A Commercial Diving Safety Manual establishes safe operating procedures, responsibilities, equipment requirements, emergency procedures, and other controls for employers performing commercial diving and related support operations.
Commercial divers may perform underwater construction, inspection, repair, maintenance, welding, cutting, cleaning, demolition, material handling, salvage, pipeline work, vessel work, marine construction, and other specialized operations.
These activities can expose divers and surface-support personnel to serious hazards including drowning, decompression sickness, arterial gas embolism, differential pressure, hazardous underwater environments, contaminated water, hypothermia, breathing-gas failure, equipment failure, entanglement, underwater tools, welding and cutting, currents, vessel traffic, and emergency ascent.
Commercial diving is also unusual because federal OSHA specifically requires covered employers to develop and maintain a Safe Practices Manual for their diving operations.
A properly developed Commercial Diving Safety Manual should therefore function as an operational safety document for the employer’s actual diving modes, dive-team organization, equipment, work activities, emergency capabilities, and diving environments.
Federal OSHA regulates commercial diving operations under 29 CFR Part 1910, Subpart T — Commercial Diving Operations.
Subpart T applies broadly to covered diving and related support operations conducted in connection with work including:
The standard establishes requirements for:
The employer is responsible for complying with requirements of general applicability and with requirements for the specific diving modes used.
Covered employers must develop and maintain a Safe Practices Manual and make it available at the dive location to each dive-team member.
The manual should not be treated merely as a generic company safety policy.
It is an operational document intended to establish how the employer will safely conduct commercial diving activities.
The Safe Practices Manual must contain the applicable OSHA commercial diving standard and the employer’s policies for implementing its requirements.
For each diving mode used by the employer, the manual must address required:
Emergency procedures should address applicable situations involving:
The manual should be maintained so it accurately reflects the employer’s diving operations.
Depending on operations, the manual may address:
The contents should reflect the diving modes and underwater work actually performed.
An effective Commercial Diving Safety Program establishes responsibilities and procedures for planning, supervising, performing, and supporting diving operations.
Management should provide qualified personnel, properly maintained diving equipment, appropriate breathing-gas systems, emergency resources, safe work procedures, and sufficient time and personnel to perform diving operations safely.
Management should also ensure that hazards are evaluated before work begins and that employees have the authority to stop diving operations when conditions become unsafe.
The employer or an employee designated by the employer should be at the dive location and in charge of aspects of the diving operation affecting dive-team safety and health.
The Designated Person-in-Charge should have experience and training appropriate to the diving operation being conducted.
Responsibilities may include:
The person in charge should have sufficient authority to control the diving operation.
Each dive-team member should have the experience or training necessary to safely perform assigned duties.
Training and experience should address:
Employees should not be assigned duties for which they are not qualified.
Dive-team members should receive required first-aid and cardiopulmonary-resuscitation training.
Training should be current and appropriate to commercial diving operations.
Dive personnel should understand how to respond to:
Dive-team members who are exposed to hyperbaric conditions, or who control the exposure of others to hyperbaric conditions, should receive training in diving-related physics and physiology.
Training should help employees understand hazards associated with:
Each diving operation should have sufficient qualified personnel to safely perform the planned work and respond to reasonably anticipated emergencies.
Assignments may include:
Actual team composition should reflect the diving mode, work, depth, environmental conditions, equipment, and applicable requirements.
The working diver should:
Divers should not continue a dive when conditions make continued operation unsafe.
Where required, a standby diver should be available and properly equipped to provide assistance.
The standby diver should:
Tenders may be responsible for:
Tenders should understand line-handling and entanglement hazards and maintain awareness of changing surface and underwater conditions.
Every commercial diving operation should be planned before the diver enters the water.
Planning should consider:
Conditions should be reassessed when circumstances change.
The dive team should identify hazards associated with both the underwater work and the surrounding environment.
Potential hazards may include:
Controls should be established before the dive begins.
Before each diving operation, the employer should evaluate conditions and establish appropriate procedures.
Pre-dive activities should include applicable:
Required information and emergency resources should be available at the dive location.
Dive-team members should be briefed before the dive.
The briefing should address applicable:
Employees should have an opportunity to raise safety concerns before operations begin.
Required emergency information should be available at the dive location.
Information should include applicable means of contacting:
The dive team should know how to initiate emergency response without unnecessary delay.
Appropriate first-aid supplies should be available at the dive location.
Equipment should reflect the hazards of commercial diving and the work being performed.
Supplies should be maintained, accessible, and periodically inspected.
A reliable means of emergency communication should be available at the dive location.
The communication system should be appropriate to:
Emergency communication should be tested or otherwise verified before operations where appropriate.
The dive location should be organized to support safe diving operations.
The employer should consider:
Nonessential personnel should remain outside controlled diving work areas where necessary.
Appropriate warning signals, flags, lights, or other notifications should be used where required to alert vessels or other operations that diving is underway.
The dive team should consider nearby vessel traffic before and during the dive.
The diving operation should be continuously managed while divers are underwater.
The dive team should monitor applicable:
Conditions requiring termination of the dive should be understood before work begins.
Required communication between the diver and surface personnel should be maintained according to the diving mode and operation.
Communication equipment should be:
Loss of required communication should be treated according to established emergency or dive-termination procedures.
Breathing-gas systems should provide an appropriate supply for the diving mode and operation.
Systems should be protected against:
Reserve or emergency breathing-gas capability should be provided where required.
Compressed air used for breathing should meet applicable purity requirements.
Compressors and breathing-gas systems should be maintained to prevent contamination.
Air intakes should be located to avoid contamination from:
Breathing-air compressors should be:
Applicable filters, separators, receivers, relief devices, and monitoring equipment should be maintained.
Air receivers and volume tanks should be maintained according to applicable requirements.
Equipment should be protected from:
Required gauges and relief devices should remain functional.
Umbilicals may contain:
Umbilicals should be inspected and protected from:
Surface personnel should manage the diver’s umbilical to minimize:
Umbilical routing should be considered during dive planning.
Harnesses should be appropriate to the diving mode and equipment configuration.
Where required, harnesses should provide attachment points for:
Harnesses should be inspected before use.
Helmets and masks should be:
Valves, seals, communications, and other components should be checked before use.
Commercial SCUBA operations should comply with applicable OSHA requirements for SCUBA diving.
Dive planning should consider:
SCUBA should not be selected merely because it is convenient when another diving mode provides necessary protection for the work.
SCUBA cylinders should contain appropriate breathing gas and be maintained, inspected, and tested as required.
Divers should verify:
Surface-supplied air diving provides breathing gas to the diver from the surface through an umbilical.
Operations should address:
Surface-supplied systems should be configured for the planned operation.
The breathing-gas supply should provide sufficient pressure and volume for the diving operation.
Backup or reserve systems should be available as required.
Surface personnel should monitor equipment during the dive.
Mixed-gas diving introduces additional life-support and physiological considerations.
Operations should address:
Only appropriately qualified personnel should perform or support mixed-gas operations.
Breathing-gas mixtures should be appropriate to the planned depth and exposure.
Gas composition should be verified using appropriate procedures and equipment.
Cylinders and supply systems should be clearly identified to reduce the possibility of incorrect gas use.
Elevated oxygen concentrations can create increased fire hazards.
Oxygen systems should be kept free from:
Only equipment intended for oxygen service should be used where required.
Liveboating involves supporting surface-supplied diving from a vessel underway.
This operation creates significant hazards involving:
Liveboating should be performed only under conditions and procedures meeting applicable requirements.
Divers and umbilicals should be protected from vessel propellers and other propulsion systems.
Procedures should address:
A diver should never rely solely on assumptions about propulsion status.
Differential pressure, sometimes called Delta-P, can create extremely dangerous forces where water flows through or around:
A diver can be pinned or trapped by differential pressure even when the flow appears insignificant at the surface.
Before diving near structures capable of creating differential pressure, the employer should determine whether water movement, pressure differential, suction, or discharge could endanger the diver.
Potential sources should be identified before entry.
Controls may require:
Divers should not approach active intakes, discharges, gates, valves, pumps, or similar systems unless hazards have been evaluated and effectively controlled.
Facility personnel and the dive team should coordinate system status before diving begins.
Underwater work may expose divers to energy from:
Hazardous energy should be isolated and controlled before the diver enters the danger area.
Where underwater work can be affected by hazardous equipment or systems, appropriate energy-control procedures should be established.
The dive team should verify relevant equipment status before entry.
Coordination is especially important when the dive team is working at another employer’s facility.
Commercial divers may use:
Divers should be trained in the tools assigned to them.
Tools should be inspected and maintained.
Hydraulic tools are commonly used underwater.
Potential hazards include:
Hoses and fittings should be inspected and routed to minimize damage and entanglement.
Pneumatic tools may create:
Divers should maintain control of the tool and avoid entanglement with supply lines.
Underwater welding and cutting can expose divers to:
Only qualified divers should perform underwater welding or cutting.
Electrical equipment used underwater should be designed and maintained for the intended environment.
Procedures should address:
The diver should be protected from unintended energization.
Burning or cutting can generate gases that may collect in enclosed or overhead spaces.
Before underwater burning begins, the dive team should evaluate whether gases can accumulate and create an explosion hazard.
Appropriate venting or other controls should be provided where necessary.
Some commercial diving operations may involve underwater explosives.
Only properly qualified and authorized personnel should perform explosive work.
Procedures should address:
Divers may install, remove, or position:
Divers should avoid placing themselves beneath suspended loads or between loads and fixed structures.
Underwater rigging should account for:
Divers should move to a safe position before lifting begins.
Lift bags can create rapidly changing buoyancy and uncontrolled load movement.
Procedures should address:
Divers should not position themselves directly above a lift bag or rising load.
Divers may become entangled in:
Dive planning should identify known entanglement hazards.
Divers should have appropriate means to free themselves where necessary.
Low visibility can increase the risk of:
Procedures should account for visibility conditions and provide appropriate communication and navigation methods.
Current can increase:
Operations should consider current speed, direction, tides, and expected changes.
Diving should be suspended when current makes the operation unsafe.
Cold water can contribute to:
Thermal protection should be appropriate to water temperature, dive duration, and diving mode.
Divers and surface-support personnel should recognize symptoms of cold stress and hypothermia.
Procedures should address:
Divers can also experience heat stress, particularly while wearing heavy suits or waiting on deck in hot conditions.
Dive planning should consider both water temperature and topside environmental conditions.
Commercial divers may work in:
The employer should evaluate contaminants before selecting diving equipment and protective measures.
Controls may include:
Equipment should be selected according to the contaminants present.
Where contamination is present, procedures should prevent contaminants from spreading to:
Decontamination procedures should reflect the substance involved.
Contaminated water may expose divers to biological hazards.
Employees should protect:
Appropriate hygiene and medical follow-up should be provided when exposure occurs.
Depending on the location, divers may encounter hazardous marine life.
Pre-dive planning should identify known local hazards and establish appropriate response procedures.
Diving near active waterways can expose divers to:
Dive operations should be coordinated with vessel traffic as necessary.
Where diving is conducted from a vessel, the vessel should provide an appropriate platform for:
Equipment should be secured against movement.
Safe means should be provided for divers to enter and leave the water.
Procedures should consider:
Assistance should be available where necessary.
Procedures should provide a means of recovering an injured or incapacitated diver.
The dive team should consider the weight of the diver and equipment when planning recovery.
Dive profiles should comply with applicable decompression requirements.
Dive personnel should accurately track:
Unplanned deviations should be evaluated promptly.
Applicable decompression tables or procedures should be available to personnel responsible for dive planning and decompression.
Employees should understand how to use the system adopted by the employer.
A decompression chamber should be available at the dive location where required by the diving mode, depth, or planned decompression exposure.
Chambers should be:
Personnel assigned to operate recompression or decompression chambers should understand:
Dive-team members should recognize potential signs and symptoms of decompression sickness.
Possible symptoms can involve:
Suspected diving-related illness requires prompt medical evaluation.
Arterial gas embolism can be a life-threatening diving emergency.
Dive personnel should recognize the need for immediate emergency response when neurological or other serious symptoms occur after ascent.
Pressure changes can injure:
Divers should understand pressure-equalization procedures and report symptoms promptly.
The Safe Practices Manual should establish emergency procedures appropriate to the employer’s diving operations.
Potential emergencies include:
Dive-team members should understand their assigned emergency responsibilities.
Procedures should address failure of the diver’s primary breathing-gas supply.
Depending on the diving mode, emergency response may involve:
Emergency systems should be checked before diving.
The dive team should establish procedures for communication failure.
Depending on the diving mode, procedures may include:
Employees should understand the backup communication method before the dive.
Emergency planning should consider potential entrapment involving:
Standby personnel should understand the hazards before attempting rescue.
The dive team should have procedures for recovering and providing immediate care to an unconscious diver.
Planning should address:
Fire can threaten diving operations through:
Emergency procedures should address both diver safety and topside evacuation or response.
Diving operations should be modified or suspended when environmental conditions make continued work unsafe.
Potential conditions include:
After a dive, procedures should address:
Divers should report physical symptoms that may be related to the dive.
Divers should be monitored as appropriate following dives involving decompression or other increased physiological risk.
Dive-team members should understand symptoms requiring medical evaluation.
Post-dive procedures should address altitude exposure where relevant.
Divers should follow applicable restrictions or procedures before flying or traveling to higher elevations after diving.
Diving equipment should be inspected, tested, maintained, and repaired according to applicable requirements.
Equipment may include:
Defective equipment should be removed from service.
The Safe Practices Manual should include equipment procedures and checklists appropriate to each diving mode.
Checklists may address:
Checklists should reflect the employer’s actual equipment.
A preventive-maintenance program should address safety-critical diving equipment.
Maintenance should be performed by personnel qualified for the equipment involved.
Records should be maintained where required.
Depth gauges, pressure gauges, timekeeping devices, and other instruments used to control diving exposure should be maintained and tested as required.
Dive personnel should not rely on visibly damaged or malfunctioning instruments.
Diver communication equipment should be maintained in operating condition.
Connections, cables, headsets, speakers, and power supplies should be checked as appropriate.
Emergency equipment should be readily available and maintained.
Depending on the operation, this may include:
PPE for commercial diving may include both diving equipment and topside protection.
Depending on tasks, PPE may include:
PPE should be selected according to the work and environment.
Surface-support personnel can be exposed to significant hazards even though they do not enter the water.
Potential hazards include:
The Safe Practices Manual should address relevant topside hazards.
Commercial diving projects may require cranes or lifting equipment to position:
Lifting operations should be coordinated with the dive team.
Divers should remain clear of suspended loads.
Surface-support employees working near unprotected water hazards should use applicable fall and drowning protection.
Appropriate rescue equipment should be available.
Electrical equipment used at the dive site should be appropriate for the environment and maintained in safe condition.
Procedures should consider:
Damaged electrical equipment should not be used.
Cylinders should be:
Oxygen cylinders and systems should be protected from oil, grease, and incompatible materials.
Dive operations may involve:
Applicable chemical hazards should be addressed through the employer’s Hazard Communication Program.
Diving equipment can be heavy and awkward.
Employees may handle:
Mechanical assistance and team lifting should be used where appropriate.
Dive stations should be organized to prevent:
Umbilicals, hoses, cords, and tools should be routed and stored appropriately.
Employees should promptly report:
Significant events should be evaluated before similar diving operations continue.
Diving incidents should be investigated to identify:
Investigations may consider:
Root Cause Analysis may identify underlying issues involving:
Corrective actions should address identified causes rather than simply assigning blame.
Training should reflect each employee’s assigned diving and support duties.
Depending on responsibilities, training may address:
Employees should not perform work for which they have not received appropriate training or demonstrated the necessary experience.
Before diving begins, the dive team should review the planned work and hazards.
Topics may include:
Dive-team members should immediately communicate unsafe conditions.
The person in charge should suspend or terminate diving operations when conditions create unacceptable risk.
Production or schedule pressure should never override required diving safety procedures.
Commercial diving employers should maintain records required for their operations.
Records may include:
Records should be retained for applicable periods.
Dive records should document required information concerning commercial diving operations.
Accurate records can help establish:
Records should be completed promptly and accurately.
Depending on diving operations and employee exposures, additional programs may be necessary for:
Programs should be included when the employer’s diving modes, underwater work, equipment, environmental conditions, and employee exposures make them applicable.
A useful Commercial Diving Safe Practices Manual should reflect the employer’s actual diving operations rather than relying on a generic set of underwater safety rules.
A surface-supplied commercial diving contractor may require extensive procedures for dive stations, air compressors, volume tanks, umbilicals, communications, bailout gas, standby divers, underwater tools, decompression, vessel support, and emergency recovery.
A contractor performing underwater construction or infrastructure work may require additional procedures for cranes, rigging, hydraulic tools, underwater cutting and welding, differential pressure, hazardous energy, concrete or structural work, and heavy material handling.
A vessel-maintenance diving company may require greater emphasis on propellers, thrusters, sea chests, intakes, hull cleaning, vessel traffic, Lockout/Tagout, contaminated water, and coordination with vessel personnel.
A potable-water, wastewater, or industrial diving contractor may require specialized procedures for contamination assessment, protective diving equipment, decontamination, biological or chemical hazards, facility isolation, and diver hygiene.
A salvage contractor may require additional procedures for unstable structures, rigging, lift bags, heavy lifting, entanglement, poor visibility, vessel condition, cutting, and changing underwater conditions.
The Safe Practices Manual should therefore be built around the diving modes and work actually performed.
A Commercial Diving Safety Manual can be developed around the employer’s diving modes, dive-team organization, underwater work, equipment, breathing-gas systems, vessels, environmental conditions, emergency capabilities, and other occupational hazards.
The finished manual may incorporate applicable procedures for SCUBA, Surface-Supplied Air Diving, Mixed-Gas Diving, Liveboating, Dive Planning, Differential Pressure, Underwater Tools, Underwater Welding and Cutting, Contaminated-Water Diving, Diving Equipment, Emergency Response, Decompression, Crane and Rigging Safety, Hazardous Energy, and other hazards associated with commercial diving operations.
Most importantly, the manual can be structured around the OSHA Safe Practices Manual requirements for commercial diving operations, providing the employer with a practical document for use by dive-team members at the dive location.