Promoting inherently safe design and deference to expertise in commercial diving: A call to action

The views and opinions expressed in this text are solely my own and do not necessarily reflect those of any individual or organisation. This content is intended for informational purposes only and should not be construed as representative of any collective perspective. Additionally, I affirm that I have no direct or indirect conflict of interest with any individuals or organisations mentioned herein. The following insights and recommendations arise from candid feedback provided by various offshore and onshore personnel, including project managers, engineers, technicians, physicians, divers, and supervisors. Over the past four decades, these professionals have gained invaluable experience collaborating with different diving contractors and oil and gas companies. They have shared their perspectives with me, and I am pleased to express them, as they can inspire positive changes, particularly in regions of the world where diving-specific local regulations either do not exist or are not considered mandatory to follow..

Fit for diving? As occupational medicine specialists, we must confront the issue of issuing medical certificates for fitness to work, which can often be misinterpreted as "blank checks." What does it mean for a commercial diver to be declared "fit for diving"? The value of a fitness-to-dive certificate issued without the Medical Examiner’s reasonable knowledge of the local environment, diving methods, tools, procedures, emergency response plans, and the specific scope of subsea projects is questionable. Adequate communication of reliable information is key. Employers must ensure that medical doctors are informed about the working environment and associated residual risks before issuing a medical certificate for fitness to dive. This communication must flow efficiently among the employer, diver, and medical doctor, while strict confidentiality regarding medical information must always be maintained. It is critical to understand that a medical certificate does not shield divers from the dangers posed by substandard project design, inadequate methods, or faulty equipment. Additionally, it does not absolve oil and gas companies or diving contractors of responsibility if a diver, although undoubtedly medically fit, suffers an injury, illness, or long-term consequences because of such deficiencies in project design, preparation and execution. Oil and gas companies remain accountable for the quality of project design, preparation and execution.

Proposed fundamental statements for agreement. Given the unique hazards and inherent risks of the subsea hyperbaric environment, as well as the critical trust divers place in their surface support teams, our prevention strategies must be not only cautious but also fundamentally safer than those designed for onshore or offshore topside operations environments. Oil and gas companies, along with diving contractors, must uphold rigorous due diligence to ensure a safe working environment for all employees. These entities are responsible for clearly articulating the justification for diving and hyperbaric activities. Once the rationale/justification for manned underwater operations is agreed upon, oil and gas companies and diving contractors must identify hazards, assess risks, prevent exposure to those risks, and manage residual risks. Furthermore, all project designs, diving methods, equipment, procedures, and tools must be optimal for safe manned underwater operations. Both oil and gas companies and diving contractors must prioritise risk prevention (levels I, II, III, IV) over cost-cutting strategies. This involves minimising diver risk exposures to as low as reasonably achievable (ALARA). Factors such as bottom time, depth limitations, saturation duration, surface intervals, and excursion distances must be considered carefully. Given the current constraints in occupational and diving medicine and the impossibility of establishing threshold values—particularly concerning the number and amplitude of variations in ambient and partial pressures that might trigger inflammation—it is vital that prevention strategies adhere to the ALARA principle. From a legal perspective, we should anticipate the questions that a judge may ask following an incident: 1 - How does one justify exposing individuals to risk rather than eliminating that risk? This question pertains to the “Justification Principle”. 2 - Are established guidelines and limit values being adhered to, mainly when such values have been set by regulations? This relates to the “Limitation Principle”. 3 - Has risk exposure been minimised to the lowest possible level in accordance with state-of-the-art practices? This encapsulates the essence of the “Optimization Principle” under the ALARA Principle. In other words, oil and gas companies and diving contractors must adhere to these principles, conceiving safety and risk mitigation as their paramount responsibilities. By committing to a safety culture that prioritises the ALARA principle, we safeguard our workforce and strengthen our operational integrity. It is crucial to establish a proactive approach in which risk management is not just a legal obligation but a hallmark of professionalism and dedication to human life.

"As Low As Reasonably Achievable" versus "As Low As Reasonably Practicable". Consider a critical scenario for a diving contractor’s project manager: an oil and gas company can ensure an intrinsically safe design for a diving project by adhering to industry state-of-the-art. They understand the minimum safe price required for project execution. However, when this company chooses to award a contract to a diving contractor at a total price 30% below this minimum safe price, it creates an untenable situation. Such cost-cutting measures make it impossible for the diving contractor's project management team to uphold best practices in preventive measures and lead to significant compromises in safety across multiple levels: 1 - Primary Prevention: Substandard, cheap choices, such as opting for a poorly equipped Dive Support Vessel, will become the norm. Essential resources like ROV support will be lacking. There is a risk of inadequate procedural and physical barriers, insufficient training and familiarisation, cheaper manning with reduced team sizes and competencies, compromised necessities such as food quality and hygiene in accommodations, and non-compliance with safety protocols during transit between home/shore-base and offshore operations, etc. 2 - Secondary Prevention: Communication systems will become less effective, leading to failures in early detection and reporting of anomalies. Any complacency, intentional or unintentional, in implementing and auditing Planned Maintenance Systems (PMS) will only exacerbate this issue. 3 - Tertiary Prevention: The quality and reliability of both onshore and offshore emergency preparedness will decline for topside and diving/hyperbaric emergencies, including those related to telemedicine, medicines and medical equipment, treatment procedures, hyperbaric evacuation, hyperbaric reception, hospitalisation, and repatriation processes. 4 - Quaternary Prevention: A poor emergency response framework will not only fail to protect divers but could also create severe risks for rescue teams during both topside and subsea/hyperbaric interventions.

Lump-sum contracts: A formula for disaster. Lump sum contracts foster a culture of dangerous complacency, whether intentionally or unintentionally. They pose serious risks that can jeopardise project safety and integrity. Consider a typical example: a supervisor operating with an outdated version of a diving manual makes a misguided and biased decision. The supervisor deems the requirements of the current diving manual impractical, considering the constraints of the lump sum contract, scope of work, and unrealistic project timelines that the onboard client representative indeed knows. They erroneously conclude that the only viable method to complete the project within commercial constraints is to revert to outdated, more lenient guidelines. Such an approach compromises safety and exposes the diving supervisor to legal issues. The adverse consequences of lump sum contracts extend further: they lead to dangerous avoidance or delays in crew changes, resulting in prolonged saturation durations. Offshore periods for critical topside personnel, including crane operators, riggers, and other essential roles, are unduly extended. This atmosphere also encourages complacency and fosters inaccuracies during handovers, potentially causing significant lapses in transferring vital information. Additionally, to keep pace, crew members are often reluctant to report unsafe conditions, near-misses, or other incidents, contributing to a culture where significant events remain uninvestigated. The effects are evident in inaccuracies during routine checks, inaccurate risk assessments, and poor management of changes, all highlighted by blatant non-compliance with stop-work policies. Familiarisation, onboard training, drills, and handover periods are often insufficient or overlooked. The overall focus on cost reductions overshadows the critical need for safety. Decision-makers must recognise the inherent dangers of lump-sum contracts. We must prioritise safety, adhere to industry state-of-the- art, and abandon outdated practices that put lives at risk. The emphasis should be on effective project execution without compromising safety for financial gain; anything less is unacceptable.

Examples of dangerous practices still encountered • An oil and gas company irresponsibly instructed diving contractors to use air diving for clamp installations at 40 meters of seawater, claiming adherence to UK HSE despite evident safety hazards. The company also asked diving contractors to set the working depth for saturation divers as shallow as 13 msw solely for convenience, ignoring safety protocols and proper risk assessments. Alarmingly, the company permitted diving contractors to operate without an ROV on board during saturation diving operations where seabed depths exceed 50 msw, exposing divers to unnecessary risk. • An oil and gas company encouraged diving contractors to adopt rapid compression and decompression procedures without valid justification or necessary validation. It insisted on selectively using portions of the U.S. Navy diving manual while ignoring critical requirements stated in that same manual. For instance, the excursion tables from the U.S. Navy were utilised to their maximum limitations. Yet, necessary U.S. Navy diving manual safety protocols were disregarded, such as the mandatory 8-hour stop during decompression, the bend-watch guideline (less than 30 minutes away from the chamber for 48 hours), and the 72-hour surface interval before flying. Despite explicit warnings, the oil and gas company endorsed surface decompression as the preferred method. Divers have consistently reported significant physical and cognitive fatigue, and diving medicine specialists have provided documented warnings that the oil and gas company chose to ignore. • A diver operating at a storage depth of 100 msw while working during project A could ascend a maximum excursion distance of 14 meters according to stringent local state regulations. Yet, two months later, during a project executed for the same oil and gas company but in another country that does not impose such rules, the same diver was required to perform identical tasks at the same depth but was cleared for a 30-meter ascent during project B. Such disparities do not refer to any justification other than financial ones. Alongside the unjustified discrepancy, how can we effectively monitor cumulative exposure? Exposure to what? Furthermore, the assessment of long-term effects is far from complete straightforward. • An oil and gas company actively urged diving contractors to seek dispensations from medical advisors without providing relevant justification, typically in the absence of "exceptional circumstances." This practice led to unjustified extensions of saturation periods and presented a substantial risk. How could a Medical Advisor reliably assess the context—including the health status of unknown divers, the working environment, and the scope of work—when crucial factors remain unknown? Moreover, saturation divers were often placed into saturation prematurely or stayed in it well beyond the necessary duration required to complete their tasks and undergo final decompression. This rationale is typically rooted in logistical challenges—namely, the difficulties and delays in crew changes and the need for onboard accommodations for topside visitors and client representatives. Such unjustified additional exposures to a hyperbaric environment should be forbidden. • An oil and gas company actively urged diving contractors to work in heavily contaminated environments—such as topside structures, subsea structures, seawater, and seabed covered with crude oil—despite being aware that complete protection and encapsulation for divers is nearly unattainable. Achieving complete protection requires specific equipment and complex dressing, undressing, and decontaminating procedures, making it impractical given the pressures for minimal non-productive time. This happened in both surface-supplied and saturation diving contexts. Furthermore, the reliance on "Dräger tube readings" obtained within the Diving Bell is insufficient. The oil and gas company's minimal sample analysis results are often unacceptable, as they lack proper interpretation or recommendations concerning safety precautions. The reliability of hydrocarbon automatic detectors has been compromised while diving in tropical waters due to excessive temperatures in poorly climatised diving bells. The client representative was not aware of the equipment specifications.

Concerns extend to hyperbaric evacuation: The overall complacency surrounding this issue cannot be overstated, particularly concerning hyperbaric rescue units (HRUs) type and quality and the immediate steps required post-launch. There are unwarranted exemptions and an overreliance on risk ranking matrices, especially the attitude of “this has never happened before.” The lack of adequate assessment regarding levels of preparedness and readiness is unacceptable, as is the absence of drills, tests, or trials to ensure secure connections. Finally, there is a failure to guarantee the rapid recovery of the HRU onto an appropriately manned and equipped Nominated Rescue Vessel (NRV) with competent Life Support Technicians and a reliable Life Support Package (LSP).

Emergency preparedness and response: Whether medical or surgical, topside or hyperbaric, the level of preparedness is often inadequate. A culture of complacency exists, evidenced, for example, by the frequent disregard for DMAC recommendations and IMCA D 061 guidance. According to state-of- the-art medical references, a specific contract must be adjusted with a competent medical service provider capable of intervening offshore and onshore for each diving project. Furthermore, reliance on inexpensive and unreliable communication equipment and networks presents a significant risk. It is crucial to accurately assess medical risks rather than dismiss potential threats with remarks like, “This has never happened.” We often fail to thoroughly evaluate our preparedness and readiness, and it is inexcusable that we do not conduct regular drills. In the face of these critical issues, we should take decisive action rather than accept resignation.

Conclusion: The urgency to promote inherently safe design in commercial diving practices, including methods, equipment, tools, and procedures, cannot be overstated. It is the way forward. Doing so can significantly reduce the incidence and severity of occupational injuries and diseases within our workforce. It is imperative to approach prevention—from levels I through IV—from a healthcare perspective, guided by competent professionals with appropriate medical training and expertise.

Doctor Jean Yves Massimelli

Warning about an IOGP misleading statement: Appendix 1 of the current version of the IOGP report 411 published in January 2021 states the following as a requirement for saturation diving: QUOTE Any SDC (Diving bell) to contain equipment that can measure H2S and hydrocarbon contamination of an equivalent or greater Specification to the Analox Hypergas 2. This equipment to be capable of alarming and notifying both the Surface Diving Supervisor and the SDC inhabitants of contamination of the breathing atmosphere. UNQUOTE. We believe the Analox Hypergas 2 is a reliable equipment. However, it only alarms and notifies the surface team and saturation divers in the diving bell about hydrocarbon contamination. It is not equipped with an H2S sensor. Hence, the IOGP 411 statement is misleading, as it presents the Analox Hypergas 2 as capable of detecting, alarming, and notifying about H2S contamination. It is worth highlighting that this error was pointed out in the document “CCO Ltd—Diving study #9—Analysis of IOGP 411—Page 76 of 94". This study can be downloaded from https://diving-rov- specialists.com/docs-diving-rov-specialists.htm. Despite the references provided by CCO Ltd, the IOGP has yet to amend the report accordingly. Note that CCO Ltd mentions the UK HSE report 030 “Development of the ANALOX Hyper-Gas Diving Bell Monitor”, written by Valerie Flook and published in 2003 (https://www.hse.gov.uk/research/rrpdf/rr030.pdf).

• Workers exhibit reluctance to cease operations or report their conditions, fueled by a fear of jeopardising future employment, particularly under lump sum contracts. • The information provided to the divers and topside workers regarding chemical exposure risks, actual exposure levels, and medical follow-up requirements is not yet accurate and easily accessible. We must improve our assessment of chemical exposure risks and our monitoring of ill-health effects. • Furthermore, the IMCA D 044* and IMCA D 006** guidance notes have often been unknown and/or ignored. Diver isolation and preparedness for accessing subsea systems have often proved inadequate. (Notes: IMCA D 044* “Guidelines for isolation and intervention: Diver access to subsea systems”. IMCA D 006** “Guidance on Diving Operations in the Vicinity of Pipelines”)