Diving and snorkelling risk management

The hazards of diving and snorkelling must be managed to eliminate or minimise the risks of death, injury or illness as far as is reasonably practicable.

Effective risk management requires persons conducting a business or undertaking (PCBU) to identify all hazards, assess risks and implement, maintain and review control measures.

Generally the hazards of diving and snorkelling are either:

hazards that apply to the activity all or most of the time (e.g. drowning if an air supply fails or decompression illness)
specific to the workplace environment, human factors or the natural environment.

PCBUs undertaking high risk diving work and general diving work must undertake and document their risk management process and include specific control measures in their dive plan. PCBUs undertaking recreational diving and snorkelling should undertake risk management.

The four step process for managing risks

Identify hazards
Assess the risk
Control the risks
Reviewing risk controls

Identify hazards

The first step in the risk management process is to identify all hazards that might affect the health and safety of divers and snorkellers. Hazards generally arise from the following aspects of diving work and their interaction:

workplace environment
human factors
natural environment factors.

Hazards may be identified by looking at the workplace and how work is carried out. It is also useful to talk to workers, customers, manufacturers, suppliers and health and safety specialists and to review relevant information, records and incident reports.

Workplace environment

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 factors

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
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).

Natural environmental factors

Diving and snorkelling usually takes place in a natural environment which may create risks for different activities (e.g. conducting resort diving in poor visibility). PCBUs should identify natural environmental hazards before and immediately prior to the activity commencing. They should also be monitored during the activity for changes.

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.

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.

Assess the risk

A risk assessment involves considering what could happen if someone is exposed to a hazard and the likelihood of it happening. A risk assessment can help determine:

how severe a risk is
whether existing control measures are effective
what action should be taken to control the risk
how urgently the action needs to be taken.

Many hazards and their associated risks are well known and have well established and accepted control measures. In these situations, the second step to formally assess the risk is unnecessary. If identifying a hazard where the risk and how to control the risk are already known, the controls can simply be implemented.

The severity of health and safety outcomes for many hazards associated with diving work mean that most identified hazards will require high level control measures, multiple control measures, redundancy in the event of system failures and emergency back-up.

Control the risks

When implementing control measures consider the following:

diving qualifications and competency
medical fitness
supervision
information and advice for divers and snorkellers
non-English speaking participants
diving and snorkelling equipment
dive plans
emergency planning
decompression management
keeping dive logs
head counts
recreational technical diving
marine stingers
vessels
entry and exit from water
boarding facilities.

Once the PCBU has assessed the risks of the diving, the next step is to manage the risks by eliminating them, or if that is not practicable, minimising them so far as is reasonably practicable.

In selecting any control measures, standard operational practices such as Australian Standards or training agency standards may be used if the control measures are compatible with the diving legislation.

There are a number of ways to minimise and control risks associated with diving. Some control measures are more effective than others. Control measures can be ranked from the highest level of protection and reliability to the lowest. This is known as the hierarchy of control.

Elimination: 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 – 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.
Substitution: 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 – 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.
Isolation: 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 – Divers sharing the same work area with surface vessels risk coming into contact with the vessels which could result in serious injury or death. Isolating the diving work area from the surface vessels by using signals and barriers such as ropes and floats will contribute to minimising the risks associated with the surface vessels.
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.
Engineering control: 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 – Requiring a diver to work from a moving vessel exposes the diver to a risk of being injured by the vessel's propeller. Guarding the vessel's propeller will contribute to minimising this 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.
Administrative control: 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 – 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.
View a sample operations manual for recreational diving .
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.

Personal protective equipment (PPE): 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 may be exposed to risks from marine stings. Where higher order controls are not reasonably practicable, or to further minimise the risks, divers should be provided with suitable diving suits, hoods, gloves and boots.
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.
Combinations of control measures: In many cases a combination of control measures will be required to minimise the risks to health and safety.
Example – The risk to divers working in the same area as moving vessels could be controlled by implementing a number of measures such as:
- replacing a vessel which has a restricted field of vision by one that has a clear field of vision (substitution)
- segregating the divers and vessels through signs, barriers, distance and time (isolation)
- ensuring there is adequate voice communication between all vessel masters, the dive supervisor and any lookouts (engineering)
- installing guards on relevant exposed propellers (engineering)
- developing and implement a vessel traffic management plan for the activities being undertaken (administrative)
- ensuring all relevant workers are competent, are provided with adequate information and training and are supervised to implement the control measures (administrative),
- requiring all divers to wear high visibility reflective clothing or headgear (PPE).

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.

Marine stingers

Australia's marine environment is home to some harmful jellyfish collectively known as marine stingers. The sting from marine stingers can cause discomfort, and some of the tropical waters species such as the irukandji and the box jellyfish can be lethal.

Caution must be exercised when entering tropical waters (generally north of Bundaberg in Queensland and Geraldton in Western Australia). Whilst marine stingers may be present throughout the entire year in tropical waters, the risk associated with dangerous jellyfish are higher during the 'Marine Stinger season' that typically runs from November through to May.

PCBUs should manage the risk of marine stingers by:

advising divers of the risks of marine jellyfish, where to access first aid and appropriate precautions including wearing protective clothing such as lycra bodysuits or wetsuits
ensuring the first aid kit is equipped to deal with marine stings.

Vessels

Examples of measures to minimise or eliminate the risk of divers or snorkellers being injured or killed by moving vessels include:

fitting propeller guards to tenders
using buoys and markers to separate diving activity from vessels
using flags, day shapes and lights to indicate that divers and snorkellers are present
appointing lookouts to maintain watch and form part of the communication system
ensuring that workers are familiar with sites and are able to navigate
consulting and advising other persons in the vicinity of where and when diving is occurring
implementing safe systems of work, such as shutting off engines when divers are alongside
ensuring divers using surface supplied breathing apparatus have redundant breathing systems so they can surface safely if a vessel damages their main air supply.

Entry and exit from water

When a person is entering and exiting the water ensure:

all persons engaging in diving-snorkelling/snorkelling are aware of the entry and exit location from the water
entry and exit locations are free from obstacles and other hazards
entry and exit locations are suitable for the fitness and physical capabilities of the persons engaging in diving-snorkelling/snorkelling activities
the entry and exit is suitable for an emergency (e.g. rescuing an unconscious person)
where applicable, assistance is made available to persons entering and exiting the water to reduce their physical exertion. This may include providing assistance in removing and stowing heavy equipment. (Note: additional physical exertion by a diver exiting the water may contribute to some type of physical strain or injury including the onset of decompression illness).

Boarding facilities

Risks to health and safety can be minimised by adopting a method that reduces the gap between the vessel and shore or pontoon facility which prevents a person or part of a person from falling through the gap (e.g. a gangplank, handrails and/or steps).

Where wheelchair-bound persons or persons with other disabilities use vessels, mechanical lifting equipment or ramps could be used to prevent or minimise risks to health and safety.

Also, mechanical equipment and the use of pallets or containers could be used to prevent or minimise risks when moving baggage to and from vessels.

Reviewing risk controls

Diving workplaces regularly change, no two workplaces are the same. Environmental factors can change quickly while tasks and sites can change on a daily basis.

Ensuring work health and safety within this dynamic workplace requires a PCBU to ensure that a competent person (e.g. the dive supervisor) continually monitors, consults, and reviews work practices, hazards, risks and control measures.

Once the control measures have been implemented, they must be reviewed regularly to make sure that they remain effective. For example, a dive supervisor must review risk control measures if there is a significant change to:

the manner in which diving work is to be carried out
the environmental conditions in which the work is to be carried out or if the following occur:
- a notifiable incident occurs in relation to diving work
- a risk control measure does not control the risks associated with diving work
- a health and safety representative at the workplace requests a review
- consultation indicates that a review is necessary.

The PCBU must revise a control measure if the review identifies that the control measure is not minimising the risks to health and safety.

If diving work is occurring and there is a significant change that is outside the scope of the initial assessment in the dive environment or way the work is being undertaken; and the change increases the risks to health and safety, then the PCBU should ensure that:

the work stops immediately
the work is not resumed until the control measures are reviewed and as necessary revised and any new or different control measures are implemented.

Reviewing the risk controls involves considering whether applying a higher order risk control is now reasonably practicable.

The PCBU must also ensure information about any changes to control measures is provided to all relevant persons. This may include training about the new control measures (e.g. by a toolbox talk) and the revision of administrative controls such as diving operations manuals and dive plans.