India has an EEZ of 20.4 Lakh Sq Km and large oil and gas fields which are predominantly located in offshore waters off the Eastern and Western coasts of India with their offshore infrastructure installed at varying depths of water. The Oil and gas industry requires a large number of support services for its continued development and maintenance and amongst these is ‘subsea intervention’ comprising of manned diving and use of Remotely Operated Vehicles.
The Commercial Diving Industry in India was pioneered in the early 80’s but to date there is no legislation in place to govern this sector nor the Oil & Gas industry in it’s entirety. This has sadly led to a number of accidents and fatalities not only within the Commercial diving industry but also the oil and gas sector as a whole, the most recent being the loss of a work barge at sea with many lives being lost and their families dreams shattered.
The magnitude of subsea intervention work that needs to be undertaken to realize the full scope of the Underwater Domain Awareness initiative driven by the Maritime Research Centre, comprises of Commercial Diving (Inshore & Offshore), Scientific Diving and Archeological Diving. It is of utmost importance that concrete steps are taken for developing broad legislation to regulate such diving activities. The legislation should be supported by a mandatory regulatory compliance control frame work and Codes of Practice (COP) that lay down minimum safe requirements prior to the conduct of such diving operations.. The framework & COP when implemented will improve safety tremendously, making the Diving Contractors accountable for safety, impose duties on employers and employees and also act as a basis for enforcement and prosecution should employers choose not to comply.
A safer diving industry instills confidence in the existing Diving fraternity to continue with their profession and encourages the next generation to take up this career path that needs courage, resilience and dedication to serve the nation. From the National Development point of view the need to regulate and develop the nations offshore and inshore diving capability is of great significance since ‘Diving’ Support will always be required to build underwater assets and maintain ageing subsea infrastructure.
This blog is a yellow paper for further consideration and acceptance at the appropriate forum, administrative and governance level.
India needs to urgently consider developing and implementing a National Regulation that would facilitate creation of an expert regulator for Offshore Oil & Gas Operations including commercial / civilian diving operations both offshore and inshore . The aforesaid regulation first needs to be drafted, discussed and approved at the Parliamentary Level and passed as a Law.
- These proposed Indian Diving Regulations shall apply to all those engaged in any diving project either Inshore or Offshore with the exception of the following
- the care or treatment of patients in a hospital or other place, not under the control of the diving contractor, where emergency medical treatment is provided or in transit to such hospital or place where the means of transit is provided by or in respect of the hospital or other place;
- operations in which members of the armed forces of the Crown or of a visiting force are engaged in warfare or training for warfare;
- work carried out in any air which is compressed in order to prevent the ingress of ground water to the works or to stabilize the area around the works.
- Any compressed air work in support of tunneling operations
- These Regulations shall apply to and in relation to the premises of Indian occupation and commercial diving activities conducted offshore and in inshore territorial waters and costal EEZ
- Duty to ensure compliance with these Regulations
Every person who to any extent is responsible for, has control over or is engaged in a diving project or whose acts or omissions could adversely affect the health and safety of persons engaged in such a project, shall take such measures as it is reasonable for a person in his position to take to ensure that these Regulations are complied with.
For Offshore Oil and Gas Diving Operations – the regulation would define (inclusive of but not limited to).
- The Role and Responsibility of the Oil and Gas Operator / End User.
- The Role and Responsibility of Employer (all Contractors)
- The Role and Responsibility of the Diving Contractor.
- The Role and Responsibility of the DSV/ Barge Owner and Operator.
- The Role and Responsibility of the DSV Master and DPO.
- The Role and Responsibility of the Diving Personnel ( also known as Employees).
- The Role and Responsibility of the Employee .
- Define the duties of the Employer and Employee from a Health & Safety Context
- Define with support of the Diving Control Framework the minimum compliance requirements prior to commencement of a Diving Operation.
- Identify Diver Training Institutes both Nationally & Internationally that are credible and approved to provide diver training..
- Identify the need for a vessel Safety Case when offshore work vessels( Eg: Dive Support vessel) are operating close to manned offshore platforms Stipulate maximum age requirements for specialist vessels (eg; Diving Support vessels) for conducting Diving Operations in an Offshore environment close to platforms.
- Promote and Enforce, use and employment of Indian Nationals in the Offshore energy sector to achieve self reliance
- Define the concordance tables for the Diving Contractor Diving Safety Management System.
- Define the concordance tables for the Project Specific Diving Project Plan.
- Identify the Nodal agency that shall be responsible for auditing and approving the audits associated with Diving Systems and the qualification of the auditors, this will need competence and capacity building.
- Define the Emergency Response Plan arrangements that need to be in place prior to commencing Diving Operations, that would ensure that safe recovery of divers in saturation should the DSV integrity be compromised at sea.
- Identify the Diving Medical Specialists who are able to provide assistance in the event of a Diving Emergency
- Define the competencies, Role and Responsibility of the Regulators Site Representation at a Dive Site.
- Define grievance redressal protocol.
- Define the incident / accident reporting and investigation protocols.
- Define the extent of Public Participation and RTI.
The guideline for the inshore, scientific and Archeological diving shall be developed more or less on the above lines, but may not be as onerous as those for offshore diving operations.
For the Legislation to be drafted, an Executive Advisory Team should be constituted, the Team would be inclusive of but not limited to those below mentioned
- Be led by a seasoned and experienced Parliamentary Mentor who will be the voice of the executive team in the Parliament to facilitate the approval of the Diving Legislation.
- Naval Representation.
- Working Groups comprising of Diving Subject Matter Expert(s) who have minimum 30+ years experience in the field of Offshore Oil and Gas Diving Operations having worked with Oil and Gas Operators that operate under a Diving Legislation and recognized by the Indian Commercial Diving Fraternity. These individuals shall have no conflict of interest.
- Diving Doctor(s) who possess National and International accreditation as Hyperbaric Doctors.
- Support from National Informatics Centre for Digitizing and creating an app that will interface all aspects of this Legislation, Executive Team Functions, Stake Holders, Service Users, Diving Contractors, Divers and the Public.
- Operational Support Team
“Diving Advisory Group” acronym DAG(India) would be the nodal agency for dissemination of diving knowledge, enhancement and provision of diving advisory service to the Nation. The key interfaces will be identified in detail following the setting up of the Executive Advisory team.
The role and responsibility of this Executive Team shall also extend to
- Developing the Diving Control Framework and Codes of Practice(COP)
- Rolling out the COP to the Diving Contractors through forums
- Appointing competent Diving Safety Inspectors to enforce the Codes of Practice.
- Defining the roles and responsibilities of such Inspectors
- Interfacing with other Regulatory Bodies
It should be noted that the Control Framework and Codes of Practice will contain detailed information pertaining to the assurance process and a few examples are below:
- Approval of Diving Contractors
- Approval of Diving Contractors Diving Safety Management System,
- Verification audits of Diving Sites to ensure compliance is maintained
- Appointment of competent Diving Inspectors to enforce the Regulations
Offshore commercial diving is undertaken throughout the lifecycle of an offshore energy project from supporting its construction, to carrying out inspections and repairs to decommission. The work is inherently dangerous requiring its workforce to work under challenging conditions and operate specialized equipment in an underwater environment that does not support human life. It is imperative that the Legislation is developed and implemented in order that Diving operations are conducted within defined safe parameters and the health and safety of the workforce is protected.
Courtesy feedback and IDR from a Senior SME Subsea Intervention – Diving and ROV Operations (Oil and Gas).