Maritime industry compliance: Meeting AMSA’s drug & alcohol testing requirements

Maritime industry compliance: Meeting AMSA’s drug & alcohol testing requirements

From 1 June 2025, every domestic commercial vessel (DCV) operator in Australia will need to have a drug and alcohol policy as part of their Safety Management System (SMS), a significant update from the Australian Maritime Safety Authority (AMSA) designed to strengthen safety across Australian waters.

For operators, this new requirement isn’t just a procedural update. It’s a call to take proactive steps toward building safer, more accountable maritime workplaces both at sea and on shore.

 

Why the New AMSA Rules Matter

The maritime sector faces unique safety challenges. Long shifts, isolation, fatigue, and high-risk working environments make it essential to ensure that everyone on board is fit for duty.

The AMSA policy change reflects growing concern over impairment-related incidents and aligns domestic safety requirements with international frameworks such as SOLAS (Safety of Life at Sea). By mandating drug and alcohol management policies, AMSA aims to minimise risk, protect crew and passengers, and promote a culture of responsibility and accountability.

For operators, the message is clear: compliance is now a core part of safety operations.

 

Understanding AMSA’s Drug & Alcohol Policy Requirements

This new directive stems from amendments to Marine Order 504 (Certificates of Operation and Operation Requirements) and forms part of AMSA’s ongoing commitment to reducing risk and improving crew safety across Australia’s domestic fleet.

Who the Policy Applies To

The regulation applies to all DCVs operating under a Certificate of Operation regardless of vessel size, operation type, or area of navigation.

This includes:

  • Fishing vessels
  • Ferries and passenger craft
  • Towage and barge operations
  • Offshore and port service vessels
  • Charter and tourism vessels

Essentially, if your vessel operates under an AMSA Certificate, your organisation must have a compliant D&A policy integrated within its SMS.

What the Policy Must Include

AMSA’s expectation is not just for operators to “have” a policy, but to implement a structured, verifiable framework that actively prevents and manages impairment risks.
A compliant Drug and Alcohol Management Plan (DAMP) or policy must outline the following elements:

1. Purpose and Scope

Define the policy’s intent: safeguarding health, safety, and operational integrity by ensuring no crew or staff member performs safety-sensitive duties under the influence of drugs or alcohol.

2. Roles and Responsibilities

Clearly assign accountability for:

  • Conducting and overseeing tests (usually the Master or Safety Officer).
  • Managing records, incident reporting, and investigations.
  • Training crew on policy requirements and legal obligations.

3. Testing Procedures

Detail when and how testing will be conducted:

  • Pre-employment or pre-duty testing.
  • Random or unannounced testing.
  • Post-incident or reasonable-suspicion testing.
  • Follow-up testing after a positive result.

Testing procedures must reference relevant Australian Standards, including:

  • AS 3547 – Breath alcohol testing devices.
  • AS/NZS 4308 – Collection and analysis of urine samples for drugs of abuse.
  • AS/NZS 4760 – Oral fluid drug testing (if saliva testing is used).

4. Alcohol and Drug Limits

State the maximum permissible levels for alcohol and the zero-tolerance stance for illicit drugs.

Under AMSA guidelines, a crew member must not perform duties if their Blood Alcohol Concentration (BAC) is 0.02% or higher.

For drugs, any detection of prohibited substances constitutes a breach.

5. Response and Disciplinary Action

Outline the steps following a non-negative test, including:

  • Immediate stand-down from safety duties.
  • Formal investigation or confirmatory laboratory testing.
  • Reporting to AMSA if a safety incident or breach has occurred.
  • Documentation and record-keeping of actions taken.

6. Record-Keeping and Privacy

The policy must explain how test results and related data are stored, secured, and retained, typically for a minimum of two years. Operators must ensure confidentiality while still providing access to AMSA inspectors during audits or investigations.

7. Education and Training

AMSA places strong emphasis on crew education.
Operators should implement periodic awareness sessions covering:

  • The dangers of impairment.
  • Testing expectations and procedures.
  • Crew responsibilities under Marine Order 504.
    • Training logs should be recorded as part of the SMS documentation.

8. Incident Reporting and Review

Every suspected or confirmed case of impairment should trigger a review of procedures to identify causes, preventive actions, and potential SMS updates. This demonstrates continuous improvement, a key expectation in AMSA audits.

 

Why AMSA Has Introduced This Change

Previously, drug and alcohol management was strongly recommended but not mandatory.  After several high-profile maritime incidents linked to impairment, AMSA’s review found inconsistencies in testing practices and gaps in SMS documentation across the sector.
By formalising D&A policies, AMSA aims to:

  • Standardise safety practices across all DCVs.
  • Reduce incident rates related to impairment.
  • Strengthen accountability through documentation and audit readiness.
  • Align Australia’s domestic maritime safety with SOLAS and ISM Code requirements for international vessels.

Integration with the Safety Management System (SMS)

AMSA expects the D&A policy to be an integrated component of the SMS and not a standalone document. That means your SMS should:

  • Reference the D&A policy under “Operational Safety” or “Crew Fitness.”
  • Include procedures for testing, reporting, and corrective actions.
  • Show clear evidence of implementation, not just a written commitment.

During audits, inspectors may request to see:

  • Your D&A policy document.
  • Crew training records.
  • Recent test logs and calibration certificates.
  • Incident reports involving impairment.

Failure to provide these may result in non-conformity notices, requiring corrective action within a defined timeframe.

Testing Obligations Explained

Alcohol Testing

Regular alcohol tests are required before a person begins safety-sensitive duties and after incidents or near misses.

  • Recommended practice: Pre-shift or random breath testing.
  • Acceptable limit: Blood alcohol concentration (BAC) must not exceed 0.02% while on duty.
  • Testing tools: Use only AS 3547-certified breathalysers to ensure accuracy and compliance.

Drug Testing

Drug screening must be carried out:

  • Randomly, across different crew members and duty cycles.
  • Post-incident, following any safety or navigational event.
  • Pre-employment, for new hires in safety-critical roles.

All drug testing should follow AS/NZS 4308, which defines proper collection, chain-of-custody, and laboratory confirmation procedures.

Record-Keeping

AMSA requires that testing records be securely stored for a minimum of two years and made available during audits. Records should include:

  • The date, time, and reason for the test.
  • The type of test (random, incident, routine).
  • Results and follow-up actions.
  • Calibration and device maintenance logs.

 

Unique Maritime Testing Challenges

Unlike land-based industries, maritime operations face distinctive logistical hurdles:

  • At-sea testing limitations: Ships may lack medical staff or stable environments for accurate testing.
  • Crew turnover and shift patterns: Ensuring fair and random testing can be complex.
  • Environmental conditions: Humidity, vibration, and movement can affect test accuracy.
  • Dual compliance: Operators must align with both AMSA and international maritime codes (SOLAS, ISM Code) if vessels travel internationally.

These factors highlight the importance of fit-for-purpose testing equipment and a well-documented compliance framework.

 

Compliance Checklist for DCV Operators

Below is a practical checklist to help operators prepare for the 2025 AMSA requirements:

Step

Action

Purpose

1

Review current SMS

Identify whether your Safety Management System includes a drug & alcohol section.

2

Draft or update a DAMP

Outline your prevention, testing, and disciplinary procedures.

3

Select compliant devices

Use only AS 3547-certified breathalysers and AS/NZS 4308-compliant drug tests.

4

Train crew and supervisors

Ensure everyone understands the policy, testing methods, and consequences of non-compliance.

5

Establish record-keeping processes

Create secure logs for all tests, calibrations, and results for at least two years.

6

Schedule regular internal audits

Verify compliance with AMSA and prepare for official inspections.

7

Integrate with safety reporting

Link your testing outcomes to incident and safety review processes.

Implementing this checklist not only helps meet AMSA obligations but also strengthens overall safety culture and operational transparency.

How Andatech Supports Maritime Compliance

At Andatech, we’ve long supported Australia’s transport and logistics sectors in meeting national safety and testing requirements.

For the maritime industry, we provide:

Our solutions are designed to perform reliably in challenging maritime environments, helping operators maintain compliance, protect their crews, and promote safety at sea.

 

Final Thoughts

With AMSA’s updated requirements taking effect in June 2025, now is the time for DCV operators to act.  A proactive approach backed by compliant testing equipment and accurate record-keeping, not only ensures regulatory compliance but reinforces your commitment to safety, accountability, and professionalism.

Equip your vessels with certified testing devices and ensure your Safety Management System is fully compliant.

Explore Andatech’s maritime testing solutions or speak with a compliance specialist today.