Marine Order 32 (MO32) is one of the most important and often misunderstood pieces of maritime regulation impacting vessels operating in Australian waters. Issued by the Australian Maritime Safety Authority (AMSA), MO32 sets out stringent requirements for cargo handling operations, including the inspection, testing and maintenance of equipment, and the safety of crew and stevedores involved in those operations.
What is MO32?
MO32 is part of a wider set of “Marine Orders” used by AMSA to enforce international and domestic maritime regulations efficiently within Australia. These Marine Orders translate international safety and labour standards into enforceable Australian law.
MO32 – Cargo Handling Equipment specifically applies to any vessel whether Australian or foreign-flagged, whether they are loading or unloading cargo at an Australian port. The regulation covers:
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Responsibilities of ship operators during loading/unloading
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Inspection, testing, and maintenance of lifting appliances and gear
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Management of Safe Working Load (SWL)
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Crew restrictions for cargo handling activities if shore labour is available
In effect, MO32 treats the ship as a functional extension of the port during cargo operations, thereby subjecting it to Australia’s strict Work Health and Safety laws.
Why is MO32 Significant?
Unlike general international regulations such as SOLAS or the ILO code, MO32 goes further and is often more prescriptive, particularly regarding design features, work area protection, and crew access requirements.
For example, ships alongside in Australia are frequently required to modify or adapt existing working areas to comply with MO32’s specific fencing, fall protection, and access stipulations - elements not always addressed in other jurisdictions. These enhanced obligations make MO32 compliance both critical and operationally challenging for shipowners and managers.
Furthermore, AMSA holds authority to:
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Issue notices of non-compliance
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Stop cargo operations immediately
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Refuse port access or request vessel departure
Charterers, operators, and owners can be directly impacted by even minor non-conformities. Vessels delayed or denied cargo operations may suffer commercial disruption, revenue loss, reputational damage, and in some cases, legal liability if injury or incident occurs during non-compliant operations.
The Commercial Risk of Non-Compliance
At Idwal, we are increasingly approached by owners and charterers concerned about MO32 implications, particularly for container vessels and bulk carriers using their own gear. Poor onboard safety culture, ageing cargo gear, inadequate fencing, or missing inspection records are some of the most common issues we observe. These seemingly minor oversights can and do result in significant commercial consequences in Australian ports.
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