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.