The reporter has raised a safety concern in relation to the Master's forward vision potentially obstructed by cargo containers on a domestic commercial vessel.
The reporter advised on the [date], the cargo supply vessel '[Vessel name]' travelled to [Location 1], [State]. The vessel was loaded with 10 containers that would potentially obstruct the Master's view forward of the vessel. The reporter is concerned as there was a previous incident with a barge hitting a small fishing vessel in [Location 2] harbour, where people were thrown into the ocean and nearly drowned. The reporter states, 'The barge crew at the time did not even know they had hit someone and did not stop. Many people fish near the shipping channel in [Location 2] harbour and along this vessels route from [Location 2] to [Location 1]'.
The reporter is further concerned as the vessel would be travelling at night with obstructed forward visibility. It would be catastrophic should the vessel collide with a small vessel at sea.
The reporter finally states, 'This vessel appears to be outside the regulations for line of sight on a commercial vessel'.
The reporter's intention for raising the REPCON is to ensure this operator is safely managing their vessel along with the safety of the crew and other vessel operators.
The Master of [Vessel name] has operated landing craft in [Region] for the past 14-15 years. [Master] contends that their forward view from the bridge of [Vessel name] was not obstructed.
[Master] reports they had a clear view of the horizon and the water 'about' 20 m in front of the bow from mid-ships on the bridge. Due to the design of the bridge on [Vessel name], from the port and starboard sides of the bridge, they and the crew had a completely clear view forward and to the sides of the vessel.
[Vessel name] is also fitted with radar to further aid [Master] and the crew with the vessel's safe operations. For nighttime operations [Vessel name] is fitted with high powered lights and even a search light if this was ever required.
Our crew when on deck are equipped with two-way radios to the bridge and therefore can also communicate with [Master] any navigational concerns or hazards.
We note the photograph you shared of [Vessel name] on approach to the ramp at [Location 1]. On final approach the crew were on deck keeping watch and communicating with the bridge in readiness for the vessel's landing. To improve the crew’s own view [Master] had partially lowered the bow door.
In summary, we are not of the belief the vessel’s safe operation was compromised and nor were there any reportable incidents or navigational concerns on that voyage.
In response to REPCON RM2025-00022, below is a summary of the actions taken by the Australian Maritime Safety Authority (AMSA) regarding the Domestic Commercial Vessel (DCV) [Vessel name] ([identifier]), a 34.8 m landing barge operating under a valid 2B Certificate of Survey, Load Line Certificate (to [date]), and Certificate of Operation (to [date]).
As a DCV, Safety of Life at Sea (SOLAS) does not apply. However, the master must comply with Convention on the International Regulations for Preventing Collisions at Sea (COLREGS), the National Law Act 2012, Marine Orders, and the field of vision requirements in National Standard for Commercial Vessels (NSCV) C1.
The investigation confirmed that an accredited surveyor recommended the vessel be aligned with the deemed-to-satisfy (DTS) visibility solutions, supported by approved drawings. AMSA has not issued any exemptions relating to field of vision requirements; therefore, responsibility for compliance remains with the owner and master.
AMSA [Location 2] attempted to contact the operator for information about cargo loaded on [date] but received no response. With the vessel unavailable for inspection, the assessment relied on the complaint and approved drawings.
The vessel is authorised to load containers in accordance with its approved stability book. However, cargo must not obstruct the required field of vision from the primary operating position, as this creates an operational hazard under NSCV C1.
As a result, AMSA issued:
- A Prohibition Notice preventing the vessel from loading cargo that would breach COLREGS or NSCV C1 section 3.4.
- An Improvement Notice requiring updates to the SMS to ensure cargo operations comply with regulations and the approved vessel design.