By Phil Newsum
I hope you enjoy this edition of Underwater Magazine. There are several articles featured, including the piece on the ADCI’s new ship husbandry guidelines. The magazine is always looking for relevant content. Whether it’s new gear, a challenging operation, or a lesson learned, share this knowledge and experience with other industry stakeholders.
I want to inform you of some of the latest developments in the industry concerning the association. First, the ADCI and IMCA provided a presentation at the National Offshore Safety Committee (NOSAC) in which the two associations proposed an interim policy for diving in the outer continental shelf (OCS). The proposal would require diving contractors to be either ADCI or IMCA members, and they would have to adhere to all standards for equipment, operations and certifications. The USCG would still issue certificates of inspection for the vessels and perform inspections and investigations as needed. The current 46 CFR Part 197 Subpart B would still be in effect. The proposed change would be authorized via a policy letter. This has been done on at least two previous occasions by the USCG, the last being USE OF THE UNINSPECTED TOWING VESSEL (UTV) DECAL TO MEET CERTAIN REQUIREMENTS REGARDING ISSUANCE OF THE INITIAL COI UNDER SUBCHAPTER M. This proposal was discussed at the ADCI-USCG Partnership Action Team (PAT) meeting, last April at HQ in D.C. At the (PAT) meeting, it was recommended by the USCG that the proposal be presented at the fall NOSAC meeting. The proposed interim policy was well received by NOSAC. Given that the current CFR was originally issued in 1977 and minimally revised in 1998, it is woefully behind current industry best safe practices. The committee is supportive of any initiative to increase safety, until such time as the proposed revised CFR has been passed into law. The hope here is that both operators and diving contractors that are not ADCI or IMCA members, or abide by the association’s standards, will be forced to raise their operational and equipment standards to reflect current recognized safe practices. As for the next step with this proposal, NOSAC will meet again in late October and form a task statement directing the USCG to develop a policy letter reflecting the proposed interim policy for diving in the OCS.
Another major development is the near completion of the long-awaited ADCI Guidance for Underwater Ship Husbandry (UWSH). For quite some time, the document has been revised to try to appease parties who perform UWSH on both large and small vessels. Clearly, there are manning level differences when performing UWSH on a tanker versus on a small tugboat, so the association has revised the guidance for Underwater Ship Husbandry for Cargo Ships/Freighters. The guidance is specific the six categories of cargo vessels (general cargo vessels, container ships, tankers, dry bulk carriers, multi-purpose vessels and reefer ships.) This allowed the document to call for a minimum number of five dive team members (one supervisor, one diver, one standby diver and two tenders.) The document is being reviewed by the ADCI Board of Directors and should be ratified for release by mid-November. This UWSH document was primarily designed to spell out guidance for performing work in the safest manner possible. One major issue that the document will address is prohibiting the use of scuba. Most fatalities in the international sector have come from the use of scuba with UWSH operations. One would think that “lessons learned” over the past eight to 10 years would show stakeholders that this operation should be reserved for surface-supplied diving only. Unfortunately, because there are those looking to do things on the cheap end, industry had to develop guidelines mandating the use of surface-supplied diving for UWSH. In fact, two days before I updated the International Diving Improvement Forum (IDIF) at its fall meeting, there was another diving fatality with the use of scuba on an underwater ship husbandry operation. This signals that the document’s release cannot happen soon enough.
Lastly, I want to thank Mr. William (Billy) Bratkowski for his service on the ADCI Board of Directors for the past eight years. Billy has served as both first and second vice president of ADCI and has been very instrumental in helping industry address some of its biggest operational challenges. As a director on the board and a member of the DSWG executive board, Billy was able to keep both entities abreast of issues to be worked. A friend to all on the board, Billy will be sorely missed. I wish there was more than one Billy Bratkowski, so that his presence would be at all industry work groups focused on safety.