Nearly a year has now passed since the 2014 version of the Approved Codes of Practice (ACoP) was published – so what implications has it had since its introduction? First impressions would suggest a very positive impact, no real challenges to the revised content, and what would appear to be a broad acceptance that the changes were timely, well thought through and fully warranted.

I suppose you could say that is pretty much as expected, as industry representatives were very involved with the HSE in developing the changes – after all, ownership is the important thing here. If it was simply all about the Regulator telling us what we should or should not be doing, many more challenges could have been expected, but when industry helps guide the changes to include what should be considered as industry best practice, significantly less hassle should result.

The topics that seem to have generated the most comment or attention are the subtle changes to the team size requirements and, most importantly, the selection of equipment appropriate to the task, location and prevailing conditions.

Despite popular misconception, the use of a five-man team when using surface supplied equipment has for sometime been the accepted minimum, and has been the norm for many contractors. The fact that it is now in print in an important guidance document only helps to ensure that there is less wriggle room for clients or others who may try to interpret safe requirements in a different way.

UNDERSTAND

I would say that the jury is still out on the changes to the wording about the availability of compression chambers. Whilst contractors had come to understand the requirement for access to a chamber on site, or availability within two or six hours travel time, the revised wording, which effectively removes the two-hour requirement and forces availability to be established as a result of a robust risk assessment, is likely to be more challenging and will take sometime to settle down.

Sadly the time required for the understanding to settle down will probably mean that the HSE has to stress test some of the emergency plans that they are presented with on site, and that means some contractors might be exposed the recovery costs under the Fee for Intervention scheme that now exists. Only then will we get a clearer understanding of what should and should not be included in the emergency action plan.

Taking a brief look at the industry’s safety performance over the longer term, the step change in the approach to health and safety that occurred around 1997 with the introduction of the current regulations and first use of the ACoP has improved safety. However, there is still scope for improvement. Whilst aiming for a zero figure in terms of fatal accidents and major incidents remains the objective, in the very diverse industry sector covered by the scope of the inland/ inshore ACoP, actually achieving and maintaining a zero figure is a tall order.

In October, the HSE should make available the updated statistics for the period ending 4 April 2015. Sadly, we already know that there have been some fatal accidents in one sector – let us hope that the other statistics indicate that the efforts now being put in to the planning and conduct of commercial diving operations in this sector are continuing to show through.

Roger O'Kane, ADC Secretary

secretary@adc-uk.info