An updated version of Marine Order 504 came into effect on 1 June 2025. Here are the new Safety Management System requirements, with direct links to AMSA's guidance for each.
The revised Marine Order 504 (Certificates of operation — national law) 2024 commenced on 1 June 2025. AMSA describes the review as aimed at making SMS requirements "easier to understand, fit for purpose and practical for the diverse range of DCVs across Australia".
The changes affect all Domestic Commercial Vessels. AMSA has published guidance and a tile-based step-through on its MO504 changes page.
Every SMS must now include a fatigue management plan that identifies fatigue risks specific to the vessel's operation, and the controls in place to manage them.
Applies to: all DCVs. AMSA guidance: Fatigue risk management plan
SMS must include a documented drug and alcohol policy. The detailed requirement differs by vessel class — there are separate AMSA guidance documents for Class 1, 2, and 3, and for Class 4 hire and drive vessels.
Applies to: all DCVs (different requirements for Class 1/2/3 vs Class 4). AMSA guidance: Class 1, 2 and 3 policy | Class 4 policy
SMS must include specific procedures for key vessel operations and emergencies. AMSA's guidance lists which procedures must now be in place.
Applies to: all DCVs. AMSA guidance: Operations and emergencies
SMS must add or clarify a statement of responsibility for the master and the designated person, so the lines of accountability are unambiguous.
Applies to: all DCVs. AMSA guidance: Master and designated person
Changes to the assembly station requirements, and how this affects what must be documented in the SMS.
Applies to: as set out in AMSA guidance. AMSA guidance: Assembly station
SMS must identify risks to vessel stability specific to the vessel and its operation.
Applies to: all DCVs. AMSA guidance: Stability risk assessment
SMS must include a process for recording modifications to the structure or equipment of a vessel that may change its stability.
Applies to: all DCVs. AMSA guidance: Record vessel modifications
Alongside the 1 June 2025 changes, AMSA introduced a simplified SMS option for eligible vessels. This is designed to reduce paperwork for smaller, lower-risk operations.
Class 1 (passenger) vessels are not eligible for the simplified SMS option.
AMSA's guidance is direct: "If you're updating an existing SMS or developing a new SMS, follow the guidance below and the guidance about the changes so you comply." AMSA provides templates, step-by-step guides, and webinar recordings to help operators implement the new requirements.
Vessel SMS Builder is configured for the post-1-June-2025 requirements, including fatigue management, drug and alcohol policy, and stability risk assessment. Free to start.
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