ADCI‘s New Guidelines for Underwater Ship Husbandry

By Phil Newsum

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It was in early 2014, that ADCI and IMCA held their Chapter and Section meetings in Kuala Lumpur. Mr. Nigel Lusby, with the Shell Center for Diving Excellence, presented at the hugely attended IMCA Asia Section Meeting on a rash of fatalities with the use of scuba while performing underwater ship husbandry (UWSH) on tanker vessels. The incidents were in the Port of Fujairah and occurred in 2013. A total of three fatalities were recorded in the port for that year, and as a result, the port captain mandated that all diving contractors operating in the port had to be either ADCI or IMCA members. Since most of the UWSH operations in the port and anchorage are in 30 meters or less water depth, most contractors opted to pursue ADCI membership. With the Port of Dubai and Abu Dhabi following suit, the number of fatalities in the region was drastically reduced. While there has been one fatality in the Port of Fujairah since that time, the contractor that performed the operation on scuba lost its ADCI membership and ability to work in the Port.

Singapore has also historically experienced fatalities due to the use of scuba with ship husbandry. While folks will tell you that it is a diver certification issue, the real blame must be laid at the feet of the diving contractors, end-users (clients), and the country’s regulatory authority. It appears that over the past several years, the Ministry of Manpower has positively responded to the lack of oversight with commercial diving, specifically with underwater ship husbandry.

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I can also recall being invited to speak at a Town Hall meeting in Trinidad to cite “lessons learned” with the performance of UWSH on scuba, as the country was about to revise its guidelines for commercial diving. To my surprise, many of the local contractors in attendance were opposed to any proposed guidelines restricting the use of scuba with ship husbandry. As a result, the country succumbed to the local contractors demands and allowed the continued use of scuba with UWSH. Even as recently as September of 2019, an international contractor experienced a fatality with the planned operational use of scuba with UWSH.

Because of this industry challenge to operational safety, the ADCI was approached by the International Oil and Gas producers’ Diving Operators Safety Committee to develop guidance for underwater ship husbandry. The proposed guidance would look at such issues as equipment and manning levels, with specific focus on prohibiting the use of scuba. This was first and foremost a priority for all of us on the Diving Safety Work Group (now the International Diving Improvement Forum). This group is comprised of members of the Diving Operators Safety Committee, ADCI and IMCA.

ADCI initially set out to create a document that would encompassing the underwater ship husbandry of all vessels. This presented challenges on several different levels, especially in the area of manning levels. After numerous drafts attempts, as well as presentations and discussions at industry meetings, the Association decided to tailor the guidance to the specific types of vessels that were experiencing fatalities in the performance of UWSH. The result is the ADCI Underwater Ship Husbandry for Cargo Ships/Freighters section of the International Consensus Standards for Commercial Diving and Underwater Operations.

The section is eight pages in length and formatted like that of the other sections of the Consensus Standards. A general description of the various operations that fall under ship husbandry is comprehensively covered. The guidance then goes on to list out safety measures for ship husbandry, with a detailed outline of the lockout-tagout (LOTO) of vessels. The section also provides a robust requirement for a clear and concise dive plan and what the dive plan should adequately cover. The guidance examines minimum personnel requirements for performing UWSH on vessels of this size and the necessity of a thorough dive plan, risk assessment analysis and job hazard analysis. It also sets out the duties and responsibilities for the diving supervisor, diver, standby diver and tender/divers.

Minimum equipment requirements are also provided and most importantly the operational guidelines are presented in a very black and white manner, that leaves no room for misinterpretation. For example, “THE USE OF SCUBA IS NOT AUTHORIZED FOR THE PERFORMANCE OF UNDERWATER SHIP HUSBANDRY OPERATIONS.” The requirement for when a DDC is also spelled out, along with the requirements for diver umbilical and hull-cleaning machine umbilical management.

In summary, guidance documents are only as good as the commitment of diving contractors to follow it. The ADCI has solicited the input of stakeholders across the globe. There was no rush in the development of the guidance, as we wanted something that everyone felt vested in. Hopefully, the development and issuance of this new section of the ADCI Consensus Standards will help mitigate diving-related accidents in the performance of underwater ship husbandry.

A sincere thanks to all the various individuals and work groups who took the time and opportunity to provide comments and input during the development and review process of the new ADCI UWSH guidance.