Diving operations

The first stage of the approval pathway for undertaking diving at or associated with a facility is for an operator of that facility to have an accepted safety case that specifically addresses diving activities. If diving is to be included in a safety case, the Safety Regulations requires the operator to engage and involve divers and members of the workforce in developing or revising the safety case.

For an operator to engage a diving contractor to undertake diving operations, the diving contractor must have a current Diving Safety Management System (DSMS) accepted by NOPSEMA before diving can commence. The diving contractor may utilise their accepted and current DSMS across one or more petroleum activities and operators.

In addition to a diving contractor having an accepted and current DSMS, a Diving Project Plan (DPP) must be developed, in consultation with the operator and relevant qualified diving personnel. The DPP is required to be approved by the operator, or accepted by NOPSEMA if there is no operator of a facility associated with diving project, before the next step can progress.

The final approval pathway is for the diving contractor to submit, within 28 days of the commencement of any diving, a Diving Start-up Notice (DSN) to NOPSEMA for assessment. Diving cannot commence until the diving contractor and operator receives notification from NOPSEMA that the DSN has been accepted.

The Safety Regulations require operators and diving contractors to undertake revisions of their permissioning documents (Safety Case, DSMS or DPP) under various circumstances. If a revision is required, further consultation with the diving workforce and resubmissions for acceptance or approval will be required before any diving can commence. 

Prepared by the diving contractor, in consultation with their workforce, a diving safety management system (DSMS) sets out how the diving contractor will manage risks to the health and safety of their workforce, while undertaking any diving project, to as low as reasonably practicable (ALARP).

The DSMS must demonstrate, through its contents and supporting materials, how the diving contractor will manage the technical and human activities of their diving project, how safety will be ensured in the event of an emergency, and the methods to be used for monitoring and reviewing their activities to ensure the continual improvement of safety arrangements. 

For further information how to prepare and submit a DSMS to NOPSEMA please refer to NOPSEMA’s Diving Guidelines - Diving Safety Management Systems and Diving Project Plans and Diving Safety Management System submission coversheet in the related documents below.
 

The DSMS must meet all requirements of the Safety Regulations to be accepted.  Once accepted, the DSMS will remain in force for five years. After five years, a revision must be submitted to NOPSEMA for assessment. A revision of a DSMS must also be submitted to NOPSEMA where the diving contractor has identified a new or increased risk or has made a change to how their diving activities will be undertaken.

NOPSEMA aims to make decision within 60 days for new submissions and 28 days for revised submissions.  If NOPSEMA requests further information to assist in making a decision, the assessment timeframe is paused until it receives the requested information from the diving contractor.

The diagram below provides a broad overview of the DSMS assessment process:

Concordance table - DSMS

A DSMS concordance table must be included in the DSMS that clearly indicates which section(s) of the DSMS (including any supporting appendices) address the principles described in Diving Guidelines - Diving Safety Management Systems and Diving Project Plans listed in the related documents below.

Diving contractors should use the DSMS concordance table prepared by NOPSEMA (see Related Documents below).

When a diving contractor has an accepted DSMS, and an agreed contract of work with a facility operator, then they are required to prepare, in consultation with their workforce and the facility operator, a Diving Project Plan (DPP).

The DPP is a detailed plan developed to manage a specific diving project. It must take into account the requirements of the project and dive site, cover the general principles of the diving techniques to be used and provide contingency procedures for any foreseeable emergency, including retrieving injured and unconscious divers from the water.

The DPP must ensure arrangements between the safety management systems of the accepted DSMS and facility safety case are coordinated and clearly understood, and that there is common understanding and agreement between the diving contractor and facility operator on issues such as simultaneous operations and emergency response.
 

All DPPs are assessed by the facility operator in accordance with the requirements of the Safety Regulations. NOPSEMA will assess a DPP where a diving contractor seeks to undertake a diving project where there is no facility operator, such as diving for survey purposes prior to construction of a pipeline or a well that is in a non-producing state.

If a diving contractor makes any changes to the DPP, those changes must be made using management of change procedures in consultation with their workforce and facility operator and be accepted by the operator. The DPP remains in force for the duration of the diving project.

All operator-approved DPPs are required to be submitted to NOPSEMA by the diving contractor in conjunction with the Diving Start-up Notice (DSN) in accordance with the requirements of the Safety Regulations. 

The diagram below provides a broad overview of the DPP assessment process.

Concordance table – DPP

A DPP concordance table must be included in the DPP that clearly indicates which section(s) of the DPP (including any supporting appendices) address the principles described in NOPSEMA's Diving Guidelines - Diving Safety Management Systems and Diving Project Plans.

Diving contractors should use the Diving Project Plan (DPP) concordance table listed in the related documents below.
 

A Diving Start-up Notice (DSN) is required to be submitted to NOPSEMA for assessment at last 28 days before diving is due to commence, or alternatively a lesser period can be agreed between the diving contractor and NOPSEMA if extenuating circumstances exist.  The relevant approved DPP is also required to be submitted with the DSN in accordance with the Safety Regulations.

The operator of a facility in connection with a diving project (or the diving contractor if there is no operator of facility) must not allow diving to commence unless the diving contractor has submitted the DSN (and DPP) to NOPSEMA and received confirmation from NOPSEMA the submission has been accepted.

Diving contractors should use the DSN form when submitting a DSN (see related documents below).
 

The DSN must meet all requirements of the Safety Regulations to be accepted. NOPSEMA uses the DSN to confirm that diving operations are occurring safely and in accordance with the approved DPP and relevant safety case.

Once an assessment decision is made, NOPSEMA is required to notify the operator of the facility in connection with the diving project and/or the diving contractor its decision.  

NOPSEMA aims to make a decision within 28 days of receiving the DNS. If NOPSEMA requests further information to assist in making a decision, the assessment timeframe is paused until it receives the requested information from the diving contractor. 

The diagram below provides a broad overview of the DSN assessment process.

Workforce consultation and participation is mandatory during the development and revision of a DSMS and DPP. Engagement with the workforce ensures they are informed about the risks they may be exposed to during a diving project, and the control measures and safety management systems to be applied in the management of those risks.

It is the responsibility of the facility operator to ensure risks at their facility are managed in accordance with the accepted DSMS, DPP and facility safety case.

NOPSEMA reviews the safety performance of the diving contractor and facility operator through inspections and/or the investigation and analysis of incidents to determine if the Safety Regulations and commitments in the accepted DSMS, DPP and safety case are being followed.

NOPSEMA inspectors have powers to undertake inspections and investigations of diving activities prior to, during, and after diving activities have ceased.  Inspectors may conduct compliance activities at the operator’s facility or regulated business premises, or at a diving contractors’ business premises and dive support vessel (DSV).

NOPSEMA’s diving inspection and investigation powers extend to operators of a facility conducting diving activities, a vessel operating as a DSV, diving contractors, diving supervisors, divers and members of the work force.

In the event a diving accident or dangerous occurrence happens, NOPSEMA inspector powers also extend to a vessel where the accident or incident occurred, regardless or not if the vessel is deemed a facility or an associated offshore place. 

The Safety Regulations require operators to notify and report accidents and dangerous occurrences to NOPSEMA that occur at or near a facility, regardless if they are diving-related or not (see Report an incident).  

In the case where an accident or dangerous occurrence happens on a dive vessel that is not a facility or associated offshore place (e.g. when a dive vessel is sailing away from a facility and decompression procedures are taking place), the diving supervisor is responsible for notifying and reporting the accident to NOPSEMA.
 

The Safety Regulations require NOPSEMA to make available a register of original and revised DSMSs and DPPs.  

(See Register of current diving safety management systems and diving project plans in related documents below).