Diving and snorkelling risk management

General workplace environmental hazards include:

• physical work environment (e.g. slips trips and falls, fixtures and fittings and housekeeping, noise, confined spaces, lighting and working temperature)
• equipment, materials and substances used (e.g. plant, electrical equipment, hazardous chemicals)
• work tasks and how they are performed (e.g. hazardous manual tasks)
• work design and management (e.g. fatigue).

Specific diving and snorkelling workplace environmental hazards include:

• diving equipment
• compressors, storage and gas supply systems
• air purity
• vessels, including dive vessels, tenders and shipping movements
• entry and exits
• vessel boarding
• associated activities such as crane operation, rigging, construction or demolition
• entrapment or entanglement hazards
• overhead environments
• pressure differentials (e.g. water inlets, sluices or valves)
• use of plant underwater.

Human risk factors apply to both workers and others, such as recreational diving and snorkelling participants.

Specific human risk factors include:

• medical and physical fitness – this is especially relevant for the recreational industry where the medical and physical conditions of the divers and snorkellers is unknown. Dive operators must implement a system to assess the participant’s ability to conduct the activity prior to the provision of the activity.
• competence such as:
  • relevant qualifications, training and information
  • the ability of the individual to understand and act on any advice (e.g. risks to non-English speakers).

Diving and snorkelling usually takes place in a natural environment which may create risks for different activities (e.g. conducting non-certified diving in poor visibility). PCBUs should identify natural environmental hazards before and immediately prior to the activity commencing. For recreational diving, a staff member should confirm the current and visibility by conducting an in-water assessment. Environmental conditions should be monitored during the activity for any changes that would affect the health and safety of participants.

A record (e.g. a dive safety log) should be kept of key environmental conditions and a risk assessment undertaken to decide if activities should be modified or cancelled. This should be documented along with any modifications to the operations.

Environmental factors include:

• non-respirable nature of water
• water temperature
• current and tide
• visibility
• depths
• time of day
• underwater terrain
• surface conditions- waves and surge
• weather
• isolation
• chemical or biological hazards
• dangerous marine animals such as jellyfish, sharks and crocodiles.

The most effective control measure involves eliminating the hazard and associated risk. The best way to do this is by, firstly, not introducing the hazard into the workplace.

Example 1 – Environmental conditions on the day of travel are beyond the ability of the passengers and crew to conduct the activities safely under normal operating conditions. The dive operator takes the decision to reduce the ratios of diving groups (i.e. taking non-certified divers at a ratio of 2:1 instead of 4:1). Or if the conditions are sufficiently bad then the operator may decide to cancel the activities until such time as the conditions improve.

Example 2 – Risks could be eliminated from diving work by undertaking the work at the surface, such as by waiting for low tide to undertake work in the inter-tidal zone.

Substituting an activity, procedure, plant, process or substance for one that lessens the risk to health and safety will contribute to minimising the risks to health and safety associated with the hazard.

Example 1 – A dive operator arrives at their main snorkelling site, but the wind is blowing from a different direction to normal causing poor surface conditions. The operator substitutes by using a different site that is sheltered from the prevalent winds.

Example 2 – Requiring workers to undertake multiple ascents to bring catch to the surface while diving for seafood exposes the divers to increased risk of developing decompression illness. This risk could be controlled by substituting this activity with plant and procedure allowing the catch to be sent to the surface unattended by the diver.

Isolating persons from a hazard by removing or separating the person from the source of the hazard will contribute to minimising the risks associated with the hazard. Isolation is only effective if the control measure ensures that a person is unable to expose themselves to the risks associated with the hazard.

Example 1 – A busy pontoon operation has multiple vessels operating in close proximity to snorkellers and divers. The operator isolates the snorkelling/diving area from surface vessels by using signals and barriers such as ropes and floats, to minimise the risk.

Example 2 – Divers in some environments may be at risk of attack by marine predators such as crocodiles. Isolating the diving work area by using cages or physical barriers will contribute to minimising this risk.

An engineering control measure is where the physical characteristics of the plant, structure or work area are changed to remove or contribute to minimising the risks to health and safety associated with the hazard.

Example 1 – A rescue tender is expected to operate in the near vicinity of persons in the water, exposing them to the risk of being injured by the vessels propeller. Guarding the vessels propeller will contribute to minimising the risk.

Example 2 – A diver accessing a confined space, such as a storage tank, is at risk if they are unable to be retrieved from the tank should they need to be rescued. Erecting a frame to which lifting equipment suitable for extracting the diver from the tank will contribute to minimising the risk.

An administrative control measure is where procedures, signs and training are used to minimise the risk to health and safety. Administrative controls rely on a person's behaviour and therefore require initial competence, thorough training and a high level of supervision to ensure that the procedure is being adhered to.

Example 1 – A dive operator wants passengers to follow some safety guidelines in the water. The operator provides a briefing to customers detailing what these guidelines are.

Example 2 – A PCBU wishes to ensure breathing apparatus and other items of the diver's equipment are correctly fitted and functioning. In combination with higher order control measures a pre-dive equipment checklist is developed and implemented. Implementation includes providing information and training to the divers about the use of the checklist, and supervision to ensure that the checklist is being correctly and consistently used.

An administrative control must only be considered where higher order control measures are not reasonably practicable or where the use of an administrative control will further minimise the risks to health and safety in combination with higher order controls.

Almost every aspect of dive planning falls into this administrative category. Administrative controls include:

• training, supervision, experience and selection of workers, including staffing levels
• provision of an appropriate diving operations manual
• organisation and planning before, during and after the dive.

Many PCBUs develop operational documents to clearly identify the control measures they have adopted. Workers must be instructed so that they clearly understand their duties and responsibilities with regard to the implementation of any control measures.

AS/NZS 2299.1: 2015 Occupational diving operations – Standard operational practice Appendix [E] provides an example of the structure of a diving operations manual for general diving work.

PPE is the lowest order control measure in the hierarchy of control. PPE as a control measure relies on a person's behaviour and therefore requires thorough training and a high level of supervision to ensure compliance and effectiveness. PPE includes any clothing or equipment designed to be worn by a person and to contribute to minimising risks to the person's health and safety.

Example 1 – Divers and snorkellers may be exposed to risks from marine stings. Where higher order controls are not reasonably practicable, or to further minimise the risks, participants should be provided with a stinger suit to minimise the risk of a marine sting.

Example 2 – The operation of machinery associated with diving work, such as air compressors exposes workers to the risk of injury from noise. In conjunction with higher order controls, workers should wear hearing protection.

In many cases a combination of control measures will be required to minimise the risks to health and safety.

Note: The PCBU must ensure that, in selecting a control measure, new hazards are not being created. If new hazards are created, these must be identified, risk assessed and either eliminated or controlled.