IMCA's policy and regulatory affairs adviser Eleni Antoniadou and senior diving technical adviser Bryan McGlinchy explain why IMO's decision to update two of its diving safety instruments is timely
IMO’s decision to review its Code of Safety for Diving Systems (1995) and Guidelines and Specifications for Hyperbaric Evacuation Systems (1991), shows that commercial diving safety is an important issue for global shipping and the International Marine Contractors Association (IMCA) welcomes it.
The main aim of the review is to enhance offshore commercial diving safety by amending the IMO diving instruments to reflect the experience and knowledge gained by the industry since these instruments were developed in the 1990s.
IMCA’s delegation at IMO was one of the main advocates of the proposed revision. Together with the Marshall Islands, the Russian Federation, Vanuatu and the International Association of Oil and Gas Producers (IOGP), IMCA submitted technical papers to two different IMO Committees over the winter period and gave a presentation at IMO’s London headquarters to help raise awareness of diving and hyperbaric evacuation system (HES) safety issues.
When the proposal to re-evaluate and revise the diving instruments was considered by IMO’s Maritime Safety Committee on 18 May, it received overwhelming support. The need to review the code and associated guidelines was recognised by 15 IMO delegations, and it was agreed that the proposed new output would be included in the post-biennial agenda of the IMO Sub-Committee on Ship Systems and Equipment (SSE) for 2020-2021.
The exact wording of the new output was recorded as: “Amendments to IMO instruments on diving resolutions А.831(19) and resolution А.692(17) to be harmonised with the current industry practice.”
The code was originally developed to provide a minimum international standard for the design, construction and survey of diving systems on ships and floating structures engaged in diving operations, to enhance the safety of divers/personnel. Chapter 3 states: "An evacuation system should be provided having sufficient capacity to evacuate all divers under pressure, in the event of the ship having to be abandoned …"
Significant advances have been made in the provision and use of HES since the Code was written. New and detailed industry guidelines on the systems have been prepared by IMCA - such as IMCA D 051 hyperbaric evacuation systems (HES) interface recommendations - and by IOGP.
The re-evaluation and revision of the two IMO diving instruments will ensure that suitable diving systems, incorporating appropriate HES, are installed on all ships and floating structures engaged in saturation diving operations. The first SSE review meeting will take place in March 2020, with a target to complete its work in 2021.
One of the main challenges of the initiative is to maintain its momentum over the next two years. IMCA plans a workshop in spring 2019 to give offshore diving industry stakeholders the opportunity to come together to identify and discuss the most important amendments that they believe should be made to the IMO diving instruments. The broader aim would be to facilitate the work of the IMO Sub-Committee when it begins its work.
IMO’s decision to embark on the review is a clear signal that there is broad agreement that the re-alignment of IMO diving instruments with current industry guidelines is necessary. The proposed revisions should have minimal financial implications for the offshore industry generally, but are expected to align IMO publications with current industry practice and so achieve reinstatement of the Code as the minimum standard for diving and HES safety for years to come.
Diving will feature prominently at IMCA’s Annual Seminar (28 -29 November) in The Hague. On 28 November IMCA will be promoting the theme of ‘Working Together: Getting back to business – oil companies and contractors finding new ways of working’. This will be followed by two technical seminars on Diving and Marine, on 29 November. Further information on IMCA’s website.