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September 2022

Diving System Auditing and Assurance – Changing Attitudes

Image: IMCA Auditing and assurance plays a crucial part of ensuring the safety and integrity of any diving system as well as ensuring efficient diving operations. Therefore it is essential that all diving systems are audited by a competent auditor, periodically or post mobilization.
The past twelve months have seen a substantial change in diving system auditing and assurance within the industry due to a requirement for higher competencies of diving system auditors. October 2010 saw the release of the International Marine Contractors (IMCA) Information Note D10/10 Competence of Auditors of Diving Systems and Diving Contractors, which was the first of several IMCA documents giving guidance on the competencies of auditors and the process of diving system auditing against the IMCA DESIGN documents.

IMCA D10/10 identifies that the auditor would be expected to have appropriate operational knowledge of the type of diving system to be audited and to have undergone formal training in auditing techniques. For a safety management company audit aimed at evaluation of the health and safety management company management systems of a diving contractor, the auditor would normally have an auditing qualification, and where the auditor does not have technical diving expertise, be supported by a technical assessor.

Although IMCA D10/10 identifies that auditors of diving systems should have undergone formal training, IMCA have also advised this may not be applicable to auditors who have been carrying out audits over the past two years. Auditors in this position can provide evidence of their auditing experience as well as the ability to demonstrate competencies as laid out in D10/10 to provide assurance of their experience.

IMCA followed up the release of D10/10 with the release of IMCA Guidance Note D011 The Annual Auditing of Diving Systems, in December 2010 which gives guidance on the process of diving system auditing against the DESIGN documents as well as the roles and responsibilities of all involved. The document gives further guidance of the types of audits, frequency and variations of diving system audits, to assist with the planning and implementation of a DESIGN audit. For many years the duration of an audit has been stipulated by the client or auditee depending on the time available between diving operations to carry the audit out. This along with the lack of guidance previously of diving system auditor competency has been the root cause of unacceptable audits being carried out over the years.
Now with the guidance from both IMCA D10/10 and IMCA D011 the industry has a minimum requirement for carrying out diving system auditing against the DESIGN documents. This guidance should be followed globally to ensure diving operations can be carried out more safely and efficiently than previously.

The aim of the IMCA DESIGN documents are to provide a comprehensive reference source addressing the philosophy of what equipment and layout is required for a safe diving operation plus the examination, testing and certification requirements necessary to meet agreed industry practice, applicable anywhere in the world. IMCA are currently in the process of revising the DESIGN documents to ensure diving systems meet the criteria the industry now expects. The DESIGN documents will be released under the title of Diving Systems Auditing and Assurance (DSAA) and should be available early 2012.

OGP Task Force
In addition to the International Marine Contractors Association (IMCA) documentation available to provide guidance for safe and efficient diving operations, the Oil and Gas Producers (OGP) have also developed documentation which is to be followed to ensure compliance with the requirements of OGP within the diving industry. These include OGP 411 Diving Recommended Practice which gives its members engaged in diving operations guidance for a clear and uniform approach to the minimum standard required for managing diving operations.

OGP have also identified the requirement to ensure that diving systems meet a minimum requirement and are audited accordingly. Therefore, OGP have recently set up a task force to develop the OGP Diving Systems Assurance Process. This process will identify a minimum requirement the diving system and supporting documentation must meet and may include documents such as the IMCA DESIGN audit, diving system FMEA, classification society survey’s and planned maintenance systems. Furthermore the process will address a suitable means of auditing Programmable Logic Control (PLC) systems, which are being used throughout diving systems more frequently and will ensure their safety and suitability.

The OGP Diving System Assurance Process task force has been made up of various operators as well as diving contractors and includes BP, Conoco Phillips, Exxon and Shell. The National Hyperbaric Centre (NHC) is also part of the OGP task force and have been contracted to represent Conoco Phillips to provide technical and operational support during the development and implementation of the Diving System Assurance Process.

Industry Development
It is the intent that with the development of the OGP Diving System Assurance Process and IMCA Diving System Auditing and Assurance document, as well as additional information and guidance notes, that safe and efficient operability of diving systems will be greatly improved globally. To assist with the development of diving system safety and efficiency, the National Hyperbaric Centre have developed several products and services which include the Diving System Auditing and Assurance training course. The three day training course provides the delegates with guidance of the process of auditing diving systems and provides a practical hands on auditing exercise utilizing the NHC saturation diving system. This course can be facilitated at the NHC in Scotland or globally where we would carry out the practical session utilizing a local diving system.
The NHC have also identified, through its extensive auditing of diving systems throughout the globe, that one of the major contributing factors of audit failings is certification. Therefore, the NHC has developed a diving system software package DiveCert, which manages all diving systems certification while organizing it in accordance with the IMCA guidance documents to assist with successful audits.
The industry should now be confident that with the initiatives taken by IMCA, OGP and the NHC there should be enough guidance, products and services available to the industry to ensure diving systems can be audited and operated to provide safer and more efficient diving operations. For more information on how to prepare your company for diving audits contact Sandy Harper at the National Hyperbaric Centre

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