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Committee Work Group

GOM Diving Safety Work Group

COMMITTEE WORK GROUP
Emergency Response and Procedures Committee Work Group

SEPT 2014

DISCLAIMER

This US GOM DSWG document is not meant to be all inclusive, and not every rule and regulation
is contained herein. The US GOM DSWG does not issue policy or create regulations. The reader
should consult additional resources and subject matter experts for more detailed information as
required.

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Emergency Response and Procedures Committee Work Group

The GOM Diving Safety Workgroup is a US GOM focused, non-competitive and non-commercial group of
oil and gas operators, transmission companies, commercial diving companies, supporting sub-contractors,
organizations and industry stake holders. The group will provide a unified voice to promote and improve
diving safety, through the following:

• Identification and sharing of best practices

• Identify and seek solutions to industry challenges and issues

• Review and comment of existing and proposed standards and guidelines

• Provide input to the regulators and industry associations

Purpose of Committee
This document has been prepared by the US GOM DSWG as guidance for:

The preparation of emergency response plans for diving operations. The guidance provided is meant to
be a tool in preparing a project site specific plan. This is not an exhaustive plan nor do all of the
mentioned features required for every plan.

Committee Chairman Jake Fichter

Executive Sponsor Herb Pourciau / David Gilbert

Committee Members (Names Only)

Fon Stonum Eva Cancienne
John Hocutt John Naylon
David Gilbert

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Part 1: Executive Summary of Committee

In the workplace, both onshore and offshore, barriers to prevent incidents are put in place to make
the work being performed safer for personnel and assets. Even the most well thought out plans and
procedures to prevent incidents are not always successful. Inevitably equipment can break and
personnel can make mistakes. In those events, the actions that take place after an incident occurs
can be critical and may determine the severity of the outcome. The Emergency Response Plan (ERP)
is therefore an important reactive component to the overall mitigations of risk.

For the purposes of this discussion it is assumed that an effective preventative plan focused on the
left side of the bowtie is in place. Our focus will be on the right side, the reactive side. It is here that a
practical attempt will be made to effectively control the event and prevent escalation. The bowtie
diagram (figure 1) is shown below to demonstrate the ERP focus on the reaction side of the incident.

Figure 1: An example of a risk analysis bowtie; Emergency Response Plans would fall to the right of
the incident, found in the middle of the diagram. http://www.r4risk.com.au/Bow-tie-Analysis.php

It is the opinion of the committee that emergency plans lacking in detail can fall short in fulfilling their
mission. Therefore, it is recommended that the plan be specific to the vessel, systems, equipment,
work performed and location of the worksite. It should account for environmental factors such as
climate, weather and work environment. It is also important that the ERP is up to date with the most

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current information available. The entity performing the work will ultimately be the best evaluator
of what should be included in the Emergency Response Plan.

The focus of this document is on the overall planning for emergency response rather than laying out
of a standard for technical competency and equipment. There are various entities that have
adequately reviewed those issues and so for the purposes of this discussion those issues will not be
addressed. Our focus will be on the plan, the risks associated with the plan and the practice of the
plan through drills. This document is intended to aid in the creation and updating of an effective site
specific and scenario specific ERP; one that can be relied on in an emergency situation to guide those
involved in that emergency through the response. These guidelines can help the planner identify the
tools they need to bring an incident under control minimizing the overall impact of the event.

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Part 2: Definition
Emergency Response Plan (ERP) is a plan that identifies plausible incidents that could reasonably
occur during the execution of a work scope. The plan identifies the resources required to manage an
incident as well as the actions that will need to be taken in order to prevent the incident from
escalating. The plan should be practical and executable avoiding over complexity. Emergency
response plans should be job and site specific. The plan should be up to date with the most current
information available.

The ERP can further be defined as a plan of actions to be taken after an incident has occurred that
prevents the incident from becoming a worst case scenario. The plan should lay out the framework
tying together other operational plans in support of managing an emergency.

Emergency plans must have the following characteristics:

• Believable, they should address realistic risk.

• Doable, able to be performed by the personnel at the potential incident site.

• Executable in a timely manner, able to response effective with minimal delay.

• They must clearly define the roles and responsibilities of competent personnel and be scenario
based.

• They must adequately spell out the actions taken to remedy the situation following through until
the response to the incident has been concluded.

• They must be practiced as drills onboard the respective vessel(s) or worksites.

In summary, an ERP is a plan of action for the efficient deployment and coordination of resources to
provide the earliest possible response to an emergency providing aid to the injured and returning the
operation to under control.

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Abbreviations:
ERP Diving Emergency Response Plan
PRP Primary Responding Personnel
SRP Supporting Responding Personnel
IMCA International Marine Contractors Association
ADCI Association of Diving Contractors International
USCG United States Coast Guard
OSHA Occupational Safety and Health Administration
DSWG Diving Safety Work Group
OGP Oil and Gas Producers
SAT Saturation Diving
Surface Surface Supplied Diving
US United States
GOM Gulf of Mexico
FSW Feet of Seawater
HSE Health Safety and Environmental
DMT Diving Medical Technician
LSP Life Support Package
SPHL Self Propelled Hyperbaric Lifeboat
HRC Hyperbaric Rescue Craft
HRF Hyperbaric Rescue Facility

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Part 3: Regulatory and Industry GAP Analysis

In order to initiate a GAP analysis with pertinent governing agencies and industry organizations,
the table below lists the best practices identified by this committee. It further identifies those
that have been addressed by the listed agencies and industry organizations. An asterisk is used
for those items that have not been specifically addressed or the information needed to perform
a GAP analysis is not readily available and as such will require further review outside of the
charter of this committee.

Item Description of Item IMCA ADCI USCG OSHA Comments

1 ERP written in font style and size able * * * *
to be read in low light conditions.
Consider having a battery powered
light source attached to or in close
proximity to the ERP.
2 Location of the ERP on the job site * * * Yes
readily available with the location
known by PRP and SRP. Consider
multiple copies to accommodate
restrictions to the access of the ERP
(i.e. large areas or compartmentalized
locations such as vessels)
3 ERP is easily identifiable by PRP and * * * Yes
SRP.
4 ERP written in the native language(s) * * * *
of PRP and SRP.
5 ERP constructed of durable material * * * *
able to perform in the environmental
conditions of the job site (i.e. water,
hydrocarbons, high/low temperatures,
etc.).
6 ERP contains primary and alternate Yes Yes Yes Yes
contact information for supplemental
support (i.e. relevant
company/operator personnel,
response teams, emergency services,
hospitals, regulatory agencies, etc.).

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7 ERP identifies primary and alternate * * * *

location identifiers (i.e. address, GPS
coordinates, latitude and longitude,
etc.).

Item Description of Item IMCA ADCI USCG OSHA Comments

8 ERP details the location and contact Yes Yes Yes Yes
information of primary and secondary
medical facilities capable of providing
the level of care required (i.e.
hyperbaric treatment, burn centers,
surgical centers, etc.). Consider listing
the maximum levels of care for each
facility listed.
9 Incorporate third party logistical * * * Yes
support at the work location in the
ERP (i.e. other in- field vessels,
platforms, helicopters, onshore
facilities, docks, crane services, etc.)
10 Demonstrate the critical elements in * * No No
the ERP in the form of a process map
or flow chart.
11 ERP incorporates a site specific * * No No
hyperbaric treatment abort plan
(abandon ship/facility).
12 Schedule and perform drills for each Yes Yes Yes Yes
of the elements of the ERP on a
regular basis and at the beginning of
the work scope. Incorporate SRP and
third parties in the drills.
13 Perform a risk assessment of the ERP Yes Yes Yes Yes
and drills. Using the findings update
and/or modify the ERP.
14 ERP defines the site specific injured Yes Yes Yes Yes
diver recovery method.
15 ERP lists the site specific references Yes Yes Yes Yes
the detailed procedure for common
emergencies as well as project and
site specific scenario should be in
place (i.e. decompression sickness,

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omitted decompression, hand injuries,

etc).
16 List and detail the roles and Yes Yes Yes Yes
responsibilities of all PRP and SRP in
the ERP.

Item Description of Item IMCA ADCI USCG OSHA Comments

17 Incorporate the job specific Yes Yes Yes Yes
equipment that could impact the
execution of the ERP in the plan.
Provide instructions as to how to
safely disengage or de-energize the
equipment to secure the worksite.
18 PRP and SRP trained to the level of Yes Yes Yes Yes
competency required to perform their
assigned role and/or task (i.e. the use
of emergency equipment, execution of
relevant procedures, etc.).
19 Ensure that PRP and SRP are not Yes Yes Yes Yes
assigned other emergency duties that
could conflict with the execution of
the ERP (i.e. vessel firefighting,
medical response, etc.).
20 Maintain adequately trained onsite Yes Yes Yes Yes
medical support such as an EMT or
DMT. Evaluate the number personnel
and work hours when determining the
manning requirements. Consider
training SRP as first responders to
supplement the onsite medical
support.
21 Cross train personnel for critical PRP No No No No
and SRP roles.
22 Identify alternate personnel to cover No No No No
PRP and SRP roles in the event PRP are
rendered in effective.
23 Identify long lead critical spares for life * * * *
support and emergency equipment.
Maintain spares onsite.

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24 Include up to date life Yes Yes Yes Yes

support/emergency equipment
operation manuals, schematics,
process maps/flowcharts and d
checklists in the ERP (i.e. SPHL,
decompression chambers, firefighting
equipment, etc.).

Item Description of Item IMCA ADCI USCG OSHA Comments

25 Verify that all life support/emergency Yes Yes Yes Yes
response equipment is fit for purpose
and at a minimum meets all regulatory
requirements (i.e. equipment running
proper fuel and lubricants for climate,
etc.).
26 Include mitigation of common * * * *
weather events that may impact
emergency operations. Take into
account (i.e. lightning storms, tropical
weather, tornadoes, freezing rain,
etc.).
*Not specifically addressed in reviewed material.

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Part 4: Past Incidents

THIS SECTION HAS BEEN INTENTIONALLY LEFT BLANK

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Part 5: Hazard Analysis

The list below identifies some known and possible hazards to the performance of emergency
response activities itself (not addressing the primary work) as well as training or drills for the ERP.
The hazards are listed with their associated risks as well as some specific mitigation
considerations that could be implemented to reduce or eliminate each risk. This is not an
exhaustive list and should only be used as a tool to assist the planner.

Item Hazard Identified Risk Associated with Hazard Mitigation Considerations

(Be Specific)
Personnel becoming  Slowdown of response time due  Identify potential third party
1 involved in the to miscommunication. responders and incorporate
emergency response  Personnel becoming at risk due them into the emergency
that do not have the to lack of knowledge of various response plan.
proper training and or risks present at the site.  Include the identified third
experience. party personnel in the drills
and training.
 Train primary personnel to
manage third party responders.
Personnel operating  Personnel have tunnel vision  Train personnel in realistic
2 at an elevated decreasing their field of vision scenarios.
emotional state or when it comes to hazards.  Cross train personnel.
become panicked.  Personnel forget critical steps to  Train personnel to be able to
response plan. recognize the symptoms and
 Personnel encounter fight or consciously address them.
flight causing them to either  Provide easy to understand
have a decreased sense of risk or instructions to supplement the
an irrational over assessment of loss of memory and decreased
risk. understanding during event.
Disruption of the  Confusion.  Cross train personnel to be able
3 chain of command.  Panic. to perform the role of their
 Necessary information lost. supervisors and visa versa.
 Loss of communication.  Perform realistic drills and
 Demoralized. training scenarios that
eliminate key members of the
chain of command.
 Have multiple copies of the
emergency response plan
available to the personnel for
study and familiarization.

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Item Hazard Identified Risk Associated with Hazard Mitigation Considerations

(Be Specific)
4 Loss of  Loss of access to critical  Review the work to be
communications with technical support to handle the performed and the possible
remote support. situation. medical developments and
consider having critical rolls
 Loss of access to critical medical
onsite instead of remote.
support to handle the situation.  Provide backup
communications able to
operate under independent
power.
Partial or total  Disruption of emergency  Review the work site and
5 systems failure of response plan. associated emergency
critical equipment.  Increased risk of injury to response plans for critical
responding personnel. single points of failure and
 Risk of further escalating the consider adding redundancy.
emergency.
Debris impeding  Disruption of emergency  Review the work site and
6 access to critical work response plan. associated emergency
sites.  Increased risk of injury to response plans for critical
responding personnel. single points of failure and
 Risk of further escalating the consider adding redundancy.
emergency.  Establish alternate access
points and pathways.
 Have tools/equipment
available that can remove or
gain access through the debris
to the critical components.
Chemicals, materials  Disruption of emergency  Review all of the chemicals and
7 that normally are response plan. materials that will be at the
isolated comingle due  Increased risk of injury to worksite and determine what
to damage of their responding personnel. the worst case scenarios would
respective  Risk of further escalating the be for the mixture of the
containment. emergency. components at the expected
 Fire. quantities and update the
 Poisonous gas. emergency response plan.
 Corrosive mixture.  Have the containment and
protective equipment available

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on site to handle the worst

case cross contamination
event.

Item Hazard Identified Risk Associated with Hazard Mitigation Considerations

(Be Specific)
8 First responders and  Mistakes made in the execution  Review the fluency of the
third party personnel of the plan due to personnel that could become
do not speak, read or misunderstanding or inability to involved in supporting the
comprehend the read the instructions or emergency response and
language the understand verbal instructions identify all of the languages of
emergency plan is from the primary personnel. the possible responders.
written in.  Consider having the emergency
response plan available in
alternate native languages.
 When possible have personnel
available onsite that are
bilingual and capable of
translating.
9 First responders and  Mistakes made in the execution  When possible include
third party personnel of the plan due to illustrations in the plan to
do not speak, read or misunderstanding or inability to describe critical steps.
comprehend the read the instructions or  When possible write the
technical jargon of the understand verbal instructions instructions in non technical
emergency plan. from the primary personnel. terms.
10 Poor visibility due to  Personnel at greater risk of slips,  Train personnel to memorize
loss of light source or trips and falls. the location of critical controls
smoke impeding the  In correct operation of critical without the aid of sight.
execution of the equipment and systems due to  Use systems or modify existing
emergency response inability to see controls. systems that have or to have
plan.  Personnel unable to reach easily identifiable controls in
critical equipment, systems or low to no visibility conditions.
areas due to in ability to see.  Drill the execution of the
emergency response plan with
simulated smoke or visibility
restraint.
11 Personnel have  Personnel at greater risk of slips,  Train and drill personnel to
limited visibility, range trips and falls. perform their duties with the
of motion, increase

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heat risk due to PPE  In correct operation of critical PPE that would be worn in a
when executing the equipment and systems due to worst case scenario.
ERP inability to see, feel or hold
controls.
 Personnel unable to reach
critical equipment, systems or
areas due to in ability to see.
 Difficulty breathing.

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Part 6: Drills and Preparation

Below is a list of drills that can be performed to familiarize the crew with the various emergency
response procedures. While performing the drill the personnel practice the emergency response
procedure to help mitigate the inherent risks and hazards of the emergency response plan itself.
The emergency response plan drills should be appropriate for the onsite conditions. Site specific
environmental and technical factors should be incorporated into the drills and simulated.

The drills can be combined with each other for other plausible scenarios to increase the realism.
Upon completion of the drill(s), the level of success should be evaluated; adjustments are then
made to the emergency response procedure if required. It may be necessary to repeat the drill
with the incorporated changes.

Item Drill Name Describe Drill

1 Loss of breathing gas drill Loss of primary breathing gas to the working diver.

2 Loss of diver to surface Loss of communications between the working diver and
communications drill dive control.
3 In water hose change out for Entrapped or fouled working diver.
fouled or entrapped diver drill
4 Injured diver in water drill Recovery of an injured diver. The scenario should be
relevant to the work to be performed.
5 Severance of diver’s umbilical – The primary breathing gas hose of the working diver
breathing gas hose only drill becomes partially severed. This drill should be
incorporated with other scenarios such as loss of gas, loss
of communications, etc.
6 Diver’s umbilical completely The complete severing of the working diver’s hose. This
severed drill should be incorporated with other scenarios such as
loss of gas, loss of communications, etc.
7 Topside fire drill A fire at the worksite, on the vessel (non hyperbaric).

8 Fire inside PVHO drill A hyperbaric fire inside the PVHO. Consider performing
this in conjunction with another drill such as abandon
ship, topside fire, etc.
9 Adverse environmental Simulation of a response to an environmental condition
conditions drill such as a hurricane or lightning storm.
10 Oxygen toxicity in water drill Simulation of a diver experiencing Oxygen toxicity while
in the water.

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11 Oxygen toxicity during Simulation of a diver experiencing Oxygen toxicity during

treatment drill decompression in a PVHO.
Item Drill Name Describe Drill
12 Emergency evacuation drill Simulation of the evacuation of the worksite, vessel.
13 Diver becomes dizzy on ascent Simulation of a diver experiencing while ascending from
depth.
14 In water bell to bell transfer of Simulation of the transfer of a diver(s) from one systems
diver(s) bell to another systems bell at depth.
15 CO2 build up in chamber An alarm is received indicating an unsafe level of CO2
buildup in the PVHO. The personnel perform the
emergency procedures to restore the CO2 to a safe level.
16 CO2 build up in bell An alarm is received indicating an unsafe level of CO2
buildup in the bell. The personnel perform the
emergency procedures to restore the CO2 to a safe level.
17 Contaminated breathing gas The diver(s) main breathing gas having become or been
found to be contaminated with an unsafe contaminant.
Diver is switched over to secondary gas supply or
emergency gas and instructed to free flow to clear dive
hose until uncontaminated gas is restored.
Note: The diver’s bailout gas is a source of
uncontaminated gas, but should only be used as a last
resort.
18 Type I/Type II decompression A diver experiencing Type I or Type II decompression
sickness sickness either in water, on surface prior to SURD, under
pressure while performing SURD or on surface after
completion of SURD.
19 Diver electrically shocked while Diver experiences an electrical shock resulting in injury
underwater welding, burning, or and possibly becoming unconscious. This drill can be
from coming in contact with combined with lifesaving drills such as utilization of an
energized electrical source. AED for restoring normal heart rhythm
20 Diver with pneumothorax Diver while working or decompressing encounters the
symptoms of a pneumothorax. Support personnel
simulate the medical response to the diagnosis.
21 Heat related injury Topside personnel or diver while working on deck or at
depth encounters the symptoms of a heat related illness.
Support personnel simulate the medical response to the
diagnosis.
22 Recovery of unconscious diver Diver becomes unconscious at depth while working or
in water or in the bell. decompressing. The standby diver and support personnel
respond to the event to bring the diver into a stable

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environment for further treatment of the root cause.

Consider combining this with another drill for realism.

Item Drill Name Describe Drill

23 Hydrocarbons in the bell Hydrocarbons in the bell are simulated to be detected.
Divers in the bell and support personnel respond to
stabilize the divers breathing gas and regain control of
the atmosphere in the bell.
24 Arterial gas embolism Diver while working or decompressing encounters the
symptoms of an arterial gas embolism. Support
personnel simulate the medical response to the
diagnosis.
25 Evacuate injured Injured personnel are evacuated to a platform with
person/personnel via platform support of the platform crew.
crane to platform
26 Evacuate injured Injured personnel are evacuated to another vessel with
person/personnel via platform support of the platform crew and supporting vessel.
crane to another vessel
27 Evacuate injured Simulation of injured personnel being evacuated to via
person/personnel via helicopter helicopter. Personnel are prepared for transportation
from vessel helideck short of actual flight.
28 Evacuate injured Injured personnel are evacuated to another vessel with
person/personnel via vessel the vessels crane with support from supporting vessel.
crane to another vessel
29 Emergency loss of pressure in One or more of the chambers begins losing pressure. In
one of the PVHO chambers chamber personnel as well as topside support isolate the
leak.
30 Loss of anchorage or DP while The loss of anchorage or DP is simulated. Divers and
diver(s) is in the bell or working support personnel respond to recover the diver(s), stage,
at depth. bell, etc. to surface.
31 Lost bell recovery ROV or surface diver simulates the connecting of the
recovery rigging in support of recovering a lost bell.

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Part 7: Appendix

The listed documentation, reports, drawings, etc. in this section are provided for more depth
or relevant information to this report.

Item Appendix Item Description of Item

Example Drawing of Dive Spread #1 A Handwritten written drawing of a possible dive spread
schematic that is appropriate for Live Boating
1 OGP – Diving recommended Diving standard for the International Association of Oil
Practice, Report No. 411 June and Gas Producers
2008
2 International Consensus Diving standard for the Association of Diving Contractors
Standards for Commercial International
Diving and Underwater
Operations, 6th Edition
3 DMAC 15 REV 3 Medical equipment to be held at the site of an offshore
diving operation
4 DMAC 28 REV 1 Provision of emergency medical care for divers in
saturation
5 AODC 019 REV 1 Emergency procedures - provisions to be included for
diving bell recovery
6 AODC 026 Diver emergency heating

7 AODC 048 Offshore diving team manning levels

8 IMCA C 013 First Aid and Other Emergency Drills

9 IMCA C 002 REV 2 Guidance on Competence Assurance and Assessment –

Marine Division
10 IMCA C 003 REV 2 Guidance on Competence Assurance and Assessment –
Diving Division
11 COMDTINST 6260.31B Commandant Instruction 6260.31B Safety and Health
Training for Emergency Response Operations
12 OSHA 3122-06R 2004 Principle Emergency Response Preparedness

13 CPL 02-00-151 29 CFR Part 1910, Subpart T - Commercial Diving

Operations
14 SLG 101 Guide for All-Hazard Emergency Operations Planning

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