Maritime Industry Australia Ltd (MIAL) welcomes the opportunity to provide feedback on the draft
report and recommendations produced by the independent review panel as part of the Independent
Review of Domestic Commercial Vessel Safety Legislation and Costs and Charging Arrangements
MIAL was afforded the opportunity to meet with the panel both prior to and after the provision
of the report and the following submission aims to supplement the information provided directly
to the Panel. Some of the concerns articulated by MIAL during those discussions have been set
- The unknown basis for the classification of a vessel as high risk.
- Capacity of Operators to access appropriately trained crew.
- Mitigation of risks would have different requirements and outcomes if a vessel was required to comply with the Navigation Act as opposed to the National Law.
- Lack of clarity around the extra powers that inspectors would have.
- Passing on of costs in utilising the ATSB as the body to conduct investigations into
Following the release of the Governments Independent Review Panels release of the Phase 1 draft
report, there has been much trepidation from the Domestic Maritime Industry around the language
used in the reports recommendation, and an apparent lack of details in the report in how the
recommendations could be achieved – IE, what are the measurable Outcomes.
We cannot highly stress our view enough, and our members view, that any requirement for a
Domestic Vessel Operator, to be required to move from the Domestic National Law to the
Navigation Act, would have a large impact on the operations. In some cases, this maybe operators
that were told by the regulator that they were required to operate as a DCV not a Regulated
Australian Vessel. Their entire business model has been based around this direction.