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This submission is intended to identify what the Australian Diver Accreditation Scheme ADAS considers to be defects in the draft Model Regulations and to propose constructive alternatives that in our view will serve to avoid them. ADAS, the Australian Council of Trade Unions and the Maritime Union of Australia have analysed the draft regulations and feel that they are deficient in a number of ways that effect diver safety. In fact, we feel that the draft regulations result in a lower level of safety and efficacy than those that currently exists, and will adversely affect competitiveness and the adoption of good practice within the construction diving industry. ADAS has conferred widely regarding the draft diving work regulations with divers, diving contractors and employers of diving contractors and divers, including those involved in onshore and offshore construction, military, police, aquaculture and scientific diving operations. There has been substantial interest and concern shown by this very significant section of the diving industry as to the potential impact of the draft regulations. In the broad, we have significant concerns about the effective opening up of general diving work to recreational scuba divers allowed by the draft regulations. We have long argued that recreational scuba training is NOT appropriate to prepare divers for the hazards of occupational diving. We would make the point however, that from our viewpoint, there are many flaws in the draft as presented for public comment. In our view, current regulation in regard to diving work is inconsistent and insufficient in many places across Australia. We feel that the nation has been very lucky not to have had a much grimmer record of casualties resulting from the operations of this high risk industry sector including as it does aquaculture, scientific, police, military and construction diving operations. Fundamentally, humans are adapted to living in air and at one atmosphere of pressure. All diving involves operating in a non-respirable environment and exposure to risk of drowning and injury or death from a number of diving maladies caused by the vastly increased pressure experienced underwater by divers hyperbaric pressure. With occupational diving, additional risks can also result from the work being undertaken, either by the diver himself or from other activities undertaken in support of the diver overhead lifting and lowering, blasting etc. The Dutch Labour Inspectorate www. Immediate medical assistance may not always be possible. The risk from occupational diving is still with the Australian community. Diving accident statistics are notoriously scant around the world and Australia is no different. This is approximately 1 death per year. He was effectively paralysed from the waist down. Training Framework arrangements. ADAS and the industry make the following points in support of these contentions. Failing to mandate the safe practice provisions of The This anomaly results in an unacceptable reduction in the current safety standards of working divers. Such a comprehensive deficiency in the draft regulations is, in the view of the industry, unsupportable. The provisions of Regulation 4. Regulation 4. As this is a complete alternative to a somewhat more robust arrangement in Regulation 4. The diving work undertaken in support of the Tasmania Salmon farms has a similar history. The industry now has a decompression illness incidence of 0. But this is not just an Australian issue. There is for example no recreational equivalent for abrasive blasting. No such distinction is made for diving. They are overweighted so as to stay anchored to the work task. It involves a situation where a leak occurred in the wall of a dam in Victoria. The dam owner then approached the local scuba shop and recruited two scuba divers to do the job. They took an enormous risk to attach a line to the diver. The draft regulations divide diving work in two classes — general diving work and construction diving work. General diving work is defined as all diving work other that construction diving work. Construction diving work is defined as diving work that involves construction work. As noted in Section 4. Furthermore, Regulation 4. As noted earlier, occupational diving is universally accepted to be a high risk activity. Such students are learning to dive and they often make mistakes and do illogical and unexpected things. In , a total of 41 reports were received. Student diver was conducting a 42 metre dive to undertake work on a workbench. During the ascent Diver 1 got entangled with hydraulic tool at 26 meters. Panel operator ordered the tool to be raised. Diver 1 made it to ladder after entanglement issue was cleared at 7 min. Divers blown down to 12m on O2 in chamber and checked but were asymptomatic. Student was completing a progressive circular search in zero visibility tethered to a surface float. During this activity the float line tangled around a boulder that was on the bottom of the lake. Student left surface and commenced undertaking circular search. Then without instruction the student commenced an emergency ascent. At this time the student appeared both stressed and fatigued. Recompression treatment commenced. A 41MSW dive was planned for 20minutes using hydraulic rock drill. A fully qualified standby diver must be at immediate readiness throughout the high risk training. Commonwealth and State governments. ADAS as an example of a qualification that would meet the requirements of the regulation. ADAS, through Regulation 4. The NZ government will have to find another basis for its diving certification requirements. As has already been noted more than once, diving work is universally recognised as a high risk activity. The dive supervisor is the person specifically responsible for ensuring the safety of the diver. The regulations do NOT identify any of the dive supervisor's emergency management roles. As noted earlier, whilst We propose the following two options to resolve this issue. ADAS and the industry at large would very strongly prefer that The industry is very comfortable and familiar with If, and only if, it should prove impossible to call up As noted earlier, it seems obvious that regulation 4. A review of the functions detailed in paragraph 4. Australia are already within the Scheme. Safety Regulation were reprinted as in force on 1 February Greenhouse Gas Storage Safety Regulations We have proposed a number of alternatives to rectify the deficiencies and these are summarised below. North Sea safety authorities Norway and the U. ADAS is structured and operates on a not-for-profit, cost recovery basis. Australia and New Zealand. Department to accredit additional training and certification for any specialist areas should the need arise. The quality and credibility of ADAS training and certification are key elements to this certainty. The following extract from the MOU details the essential operative clauses concerning the administration of the Scheme. These external training providers must meet, and continue to meet, ADAS accreditation requirements. ADAS has over the past decade worked actively to achieve and maintain a prominent international standing. ADAS with the capacity to benchmark its services and activities against international best practices. The IDRF meets annually to report on member activities and to exchange best practice learnings. Technician certifications are recognised in all regions where IMCA contractors operate effectively the whole world. IRG which includes expert representatives from all occupational diving industry sectors. None of the commercial schools are working at capacity at this time. This spreadsheet is a personal compilation of information gathered from the public domain, incident reports and personal communications. Although I have tried to verify details, accuracy is not guaranteed. There are omissions, typos and errors, and it is incomplete. Clarification, input, corrections welcome. In the process of being expanded with as much detail as possible. Use of background fill indicates that this is new or significantly updated data from previous version of the list. Share Embed Flag. View less. Taylor SCUBA Summary diver diving scuba aged divers reported recorded adas recovered australia submssion australian accreditation www.