Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
M2282
Initial Report
Onboard a small motor yacht alongside the dock, someone dropped their radio into the water by the stern, directly under the propellors. The captain directed that it be retrieved by sending someone down with scuba gear. When informed that this would require a permit to work, the captain insisted it was not required. Despite concerns about the need for a permit or some formal procedure, the captain dismissed the idea and requested proof of legislation that mandated a permit to work for diving under the boat. When the suggestion to consult the Code of Safe Working Practices (COSWP) was made, the captain insisted on quickly retrieving it without any permit.
CHIRP Comment
In this situation, the appropriate steps involve consulting the Code of Safe Working Practices for Merchant Seafarers, which provides guidelines for safe practices, including diving operations. If unsure, calling the Designated Person Ashore
(DPA) to seek advice on the diving risk would be appropriate.
A stop-work authority would be the ideal tool for evaluating the risks. However, the company’s safety culture must be proactive enough to implement this process.
According to the latest Diving at Work Regulations, diving operations conducted as part of work activities require a risk assessment and proper procedural adherence. The COSWP chapter on diving operations outlines the need for permits and safety procedures for diving. The relevant excerpts indicate that before any diving operation is undertaken, a risk assessment must be carried out, and a diving permit must be issued to ensure all safety measures are implemented. This aligns with the requirement that only a person shall dive in connection with a work activity if a suitable and sufficient assessment of the risks to health and safety has been made.
Most divers on board superyachts have a Professional Association of Diving Instructors (PADI) certification. This is for recreational diving only and is NOT sufficient to undertake commercial diving; that needs a professional commercial diving certification, which requires a higher standard of training and an equally well-trained diving support team.
CHIRP recognises that standing firm can be daunting when an authoritative figure pressures a crew member.
Safety protocols, such as contacting the Designated Person Ashore (DPA) or a stop-work policy, are crucial for justifying the issuance of permits. The master’s conduct was unacceptable, and the company’s lack of written guidelines for diving operations reflects a tolerance for risk.
Key Issues relating to this report
Culture—The crew’s attempt to influence the master’s decision to retrieve the radio using a diver was blocked, and there was no safety, highlighting a poor safety culture. Thinking about your experiences on your vessel and past vessels, have you encountered this type of behaviour? What would you have done?
Alerting—How would your DPA respond if you contacted them to seek advice on this matter? You can also contact the Flag State to seek advice. The master should have made this call.
Teamwork- A shared mental model of the safety risks and the usefulness of retrieving the radio was not shared by everyone. How good would you be at creating a shared mental model where the risks for carrying out a dive to retrieve the radio could be persuasive enough to stop the operation?