Published on 14 October 2022
Bryan McGlinchy, Diving Manager at the International Marine Contractors Association (IMCA) explains the purpose behind the major review of the association’s DESIGN (Diving Equipment Systems Inspection Guidance Note) suite of documents and next steps:
The provision and use of well-maintained and fit for purpose diving systems has long been a cornerstone of marine energy diving safety. This is why IMCA publishes an authoritative range of technical documents intended to help diving contractor members confirm that their diving systems are always suitably equipped and appropriately configured to conduct diving operations safely.
It is essential that our documents are periodically updated to clarify any anomalies and bring the guidance into alignment with the latest industry good practice. The new DESIGN document revisions are intended to be capable of assuring the safety and suitability of both traditional diving plant and equipment and the most modern complex diving systems.
Reviewing these documents has been a significant task for the specially convened Diving Division workgroups assembled to work on the key documents within IMCA’s DESIGN suite:
- IMCA D 018 Rev. 2 Code of practice for the initial and periodic examination, testing and certification of diving plant and equipment.
- IMCA D 024 Rev. 3 DESIGN for Saturation (Bell) Diving Systems.
- IMCA D 063 DESIGN for Hyperbaric Rescue Unit (HRU) Life Support Packages (LSP).
- IMCA D 023 Rev. 2 DESIGN for Surface Orientated (Air) Diving Systems.
The workgroups have excelled themselves on the revision of these important pillars in maintaining diver safety, and we thank them for their dedication and professionalism
The above documents form the backbone of IMCA’s diving system DESIGN assurance process. By following the recommendations for the initial and periodic examination, testing and certification of diving plant and equipment set down in IMCA D 018; and by periodically carrying out relevant DESIGN audits of their diving systems against the requirements of D 018, diving contractors are able to assure themselves, their divers, their clients, and other industry stakeholders that their diving systems are fit for purpose and safe to use.
Several supporting documents have been published to assist diving contractor compliance with the revised DESIGN suite of documents, including the brand-new IMCA D 069 Guidance on the Systematic Assessment of Control Systems in Automated Diving Plant and Equipment, and IMCA D 039 Rev. 1 FME(C)A Guide for Diving Systems, which has undergone a comprehensive update. Both are available from the Member website.
IMCA recognises that changes to DESIGN mean that members must make corresponding adjustments to their diving and management systems, and that these will take time to complete. For this reason, as revised DESIGN guidelines are published, each of the new documents will not compulsorily replace the previous versions for a period of up to one year. After a year has elapsed the older version of each document will be withdrawn, and members will be expected to comply with the latest revision.
During the year of overlap, IMCA members may choose to comply with DESIGN by meeting the requirements of either the old or the new versions. Both versions are available to members. Four IMCA Information Notes summarising the changes contained within the updated DESIGN documents are proving invaluable to members as they transition to the new versions of DESIGN.
This arrangement is intended to give IMCA members a suitable period of time to make appropriate adjustments to their diving plant and equipment, and to their equipment management arrangements, so as to facilitate full compliance with the new DESIGN documents once the old versions have been withdrawn.
Have we finished working on DESIGN document revisions? No, updating of the DESIGN suite is ongoing. The next one to be revised is expected to be IMCA D 040 DESIGN for Mobile/Portable Surface Supplied Systems and we welcome feedback on an ongoing basis on all of these key documents.
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Although those holding sports diving qualifications have some knowledge of diving, they certainly do not understand the world of commercial diving, with its unfamiliar industrial hazards and risks, radically different diving techniques, and specalised diving plant and equipment. This is why individuals who only hold sports diving qualifications must never be permitted to participate in commercial diving projects. They are likely to be a danger to themselves and others.
Ideally, there would be a single commercial surface orientated diving qualification and a single closed bell saturation diving qualification. Courses leading to the award of these certificates would be taught to globally recognised syllabuses, and both qualifications would be accepted universally. Unfortunately, that is far from reality.
Governments of many countries have not put any arrangements in place for the appropriate training of commercial divers, while others have set up commercial diver training and certification programmes to serve their own national needs, but not necessarily the wider needs of the global commercial diving industry.
In countries where specific diving at work legislation has been enacted, a list of diving qualifications approved for diving at work in the waters of that country have been introduced by the regulatory authorities. One example is the British Health and Safety Executive’s List of Approved Diving Qualifications. Where national legislative requirements for commercial diving qualifications are in place, they must always be observed.
All this is perfectly understandable, but it does leave us in a situation where the harmonised cross border training and certification of commercial divers has not been achieved. There is no single air or closed bell saturation commercial diving qualification taught to a globally recognised standard that is universally recognised in all countries and by all industry stakeholders, and no single body has accepted responsibility for assessing the quality and suitability of commercial diver training courses on behalf of the international commercial diving industry.
So, in the present circumstances, how can diving contractors and their clients working internationally identify suitably qualified commercial divers capable of diving safely and efficiently wherever their services are required? What diving qualifications should commercial divers hold?
At IMCA, we have compiled our own list of basic diver training certificates (surface supplied and closed bell) that we recommend to our members as suitable for demonstrating the basic competence of marine energy industry commercial divers (available from IMCA).
The diver training certificates on IMCA’s list are issued by national governments or government appointed agencies. In the vast majority of cases they are issued by members of the International Diving Regulators and Certifiers Forum (IDRCF), which is an organisation representing a group of national regulatory bodies for occupational diving with the shared objective of harmonising cross-border diver training.
At IMCA, we believe members of the IDRCF are almost the only certifying bodies providing credible oversight of the training regimes for the diver training qualifications they issue. IDRCF members are the only certifying bodies undertaking reliable regular inspections/audits of all the commercial diver training schools, facilities, and courses they approve. No single certifying body can do this globally, but collectively IDRCF members provide an important service to IMCA and the international commercial diving industry as a whole. Thanks to the activities of the IDRCF members, IMCA can sort the wheat from the chaff and have confidence in the quality and suitability of the diver training qualifications it recognises.