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CODE OF PRACTICEOccupational diving in Western Australia

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Table of contentsForeword..................................................................................................................................5

1 Introduction....................................................................................................................81.1 Definition............................................................................................................................ 8

1.2 Overview............................................................................................................................ 9

2 Ensuring the safety and health of divers..................................................................102.1 Practicable safety measures............................................................................................10

2.2 Role of the employer........................................................................................................10

2.3 Role of the diving supervisor............................................................................................11

2.4 Role of the diver...............................................................................................................11

3 The core basics............................................................................................................123.1 Health and fitness.............................................................................................................12

3.2 Competence..................................................................................................................... 12

3.3 Induction........................................................................................................................... 14

3.4 Supervision.......................................................................................................................14

3.5 Dive plan.......................................................................................................................... 14

3.6 Dive log requirements.......................................................................................................16

3.7 Emergency management plan..........................................................................................17

3.8 Task-specific equipment...................................................................................................17

3.9 Required records..............................................................................................................17

3.10 High risk and confined space diving.................................................................................18

3.11 Hazard management........................................................................................................18

3.12 Fatigue............................................................................................................................. 18

4 Risk management process for diving........................................................................204.1 Hazard identification.........................................................................................................20

4.2 Risk assessment..............................................................................................................21

4.3 Risk control.......................................................................................................................22

4.4 Monitor and review control measures...............................................................................23

4.5 Air quality.......................................................................................................................... 23

4.6 Maintenance of equipment...............................................................................................24

5 Emergency management............................................................................................265.1 Emergency management plan..........................................................................................26

DRAFT CoP – Occupational diving in Western Australia A31508549 Page | 2

6 Industry-specific considerations...............................................................................276.1 Pearling............................................................................................................................ 27

6.2 Abalone............................................................................................................................ 27

6.3 Scientific diving................................................................................................................. 27

6.4 Others............................................................................................................................... 27

Appendix 1: Diving risk management tool.........................................................................33

Appendix 2: Diver medicals.................................................................................................37

Appendix 3: Glossary of abbreviations and terms used in this code..............................38

Appendix 4: Legislative framework for occupational safety and health.........................39

Appendix 5: Other sources of information.........................................................................40


DisclaimerThe information contained in this publication is provided in good faith and believed to be reliable and accurate at the time of publication. However, the information is provided on the basis that the reader will be solely responsible for assessing the information and its veracity and usefulness.

The State shall in no way be liable, in negligence or howsoever, for any loss sustained or incurred by anyone relying on the information, even if such information is or turns out to be wrong, incomplete, out-of-date or misleading.

In this disclaimer:

State means the State of Western Australia and includes every Minister, agent, agency, department, statutory body corporate and instrumentality thereof and each employee or agent of any of them.

Information includes information, data, representations, advice, statements and opinions, expressly or implied set out in this publication.

Loss includes loss, damage, liability, cost, expense, illness and injury (including death).

ReferenceThe recommended reference for this publication is:

Commission for Occupational Safety and Health, 2020, Occupational diving in Western Australia — code of practice: Department of Mines, Industry Regulation and Safety, Western Australia, XX pp.

ISBN (paperback)

(web)

The Department of Mines, Industry Regulation and Safety supports and encourages the dissemination and exchange of its information. The copyright in this publication is licensed under a Creative Commons Attribution 4.0 (CC BY) licence.

Under this licence, you are free, without having to seek our permission, to use this publication in accordance with the licence terms.

We also request that you observe and retain any copyright or related notices that may accompany this material as part of the attribution. This is also a requirement of the Creative Commons Licences.

For more information on this licence, visit creativecommons.org/licenses/by/4.0/legalcode

This publication can be available on request in other formats for people with special needs.

Further details of safety publications can be obtained by contacting:

Safety CommunicationsDepartment of Mines, Industry Regulation and Safety100 Plain StreetEAST PERTH WA 6004

Telephone: +61 8 9358 8154NRS: 13 36 77Email: [email protected]


Foreword This code of practice is issued by the Commission for Occupational Safety and Health (the Commission) under the Occupational Safety and Health Act 1984 (the OSH Act). The Commission’s objective is to promote comprehensive and practical preventive strategies that improve the working environment of Western Australians.

To develop this code of practice, the Commission was advised by the Occupational Diving Working Party, a tripartite group consisting of representatives from the Maritime Union of Australia, The University of Western Australia, the Department of Primary Industries and Regional Development, UnionsWA and the Chamber of Commerce and Industry of WA (CCIWA).

The Working Party membership being:

Darren Kavanagh WorkSafe Commissioner and Chair

Owen Whittle representing UnionsWA

Jack McCabe representing UnionsWA

Aaron Irving representing CCIWA

Arnold Piccoli representing CCIWA

David Passmore Divesafe

Warren Star University of Western Australia

Anthony Hart Department of Primary Industries and Regional Development

Assistance was also provided by the Australian Defence Force.

Scope and application of this code On [insert date], the Minister for Industrial Relations approved this code under section 57 of the OSH Act.

This code provides general guidance for occupational divers in Western Australia on the management of occupational safety and health issues relevant to preparing for and performing tasks while submerged in a fluid using artificially supplied compressed gas. The guidance provided by this code is not limited to workers who primarily perform diving work. Regardless of your job title, or the main duties of your job, this code applies to you if any part of your employment consists of diving work.

While elements of this code are relevant to all forms of diving work in Western Australia, workers who perform construction work underwater are required to comply with the AS/NZS 2299.1:2015 Occupational diving operations – Standard operational practice (the diving standard). Other Australian and international standards applicable to the type of diving work to be performed may also contain information about the control measures that are practicable to ensure the safety of divers.

The information in this code is broadly applicable to all forms of occupational diving work. Separate guidance material will be made available for specific tasks and industries.


The OSH Act does not apply to some workplaces in Western Australia and divers will need to contact the appropriate regulators for guidance. Examples include:

Category RegulatorDiving on a mine Mines Safety Directorate, Department of Mines,

Industry Regulation and Safety (DMIRS)Diving from an offshore drilling rig National Offshore Petroleum Safety and

Environmental Management Authority (NOPSEMA)

Diving from a vessel within the federal jurisdiction

Australian Marine Safety Authority (AMSA)

Diving on Commonwealth facilities Comcare

General duty of care

Section 19 of the OSH Act – Duties of employers

The employer's general duty of care obligations for safety and health under the OSH Act include:

providing a safe workplace and system of work, as far as practicable, so divers are not exposed to hazards

providing divers with information, instruction, training and supervision to enable them to work in a safe manner

consulting and co-operating with divers and safety and health representatives (where they exist) in matters related to safety and health at work

where it is not practicable to avoid hazards at the workplace, providing divers with adequate personal protective clothing and equipment.

Section 20 of the OSH Act – Duties of employees [workers]

Where divers are employees [workers], they must:

take reasonable care to ensure their own safety and health at work and that of others who may be affected by their work

use protective clothing and equipment in the way they have been instructed

report hazards

cooperate with their employer on safety and health matters.


Section 23D of the OSH Act – Contract work arrangements

People who engage contractors and their workers, who hire labour or have a labour hire arrangement, have the above-mentioned responsibilities of an employer towards their workers in relation to matters over which they have the capacity to have control. Divers in these arrangements have the above-mentioned duties of an employee.

In addition, under the OSH Act, a self-employed person must:

take reasonable care to ensure their own safety and health at work

ensure their work does not affect the safety and health of others.

People who have, to any extent, control of a workplace where people work must undertake measures to ensure hazards that could arise from the state of the workplace, are identified.

Who should use this code of practice? This code of practice has been developed by the Commission to assist all people and parties involved in occupational diving with duties under the OSH Act.


1 Introduction This code of practice was prepared by a joint working group comprised of members from across the diving industry in Western Australia including abalone, defence, offshore, onshore, pearling and scientific.

Occupational diving work involves substantial hazards that require careful planning, preparation and training to be appropriately managed. Divers are usually working in an environment that requires compressed gas to be supplied by a breathing apparatus system.

Hazards that apply in other industries may also apply to diving work, such as fatigue, the use of equipment, poor visibility and biological hazards. In addition, divers must consider the potential for diving-related injuries including decompression illness, entanglement, entrapment and the risk that minor medical conditions may have a serious effect on a diver’s health.

The national model Work Health and Safety (WHS) Regulations (the model WHS Regulations) set out detailed requirements and prescribe procedural or administrative requirements for workplace health and safety in Australia. However, this code of practice provides practical guidance on achieving the standards of health and safety required under the occupational safety and health laws in Western Australia.

1.1 DefinitionOccupational diving is defined as performing work under water or in any other liquid, irrespective of whether or not diving is the principal function of that employment.

High risk diving work is defined as work carried out in or under water or any other liquid while breathing compressed gas, and which involves one or more of following:

construction work

testing, maintenance or repair work of a minor nature carried out in connection with a structure

inspection work carried out to determine if the above is necessary

the recovery or salvage of a large structure or item of plant for commercial purposes.

For example, a scientist who dives only three or four days each year, or a crewperson on a fishing boat who may occasionally don gear to free a fouled propeller, are both conducting occupational diving work.

Careful planning and preparation is required whenever occupational diving work is proposed and additional care may need to be taken if diving work is not done regularly.


1.2 OverviewThis code provides an overview of the risk management processes to be conducted for all types of diving work in relation to prevention of injuries. Every dive is different and specific industries and activities have their own challenges and hazards.

While there are systems of work issues to look at when eliminating and reducing the risks of diving, this code’s focus is on addressing general hazards common to occupational diving. Organisations should conduct hazard identification and risk assessments.

Reviewing current safe systems of work for diving is a good way to get started to ensure all hazards are addressed. A risk management tool is provided in Appendix 1 to assist with this process. Recommendations for controls to implement are in Section 4.3.

In broad terms, the hazards posed by occupational diving work can be divided into hazards that are:

specific to diving work (supply of compressed gas, decompression, fauna)

common to work more broadly (slips and trips, manual handling, guarding of machinery).

Divers and their employers are more likely to be familiar with planning for hazards directly associated with the dive and take appropriate precautions, but a risk assessment should also account for other hazards that are not directly associated with the dive. For example, clutter on the deck of a boat may delay divers preparing to conduct a rescue.


2 Ensuring the safety and health of divers

2.1 Practicable safety measuresThe general duty of care to ensure the safety and health of workers under the OSH Act is qualified by the words, as far as practicable. This means that the practicability of different control measures to implement during a dive must be considered and advances in technology and equipment taken into account.

Under the OSH Act, ‘practicable’ means ‘reasonably practicable’ taking into account:

the severity of any potential injury or harm that may occur and the degree of risk of that injury or harm occurring

how much is known about the risks and ways to eliminate, reduce or control them

the availability, suitability, reliability and cost of safeguards, which means taking into account whether new equipment, as it comes onto the market, is reasonably practicable.

To be practicable, something must be capable of being done, and reasonable in light of the above factors. Common practice and availability of information and knowledge throughout the industry are taken into account when judging whether a safeguard is reasonably practicable.

Section 19 of the OSH Act – Duties of employers

2.2 Role of the employerPeople with responsibilities for the safety and health of divers must ensure there are:

systematic risk management processes in place to address potential hazards and risks in relation to divers

safe systems of work in place to prevent incidents

effective emergency measures in place to minimise the risks of injury, harm or death if an incident occurs.

Important measures to ensure the safety and health of divers include:

providing a safe system of work for all tasks so divers are not exposed to unnecessary hazards, which takes into account any specific aspects of the dive and plans for changes in the environment

providing adequate inductions, information, instruction and training on safe working practices that address any hazards that cannot be eliminated and enable divers to work safely. This must include training and drills on emergencies

checking and maintaining essential machinery and equipment

providing fit-for-purpose equipment

providing adequate supervision according to each diver’s skills and experience, including direct supervision of divers working in an unfamiliar environment

consulting and co-operating with divers about hazards and risks they are aware of

implementing a procedure for identifying and reporting hazards, letting divers know about them and getting them addressed through the risk management process.


2.3 Role of the diving supervisorThe model WHS Regulations require one or more competent persons to be appointed to supervise diving work at a workplace.

The dive supervisor should directly supervise the work unless the risk assessment deems this to be unnecessary and other suitable controls are in place, such as the dive supervisor being accessible and another person, able to assist the diver in an emergency, is present.

2.4 Role of the diverDivers have a role to play in safety and health during every aspect of a dive. This includes:

ensuring they work safely and do not affect the safety and health of other divers

using protective clothing in the way they have been instructed

reporting situations that may be hazardous

cooperating on safety and health matters.

The benefit of consulting with divers and getting their involvement in the risk management process is that:

they know about risks with their work

they may see things with fresh eyes and be able to come up with newer and safer ways of doing things

it may help facilitate divers’ ownership of the safety measures put in place.


3 The core basicsEvery dive is different. Divers perform work ranging from aquaculture to salvage, in a broad range of depths and water conditions, and using a wide variety of equipment. Even routine dives may be faced with variable conditions, particularly in relation to tides and weather.

This code of practice is focussed on the concept of core basics, which sets out the safety standards that should be considered good practice for all types of occupational diving. Industry specific guidance material that provides additional information or industry standards should be adopted.

The core basics to be considered are below.

3.1 Health and fitnessEmployers should ensure that divers are medically fit to dive. A medical certificate provided by a doctor trained in diving or hyperbaric medicine should be required to establish medical fitness.

The fitness test should be undertaken to meet current requirements of the diving standard.

X-rays should be done at the physician’s discretion, or as required by industry.

A certificate of medical fitness should be issued by a registered medical practitioner with training in hyperbaric medicine. It is preferable the physician is registered with the South Pacific Underwater Medical Society. It is good practice for employers to retain copies of the medical certificate for the duration of the diver’s employment, or until the next medical review is conducted.

A suitably trained doctor should be able to advise how often a diver’s medical fitness should be reviewed. For divers who spend most of their time on compressed gas, medicals should be conducted at least annually, or after recovery from a diving incident; e.g. decompression illness (bends), salt water aspiration.

Standard checklists and forms for medical fitness are provided in Appendix 2.

Tests for general fitness should be required by the employer depending on the physical demands of the job, dive time and the needs of emergency response. At a minimum, employers should be assured the diver is able to swim a distance sufficient to reach the dive boat from the dive site. For example, the Australian Pearl Producers Association induction requires an entrant diver to swim 200 metres in less than four minutes without dive equipment.

The nature and timing of fitness activities should be determined by diving officers or appropriately experienced managers, in consultation with divers and other workers.

3.2 Competence

Section 19.1(b) of the OSH Act – Duties of employers – trainingThe general duty of care of the OSH Act requires employers to ensure that workers are provided with information, instruction and training to enable them to perform their work in such a manner that they are not exposed to hazards.

Employers should determine the level of training required before a diver is able to commence their assigned tasks. This may involve a combination of pre-employment training, mandatory skills and experience in specified environments and workplace induction.

Experienced divers in the organisation, particularly those with experience as dive supervisors, should be involved in developing these requirements for an organisation.


TrainingIt is recommended that a person carrying out any type of general diving work holds a certificate for general diving work, issued by a training organisation that demonstrates that the person has acquired the relevant competencies for that type of general diving work. Training needs to be suitable to a divers’ role (e.g. diver, rescue diver, dive leader, dive controller or supervisor).

The AS/NZS 2815 Training and certification of occupational divers series specifies the relevant competencies for general diving work. The standards detail the competency and training requirements to achieve certification as an occupational diver and supervisor, and the scope covers diving from scuba through to saturation diving and diving supervision for onshore diving.

Conversion from recreational to commercial diverRecreational diving courses are readily available in Western Australia and are the usual gateway for workers who decide to make a career out of diving. However, recreational diving courses alone may not provide a sufficient level of competency to commence work as an occupational diver. After considering the hazards and risks involved in a particular diving environment, employers may also consider more advanced diver training as a pre-requisite.

The following courses or their equivalents, provided by a training organisation, may comply with the general duty of care to ensure the minimum level of training for occupational divers:

Professional Association of Diving Instructors (PADI) Rescue Diver, Dive Master or Dive Instructor

National Association of Underwater Instructors (NAUI) Rescue equivalent, Dive master equivalent, or Dive Instructor

Scuba Schools International (SSI) Rescue equivalent, Dive master equivalent, or Dive Instructor

other equivalent underwater diver certification programs.

Knowledge A diver’s knowledge can be divided into two categories:

pre-employment knowledge

The technical knowledge needed to perform any dive safely, gained from pre-employment training and experience.

For example: general diving physics and physiology

how to plan a dive (using dive tables and/or computers)

following task-specific instruction

provision of oxygen

diving emergency and rescue procedures and planning, including first aid and incident reporting

ways of communicating with another diver and with the surface typical to that dive plan they are operating under

gas mixes and or air quality requirements and how to assess these

general familiarity with dive equipment to be used

underwater tools and equipment.

On-the-job training

Knowledge specific to the type of work to be conducted in a dive, gained through induction, training or previous experience.

For example:

refresher specifics


using dive tables specific to the intended dive

understanding industry-specific dive plans and logs, including how to make amendments when required

specifics of emergency plan, including diver rescue/recovery plan

task specifics

equipment specifics – hazards, control measures

dive site and or/dive platform specifics

pre-diver checks (person and equipment)

equipment pre-check

industry or site specific signals and communication.

3.3 InductionRegardless of pre-employment training requirements, employers are also required to ensure divers receive induction appropriate to the work tasks required, the environment in which diving is likely to be conducted and the type of equipment to be used. Fitness training may also be incorporated into induction training, particularly where the physical demands of a particular task require it.

Induction of inexperienced divers should be included in the dive plan and diving procedure manuals, and are an ideal opportunity for all divers to refresh their knowledge of, and practice, rescue drills.

3.4 SupervisionIt is important that diver induction culminates in directly supervised diving in an operational environment. Supervision should be provided by a certified dive supervisor suitably experienced in the type and style of diving being undertaken.

Dive supervisors, and divers tasked with conducting rescue operations, should be required to have higher standards or training and experience than other divers.

The appropriate level of experience can be denoted as minimum hours, or a minimum number of dives, both for pre-employment experience and to qualify to dive without direct supervision. Acceptable levels of experience should be documented as part of the workplace safe systems of work and logged. Formal sign-off, by the dive supervisor or other specified senior diver, should be included in the induction process and documented.

3.5 Dive planA dive plan is developed by the dive supervisor in discussion with workers prior to any diving work commencing. Plans can be reused for similar dives.

The diving work should be conducted in accordance with the dive plan.

Dive planning should be conducted with one overarching goal in mind:

Divers should be safe and confident of rescue.


The dive plan should set out how the general diving work will be undertaken, including arrangements to ensure workers’ health and safety. At a minimum, the dive plan should state:

a) the method of carrying out the diving work

b) the tasks and duties of persons involved in the diving work

c) the diving equipment, breathing gasses and procedures to be used in the diving work

d) estimated dive time, bottom times, and decompression profiles

e) known hazards for the diving work and measures to control the risks associated with them

f) emergency procedures (refer to Chapter 5 – Emergency Management).

Communication1

All divers in the water require a communication system that allows direct contact with the supervisor on the surface.

All such communications should be detailed in the dive plan, recorded and the recording kept until 48 hours after the diver has returned to the surface or the saturation living chamber.

All divers in the water should have a communication system that allows direct voice contact with the supervisor on the surface and vice versa.

A hard-wired communication system is preferred because the effectiveness of a through-water communication system can be degraded by acoustic shadow, sediment, air bubbles, turbulence, etc. Practical testing of the equipment in the operational location is recommended in order to ensure its effectiveness.

There are benefits to recording such communications and keeping the recording until the dive is successfully completed. For example, if an incident occurs during the dive, the recording may help in any subsequent investigation.

1 Source: Health and Safety Executive, Diving at Work Regulations 1997, Approved Codes of Practice: Commercial diving projects offshore http://www.hse.gov.uk/pUbns/priced/l103.pdf andCommercial diving projects inland/inshore http://www.hse.gov.uk/pubns/books/l104.htm


http://www.hse.gov.uk/pubns/books/l104.htm

http://www.hse.gov.uk/pUbns/priced/l103.pdf

Planning shall include current dive plan. Minimum inclusions:

dive team – personnel requirement

gas mix to be used

individual diver profile2 calculated with consistently used tables:

- the majority of industries use US Navy or Defense and Civil Institute of Environmental Medicine (Canada) (DCIEM). However, others, such as the Australian Pearl Producers Association, use their own.

many commercial operators now use computers for repetitive diving, as tables are not particularly suitable for multiple dives per day because of their bucket or square profile assumptions and increasing risk of errors in calculating bottom time manually.

a copy of tables used – needed to perform recalculations

description of the operation or task intended

risk assessment reviewed as per good practice, including:

review of outcomes and control measures which affect work site task planning and requirements, including additional diver skills and qualifications

minimum safety equipment (i.e. oxygen kit, dive flag, viable means of communication, etc.)

site specific emergency response/rescue details/procedures

standard emergency procedures for a specific dive platform are used with variety of tasks

final on-site risk assessment inclusive of environmental conditions affecting the ability to perform the required task and emergency response capabilities.

3.6 Dive log requirementsWhere general diving work is carried out, a dive safety log should be developed and maintained as this is often considered an important piece of evidence in the event of an investigation. This may be a paper record or a computer printout.

The dive log should contain the following information about each dive carried out by a worker:

a) the name of the worker who carries out the dive

b) the name of any other person with whom the dive is carried out

c) the name of the competent person appointed to supervise the diving work

d) the date and location of the dive

e) task undertaken

f) the time each diver enters and leaves the water

g) the maximum depth of the dive

h) any incident, difficulty, discomfort or injury that occurs or is experienced during the dive

i) if the dive was carried out using a dive computer – the dive time

a) if the dive was carried out using dive tables – the repetitive dive group, if available, and either the bottom time or the dive time

2 Notes on dive profile to consider pre-calculated maximum profiles (taking into account successive or repetitive days, diving distance from chamber, etc.). A consistent table or algorithm should be used for that organisation. The majority of occupational diving is with DCIEM. A variety of tables are used within Western Australia, such as in the pearling industry which has its own oxygen decompression tables. Sometimes a PADI table is referenced or mixed gas tech tables are used.


b) if the repetitive group and surface interval result in a repetitive factor (either RNT or RAT) – the surface interval and the repetitive factor

c) if the dive is carried out using enriched air nitrox (EANx):(i) the oxygen content of the EANx(ii) the maximum operating depth of the EANx

d) if the dive is carried out using mixed gas:(i) the oxygen content and the nitrogen content (if any) of the gas(ii) the maximum operating depth of the mixed gas(iii) the minimum operating depth of the bottom mix.

3.7 Emergency management planAn emergency management plan is required and should be implemented to ensure there is appropriate response in event of an incident.

Details of an emergency management plan can be found in Chapter 5.

This record may assist in future work-related illness claims.

3.8 Task-specific equipment Employers and those who have control over work equipment have responsibilities for providing equipment for use at work. This includes:

task-specific or fit-for-purpose equipment to undertake the task, accounting for the type and style of operation

redundancy or critical equipment (e.g. air supply)

emergency equipment appropriate to the of emergency plan and location of dive site.

3.9 Required recordsIt is good practice to keep a copy of:

each risk assessment until the work to which it relates is completed

the dive plan until the work to which it relates is completed.

However, if an incident occurs in connection with the work to which the assessment or dive plan relates, the assessment or dive plan (as applicable) should be kept after the incident occurs.

The risk assessment and dive plan should also be available for inspection, if required.


Catch and disposal RecordsAbalone divers record information on catch and disposal records (CDR), including dive times and number of dives in the Department of Primary Industries and Regional Development’s Fish Eye Online Services. However, CDRs do not meet the dive log requirements.

Fish Eye and the mobile application CatchER (rock lobster only) allows secure transactions making it quicker and easier to submit trip returns and catch data.

For more details, visit: http://www.fish.wa.gov.au/Fishing-and-Aquaculture/Commercial-Fishing/Fish-Eye/Pages/default.aspx

http://www.fish.wa.gov.au/Fishing-and-Aquaculture/Commercial-Fishing/Fish-Eye/Pages/default.aspx

http://www.fish.wa.gov.au/Fishing-and-Aquaculture/Commercial-Fishing/Fish-Eye/Pages/default.aspx

3.10 High risk and confined space divingHigh risk diving work is defined in the model WHS Regulations as work carried out underwater or in any other liquid while breathing compressed gas, which involves any of the following activities:

construction work

maintenance, testing or repair of a structure3

inspection worked carried out to determine whether the above listed work is necessary

recovery or salvage of a large structure or plant for commercial purposes.

The high risk diving work definition excludes minor work that involves cleaning, inspecting, maintaining or searching for a vessel or mooring in the sea, a bay or inlet or at a marina.

Where high risk diving work is carried out, the person conducting the business is to ensure that the following are in accordance with the diving standard:

a) fitness of persons carrying out the work

b) competence of persons carrying out the work

c) carrying out of the work.

3.11 Hazard managementIn managing risks to the health and safety of occupational divers, reasonably foreseeable hazards that could give rise to those risks need to be identified.

More detail is contained in section 4.1.

3.12 Fatigue

What is fatigueFatigue is more than feeling tired and drowsy. In a work context, fatigue is a state of mental or physical exhaustion (or both) that reduces a person’s ability to perform work safely and effectively. It may result from prolonged or intense mental or physical activity, sleep loss or extended wakefulness, or disruption of a person’s circadian rhythms.

Causes of fatigueCauses of fatigue can be work related, personal or a combination of both. They can also be short term or accumulate over time. Causes of fatigue include:

prolonged or intense mental or physical activity

sleep loss and/or disruption of your internal body clock

organisational change

exceptionally hot or cold working environments

work scheduling

not enough time to recover between shifts

strenuous jobs

long commuting times.

3 Structure has the same meaning as it has in section 290, Part 6.1 of the model WHS Regulations.


Who is responsible for fatigueThe duty is on employers to manage risks from fatigue. A planned and systematic approach to assessing and managing the risks associated with fatigue can improve the health and safety of workers. Employers should conduct a risk assessment that takes into account the fatigue risk factors relevant to their operation and develop a fatigue management plan.

Fatigue management plansThe risk management guidelines that accompany the Commission’s code of practice on working hours may be useful when assessing the hazard factors and risks to be addressed in the fatigue management plan. The Code of practice: Working hours (2006)4 suggests that:

Certain working hours arrangements have been linked to occupational safety and health risks, such as fatigue and impaired performance, and increased exposure to some hazards.

As with other occupational safety and health issues, employers have a general ‘duty of care’ obligation to ensure that, as far as practicable, employees are not exposed to hazards and risks that could arise from their working hours arrangements and to address them through a systematic risk management process.

If the risk is high, a fatigue management plan may be developed and should aim to maintain alertness and guard against fatigue. It should be based on a risk assessment for the operation and consider all employees, including contractors.

A generic risk assessment may be completed for similar work groups where the risk factors are the same. However, employers should ensure the assessment is valid for all workers within each work group.

4 The Code of practice: Working hours can be accessed at https://www.commerce.wa.gov.au/sites/default/files/atoms/files/copworkinghours.pdf


https://www.commerce.wa.gov.au/sites/default/files/atoms/files/copworkinghours.pdf

4 Risk management process for divingDiving has an inherently unpredictable nature and risk management processes need to be robust enough to handle the hazards.

The risk management process to address safety and health in relation to occupational divers involves the following processes:

1. identifying hazards

2. assessing risks of injury or harm arising from each identified hazard

3. implementing control measures to eliminate or reduce the risks

4. monitoring and reviewing control measures.

The risk management process should be conducted and monitored on an ongoing basis to ensure control measures are working as intended and no new hazards have been introduced when, for example, equipment or tasks change.

4.1 Hazard identification The first step in the risk management process is identifying hazards relevant to the prevention of incidents and injuries in occupational diving. This involves identifying anything that may cause an injury or incident or increase the risk of injury, harm or death, if it occurs.

Choosing appropriate processes or procedures for identifying hazards will depend on their nature and the work environment.

Hazard identification procedures may include:

using the list of hazards in the diving risk management tool in Appendix 1 of this code to consider potential hazards or developing your own hazard checklist

listing all the tasks and work activities carried out and breaking them down into a sequence of steps so that it is easier to spot hazards

looking at the ways in which different tasks and work activities may interact to cause a hazard

looking at previous incidents to identify causes or common factors

collecting relevant information by consulting with divers, contractors and boat crews

talking to industry associations and similar businesses.

Potential diving hazardsDiving work takes places in a broad range of environments, using a variety of equipment, by divers with varied levels of fitness, varied experience and varied training. Environmental factors, including changes in weather, tides and bottom structure, ensure that many dives are different. Even experienced divers may become complacent when dives are considered routine. Dive safety requires a conscientious effort by all involved. All dives require planning and thoughtful approach to safety.

The following need to be considered when planning a dive:

environment

equipment

people

practice.


4.2 Risk assessment The second step in the risk management process is assessing the risks from the hazards identified for the specific circumstance of each dive in relation to divers.

To carry out a basic risk assessment:

gather information about each hazard identified in step one

work out the chance or likelihood of an injury from each hazard (i.e. the consequences). Different situations and conditions that could increase risk will need to be taken into account

rate the risk – use the appropriate risk rating table to work out the risk associated with each hazard.

Lack of air supply and decompression sickness are risks most commonly associated with diving and should be viewed as an extreme risk, given that these incidents may lead to serious injury or a diver’s death.

Take a holistic approach – that is, look at all the risks and whether there is an inter-relationship. It is important to recognise that risks should not be considered in isolation as an inter-relationship between them may increase the risks (e.g. colliding with equipment may result in incapacity and subsequent risk of drowning).

Risk assessment is a best estimate on the basis of available information. It is important the responsible person undertaking a risk assessment has the necessary information, knowledge and experience of the work environment and work process, or such a person is involved. It is equally important that divers are consulted as they may be able to provide advice on the hazards and risks with different work activities.

When the risk assessment is completed, hazards requiring control measures should have been identified.

Appendix 1 provides examples of risk assessment tools.


4.3 Risk control The third step in the risk management process is to implement control measures to eliminate or reduce the risks of injury should an incident occur. The controls selected should aim to achieve the desired safety outcome.

There is a recommended order for control measures to implement on a dive, ranging from the most effective to the least effective, to eliminate or reduce the risks of injury, harm or death. This is outlined in the following hierarchy of control table.

Table 1 Hierarchy of control

The hierarchy of controls is an effective approach for minimising risks in all types of working environments. However, diving work, by its very nature, begins with the use of personal protective equipment (diving gear, breathing apparatus). In the context of traditional control measures, diving already begins with the use of what is traditionally considered the least effective means of controlling the risk.

What does this mean for diving work?In the traditional hierarchy, eliminating the hazard should be considered before all other controls. However, for the purpose of this code it is presumed that all other control measures have been considered, and a determination has been made the most practicable approach is to use a diver.

A combination of control measures should be considered to minimise the risks to divers. However, it is important to also consider how these control measures interact, to ensure they are effective in all circumstances, do not create otherwise unforeseen hazards, or complicate activities such as rescue operations. Multiple control measures can be seen as layers of defence against hazards but these layers may be imperfect.


Implementing control measuresWhen implementing control measures for diving work, both for the prevention of incidents and responses to them:

consider a combination of control measures, as often this will be appropriate

assess whether a control measure may introduce new risks

take a holistic approach. For example, a potential hazard may not necessarily require a single matching control measure. A response could be to implement a control measure that addresses a number of potential hazards

consult with divers about hazards, risk and controls, as they are most likely to know about risks and may be able to come up with alternative ways of doing things

look at new and different ways of doing things and assess their practicality. This might include using a small boat to recover divers to minimise interaction with propellers, and to facilitate rescue.

Use of personal protective equipment (PPE)The use of PPE is the lowest control measure as defined in the Hierarchy of Control table, but is often the most appropriate for occupational divers. PPE includes:

dive equipment

breathing apparatus

protection equipment specific for the activity to be undertaken.

4.4 Monitor and review control measuresConstantly monitor and review the control measures to ensure they continue to prevent or control exposure to hazards and are not introducing new hazards or risks.

In determining the frequency of the monitoring and review processes, consider:

the level of risk – high risk hazards will need more frequent assessments

the type of diving operation and task involved

further review of control measures when new work practices, tasks, equipment or procedures are introduced, the environment changes, or there is any indication risks are not being controlled.

4.5 Air quality5

Breathing gases for divers must not be contaminated. Even small amounts of contamination can affect divers and the effects of most contaminants increase with the depth of the dive. Possible contaminants include carbon monoxide and oil.

Contaminants can cause a range of injuries and illness including convulsions, loss of consciousness and death.

Compressor systems must be correctly designed, installed and operated to minimise risks of contamination. Gases must be regularly tested to monitor contaminant levels and a current test certificate should be available for each compressor.

Air is primarily composed of oxygen and nitrogen. Even these gases can have serious effects on a diver's health when breathed at depth. See below for more information about the effects of nitrogen.

5 Source: WorkSafe Queensland, Diving injury and illnesshttps://www.worksafe.qld.gov.au/diving-snorkelling/diving-and-snorkelling-hazards/injury-and-illness#con

More information on the required breathing gases in relation to air quality can be accessed from AS/NZS 2299.1:2015 Occupational diving operations – Standard operational practice.


https://www.worksafe.qld.gov.au/diving-snorkelling/diving-and-snorkelling-hazards/injury-and-illness#con

https://infostore.saiglobal.com/en-au/Standards/AS-NZS-2299-1-2015-101071_SAIG_AS_AS_212351/

https://infostore.saiglobal.com/en-au/Standards/AS-NZS-2299-1-2015-101071_SAIG_AS_AS_212351/

Nitrogen narcosisNitrogen narcosis can result from breathing nitrogen under pressure. It acts like a drug and affects individuals differently. Nitrogen narcosis affects reasoning, judgement, memory, perception, concentration and coordination. It may lead to over confidence, anxiety or panic. Survival instincts and responses may be suppressed. If the dive is uneventful, the narcotic effects of nitrogen narcosis may not be evident. A diver failing to follow instructions or the dive plan, or being inattentive to buoyancy, air supply or buddy signals may be suffering from nitrogen narcosis.

Diving on air at or beyond 30 metres significantly increases the risk of nitrogen narcosis. Nitrogen narcosis can develop when diving in shallower depths, but is less likely to be evident; that is, a diver may not be aware that he or she is affected by nitrogen narcosis and/or it may not be evident to an observer. Safe diving beyond 30 metres requires an awareness of the increasing risk of this condition and its symptoms, and the practices required to reduce the symptoms and the associated likelihood of an accident. Nitrogen narcosis is directly related to diving at depths and diminishes as a diver ascends to shallower water. If a diver begins to be affected by nitrogen narcosis, then immediate ascent to shallower depths, taking into account decompression requirements, is required.

Factors known to increase the effects of nitrogen narcosis include:

fatigue or heavy work

anxiety, inexperience or apprehension

the diver feeling cold

poor visibility

carbon dioxide excess

recent alcohol intake or use of sedative drugs including sea sickness medications or marijuana.

4.6 Maintenance of equipment6

Ensure that diving plant is maintained in a safe working condition.

Diving plant can be used under extreme conditions, including frequent immersion in salt water. It should therefore be maintained, examined and tested regularly. It should be inspected immediately before use by a competent person to ensure that it is not damaged or suffering from deterioration.

Planned maintenance system The employer or the contractor should establish a system of planned maintenance for plant. Maintenance arrangements should take into account both passage of time and usage. Details of the maintenance arrangements should be entered in the diving project plan. The arrangements should identify the item of plant, the date of the check, any limitations as to use, any repairs or modifications carried out and the name of the competent person.

A plant register should be maintained at the worksite with copies of all relevant certificates of examination and tests. It should contain any relevant additional information; for example, details of the materials used to construct diving bells and compression chambers. It should also contain any details of any design limitations for use; for example, maximum weather conditions, if applicable.

Periodic examination, testing and certification The frequency and extent of examination and testing required for all items of plant used in a diving project should be based on the manufacturer’s recommendations and be in accordance with the appropriate statutory provisions, and the appropriate national, European or international standards.

6 Source: Health and Safety Executive, Commercial diving projects offshore. Diving at Work Regulations 1997. Approved Code of Practice http://www.hse.gov.uk/pUbns/priced/l103.pdf


http://www.hse.gov.uk/pUbns/priced/l103.pdf

Pre-dive visual inspectionThe dive team should carry out a pre-dive visual inspection and check the plant that they are to use to ensure that it is in serviceable condition and working.


5 Emergency management Hazard identification and risk assessment are important elements to minimise the risks to divers and appropriate efforts should be made to ensure safe systems of work are in place to prevent accidents and injuries. However, every dive should be planned with contingencies in place to deal with an emergency.

Hazards that can interfere with an effective emergency response include:

inappropriate emergency plans, systems and procedures

lack of emergency equipment (e.g. suitable first aid kit recovery equipment), inadequate checks and maintenance of emergency systems and equipment

lack of appropriate induction and training on emergency procedures and equipment

lack of or inappropriate first aid equipment

lack of competent people to perform rescue or recovery.

When looking at hazards, consider whether a combination of them may increase the risks of injury and/or an inadequate response if an incident occurs.

5.1 Emergency management planPersons conducting a diving operation must ensure that they are prepared for emergency situations. Written emergency management plans should be developed, kept on site and workers should be trained in their application. As a minimum the plans should cover:

first aid, oxygen and automatic external defibrillators

rescue

evacuation

missing persons.

In addition, other plans should be developed if required. For example, a plan for emergency recompression might be developed for decompression stop diving at a work site.

Consideration should be given to:

availability of transportation

availability of recompression facilities

location and isolation from emergency response services.

Information should be detailed, such as:

training in emergency retrieval of a driver

presence of suitable equipment and personnel

emergency signalling.


6 Industry-specific considerations

The Commission for Occupational Safety and Health is seeking input from industry stakeholders to complete this section

6.1 Pearling

6.2 Abalone

6.3 Scientific diving

6.4 Others


Appendix 1: Diving risk management tool

Job step Hazard event Cause Consequence Barriers / prevention / controls

Initial risk ranking

Consequence Likelihood Risk

Diving Operations

Entry/exit methods

Injury during entry or exit or inability to exit

Risk of injury

- Dive plan and SOP for beach/vessel entry/exit points and technique

- Dive brief for beach entry/exit and contingencies for weather change/emergencies

- Staff fitness standard

Minor Likely Medium

Diving Operations

Sufficient training

Insufficient training Risk of injury

- Minimum standard of training as per Diving Procedure Manual- Additional training shall be provided (e.g. EANx, Airlifting, etc.) if

required for diving operationsModerate Unlikely Medium

Diving Operations Airlifting Insufficient/no

training Risk of injury

- Airlifting training shall be provided to staff who require the use of lift bags during diving operations

- Annual training- Pre-dive staff briefs

Moderate Likely High

Diving Operations

Pneumatic tools

Insufficient/no training Risk of injury

- Pneumatic drilling only to be carried out by highly experienced (Mollusc Section) and/or ADAS trained staff

- Dive plans and SOPS to be completed.- Pre-dive staff briefs- Alternate air source to diver for all pneumatic tool use

Moderate Unlikely Medium

Diving Operations HP jetting Insufficient/no

training Risk of injury

- Pressure jetting only to be carried out by highly experienced (Mollusc Section) and/or ADAS trained staff

- Dive Plans and SOPS to be completed- Pre-dive staff briefs- No staff to be in-water during pressure jetting; i.e. when the water

is ‘on’

Major Unlikely High

Contd/-

The following table illustrates the use of risk management tools in identifying hazard factors, assessing the risks and implementing control measures for occupational diving activities. Each organisation should take a holistic approach to developing its own risk assessment tools and subject them to continuous monitoring and periodic reviews to ensure they account for changes, such as to the internal and external risk environment, legislative and regulatory changes, and changes to organisational objectives.

Job step Hazard event Cause Consequence Barriers / prevention / controls

Initial risk ranking

Consequence Likelihood Risk

Diving Operations

Diver propulsion systems

(scooters)

No/ Insufficient training or misuse of underwater scooters

Risk of sinus injury/ barotrauma/DCI

- Dive plan and equipment manual familiarity by divers- Training with experienced dive supervisors- Pre-dive briefs- Vigilance of depth profile and ascent rates by staff using scooters

Moderate Likely High

Diving Operations

Search patterns

Insufficient training or reduced visibility

Risk of over exertion/getting lost/excessive air consumption

- Annual training.- Pre-dive staff briefs.- Abort search if diver loses effective ability to conduct search

pattern.

Insignificant Likely Low

Diving Operations Dive profiles

Reverse profiles

Bounce diving

Quick ascents

Risk of injury/ Barotrauma/DCI

- Dive supervisor to ensure deeper dives conducted earlier each day- Staff to avoid bounce diving- All staff to observe and adhere to dive computer ascent rates Major Likely Extreme

Diving Operations

Personnel equipment failure

Faulty/ damaged equipment

Increased dive accident risk – i.e. rapid ascent, out of air emergency

- Regular equipment maintenance- Proper handling and storage- Pre-dive equipment checks Moderate Unlikely Medium

Diving Operations

SSBA machinery failure

Hookah stopsIncreased risk of out of air emergency

- Regular machinery checks (checklist) form and service- Redundancy (personnel bailout cylinders AND 95 c f backup on

board air reservoir- Comprehensive staff recall system

Moderate Unlikely Medium


Risk rating matrix – example only

Risk rating table

Risk – Likelihood of occurrence

Hazard – Severity of consequence

5 4 3 2 1

5 25 (Extreme)

20 (Extreme)

15 (High) 10 (High) 5 (Medium)

4 20 (Extreme)

16 (High) 12 (High) 8 (Medium) 4 (Medium)

3 15 (High) 12 (High) 9 (Medium) 6 (Medium) 3 (Low)

2 10 (High) 8 (Medium) 6 (Medium) 4 (Medium) 2 (Low)

1 5 (Medium) 4 (Medium) 3 (Low) 2 (Low) 1 (Low)


Note:

No diving is to be undertaken if the risk rating falls in the areas shaded orange and red (risk rating ≥10) until appropriate control measures are introduced to lower the risk.

For further advice when developing risk management frameworks and programs, refer to AS ISO 31000:2018 Risk Management – Guidelines.

The following are examples of hazards that may need to be considered when planning a dive.

Environment

water depth, visibility and flow

tidal movement

weather and wave action

proximity of rocks and wrecks

local fauna (sharks, jellyfish)

water temperature.

Equipment

type of breathing gear to be used (including air quality)

entanglement hazards (posed by nets, tools)

unguarded propellers

maintenance and repair.

People

inexperienced or new divers

alcohol and other drugs

ability to swim the required distances

physical demands of work

crew skill and experience.

Practice

insufficient training on safe work practices

inadequate supervision

physicality or duration of task leading to risks associated with fatigue.


Appendix 2: Diver medicals

The Commission has provisionally proposed the use of the use of the fitness forms accompanying AS/NZS 2299. Stakeholders are encouraged to provide alternative examples that might form part of this code of practice.


Appendix 3: Glossary of abbreviations and terms used in this codeDirect supervision — The Commission for Occupational Safety and Health is seeking industry input into this definitionDive Plan — describes how a dive will be carried out, including the work to be carried out, the method and tasks to carry out the work, the equipment and dive profile, potential hazards and risks, and emergency procedures to be followed.

Diving supervisor — the diving team member who is directly responsible for the diving operation's safety and management of any incidents or accidents that may occur during the operation. The supervisor must be available at the control point of the diving operation for the diving operation's duration, to manage the planned dive and any contingencies that may occur.

Enriched air nitrox (EAN) — refers to any nitrogen/oxygen gas mixture with an oxygen concentration higher than the 21 percent found in normal air – 32 per cent oxygen is the most common.

Hazard — a hazard is something that can cause harm.

High risk diving work — work carried out underwater or in any other liquid while breathing compressed gas, which involves construction work, maintenance, testing or repair, inspection work, or recovery or salvage for commercial purposes.

General diving work — means work carried out in or under water while breathing compressed gas, and includes:

a. incidental diving work

b. limited scientific diving work

but does not include high risk diving work.

RAT — residual accumulated time.

Reasonably practicable — that which is, or was at a particular time, reasonably able to be done to ensure health and safety, taking into account and weighing up all relevant matters including the likelihood of the hazard or the risk concerned occurring (SafeWork Australia).

Recreational Diver — or sport diving is diving for the purpose of leisure and enjoyment using scuba equipment, snorkelling or free diving.

Risk — a risk is the chance that a hazard will actually cause someone harm.

RNT — residual nitrogen time.


Appendix 4: Legislative framework for occupational safety and health

Occupational Safety and Health Act 1984 (the OSH Act) The OSH Act provides for the promotion, co-ordination, administration and enforcement of occupational safety and health in Western Australia. It applies to all industries with the exception of mining and petroleum.

With the objective of preventing occupational injuries and diseases, the OSH Act places certain duties on employers, employees, self-employed people, manufacturers, designers, importers and suppliers. Principal contractors, contractors and those involved in labour hire and labour arrangements have the duties of an employer or employee, as applicable.

The broad duties established by the OSH Act are supported by a further tier of statute, commonly referred to as regulations, together with lower tiers of non-statutory codes of practice and guidance notes.

Occupational Safety and Health Regulations 1996 (OSH Regulations)The OSH Regulations have the effect of spelling out specific requirements of the legislation. They may prescribe minimum standards and have a general application, or define specific requirements related to a particular hazard or type of work. They may also allow licensing or granting of approvals and certificates, etc.

Codes of practice published under the OSH ActCodes of practice published under the OSH Act provide practical guidance on how to comply with a general duty or specific duties under the legislation.

Codes of practice may contain explanatory information. The preventive strategies outlined do not represent the only acceptable means of achieving a certain standard.

A code of practice does not have the same legal force as a regulation and is not sufficient reason, of itself, for prosecution under the legislation, but it may be used by courts as the standard when assessing other methods or practices used.

Regulations and codes of practiceIf there is a regulation about a risk in the OSH Regulations, it must be complied with.

If there is a code of practice about a risk, either:

do what the code of practice says

or

adopt and follow another way that gives the same or greater level of protection against the risk.

If there is no regulation or code of practice about a risk, choose an appropriate way and take reasonable precautions and exercise proper diligence to ensure obligations are met.

Note: there may be additional risks at the workplace not specifically addressed in this code of practice. The OSH Act requires identification and assessment of those risks and implementation of control measures to prevent or minimise exposure.


Appendix 5: Other sources of information

LegislationOccupational Safety and Health Act 1984

Occupational Safety and Health Regulations 1996

Western Australian Marine Act 1982

Codes of practice, guidance material and other documents

Commission for Occupational Safety and HealthCodes of practice: First aid facilities and services; Workplace amenities and facilities; Personal protective clothing and equipment

Code of practice – Manual tasks

Code of practice – Prevention of falls at workplaces

Code of practice – Working hours

Guidance note – Alcohol and other drugs at the workplace

Guidance note – General duty of care in Western Australian workplaces

The above can be obtained from www.dmirs.wa.gov.au

Contacts

The Commission is seeking input into the key contacts section of this code.


http://www.dmirs.wa.gov.au/

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