Clarification from NOPSEMA: Quality assurance of diving system audits

The National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) of Australia published Safety Alert 63 regarding the quality assurance of diving system audits. 

This was passed on to IMCA members as IMCA safety flash 03/17, incident 2 – Quality assurance of diving system audits.  Additional information drawn to the attention of NOPSEMA has made some changes necessary.  The alert has now been re-issued as Safety Alert 63 Rev. 1.

“A number of NOPSEMA inspections have identified a trend in the standard of audits conducted on diving systems and equipment.  Specifically, a number of operators of diving projects and diving contractors have failed to ensure diving system audits have been conducted to an appropriate standard.  While reviewing the audits conducted by the diving project operators and the diving contractors, NOPSEMA’s inspectors identified the following deficiencies:

• Man-riding wire destructive test certification was not adequately assessed, resulting in the failure to identify that the percentage deterioration was greater than that permitted by the relevant International Marine Contractor’s Association (IMCA) code/guidelines and therefore should have been replaced;
• Inappropriate application of a management of change process to justify the deferral of man-riding wire destructive tests;
• Failure to make an emergency services umbilical available for SPHL connection to its life support package;
• A high pressure (200 bar) flexible oxygen hose was found during a NOPSEMA inspection to be too long, made up with joins and was damaged, however it was marked as compliant during an earlier audit;
• Older diving systems built to class have not been upgraded, where practicable, to meet current class requirements e.g. fire suppression systems within diving chambers unable to be externally actuated.

Each of the deficiencies outlined above should have been identified and rectified as a result of the third party or in-house audits.”

NOPSEMA notes that: “Failure to identify audit non-conformances associated with safety-critical elements of a diving system may result in an increased level of risk to the air and saturation divers.  The non-conformance examples provided above have the potential to compromise the integrity of the system components and reduce functionality in an emergency.  Any loss of integrity or system redundancy has the potential to result in serious injury or fatalities to divers and others involved in diving operations.”