| 1. WHS Governance, Legal Compliance and Diving Operations Management |
- • Absence of a documented WHS and diving operations governance framework aligned with WHS Act 2011, WHS Regulations and AS/NZS 2299 series
- • Inadequate identification of diving work that is ‘high risk’ under WHS Regulations and failure to apply additional controls
- • No clear allocation of PCBU, officer, supervisor and diver responsibilities for commercial and professional diving activities (including police, military, research and aquaculture diving)
- • Inadequate process to approve and manage specialised diving activities (e.g. saturation diving, mixed gas, nuclear, underwater demolition, blasting, offshore and maritime security diving)
- • Failure to integrate diving WHS risks into the organisation’s overall risk management system and risk register
- • Inadequate review of lessons learnt from incidents and industry alerts, including hyperbaric and chamber events
- • Poor consultation with workers, contractors and health and safety representatives on diving safety matters
- • Lack of assurance that third‑party diving contractors maintain compliant systems (audit, pre‑qualification, verification of competency)
- • No formal management of change (MoC) process for new dive techniques, equipment types (e.g. rebreathers, surface supplied systems) or locations (caves, wrecks, ice, nuclear, harbour clearance, overhead environments)
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| 2. Competency, Training and Diving Authorisation Systems |
- • Divers, supervisors and support personnel lacking appropriate qualifications, licences and experience for specific commercial and professional diving activities
- • Inadequate verification of competency for advanced activities such as saturation diving, deep water decompression, cave and overhead environment diving, nuclear diving, underwater blasting and demolition, and underwater criminal investigation
- • Failure to provide and verify specialist training in diving physiology, decompression theory, emergency surface ascents, in‑water recompression (where allowed by policy), diver rescue and hyperbaric chamber operation
- • Insufficient training in specific techniques such as use of lift bags, use of bailouts, night diving, low visibility diving, ice diving, high current and surge, wreck penetration, bowline tying under water, stage cylinder rigging and left surface mark buoy deployment
- • Lack of competency frameworks for non‑diver roles such as dive coordinators, supervisors, life support technicians, chamber operators, and topside support staff for saturation systems
- • No formal assessment of competency to use planning tools such as dive computers, decompression tables, PADI RDP training, running decompression software and nitrox/trimix blending calculations
- • Poor maintenance of records of training, assessments, refresher training and authorisations to dive for specific tasks (research diving, police diving, military and special forces diving, underwater photography, maritime security diving, aquaculture diving)
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| 3. Fitness for Work, Medical Assessment and Fatigue Management |
- • Inadequate diving medical assessments for commercial and professional divers, including those involved in saturation, mixed gas, overhead environment and nuclear diving
- • Lack of processes to monitor and manage acute and chronic health issues relevant to diving (cardiovascular conditions, respiratory illness, seizures, mental health, obesity)
- • No screening for impairments due to alcohol, drugs (including prescribed medication) or other substances that may elevate risk in diving and hyperbaric environments
- • Poor fatigue management for extended shifts, offshore rotations, night diving, saturation system crew, hyperbaric chamber staff and emergency response teams
- • Absence of policies to limit breath‑holding diving and free diving in commercial and professional settings where not essential, or to manage their specific risks where required
- • Inadequate management of stress, anxiety and claustrophobia associated with cave diving, wreck penetration, overhead environments, nuclear diving and hyperbaric chamber operations
- • Lack of a process to ensure divers are acclimatised to cold water diving, high altitude diving and extreme thermal environments prior to undertaking demanding tasks
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| 4. Dive Planning, Hazard Identification and Job Safety Analysis |
- • Inadequate pre‑dive hazard identification for varied work such as aquaculture diving, harbour clearance, maritime security, research diving, underwater photography, inspection, maintenance and underwater criminal investigation
- • Failure to recognise specialised hazards of overhead environment diving, wreck diving, cave diving, swimming through narrow spaces and diving into untested waters
- • Poor assessment of environmental conditions such as currents, visibility, water temperature, tides, surf, ice conditions and vessel traffic for offshore and near‑shore operations
- • Lack of systematic differentiation between routine diving and high‑risk tasks such as underwater blasting, cutting and welding, pile driving, subsea drop testing and nuclear diving
- • Inadequate consideration of altitude, depth, repetitive diving, decompression stop diving and test depth diving in planning decompression strategies
- • Insufficient integration of research or police operational requirements with WHS risk controls, leading to unsafe compromises in dive plans
- • No formal process to halt unnecessary diving where risk is disproportionate to operational benefit
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| 5. Decompression Management, Gas Planning and Physiological Risk Control |
- • Inadequate decompression planning for deep water diving, repetitive dives, saturation diving, mixed gas diving and diving at altitude
- • Over‑reliance on dive computers or decompression software without verification against tables or organisational rules
- • Incorrect use of PADI RDP training principles and decompression tables for commercial profiles not suited to recreational algorithms
- • Nitrogen narcosis, oxygen toxicity, carbon dioxide retention and inert gas loading mismanaged due to poor gas planning and monitoring
- • Inadequate procedures for nitrox blending, trimix blending and gas analysis leading to incorrect gas mixtures being used
- • Lack of structured management of decompression sickness incidents, including in‑water recompression, therapeutic recompression and hyperbaric treatment
- • Insufficient control of breath‑holding/free diving practices in combination with scuba or surface supplied diving, increasing risk of lung barotrauma and decompression stress
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| 6. Diving and Hyperbaric Equipment Procurement, Configuration and Maintenance |
- • Procurement of diving, surface supplied and saturation equipment that does not meet relevant Australian Standards or is unsuitable for intended commercial and professional activities
- • Inadequate maintenance systems for critical life‑support equipment including regulators, rebreathers, bailout systems, dive computers, masks, dry suits, hot‑water suits and communications
- • Improper configuration of technical diving gear such as stage cylinders, rebreathers, mixed gas systems and bailout rigs for deep, wreck, cave and overhead environment work
- • Failure of surface supplied systems, umbilicals, helmet/hard hat diving equipment and associated communications due to poor inspection, maintenance or configuration control
- • Lack of formal management of changes to equipment types, configurations, software versions and firmware for dive computers and monitoring systems
- • Inadequate maintenance and inspection of hyperbaric chambers, saturation systems, life support systems, emergency gas supplies and associated control systems
- • Improper storage, handling and transport of cylinders, high‑pressure gases, nitrox/trimix blends, and explosives used in underwater blasting and demolition
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| 7. Vessels, Platforms, Access and Logistics Management |
- • Poorly controlled loading of dive boats and support vessels, including cylinders, lift bags, explosives, tools, cranes and drilling equipment
- • Insufficient vessel stability and deck layout design for safe diver entry, exit, gear donning/de‑kitting and manual handling in rough conditions
- • Inadequate integration of vessel navigation and WHS controls in busy harbours, ports and offshore locations used for harbour clearance, maritime security and offshore diving
- • Lack of safe systems of work for use of cranes, A‑frames, moonpools and other launch and recovery systems in subsea drop testing, underwater pile driving and offshore diving
- • Poor planning for remote and offshore logistics including fuel, spares, emergency equipment, communications, and medical support
- • Failure to manage the interface between vessel operators, diving contractors and other PCBUs regarding responsibilities and emergency response
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| 8. Work Environment, Water Quality and Biohazard Management |
- • Exposure to contaminated or polluted water during harbour clearance diving, underwater criminal investigation, nuclear diving, aquaculture diving and maintaining underwater exhibits
- • Biological hazards from marine life (e.g. sea urchin diving, lobster diving, aquaculture pests, stings, bites, infections) and biofouling on underwater structures
- • Poor control of biohazard diving activities, including work involving sewage, medical waste, carcasses or contaminated sediments
- • Insufficient assessment of nuclear, radiological or chemical hazards in specialised nuclear diving environments
- • Inadequate management of water temperature extremes, including cold water diving and ice diving, leading to hypothermia or cold stress
- • Unassessed hazards associated with diving into untested waters, such as submerged obstacles, entanglement risks and unknown contamination
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| 9. High‑Risk and Specialised Diving Activities Management |
- • Lack of specific system controls for complex diving such as cave diving, wreck diving, overhead environment diving, swimming through narrow spaces and overhead environment isolation
- • Inadequate planning and controls for saturation diving, saturation system maintenance and deep sea/offshore diving activities
- • Poor governance of underwater blasting, underwater demolition, underwater cutting or welding, underwater drilling and underwater pile driving
- • Insufficient risk controls for military, special forces and police diving where operational imperatives may pressure WHS decision‑making
- • Inadequate systems for night diving, low visibility diving, high current diving and diving at altitude
- • Overextension of recreational methods and equipment into technical and commercial environments (e.g. using recreational standards for deep technical or mixed gas diving)
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| 10. Communications, Signals and Situational Awareness Systems |
- • Failure or absence of reliable communications between divers and surface support during commercial, police, military, aquaculture and research diving operations
- • Lack of training or adherence to diving signals, including line signals, light/torch signals for night and low visibility diving and hand signals
- • Poor situational awareness in complex environments such as wrecks, caves, overhead structures and construction sites with cranes and pile driving
- • Inadequate procedures for lost diver, lost line, entanglement or out‑of‑gas scenarios in low visibility or high current conditions
- • Insufficient marking and monitoring of dive sites in areas with vessel traffic, including harbours and offshore work sites
- • Absence of effective communication protocols during emergency events in saturation systems, hyperbaric chambers and underwater blasting operations
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| 11. Emergency Preparedness, Rescue and Hyperbaric Incident Response |
- • Inadequate emergency response planning for diver rescue, emergency surface ascents, uncontrolled buoyant ascents and entrapment scenarios
- • Lack of effective on‑site rescue capability for overhead environment, wreck, cave, under‑ice and confined space diving environments
- • Insufficient capacity and procedures for hyperbaric emergencies, including chamber fire, rapid decompression, medical emergencies during treatment and power failure
- • Poor coordination with external emergency services for offshore, remote and nuclear diving sites
- • No structured approach to emergency recall and stand‑down of diving operations during severe weather, vessel emergencies or site security events
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| 12. Information Management, Documentation and Record Keeping |
- • Incomplete or inaccurate recording of dive profiles, gas mixes, decompression schedules and incidents, impeding analysis of decompression sickness and other events
- • Poor documentation of maintenance, inspections and testing for diving and hyperbaric equipment, including saturation systems and chambers
- • Loss or fragmentation of training, competency and medical records for divers and support staff
- • Inadequate version control for dive plans, procedures, decompression tables, decompression software configurations and emergency plans
- • Failure to capture and share lessons learned from incidents, near misses and industry alerts across all teams and sites
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| 13. Behavioural Safety, Culture and Operational Discipline |
- • Normalisation of deviance, where divers and supervisors routinely accept shortcuts to decompression, gas planning or equipment checks
- • Production or mission pressure overriding WHS controls in commercial, military, special forces, police and research diving operations
- • Poor reporting culture, with divers reluctant to report near misses, decompression symptoms, equipment failures or breaches of procedure
- • Inconsistent adherence to buddy systems, checklists, pre‑dive briefings and post‑dive debriefings
- • Complacency in routine tasks such as aquaculture diving, maintaining underwater exhibits or repetitive harbour clearance diving
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