Surveying the surveyors

New regulations are being proposed to protect Australian grain exports from contamination. ABHR speaks with Susan Hull, CEO of Australasian Institute of Marine Surveyors to learn more.

New regulations are being proposed to protect Australian grain exports from contamination. ABHR speaks with Susan Hull, CEO of Australasian Institute of Marine Surveyors to learn more.

If Australian grain becomes infested or contaminated while onboard a bulk vessel, there could be dire consequences for the country’s exports, market access and reputation.

This is why, prior to 2008, marine surveyors performing empty bulk vessel inspections needed to be independent from the shipping process and hold a Certificate of Competency as a Master Class 1 (Unrestricted), and have undertaken 10 grain ship surveys under the supervision of a qualified marine surveyor.

During that time, the Australian Wheat Board (AWB), Department of Agriculture, Water and the Environment (DAWE) and the Australasian Institute of Marine Surveyors (AIMS) believed there were sufficient numbers of Master Mariners coming ashore to satisfy the ongoing numbers of surveyors required to meet export demands.

When the AWB was disbanded in 2008, the AIMS took control of what was known as the Accredited Grain Surveyors list. For a while, everything was business as usual, and any marine surveyor could apply to have their name on the list, but cracks were beginning to form.

Susan Hull, CEO of Australasian Institute of Marine Surveyors, says in 2018, AIMS began to receive complaints from surveyors.

“We began to hear about conflicts of interest from shipping agents hiring their own surveyors, a clear reduction in dependence,” she says.

“We went out to everyone on the list, asking them to provide us with their qualifications for review, and subsequently finding that a number of these qualifications were fraudulent.”

This put Australian exports at risk of becoming contaminated, turned back or refused. Complaints were beginning to roll in, with some surveyors reporting to have finished a five-hold inspection in just 45 minutes.

Several of the marine surveyors were also acting as Authorised Officers (AO), meaning there were some situations where a shipper, only one step removed from the process had their own inhouse surveyor and AO.

“When we were going through the record of surveyors who had done their 10 ships, we also found that a certain percentage of them had carried out these surveys in a period of 10 – 30 days,” Hull says.

“Logistically, it’s highly unlikely that you’d be able to do that – you might be able to get 10 grain ships in a short period of time in a bumper season but it would be pretty hard to do. The objective is to gain good experience in the survey side of things and while you might get 10 good ships in a row, or 10 that would be easy to issue a failure notice for, it’s the borderline ones that are critical to inspect and this is why the rules were put in place.”

By 2019, complaints to the AIMS had more than doubled and due to the severity of the concerns raised, ongoing discussions with the DAWE began. Of particular concern was the potential for an Australian grain shipment to be scrutinised publicly or refused by the buyer.

In light of the ongoing reports of non-compliant practices by authorised officers and marine surveyors, the Accredited Grain Surveyor Assurance (AGSA) Scheme is being proposed and should be established and in force in early 2022.

The AGSA Scheme will provide assurances that marine surveyors performing empty bulk vessels surveys are qualified, experienced and performing these activities in accordance with the provisions of the Plant Rules.

It is proposed that the AGSA scheme will see The AIMS as the administrator of the scheme,  with high level oversight by the DAWE and that a deed of agreement and contract will be reached with department and the AIMS.

A new list will be generated through the scheme and a formal accreditation process for marine surveyors to ensure that only accredited surveyors may perform bulk vessel surveys. The list of names (and, where appropriate, contact information) will be publicly available through a single source of truth to support the appointment of surveyors by Australian exporters, the shipping industry, and authorised officers.

Under the new rules, it is expected the accredited grain surveyors will need to:

Hold or have held a Master Class 1 (Unrestricted) Certificate, or a Master Grade Certificate of Competency; and served a period of not less than six months on a bulk carrier in the capacity of chief officer


Hold an Advanced Diploma of Maritime Operations (Master Unlimited); and

six months on a bulk carrier in the capacity of Chief Officer


Hold a Diploma or Advanced Diploma of Marine Surveying with the modules for dry bulk cargo and grain operations; and

three years’ experience as a surveyor


Hold a Diploma of Maritime Operations (Watchkeeper Deck) with modules for dry bulk cargo and grain operations; and

three years’ experience as marine surveyor

The 10 initial bulk vessel surveys will still remain in place and these must be carried out by the new surveyor ‘under training’ with an already accredited marine surveyor.

Hull says the broader qualification requirements will remove barriers to entry and provide peace of mind for farmers to rely on surveyors to act professionally and ethically. Without this assurance, the risks to the grain industry are great.

It’s not a question of if it will happen says Hull it’s a question of when and in the current volatile trade market it’s a risk we just cannot take.

“What I would really like to see is other Government regulators doing more of what the Department of Agriculture are doing which is working more closely with peak industry bodies,” she says. They have acknowledged the risks and have been pro-active in reinstating sensible controls.

“In my opinion, when Government regulators get involved in matters outside of their mandate and start ‘accrediting’ or ‘licensing’ individuals, the result, more often than not, is a drop in standards. This doesn’t bode well for any part of the industry at all” 

“The Governments role is to develop and introduce sensible regulations and policy and to work closely with and collaborate with peak industry bodies. They should leave the accreditation of professionals across all sectors of the industry to the peak bodies who have the expertise and infrastructure to set, maintain and monitor the professional standards of their members.”

At the time of writing, the Deed of Contract is expected to be finalised and signed in early 2022.

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