IMCA International Code of Practice for Offshore Diving – UK Appendix

When the IMCA international code of practice for offshore diving was originally published, a UK appendix, issued as IMCA information note D 03/99, was developed which set out the additional requirements, supplementary to those contained in the IMCA code.

Since the IMCA code has now been updated and re-issued as IMCA D 014 Rev. 1, October 2007, we have reviewed the information note and updated it to reference the appropriate sections in the new code.  This revised note is attached.

A copy of the appendix for the UK is attached.

The attached has been provided for information only.  It does not purport to provide an authoritative substitute for UK legislation.

Offshore diving work under UK jurisdiction is governed by the Diving at Work Regulations (DWR) 1997 which are accompanied by an Approved Code of Practice (ACoP), both published and enforced by the Health & Safety Executive (HSE).

The list below is not a full legal interpretation of the UK requirements for offshore diving. It is meant as a guide to the main additional requirements for work in the UK given by its diving regulations in comparison to the IMCA code. It does not address other legal requirements which may exist while working offshore under UK jurisdiction and if work is planned which falls under UK jurisdiction then it is recommended that specialist advice is sought in order to comply with all aspects of the UK legal requirements.

Specific Points

References in brackets below are to the relevant paragraph numbers of the HSE ACoP or to pages or sections of the IMCA code.

  • The HSE ACoP (para 33) requires the diving contractor to have formally notified HSE in London of its details such as name, address, telephone etc.
  • Maximum bottom times allowed when surface supplied diving are specified in para 44 and Table 1 of the HSE ACoP. This contrasts with the advice given in section 7.3.3 of the IMCA code and will limit surface supplied diving to shorter times than may be the case under the IMCA code.
  • Surface supplied diving is not allowed deeper than 50 MSW by HSE (para 46) and a closed bell must be used if working deeper than this. In contrast section 7.3.5 of the IMCA code allows the use of surface mixed gas with an open bell down to 75 MSW.
  • Paragraph 75 of the HSE ACoP requires the diving contractor to use hearing protection and noise reduction techniques if required. This subject is not specifically addressed in the IMCA code.
  • Paragraph 79 of the HSE ACoP says that wet suits will have limited applications offshore in the UK. This is due to the colder waters encountered compared to other parts of the world covered by the IMCA code.
  • The HSE ACoP specifies (para 94) an absolute minimum team size of nine for one saturation bell dive with two divers in the bell. This contrasts with a minimum team of seven given in the IMCA code, section 5.3.
  • HSE (para 96) says that any diver should only take part in one bell run in each 24-hour period. This differs slightly from the IMCA code, section 5.3.
  • HSE (para 97) says the bell runs should not exceed eight hours from lock-off to lock-on which is the same as the guidance in IMCA section 7.3.21. HSE further states that in a two-man bell run, no diver shall spend more than four hours locked out and in a three-man bell run, two of the divers may lock-out together for up to six hours each but should act as the bellman and stay dry on each third bell run. IMCA guidance notes that the project plan needs to ensure that each diver spends no more than six hours out of the bell.
  • There is a requirement (HSE 104) for two qualified life support personnel to be at, or in the vicinity of, saturation control at all times. If one is required to leave, for meal breaks or other reasons, then they must be replaced by another qualified life support person. This contrasts with IMCA section 5.2.4.
  • HSE has specific requirements for first aid training to a nominated UK standard (paras 117-119). Those qualifications require to be renewed every three years. This is similar to IMCA section 6.3 but requires the UK type certificate.
  • The recording of the dive needs to be retained for 48 hours after the diver has returned to surface (HSE 133) instead of the 24 hours required by the IMCA code, section 4.7.
  • The HSE ACoP (para 145) requires independent primary and secondary braking systems on man-carrying winches with the secondary system operating automatically on hydraulic systems. This is more detailed than the requirement in the IMCA code, section 4.11.1.
  • The HSE only approves certain diver training certificates for offshore diving within its jurisdiction (para 173). A copy of this list, which changes from time to time, can be obtained from HSE in London. The list is similar to that identified in the IMCA code, section 5.1.2 (and set out in IMCA information note D 05/07), but is not identical.
  • The doctor carrying out an annual diving medical examination for use within HSE jurisdiction must be on the HSE approved list (para 192). Specific cases will need to be checked and confirmed with HSE in London.