Enhancing Offshore Commercial Diving Safety Subcommittee Report

The subcommittee, comprising industry experts and members from the diving community, aims to evaluate the state of commercial diving on the Outer Continental Shelf (OCS) and enhance operational safety. Addressing the inconsistency of CFR 46 Part 197 with industry best practices, the focus groups cover crucial aspects such as hyperbaric evacuation systems, chamber operations, equipment specifications, enforcement, and accountability. By maintaining diverse perspectives, meeting tasks on time, and focusing on OCS diving safety, the subcommittee seeks to make recommendations for the Coast Guard to improve overall commercial diving operations.

• Diving safety
• Commercial diving
• Subcommittee report
• Offshore operations
• Industry best practices

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1. NOSAC COMMERCIAL DIVING SAFETY ON THE OUTER CONTINENTAL SHELF SUBCOMMITTEE NOVEMBER 19, 2014

2. SUB-COMMITTEE BACKGROUND A Subcommittee was formed with the appointment of: A Subcommittee was formed with the appointment of: Four (4) Co-Chairs Two (2) from NOSAC Mike Brown & Kelly McClelland Two (2) from the Public Phil Newsum & Louis Schaefer Two (2) Focus Group Leaders Kevin Lord Focus Group 1 Limor BenMaier Focus Group 4 Sub-committee Members Over forty (40) members from the diving community, or who work in a related industry positions

3. TASK STATEMENT Evaluate current state of Offshore Commercial Diving Operations on the OCS Consider Past Commercial Diving Casualties Improve Commercial Diving Operational Safety on the OCS Develop Recommendations for the Coast Guard

4. BACKGROUND Technological advances have made oil exploration and production in previously inaccessible locations a reality. The search for oil has moved further offshore and into deeper water; new and unique challenges have been encountered. Diver services have been an integral part of this expansion and the diving industry has adapted as well.

5. ISSUE Current Commercial Diving, CFR 46 Part 197 is not consistent and current with Industry Best Practices.

6. SUB-COMMITTEE FOCUS GROUPS Focus Group 1 Hyperbaric Evacuation Systems Hyperbaric Rescue Facilities, Hyperbaric Rescue craft (HRC/SPHL) and Evacuation planning for Sat Divers Focus Group 2 - Chamber Operation & Decompression Competency Focus Group 3 - General Equipment - (Includes Helmet air flow specifications and Inspection) Focus Group 4 Enforcement and Accountability

7. ROLES OF FOCUS GROUPS Actively participate Respect diverse view points Complete assigned tasks within established time periods Maintain a written record (minutes) of all group meetings or conference calls Provide updates as necessary Familiarization with the NOSAC Commercial Diving Subcommittee Task Summary Maintaining the focus of increased diving safety on the OCS when proposing revisions to 46 CFR Part 197

8. LOGISTICS Monthly teleconference Co-chairs Sub Committee Members (40+ Members) Bi-monthly teleconference

9. FOCUS GROUP 1: HYPERBARIC EVACUATION SYSTEMS

10. FOCUS GROUP 1: HYPERBARIC EVACUATION SYSTEMS Purpose The Hyperbaric Evacuation Systems (HES) Focus Group is in the process of creating language for consideration to update the CFR that identifies what is required to ensure survival of saturation divers in the event of a catastrophe that requires an HES launch Goals: Must to be enforceable requirements, not guidance Must be achievable Must to be applicable for several years

11. FOCUS GROUP 1: HYPERBARIC EVACUATION SYSTEMS Overview The Focus Group is comprised of industry experts The Focus Group is working together very well Although the subject is challenging, all members of the Focus Group agree that an acceptable submittal is achievable

12. FOCUS GROUP 2: CHAMBER OPERATION & DECOMPRESSION COMPETENCY

13. FOCUS GROUP 2: CHAMBER OPERATION & DECOMPRESSION COMPETENCY Purpose Purpose To look at the recommended competency criteria for surface chamber operations and decompression. Currently, the only language that speaks to any level of required competency on this subject, in 46 CFR Part 197, is in section 410 (8) (i) A dive team member, other than the diver, is trained and available to operate the decompression chamber;

14. FOCUS GROUP 2: CHAMBER OPERATION & DECOMPRESSION COMPETENCY Goal Goal To establish general and concise competency criteria for surface chamber operations and the training and use of tables and schedules for the decompression of divers. Overview Overview The group has held three meetings. Clarified purpose and task. Reviewed initial document, focusing on training of commercial dive school candidates Decompression Theory Surface Chamber Operations. Discussed other possible pertinent issues Supervisor Responsibility and Accountability. Agreed upon some recommended language for the upcoming revision of 46 CFR Part 197 The Diving contractor is responsible for the selection of decompression tables and schedules, as well as the training of personnel in the use of the selected decompression tables and schedules.

15. FOCUS GROUP 2: CHAMBER OPERATION & DECOMPRESSION COMPETENCY Overview Overview (Continued) (Continued) Determined that input and dive school presence in the focus group would be appropriate. USCG reinforced position that it is looking for industry input on this subject and that all recommendations will be reviewed and considered. Sharing of The Ocean Corporation s curriculum Surface Decompression Chamber Operations and Decompression Theory.

16. FOCUS GROUP 2: CHAMBER OPERATION & DECOMPRESSION COMPETENCY Overview Overview (Continued) (Continued) Discussion on equipment (Focus Group 3 to address). Group to continue to solicit input from commercial diver training programs. Review of work to date and path forward Contractor in-house training and procedures for surface chamber operations will be provided, to complement material submitted from commercial diver training programs. Group to review all submitted material and then formulate a general and concise set of competency criteria for recommendation to 46 CFR Part 197.410.

17. FOCUS GROUP 3: GENERAL EQUIPMENT

18. FOCUS GROUP 3: GENERAL EQUIPMENT Purpose Purpose The General Equipment Review Committee was formed to review the existing equipment regulations listed in the current USCG CFR and to provide recommended changes as necessary to reflect current and future practices on equipment as well as provide flexibility to enable the advancement of technology for years to come. Operators and Diving Contractors that make up this group are industry recognized for their expertise in commercial diving equipment.

19. FOCUS GROUP 3: GENERAL EQUIPMENT Goal Goal: : Review existing USCG CFR as it relates to commercial diving equipment and recommend changes that will modernize the existing regulation, provide flexibility, and allow for future technological advancements The recommendation will accomplish three (3) goals as it pertains to the equipment used in commercial diving: Safe yet sufficient regulations. Enforceability Meaningful use of the regulations

20. FOCUS GROUP 3: GENERAL EQUIPMENT The committee is broken down into two (2) groups The committee is broken down into two (2) groups Surface Supplied and Saturation Diving, and their various modes. They will follow the existing equipment listing in the current CFR s; however some sections may be combined if it is decided by the group to do so.

21. FOCUS GROUP 3: GENERAL EQUIPMENT Surface Supplied Diving Surface Supplied Diving Minimum equipment standards for Specific Modes of Surface Supplied Commercial Diving to be broken down. Shallow Shallow 0 - 30 Deep Deep 31 - 165 Mixed Gas Mixed Gas 100 - 250

22. FOCUS GROUP 3: GENERAL EQUIPMENT Saturation Diving Saturation Diving Minimum equipment standards for saturation diving will be addressed by committee Minimum equipment standards for saturation diving will be addressed by committee in the future. in the future. Breathing supply hoses Divers safety harness General Equipment for all Modes of Commercial General Equipment for all Modes of Commercial Diving Diving Buoyancy changing devices Inflatable flotation devices Divers equipment First Aid and treatment equipment Gauges and time keeping devices Dive ladder and stage PVHO General Pressure piping Compressed gas cylinders

23. FOCUS GROUP 4: ENFORCEMENT AND ACCOUNTABILITY

24. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Purpose Purpose To look into the accountability and enforcement provisions, or lack thereof, To look into the accountability and enforcement provisions, or lack thereof, in the CFRs. in the CFRs. Need to add provisions for enforcement of violations what to do after one violation, second violation, third violation. Right now there is nothing in the CFRs addressing enforcement or punishment for violations.

25. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Goal Goal To establish steps for the repercussions for transgressions for CFR To establish steps for the repercussions for transgressions for CFR violations violations Right now there is no clarity for the steps that need to be taken Nor are there clear penalties for violations Purpose of goal Keep people safer Our goal is not to kill business, but want people to realize there are rules that need to be followed More expensive for the companies in the long run if incidents are happening Added standards will help save lives Don t want turned heads that just accept more expensive procedures want to avoid damage to the assets whether that is people or equipment.

26. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Overview Overview The lack of accountability provisions essentially takes the power out of the CFRs if cannot enforce it, how do you hold anyone accountable and who should be held accountable There is also an issue with cross responsibilities of authorities needs clarification One aspect would be to place enforcement and investigation requirements on the Coast Guard take away OSHA There has been an increase in diving and OSHA involvement but, CFRs are not set up for it.

27. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Overview (Continued) Overview (Continued) Specific issue of not having specificity in results or how any of the transgressions would be addressed by authorities in terms of penalties We should have one authority dealing with issues OSHA has no regulatory authority in Gulf Mexico Would help stop fighting over standing and focus more on the investigation and reporting standing issues are now just causing delays in investigation. Who needs to have responsibilities/accountability: Who needs to have responsibilities/accountability: CFR now addresses responsibilities of the person in charge and supervisor .who else should be included? Contracting company / Company of Hire Project company Project Manager Supervisors Divers Should vessel masters be included?

28. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Overview (Continued) Overview (Continued) Questions: Should we include a difference with inland diving projects? If we have a lead tender and calls up changes to the operation - they are elevated to a different position, but is there accountability? Or a diver that takes over the responsibilities of a supervisors? Offshore Diving personnel Master of vessel or designated person in charge or OIM Directly involved in the oversight and activities of any diving that takes place What about offshore construction/project manager may be representing or employed by the diving Superintendent Surface air divers Smaller job sites designated supervisors

29. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Overview (Continued) Overview (Continued) Should we consider Specific designation Provisions of life sustaining materials i.e. supervisor (day and night) Issue at hand Instead of simply designating certain titles Encourage the requirement of a dive plan to fit the principles of the operation Individuals who designate and sign-off are held accountable. Need to determine what basic practice requirements each should have and what penalties to apply for transgressions of violations Establish clear rules leaving less to interpret by the legal system

30. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Overview (Continued) Overview (Continued) Sample issues with the CFRs - 197.402 Responsibilities of the person in charge vessel or facility Designation of diving supervisors Employees vs Contractors The changes should reflect best practices not to endanger divers on sight and to strengthening the law for utilization of best practices and common sense Terms no longer applicable or should not be allowed in commercial diving projects: 197.410 item 4 scuba divers recommended that it should be eliminated not acceptable in commercial diving Get rid of heavy gear and dry suits not related to each other anymore. Decompression chambers .410 (7)(iii) what is trained and available meant?

31. FOCUS GROUP 4: ENFORCEMENT & ACCOUNTABILITY Overview (Continued) Overview (Continued) 197.420 Require operations and Dive Manuals Similar to SEMS, require approval of Operations and Dive Manuals Determination of whether Criminal or Civil Penalties should apply Blatant disregard of an exceptionally clear directive possible criminal penalties Maintenance of Records: Availability and retention of records and the equipment Who to you report to and where records are stored

32. QUESTIONS?