A plain-language guide to what a Safety Management System is, why it is required, and how Australia's Marine Order 504 compares to New Zealand's Maritime Rule Part 19 (MOSS).
AMSA defines a Safety Management System (SMS) as "a systematic approach to managing safety". It is a written set of procedures, policies, and records that describes how a vessel is operated safely — covering normal operations, emergencies, equipment maintenance, training, and risk management.
An SMS is not just a document. AMSA is explicit that it "must be put into practice and be effective" — what is written down must match what the crew actually does on board.
All Domestic Commercial Vessels (DCVs) operating under Australia's national law must have an SMS. The requirement sits inside Marine Order 504, which is administered by AMSA.
The underlying law is the Marine Safety (Domestic Commercial Vessel) National Law Act 2012.
Commercial operators in New Zealand are covered by the Maritime Operator Safety System (MOSS), set out in Maritime Rule Part 19. Maritime NZ describes Part 19's purpose as requiring operators to "develop, and operate in accordance with safety systems that are specific and appropriate to their maritime transport operation".
Part 19 was most recently amended on 21 April 2025 by the Maritime Rules Amendments 2025.
An updated version of Marine Order 504 came into effect on 1 June 2025. AMSA's guidance lists the new and revised SMS requirements as covering:
Part 19 applies to:
The detailed content requirements for a Maritime Transport Operator Plan (MTOP) and Safety Management System under MOSS are set out in Part 19 itself (linked in the Sources section below). Operators are issued a Maritime Transport Operator Certificate (MTOC) by Maritime NZ once their MTOP is reviewed and approved.
See our dedicated MTOP guide and template →
Marine Order 504 and the NSCV set out the minimum SMS requirements. Most working operators go further than the minimum, and there is nothing stopping you from doing so. Common voluntary inclusions documented in an SMS:
The rule for voluntary inclusions: if you put it in your SMS, you have to actually do it. An AMSA surveyor will check that what is written down is what happens on board. Don't promise more than you can deliver, but don't be afraid to document the extra safety steps you already take.
Holding a Certificate of Operation under Marine Order 504 is mandatory for every Domestic Commercial Vessel. The underlying Marine Safety (Domestic Commercial Vessel) National Law Act 2012 backs this with civil penalty provisions, infringement notices, and the power to suspend or cancel certificates. AMSA has the authority to:
Fines under the National Law are expressed in penalty units rather than dollar amounts. One Commonwealth penalty unit is currently $330 AUD (set under section 4AA of the Crimes Act 1914, effective from 7 November 2024; the value is indexed and reviewed regularly). Individual offences and contraventions in the National Law carry penalties expressed in those units — for example, contraventions can range from a small number of penalty units for minor administrative breaches up to thousands of penalty units for serious safety contraventions.
Beyond the regulatory consequences, operating without a current, accurate SMS exposes the operator to civil liability and, in the event of an incident, can affect insurance coverage and any subsequent investigation by AMSA or ATSB.
Many AU operators run trips into NZ waters (and vice versa). The two systems share common principles — risk-based safety management, documented procedures, crew responsibilities, and active operator oversight — but the legal instruments, certifying authorities, and procedural details differ. An SMS written for AMSA's Marine Order 504 is not automatically a Part 19 / MOSS-compliant safety system, and vice versa. Confirm requirements with both AMSA and Maritime NZ before relying on a single document for cross-Tasman operations.
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