Defence Maritime Regulator Superintendent of Diving Joint Service

Defence Maritime Regulator Superintendent of Diving Joint Service Diving Safety Conference 7 March 2018

DST Brief - Aim. • Who we are. • What we do. • Context of UK MOD diving activity. • Current issues. • DSO (AT) Update.

Who we are

Background 2002 Pelley Report - Defence Diving Regulations. 2003 HSE Crown Censure. - RN DST formed. Army Inspectorate co-located. - AT Inspectorate added to DST - S of D role detached from ops to focus on safety. 2012 DST & Army inspectorate merge to form DSEA DST. 2015 DSEA DST becomes DSA DST. - Commercial Inspectorate added.

What we do

Defence Maritime Regulator (DMR) “To protect people and the environment from the risk of harm arising from Defence Maritime activity. ” Responsible to the Director General, Defence Safety Authority for: - Independent assurance of compliance against Legislation and Regulation. - Provision of Maritime and Safety regulation (Shipping and Diving Regulation), advice and guidance on compliance. - If necessary enforce compliance (Improvement/Prohibition).

Diving Legislative Framework Legislation • Health and Safety at Work Act, 1974. • Diving at Work Act, 1997. NB: MOD derogation for Warfare and Training for Warfare. Guidance: • HSE Inshore Approved Code of Practise - Inshore ACOP • HSE Recreational Approved Code of Practise - Recreational ACOP.

Diving (and AT) Regulatory Framework DSA HQ • DSA 01. 1 • DSA 01. 2 Amplification of the Sof. S Policy Statement for Health, Safety and Environmental Protection. Implementation of Defence Policy for Health, Safety and Environmental Protection. DMR • DSA/DMR 02 - Shipping Regulations. • DSA/DMR 02 - Defence Diving Regulations. • DSA/DLSR 02 – Adventurous Training Safety Regulations. Guidance: • DSA 03/DMR/DCOP 20 – Guidance on Military Diving Projects. • DSA 03/DMR/DCOP 21 – Guidance on MAB Diving Projects. • DSA 03/DMR/DCOP 22 – Guidance on JS Sub-Aqua Diving Projects. • BRd 2806 series and BR 2807. • JSP 419 – Adventurous Training in the UK Armed Forces. • BSAC Safe Diving.

Governance of MOD Diving. Duty Holding. • Management of activities that are hazardous and present a creditable and foreseeable Risk to Life. (DSA 01. 2). Supplements Duty of Care • DH is Personally Accountable for the safety Diving activity. • DH defines and proactively manages the operating envelope. • Must be able to demonstrate that equipment used is safe to operate and can be operated safely (safety case).

Duty Holder Organisation

DST Role “To act as the focal point of all Diving conducted by the MOD by delivering regulation, assurance and specialist advice whilst promoting safety culture, the consistent and coherent interpretation of Regulation and the cross pollination of best practice across the diving domains” How: • Audit the compliance of DH Organisation with Defence Diving Regulations. • Certification audit of Diving Safety Management Systems. • D&G on policy compliance and risk control. • Exemption Certificates. • Accident Investigation in support of DAIB. • HSE focal point for MOD diving activity.

Management of Latent conditions Governance – Assurance – Regulation Diving Safety Management System Barriers/Risk Control Systems (Equipment, Training, People, Doctrine) Accident Investigation

DST Structure

Context

HUNT MCMV SANDOWN MCMV FLEET DIVING SQUADRON (FDS)

Army Military Diving Recovery Fast Water Bosnia Afghanistan EOD/UXO Search & Disposal Drowned Vehicle Recovery Cullingworth Bridge (Largest Task Since WWII) Defence Engagement Sewer Search Underwater Engineering Ice Diving - NATO (Canada) Demolitions VVIP Visit Obstacle Removal HM The Queen – Corps Review

Defence Diving School RN ARMY 114 Students. 84 Students.

Commercial Diving § Audits to ensure compliance with the DWR 97 and HSE Commercial Inshore ACOP. § MOD largest commercial contractor in UK. § Principal contracts within HM Naval Bases (Babcock/BAE/Shearwater). Principal engineering support contracts (UMC) for RN and RFA. § Sub Diving contractors (20+ Diving contractors). §

Current issues

Current Issues • DMR Review of Diving Governance. “ poor overall awareness of the diving scene in the Ministry of Defence” Pelley 2002. • Overall improvement but still evolving. • Key factor in most areas: • systemic shortage of SQEP. • poor understanding of legislative and regulatory obligations. • Inconsistent application of Duty Holding across domains.

JSAT OBSERVATIONS Recognised: The challenge of maximising participation in the activity whilst also complying in full with the DWR which places additional legislative obligations on those involved. (e. g. Tri-Dive Medicals) Impact on BSAC Branches – driving people away. Pros: Robust safety culture throughout. Training very well managed at MILMACS with comprehensive safety management. COMMAC working well. Robust expedition approval process in place. Proactive management within Associations and good communication.

JSAT OBSERVATIONS ? ✔ Role of “Sponsor” poorly defined wrt diving obligations. Collective responsibility and accountability – no “Accountable Person” defining the operational envelope. Capability Management not in place to manage risk controls and support Associations and their Branches. Equipment Management – no process to demonstrate the safety argument potential for unsafe equipment to be unintentionally introduced. Branches not certified/out of date.

Way Forward? 1* DMR led Working Group. • Defining the role of Sponsor. • Duty Holding linked to Sponsor? • Senior Operator for JSAT Diving? • Duty of Care? • Should/can JSAT Diving be “capability managed”? • Can any synergy be exploited between AT/military equipment? • Certification of Branches - DST surge to complete as soon as possible.

Current Issues • Association Branches - At Work? • HSE Medicals – Try dive. (INM Lead). • Decompression comparison/modelling. • Dive Computer guidance. • Non Freezing Cold Injury (NFCI). Protection, guidance and monitoring. • DSM 1/18.

RN/RMSAA BSAC Branches RN Branches Last Audit HMNB Gibraltar 317 19 -Sep-17 NSAC Dive Club 12 -Apr-17 PWRNSAC (HMS Collingwood) 13 -Jan-16 RMB Chivenor Mar 16 RNAS Culdrose 2016 Status BRNC Dartmouth 10 -Nov-17 DSC NOT issued* RNAS-CTCRM 01 -Mar-16 Closed

ASADA BSAC Branches Army Branches Last Audit ASADA (Army) Colchester Orca SAC (COSAC) 17/10/2017 RESDA (Royal Engineers) 05/05/2017 Lisburn and Glenavy SAC (0719) 01/05/2016 Marchwood SAC 01/12/2014 KIWI SAC (Formed 1984) 01/11/2014 Status ADMIN ONLY Blandford Garrison SAC (0733) RASAC (Royal Artillery) ADMIN ONLY Defence Medical Services Diving (DMS) ADMIN ONLY Uniake SAC TBC

RAFSAA BSAC Branches RAF Branches Last Audit Status Brize Norton SAC 07 -Dec-17 Leeming 05 -Sep-17 DSC NOT issued Benson 27 -Nov-17 Cosford 25 -Oct-13 2 May 17 TBC Odiham 14 -Sep-17 Waddington, Scampton & Digby Halton 12 -Sep-17 Newquay, Cornwall 02 -May-17 Omega (St. Mawgan) ASAP Marham 02 May 17 Lossiemouth 11 -Jan-17 Coningsby 07 -Nov-14 Henlow 05 -Nov-14 Cranwell 17 -Jul-13 Audit arranged 22 Mar 18 Honington (aka Buccaneer Divers) 01 -Nov-12 Audit arranged 5 Apr 18 ASAP Boscombe Down 11 -Feb-15 Closed Falkland Islands 06. 11. 16 Closed

ATFW CASTLE MARTIN “Vobster Quay” Diving Standards Team (AT) Area of Operations “Stoney Cove” JSSADC PLYMOUTH Gibraltar Exped 150+ “Safari Diving” LANZAROTE “Dive Shack” MALTA Dive Deep Blue MALTA JSATWC CYPRUS “Dive In” & Kembali CYPRUS “Scubamaster” BAHRAIN “Eurodivers” OMAN Ascension Exped 230+

Questions