HSE regulations for dive training

[Tank Girl]

Originally Posted by John Nortcliff

Since PADI calls confined water training 'dives', the HSE contends that they should be treated as a dive with all the requirements that that entails.

John

The issue here is not that PADI calls confined water training "dives" but the fact that the Diving at Work Regulations 1997 applies to commercial divers working in both open water and confined water (pools & tanks are known as "benign environments" in the regs & ACoP). It's not a project being classed as a dive that makes it subject to the DWR97 and relevant ACoP, but rather that a commercial project involves breathing compressed gas underwater. All instructors training divers in an at work situation, regardless of agency, irrespective of whatever that agency calls training in a swimming pool, whether confined or open water, are subject to the DWR97 and ACoP.

The requirements for a benign environment differ to open water in respect to team size. In a benign environment (confined water) any commercial dive that involves a diver breathing compressed gas underwater is required to be part of a team with a minimum of two members. The second member of the team may be at the surface, not in diving equipment provided that s/he is able to provide assistance in the event of an emergency.

The diver(s) in a benign environment are still subject to medical, risk assessment, O2 & first aid requirements, etc, as per open water.

As you will be aware the minimum team size for an 'at work' project in open water is three, two in the water (one able to provide assistance to the other), one at the surface.

Cadburysegg, also see my previous post in another thread www.yorkshire-divers.co.uk/forums/showthread.php?p=225066#post225066, it might help with the definition of an 'at work' dive and whether you'll have to abide by the ACoP or not.

TG

[Narked@50]

The whole "payment in kind" is a bit misleading, the "payment" would have to be sufficient enought to be regarded as actual "payment". No HSE officer in their right mind is going to take a guy to court for recieving "a bacon butty and a coffee" in lieu of a £300 diving course!, it can hardly be considered "payment". Reasonable out of pocket expences are perfectly acceptable, it's only when you start saying stuff like "I had to buy a new BCD at £250 to teach the course" you are heading for dangerous ground.

The HSE guy at our sceminar was quite up front about not having an interest in pursuing genuine clubs, and as Mark has pointed out, it's the instructors mascarading as clubs that they will give "special attention".

Just as an example, I have never, ever, broke even on a training course. By the time I pay travel, lunch, entry and air, I am well out of pocket, the student usualy think they are doing you a fevour buying you a coffee!

Yea, right! Try and get a days dive tuition from a Professional instructor for £1.20.

James

[londonsean69]

I don't log pool dives, we do take O2 and First Aid kit to pool. I don't have surface cover at a pool, sometimes I don't have a 'Rescue diver' either.

In Open water, I ensure that we have all of the above, as well as the project plan and dive log, which are kept with the surface cover at all times. None of us have first aid at work AFAIK.

So I don't know what to vote. I will have to really go over the HSE regs.

[John N]

I guess that's a no then. In confined water you need a safety diver (Rescue or better) and they need to have a proper HSE medical, not just a standard dive medical.

Thanks for all the useful responses/links.

[londonsean69]

Once again, typical HSE horseshit. All of these rules and regs were meant for the commercial dive industry, and by that I mean those who have to have HSE approved courses, eg. oil rig and dock workers etc.

What is the point in having a rescue diver in a swimming pool?? Does this mean we also need surface cover at swimming pools?? 2 O2 kits if we have 2 groups. Damn, the shop I work at often has 4 maybe 5 different activities going on in the pool at the same time. Does all this HSE crap mean that every diver in the water needs a rescue diver, surface cover, O2 kit, and first aid kit. Damn, I think we need a bigger van and 4 more O2 sets.

F*ckin HSE grumble grumble

[NotDeadYet]

A commie fishing a dropped tool box out of the bottom of a tank isn't that much different from an instructor in a pool. Why should the regs be any different. Either both are exempt or neither are.

I seem to remember that these requirements have been around for a long while. I remember the same thing getting discussed in the PADI journal, and it's been years since I've been teaching.

[londonsean69]

Originally Posted by NotDeadYet

A commie fishing a dropped tool box out of the bottom of a tank isn't that much different from an instructor in a pool. Why should the regs be any different. Either both are exempt or neither are.

It does beg the question would you send a commie to do it? or would you find a friendly local diver??

[Tank Girl]

Originally Posted by londonsean69

What is the point in having a rescue diver in a swimming pool??

You don't need one in the same way as in open water - the minimum team size in a benign environment is two, one in the water, the other can be in the water but could also be at the surface on the side provided that they are able to provide assistance in the event of a problem.

O2 kits - interesting, but it does make some sort of sense that if one O2 is in use and you still have divers in the water, as part of another project, then you would need an additional unit. Whether you would need one per team in the event of several projects is debateable, however. I would hope that just having redundancy is all that is required. One to run past HSE in London, not just the local inspector, as they do not always sing from the same song sheet. I'll ask and get back to you, however it may not be quick!

Ultimately, all DWR97/ACoP requirements should be implemented as it is the law, whether we like it or not. Whether it has a financial implication on the contractor (dive school) is beyond the HSE's interest, they would just argue that prices must be increased to ensure compliance with said law, irrespective of whether an instructor/school considers the application of those 'commercial' diving laws appropriate to diver training.

Consider that if all training providers / dive schools complied with all requirements then all 'commercial' recreational diver training would be competing on a level playing field, and students would receive a level of care that they expect and deserve. [that comment is aimed at those instructors/schools who operate at a minimum level of (non?) compliance before I get flamed!].

Also consider our professional instructor friends in Ireland. Their HSA (equivalent to the UK HSE) is proposing in their new Safety, Health and Welfare at Work (Diving at Work) Regulations 2005 that the minimum team size is FOUR, a supervisor, a working diver, a standby diver and a tender for the working diver. OMG See Irish HSA website.

Now that would really hurt...

TG

[John N]

Originally Posted by Tank Girl

O2 kits - interesting, but it does make some sort of sense that if one O2 is in use and you still have divers in the water, as part of another project, then you would need an additional unit. Whether you would need one per team in the event of several projects is debateable, however. I would hope that just having redundancy is all that is required. One to run past HSE in London, not just the local inspector, as they do not always sing from the same song sheet. I'll ask and get back to you, however it may not be quick!
TG

I've been told (second hand from a London HSE meeting) that you only need one O2 kit, even with multiple teams. BUT, there must be a system in place to immediately recall all other diving groups. The reason is that the kit and personnel with first aid training are no longer available to provide cover for the other groups.
I think that with more than two teams in the water at once, additional O2 and first aiders would probably be sensible given the requirements.

[londonsean69]

Originally Posted by Tank Girl

You don't need one in the same way as in open water - the minimum team size in a benign environment is two, one in the water, the other can be in the water but could also be at the surface on the side provided that they are able to provide assistance in the event of a problem.

I must say, it is rare that we don't have other instructors/dm's around, as generally there is more than one thing going on. However, this makes me think that we need to keep dive logs and have a project plan in place, even when doing a Bubblemaker for a group of 8 year olds. Would this be the case, if so, then we're f*cked if the HSE ever turn up.