Raising the safety bar in commercial diving

Compared to other industries requiring a similar?community?of manned intervention support, the commercial diving industry is comparatively new.

Over the past 60 years, commercial diving has developed from a largely salvage, military and civil engineering operation into the global offshore industry that we know today.?

Commercial diving now services the exploration, development and production of offshore hydrocarbons for an expanding, energy consuming world, albeit one with a future eye on the transition?away from fossil fuels.

Prior to 1965 commercial diving only took place on a limited scale, in the Gulfs of Mexico, Arabia and other parts of the world, but since then it has rapidly grown into the industry we know today.?We are also now seeing commercial diving as an integral part of the de-commissioning, fish farming and energy transition sectors.?

Commercial diving has always been a high-risk business and on a global scale, those risks have not always been reflected by the rewards, except in those more regulated regions, such as the UK and Norwegian sectors of the North Sea, where the high risk nature has been recognised and robust regulations established, implemented and followed.

However, even in the North Sea this has not always been the case and it is often the tragic lessons from the past that have helped drive the important diving safety continuous improvements agenda that we often take for granted now.?

As an example, in the North Sea during the 1970s there were 44 diver fatalities and a further 10 in the 1980s.

Unfortunately, it is often high profile incidents and tragedies that bring about change (Piper Alpha in offshore oil & gas, Hillsborough in football, Kings Cross in public transport) and so the introduction, in the UK, of the UK HSE 1997 Diving at Work Regulations played a major part in promoting that change for the better?within the diving industry.

Back in 2010 the UK HSE Diving Inspectorate described their goals as;

• To secure a significant and sustained reduction in the number of fatal and major accidents across all sectors of the diving industry.
• To work with all sectors of the industry to reduce risks to the health and safety of those involved in diving at work industries.
• To encourage collaboration within and across all industry sectors to develop and share best practices.?

The 1997 Diving at Work Regulations, proven best practices and these HSE strategies?have all helped to eliminate diving fatalities from the UK Sector of the North Sea in the 21st?Century, with the exception of medical related work cases. However, in too many regions across the global diving industry this is not the case, resulting in diver injuries and fatalities because the contracting entities simply do not follow best practice.?

It is not my intent to be controversial here, I’m simply stating what I see, and I believe I’m experienced and qualified to do so, but please consider the following:

• Why is it still so hard for some diving projects not to fully understand the hazards of Differential Pressures (Delta P) and the importance of establishing proven barriers ? Is it not being taught correctly? Divers are still being injured (or worse) by this?activity and I fail to see why this is still the case when, if managed correctly, it should be relatively straight forward with minimal risk?
• Why do we still see divers being killed or going missing when performing Ship’s Husbandry operations? Every Operation of this kind will have a client and a customer, so why is this still happening? Lack of control of the work???Indifference??Clearly something in the chain of communications and command is not working as it should be.
• Why is SCUBA still perceived as a safe commercial diving technique? I firmly believe that it’s not and I also believe that if we, as an industry, retired the technique we would dramatically reduce the risk of diver injury or fatality. Both IOGP and IMCA are clear regarding SCUBA having no place in the commercial diving world but every year there?are scuba fatalities, yet nothing changes.
• Saturation diving operations without SPHL or HRF. The guidance and recommendations are clear,?this is such an unethical and unprofessional approach?when it comes?to supporting safer, deeper diving.??Decompression in an SPHL supported by just an LSP is wrong. Don’t do it.
• Hot Work is still harming divers, why is this the case? Both IOGP and IMCA have robust guidance in place, as do most diving contractors.?Remember, the potential for causing harm and injury to people is significantly reduced when the correct control measures are applied and robust procedures are approved and followed.?If a change is required, then ‘Manage that Change’ in the correct way.
• Live Boating…….. Is this a method of??diving operations we need still in the 21st?century? There are?safer?alternatives such as an approved mobile/portable system.?(Not to be confused with DP Operations).
• Conducting surface supplied diving operations without a DDC on site or one that has been function tested??In my opinion, this is not acceptable. Some may say, “But it’s only 10.0m deep?”?I’ve heard this all too often.?That first 10.0m is the greatest volumetric change, consider the highest decompression risk every time. A diver suffering from an embolism has their survival chances seriously?reduced?if they have to travel offsite to a DDC. Now I know there are still some Regulations that allow this as a routine element of an operation but I categorically disagree. Regardless of an embolism, a diver with any Type 2 DCi?manifestation?is going to be very fortunate to survive without life changing complications and, as most readers will know, I speak from personal experience here.
• Diving on air to -50.0m and beyond. Why do this? There are far better and safer ways than using compressed air, in my opinion, yet many of us have done this in SCUBA and to greater depths, and some continue to do so.??What do you actually get? Very limited bottom times,??very?"narked-up" (Nitrogen Narcosis)?divers and the elevated risk of decompression illness. So why -50.0 m? It’s a nice round figure to use as a threshold, but it was also the maximum depth of the very early (1960’s) Southern North Sea Gas platforms when air and scuba were the only techniques available. My thoughts are that routine air diving operations should be limited to a more sensible -30.0m?with deeper depths only being considered as exceptional and with the correct controls in place? As I said earlier, there are alternatives. Safer alternatives.
• Air/Nitrox-TUP using an established DSV Sat bell and system. Eliminate that hazardous surface interval.
• Shallow saturation – Granted, not available to all, but another option that can be explored and implemented.
• Surface supplied free time Nitrox diving. Reduce that Nitrogen content and elevate the Oxygen within the accepted boundaries of 1.40 PPo2. It’s not without its own unique risks of Oxygen toxicity and critical depth management but still a useful alternative when supervised competently.
• Surface supplied mixed gas diving????Why do it ? Educate Clients to be safer and have better control of the work.
• Bell bounce mixed gas diving……….. Why do it?

I entered the commercial diving Industry at the end of 1976, I was 19 years old and poorly trained, I have been involved?in much of the above because that’s the way we did it back then, that’s all we knew and we did as we were instructed, but that can never make it right.

We know differently now, we are better now, but sadly many of the above are still being conducted due to industry best practice not being universally followed. Divers are still being harmed as a consequence.

It’s time to be better. Beyond time.?

Regulators, operators, contractors, trade associations, DTA?and?SME?providers, we all have a moral and ethical obligation to pro-actively prevent incidents. This has to be the way forward to ensure every diver makes it home safely at the end of their shift, back to their families, safe and well. It has got to be better than reactively reporting the impact of such incidents or having to tell a diver’s family that their loved one is?in hospital or not coming home at all.?

It's time to raise the safety bar

Archer Knight Diving Consultancy and Diving Technical Safety Services are?focused upon raising that diving safety bar.

Clients, Operators, Customers………. Do you have the correct and expected levels of diving operations competencies within your organisations ??To actually meet Regulatory compliance?

Archer Knight can provide Diving Technical Authority, Diving Responsible Person and Diving Subject Matter Expert support on an ad-hoc basis for as little as a few hours to a full season's support.

We can help manage your diving projects in a safe, sustainable, responsible and effective way.

We can review existing operators and diving safety management systems and recommend improvements.

We can become involved at any stage of a diving operation and provide elevated levels of guidance and expertise.

We can deliver,?simple, easy to follow, basic Diving Tutorials for client personnel supporting offshore diving operations but who may have limited knowledge and experience, these are modular and focus on the basic techniques in use today.

Commercial diving is not that complicated, it’s a way of getting to the worksite to perform a scope of work underwater. However, it must always be treated with the utmost??caution, respect, safety critical awareness, professionalism and diligence. Nothing less is acceptable.

If you have any uncertainties around your diving operations, whether its;

• Guidance.
• Techniques.
• Forthcoming Projects?
• ODDMR Support
• Regulations
• Best Practices.
• High Risk Operations
• Methodologies
• Procedural review
• HIRA/SRA Support
• Incident Investigation
• Refresh or revision of diving safety management systems
• Bespoke diving documentation
• Creation of Assurance, Lessons Learned processes.
• Tender/Bid submission technical evaluation?

If you would to discuss any element of diving operations, confidentially or commercially, feel free to get in touch with me directly at:

Derek Beddows???????[email protected]