IN WESTERN AUSTRALIA - Department of Mines and Petroleum

32
PWA April Edition - Diving Regulations
Andrew Pearce
Senior Safety Assessor, Safety and Environment Branch
Diving is regarded as a relatively high-risk activity
and is one of the industries associated with oil
and gas exploration and production that has been
regulated by Direction for many years. The move
away from reliance on prescriptive Directions to
objective based regulations is ongoing.
Prior to the introduction of the Commonwealth
Petroleum (Submerged Lands) (Diving Safety)
Regulations 2002 (Diving Safety Regulations) in
May last year, diving operations in both
Commonwealth and State areas were regulated
by Direction under Part 8 – Diving of the Schedule
of Specific Requirements as to Offshore
Petroleum Exploration and Production 1995 (the
Offshore Schedule).
Part 8 Diving of the Offshore Schedule was
revoked for Commonwealth areas following the
introduction of the Diving Safety Regulations;
however, diving in WA State waters is still under
the requirements of the Offshore Schedule. It is
anticipated that WA will mirror the Diving Safety
Regulations before the introduction of NOPSA
(National Offshore Petroleum Safety Authority) in
January 2005; these will apply in State waters
and the diving section of the Offshore Schedule
will be revoked.
Diving Safety Regulations
The Petroleum (Submerged Lands) (Diving Safety)
Regulations 2002 - Diving Safety Regulations) were
developed by a tripartite working group (diving
contractors, oil industry and State and
Commonwealth regulators).
Diving Regulations
These are objective based regulations with a
minimum of prescription. The main regulations
require:
• diving contractors to develop and implement
their own Diving Safety Management System
(DSMS);
• diving contractors and operators to develop a
Diving Project Plan (DPP) to identify hazards and
control risks for the specific project; and
• involvement of employees in both the DSMS
and DPP.
There are other regulations covering reporting,
recording, notification, responsibilities and
qualifications for diving personnel.
The diving contractor’s DSMS must be submitted to
the Designated Authority (DA) for review and
assessment and have the acceptance of the
regulator before the diving contractor can operate in
the upstream petroleum industry.
In addition to the DSMS, the diving contractor in
conjunction with the Operator (client) prepare a Diving
Project Plan (DPP). The Operator accepts the DSMS
and must approve the DPP for use in the execution of
works by/for the Operator before diving operations
can begin. The DPP does have to be submitted to the
DA for acceptance or approval; however, the DA can
request a copy for review and auditing.
The DSMS and the DPP are the rules by which the
diving project must be executed. Works conducted
in breach of the diving contractor’s DSMS and the
diving project plans are in breach of the diving
safety regulations.
Diving Safety Management Systems
Submissions
Many contractors were daunted by the prospect of
documenting their management systems and
revising their current documentation to ensure
compatibility with their revamped systems and
submitting them to the authorities. However, after
going through the process the overwhelming
response from the contractors was positive, with the
general acknowledgement that they wished they
had done this sooner.
Operators and the DA may audit the diving
contractor to ensure the DSMS is implemented and
they are complying with it. The DA audits operators
diving projects against the requirements of their DPP.
By the end of last year DoIR (as the Western
Australian DA) had assessed and accepted DSMS
from 5 diving contractors and provided advice to the
Victorian DA on a submission there.
There are 7 contractors with their DSMS accepted
by the DA in Australia. This represents the majority
of offshore diving contractors operating in the oil
and gas industry.
What diving approvals are required?
In WA there are 2 areas of jurisdiction: WA State
waters, where the diving requirements in the Offshore
Schedule apply and the Commonwealth Adjacent
Area where the Diving Safety Regulations apply.
Commonwealth Adjacent Area
From a DoIR perspective, operators are required to
review and accept or approve the management
systems of their subcontractors. With diving
contractors, operators are obliged to review and
approve their DSMS before developing and
approving the DPP. Operators need to ensure that