the resulting decision of the surveyor. Let’s not dwell here.

Finding holds unsuitable to carry a particular cargo (some prefer to say failed) will trigger a chain of events that often goes around the globe. There will be many questions asked, so ensure that sound evidence is gathered. High quality photographs will be essential in supporting your decision. For some parties, it is about covering their butt, ensuring the cargo will not be contaminated or damaged in transit; for others it is purely business, all about money.

 

In overall terms, there is potential for huge costs and substantial disruption to logistics, in some cases P&I Clubs will be brought in to resolve disputes arising from a negative hold cleanliness finding.

Okay, so I have probably embellished this story a little, however, consideration must be made for the complexities that exist behind the scenes and, consequentially, the thoughts that exist in a surveyor’s mind as they are inspecting the holds. Is there an existing arrangement between the surveyor or his employer and one of the concerned parties, and if so, how could this influence the decision made by the surveyor? Are there any undeclared conflicts of interest? Can the surveyor provide an impartial assessment of the cargo holds? Will the surveyor maintain an ethical approach to the job when it has potential to affect a business relationship with one of the parties? Is the surveyor’s employer supportive; is the surveyor overwhelmed and wanting to get the job done as soon as possible? Perhaps the surveyor is simply lazy and knows he will get paid for making the easy decision. Perhaps there is an arrangement with a third party that conducts hold cleaning and a ‘failure’ will be beneficial.

When cargo holds are passed as suitable to carry a cargo, everyone is happy, pressure on the surveyor dissipates, the tension in their shoulders is relieved, and the ship’s crew, Master and Owners collectively sigh relief.

This is often the easy way out. The path of least resistance. No courage required! I am not saying that all holds passed are undeserving; on the contrary, I believe most cargo holds are presented well, generally ready for the intended cargo and in need of little, if any, improvement to meet suitable standard.

Experience dictates that most vessels will prepare cargo holds to suitable standards – the stakes are high, shipping is competitive, reputation is important, future business is on the line, but passing cargo holds can require courage.

This brings me to those cargo holds that may be borderline. Pluck up the courage to do good work! Put aside your fear of failure, remain objective, be practical, consider the cargo, how it will be loaded and how it will be discharged. All these things will dictate your decision, but you must have the courage to make that decision. To make a judgement call. To back your experience.

This leads us to the question of experience. How do we gain experience, and how long does it take to become experienced?

CONVICTION noun: a firmly held belief or opinion.

Firstly, let us examine what you believe. Do you believe that a job should be done well, ethically, and in a manner that will provide the appropriate outcome? If you answer yes to this question, then you will likely seek to equip yourself with as much knowledge as possible, continuously learning and striving to understand more, building upon your expertise to become experienced. This sounds like a life- long journey, and in many ways, it is just that; however, with the right training, good mentors, critical thinking skills, the right aptitude, and a thirst for knowledge, it is possible to gain the experience to make appropriate decisions, feel confident with your decisions. From here in it is all about opinion!

Once you gain the experience and feel confident in your beliefs, you are equipped for the next stage – decision based upon opinion. This is where we start to feel that we speak with authority; we make logical argument to back our opinions and provide sound reasoning to rebut opposing arguments. Although this is challenging for many surveyors as they learn their craft, technology enables them (in most cases) to call a friend. A second opinion, a close-up photo via SMS, exchanging opinions can provide much comfort to our members who are still making their way.

So, what have we discovered on this brief journey – spend time with good mentors, absorb their knowledge, remain objective, think about what you need to achieve, be always ethical! Maintain the conviction to excel and apply those convictions with courage.

Now we come to the subject of pre-cargo or advisory surveys conducted at anchorage that are now more or less the norm for many sensitive cargoes loaded in Australia, particularly alumina and grain cargoes. This has reached the point in some cases where shippers are engaging with charter parties mandating such inspections at owners cost, irrespective of the actual vessel condition. I have personally attended vessels on maiden voyages, vessels returning for same cargo, etc, with such vessels generally considered very low risk in the past.

Despite the apparent value that this has provided in alleviating vessels being found unsuitable at berth and the raft of issues highlighted earlier in this article that can result from such events, it has equally created a whole new industry that opens many doors to unethical operators who are focussed more on the business potential than the benefits to the shipping industry. Vessels are being failed at anchorage and further pre-inspections are being recommended, often where issues identified during initial inspection were readily addressed. This is plainly a breach of trust and most unethical, however, such practices persist.

Additionally, vessels that have been pre- inspected are found wanting when they do berth, raising questions as to the competence as a way to kill two birds with the one stone – a pre-inspection and FTL certificate at the same time, pending vessel passing FTL of course; however, because the AO inspection must be conducted at berth (except as above), the FTL surveyor is unlikely to be in attendance with AO inspectors as nobody wants to pay for this to happen. I do not agree with this practice and firmly believe that FTL and AO inspections should happen simultaneously to ensure best practice and oversight for and of inspecting parties. Pre-inspections for grain loading should remain just that!

It is often the case that one thing leads to of the pre-inspecting surveyor. Some of these persons are operating outside of the AIMS membership, providing little recourse to address the issue through the institute, but the practices continue – are these operators offering cut price services or are they just plainly incompetent? All members should call out such poor practices at every opportunity, lest our profession will never obtain the recognition it deserves and may slide into the murky depths that we currently associate with some Asian and South American ports. Half the battle is to get governments, ship owners, charterers, and shippers onboard to condemn unethical practices across the globe.

A further, albeit logical extension of moves towards pre-inspection is the conducting of “official surveys” at anchorage. The alumina trade appears to have resisted this move so far, however, the grain trade has taken to it like a Bosun to a bottle of Bundy! Not only is holds cleanliness, known as ‘Fitness to Load’ certification (FTL) being conducted at anchorage, but in particular parts of Western Australia, Authorised Officer inspections are also undertaken. It is an obvious game- changer for shippers wishing to load vessels immediately upon berthing; however, owners are now insisting on anchorage FTL inspections another. In 1687 Isaac Newton’s 3rd Law proposed that “For every action, there is an equal and opposite reaction”. Why is it that more than 330 years later we keep doing things with little consideration of the consequences?

This is by no means a complete discussion of hold cleanliness, suitable standards and all that surrounds the process – perhaps that is for another day, and there are lots of opinions to consider along the way. I understand that some of what I say in this article may upset some people, however, I have reached this point in my life journey with both courage and conviction. 

Until next time,

John Holden

Vice President

The Australasian Institute of Marine Surveyors is pleased to announce our Affiliate Membership with the International Forwarders and Customs Brokers Association of Australia (IFCBAA).  

IFCBAA is Australia’s leading peak national body, representing members interests in international trade logistics and supply chain management service provision. They are committed to being the voice for customs brokers, international freight forwarders and other associate groups involved in international trade, representing, and supporting their members in a difficult regulatory environment.

AIMS are excited for the opportunities, benefits, and exposure this affiliation will provide to our members and our involvement in the vital role IFCBAA play within shipping logistics. We look forward to a mutually beneficial alliance with IFCBAA as we continue our purpose to ensure the marine survey profession and our members are represented and supported within the wider shipping industry.

On the 3rd of September 2021, Merchant Navy Day, The Australasian Institute of Marine Surveyors pays their respects and honours seafarers past and present who served on Merchant Navy vessels. Many marine surveyors begin their maritime profession on merchant vessels and we thank them for their vital contribution to the plentiful supply of goods we enjoy in our lucky country.

The Merchant Navy, Australia’s commercial shipping fleet, was a valuable resource during the Second World War frequenting trade routes to provide essential goods and supplies to Australians.  These ships were exposed to frequent attack and Merchant Navy Day acknowledges the anniversary of the first merchant marine sinking during World War II.

Sadly, today Australia’s merchant fleet has declined to only 14 Australian flagged ships despite our island continent reliant on shipping imports and exports.  

Australia's export legislation is changing and we want to hear from you....

The Department of Agriculture, Water and the Environment (the department), is proposing regulatory changes to improve export bulk vessel survey and inspection practices.  The proposed changes will provide greater assurance to the department, the shipping industry, and Australia's grain exporters that bulk vessels comply with agricultural export legislation.

The department has been collaborating on these changes with the Australasian Institute of Marine Surveyors (AIMS) and representatives of Australia's shipping and grain export industries.  AIMS and shipping and grain export industry representatives are being consulted on the proposed changes and now the department and your industry bodies would like to hear from you!

Two key changes that are proposed to come into effect from 1 November 2021 are:

1) Ensuring all bulk vessel inspection authorised officers (BVI AOs) record their BVIs using helmet-mounted video recording devices

It is proposed that BVI AOs or their employers will be responsible for:

• purchasing required equipment listed on our website 
• storing recorded video footage for up to 2 years for audit purposes
• making recorded footage available to the department on request

2) Ensuring all qualified marine surveyors are accredited under the new Accredited Grain Surveyor Assurance (ASGA) scheme to survey and certify bulk vessels.

It is proposed that:

• AIMS will administer the scheme
• AIMS members and non-members will be able to apply
• There will be an annual accreditation fee ($250) and additional application cost ($90) per marine surveyor
• Accreditation will need to be renewed annually (approximately in September/October)
• Exporters and shipping companies must source accredited marine surveyors to perform bulk vessel surveys.  BVI AOs will need to confirm a marine surveyor's accreditation.  The AIMS website will provide a publicly available list of accredited marine surveyors and surveyors will be issued identification cards.
• The qualification requirements will be updated to better reflect the qualifications and experience of existing marine surveyors in Australia that perform bulk vessel surveys for plant exports.

Further information

Please visit our Plant export legislation changes webpage for details on the proposed changes.

Feedback

The department is seeking preliminary feedback on the proposed changes.  You can provide feedback directly to us or by emailing plantexportreform@awe.gov.au.  Preliminary feedback closes at 11:59PM AEST on Sunday,12 September 2021.

Your preliminary feedback will help inform an additional formal public consultation process, which is scheduled for late September 2021.  Stakeholders will be provided with details on this consultation process closer to the date.

The August edition of our Shipshape Newsletter is out now. Some great articles in this one, plus all the latest news from our Executive.

Shipshape August 2021.pdf

The Australasian Institute of Marine Surveyors has become a member of Shipping Australia.

Shipping Australia is an industry association that represents Australia’s international ocean shipping industries. They have 29 full members, which includes ocean shipping lines and shipping agents, with over 40 corporate associate members, which generally provide services to the maritime industry in Australia. These services include port and terminal operations, pilotage, insurance, and legal advice among other things. Australia imports and exports the equivalent of about 8 million twenty-foot ocean shipping containers a year. 

Shipping Australia members handle the vast majority of these containers. They also handle a considerable volume of our bulk commodities and vehicle import trades. Their members employ more than 3,000 Australians.

AIMS CEO Susan Hull says "We are excited to be a part of the SAL team and to work with them to provide additional benefits and services to members and the shipping industry. The opportunities for working together to improve shipping standards is something that we will embrace fully. We hope to contribute positively across the many areas of common interest and particularly in the cargo sector. The team at SAL, with their shipping expertise, combined with the specialised skills of the marine survey sector bodes well for the industry at large and we welcome this alliance and look forward to a future of mutual co-operation".

Shipping Australia CEO Melwyn Noronha commented, “We are delighted that the AIMS has decided to join Shipping Australia. Every new member adds to the strength of our association. The AIMS and its members bring additional skills, expert insight and marine surveying experience to Shipping Australia, which will be of benefit to all of our members. And, given the commonality of our interests in resolving the seafarer crisis, promoting safety and the protection of the marine environment, it is a natural fit. We look forward to engaging with the AIMS in a mutually beneficial relationship”.

The AIMS newsletter for May 2021 is now out. Shipshape May 2021-compressed.pdf

Great work from the team!