The safety framework prescribed by successive issues of Marine Orders Part 54 (MO 54) has not assigned the responsibility for the overall management of the safety risks associated with coastal pilotage operations to pilotage providers or any other organisation.
The safety action that has progressively been taken by AMSA has adequately addressed the safety issue. In particular, on 1 July 2014, Marine Orders Part 54 (MO 54) specifically assigned the responsibility for the overall management of the safety risks associated with coastal pilotage operations to pilotage providers.
The Australian Transport Safety Bureau recommends that the Australian Maritime Safety Authority takes further safety action to address the safety issue by ensuring that the coastal pilotage regulations specifically assign the responsibility for the overall management of the safety risks associated with coastal pilotage operations to the pilotage providers or another organisation. The role, functions, operational and industry responsibilities of any organisation providing a coastal pilotage service should be clearly defined by the provisions of the regulations with a primary focus on the safety of the pilotage service provided.
AMSA considers that the requirement to manage the risks associated with the act of conducting a pilotage is already embodied in the provisions of Marine Order Part 54 under the mandatory requirements and requirements for pilots with respect to the safety management system.
Notwithstanding this, AMSA recognises that opportunities for improvement exist. AMSA has already implemented safety action to improve the safety issue through the implementation of standard passage plans and the requirement for pilotage providers to develop standard operating procedures for the pilotage task. The presence of such uniform procedures for the pilotage task and standardised passage plans enable ship crews to pre-plan passages. Additionally, pilots are required to carry these plans with them in either electronic or hard copies.
AMSA also acknowledges that the current review of Marine Orders Part 54 provides a timely opportunity to revise and clarify the responsibilities of pilot providers to specifically address the conduct of the act of pilotage. The review is being carried out with the intention of making a revised Marine Order under the Navigation Act 2012 which re-defines “pilotage provider” as an entity with clear responsibilities for pilotage operations, a big improvement in the current Act definition. In addition, there is an opportunity to more clearly identify the requirement for appropriate standard operating procedures in the pilot provider’s safety management systems. The revised Marine Order 54 is expected to be implemented by July 2013.
Concurrent with the review of Marine Order Part 54 AMSA is reviewing the Industry Passage Plan as standard procedure, noting the plan has been in place now for 18 months. The 2013 edition of the consolidated coastal passage plan is expected to be published by AMSA in early 2013.
As part of the oversight process, AMSA will be conducting its next annual audits of the pilot providers in late January 2013. In the past year, in response to Marine Order Part 54 issue 5, the pilot providers have been introducing standardised systems of piloting and the audits will provide an opportunity to assess the effectiveness of this approach.
In addition to these annual audits AMSA continues to work with its pilot stakeholders through the Combined Pilotage Group forum to ensure understanding and management of this concept and to inculcate an appropriate safety culture in the pilot providers and pilots. The group, comprised of AMSA representatives, pilot providers and pilots, meets three times each calendar year, with an opportunity to meet more frequently if required.
The proposed revision of Marine Orders Part 54 (MO 54) and other noted safety actions should adequately address the safety issue.
The internal review of MO 54 issue 5 has been completed. Final review of changes and change table are now being implemented into a draft revised version of MO 54 for external consultation.
In discussing the consultation process with the Pilotage Providers it is apparent that they will request an extended review time frame – beyond the standard 4 week consultation for Marine Orders as indicated on the AMSA website http://www.amsa.gov.au/forms-and- publications/Fact-Sheets/Fact_Sheet- Marine_Order.pdf .
In addition, the review of Nationals Standards for Commercial Vessels (NSCV) and the link with Pilot Launch requirements is expected to complete by the end of 2013, with implementation in early 2014.
With both these points in mind, it is anticipated that the next version of MO 54 will go into force in Q1 2014.
The proposed revision of Marine Orders Part 54 (MO 54) and other noted safety actions should adequately address the safety issue.
