October 11, 2021

Q&A for Safety Webinar 2021

Can SS511 be acquired to be signed by any vessel or master of any structure afloat by MPA?

The SS511:2018 is an Approved Code of Practice for diving at work and its provisions have to be adhered to strictly as the provisions contained within will be made reference to and in the event of contraventions and prosecutions.

It is on the onus of the diving contractor to comply with this ACOP and inform vessel master as well as any worksite owners on these requirements. It is CDAS view that you cannot make any vessel master or worksite owner sign on the ACOP to pass on this responsibility of compliance.

Is there any age restriction for a diver?

The SS511:2018 states that divers must be at least 18 years of age, possess a recognised and in-date diving qualification, relevant first aid certificates and a valid diving medical performed by an approved diving medical practitioner in order to be legally allowed to dive.

Requirements that divers to be trained and certified in diving first aid, CPR, AED... Does a diver trained in DIVER MEDIC TECHICIAN certification still be required to take all these mentioned training?

Industry players are at their free volition to send their personnel to other similar or higher training programmes to further personnel understanding of a topic.The OFAC course and diving first aid course are minimum requirements for working in Singapore in accordance to legislation and SS511:2018 ACOP respectively.

OFAC is generic for any sector while Diving First Aid is specific for the diving community and hence kept separate for now. It was good noting that such an arrangement would benefit other professions who wish to join the diving industry, as they may possess the OFAC certification. Vice-versa for divers who wish to join another profession, they may be able to utilise their OFAC certification in their new job roles.

When a diving company is unable to complete the work so contracts a second diving company to help them complete or do the work - please explain explicitly who is reasonable and accountable when the contracted diving company carries out the diving operations not in compliance with the SS511 or WSH Act ?

The onus is on both the first diving contractor (Additional duties of principals in relation to contractors under Sect 14A of the WSHA) and second diving contractor (duties of principal under Sect 14 or duties as an employer under Sect 12 of the WSHA) to ensure compliance with the ACOP SS511 and WSHA.Under Sect 14A of the WSHA, it shall be the duty of the first diving contractor to take reasonably practicable measures to ensure that the second diving contractor engaged by the first diving contractor -

(a) has the necessary expertise to carry out the work for which the second diving contractor is engaged by the first diving contractor to do. The duty imposed on the first diving contractor includes ascertaining that the second diving contractor engaged by the first diving contractor and any employee of the second diving contractor have sufficient experience and training to carry out the work for which the second diving contractor is engaged by the first diving contractor to do; and have obtained any necessary licence, permit, certificate or any other document in order to carry out the work for which the second diving contractor is engaged by the first diving contractor to do.

(b) has taken adequate safety and health measures in respect of any machinery, equipment, plant, article or process used, or to be used, by the second diving company or any employee employed by the second diving company. The duty includes ascertaining that the second diving company has conducted a risk assessment in relation to the safety and health risks posed to any person who may be affected by the work; and has informed any person who may be affected by the work of the nature of the risk involved in the work and any measure or safe work procedure which is implemented at the workplace.

It shall not be a defence for the first diving contractor to prove that he has taken reasonably practicable measures to ensure compliance solely by providing directly or indirectly, by a term in a contract with the second diving contractor, that the second diving contractor has complied with or will comply with the ACOP SS511 requirements and WSHA.

Similarly, the second diving contractor (as a principal under Sect 14 or as an employer under Sect 12 of the WSHA) shall also be liable to ensure compliance to the ACOP SS511 and WSHA when conducting any diving activities.

Since recreational scuba has risk, is there any plan to improve the situation now?
In accordance with SS511:2010 ACOP which has now been replaced with the revised SS511:2018 ACOP, together with the recently launch WSH Guidelines on Inland/Inshore Commercial Diving states clearly that recreational SCUBA is not allowed in commercial diving for a long time coming now.If infringements are found, the individual or company may face prosecutions under the Workplace Safety & Health Act.
Please advice whether Cscuba is banned for ship husbandry; as its limited supply and the work carried out is strenuous work
In accordance with SS511:2018 ACOP and the recently launched WSH Guidelines for Inland/Inshore Commercial Diving, the usage of CSCUBA in ship husbandry is limited and for most diving operations, SSDE is a requirement.
If a diver has a DMT (IMAC) qualification, must he also take the Diving First Aid Course?
Industry players are at their free volition to send their personnel to other similar or higher training programmes to further personnel understanding of a topic. The OFAC course and diving first aid course are minimum requirements for working in Singapore in accordance to legislation and approved code of practice respectively.
Does diver training include diving to and achieving proper depth exposure attainment in Singapore?
Learning Service Providers are certified institutions offering training and their curriculum shall follow what is stipulated in respective course CTAGs and Technical Notes which these institutions conduct.
Will WSH encourage and welcome new diving associations?
Currently, CDAS is the Association representing the commercial diving community in Singapore.
Will WSH encourage and welcome new dive schools in Singapore providing training to Divers in Singapore? If yes, would WSH relook at the criteria for applying? Such as having to have a 500,000 paid-up capital and having the skilled and experienced instructors have the local ACLP/ACTA qualifications?
Diving is a high risk profession in which the safety and the quality of education for course attendees are of paramount concern. Potential training institutions must therefore adhere to the strict criteria set out in order to be certified as an LSP.
How does one become a CDAS member? Must I do an audit? Who is the auditor and what is the criteria? Does everyone in CDAS, past and existing have to go through an audit by CDAS?
CDAS has 3 membership categories - Ordinary, Associate and Individual membership. For all companies who carry out diving activities and are interested in joining CDAS shall apply under Ordinary membership and will have to go through an audit by an approved third party auditor to assess a prospective member's work practices and compliance to the SS511:2018 ACOP and WSH Guidelines.
Is it mandatory for divers to have AWSHPP or SWSHPP for operating in waters of a oil/petrochemical company? or is there an equivalent ?
It would be dependent on whether the workers (i.e. divers) are short term workers or long term contractors.For long term contractors, they should attend the necessary courses to know the hazards in the process plants.
For short term workers, they would not need to attend the AWSHPP and SWSHPP. But they should at least undergo the in-house site safety orientation course conducted by the company and while these short term workers are working, they would need to be supervised by competent personnel from the plant at all times as well as have a comprehensive understanding on the risk assessment regarding the work they are doing.Depending on the type of works activities that would be required to be carried out by the divers, the oil/petrochemical company have to establish if there is a need for the short term workers to have AWSHPP / SWSHPP or an in-house site safety orientation course conducted by the company should suffice.
With the new higher enforcement measures in place would the authorities consider revoking certification or banning of diving supervisors and/or divers who infringe on the current regulations?

The penalty framework under the WSHA is currently sufficient to act as a deterrent to any person at work to discharge their duties and comply to the requirements under ACOP SS511 and the WSHA. MOM will not hesitate to take any enforcement actions against any Diving Supervisor or divers who failed in their duties under Section 15 (Duties of persons at work) of the WSHA.• Under s15(1), it shall be the duty of every person at work:
a. to use in such manner so as to provide the protection intended, any suitable appliance, protective clothing, convenience, equipment or other means or thing provided (whether for his use alone or for use by him in common with others) for securing his safety, health and welfare while at work; andb. to co-operate with his employer or principal and any other person to such extent as will enable his employer, principal or the other person, as the case may be, to comply with the provisions of this Act.• Under s15 (2), no person at work shall wilfully or recklessly interfere with or misuse any appliance, protective clothing, convenience, equipment or other means or thing provided (whether for his use alone or for use by him in common with others) pursuant to any requirement under this Act for securing the safety, health or welfare of persons (including himself) at work.

• Under s15(3), any person at work who, without reasonable cause, wilfully or recklessly does any act which endangers the safety or health of himself or others shall be guilty of an offence.

• Under s15(3A), any person at work who, without reasonable cause, does any negligent act which endangers the safety or health of himself or others shall be guilty of an offence and shall be liable upon conviction to a fine not exceeding $30,000 or to imprisonment for a term not exceeding 2 years or to both.

Sterner action, including prosecution, will be taken against any person at work who committed an egregious act / conduct / behaviour or repeatedly violated the safety requirements under SS511 and WSHA, which had caused or could cause an accident, resulting in serious injuries to himself or others.

Do we have some guidelines when diving with bunker vessel on either side?

Diving activities are only to be carried out after a thorough risk assessment with residual risks being reduced to an acceptable level when diving simultaneously with bunkering activities.The diving supervisor is responsible for ensuring that lines of communication with the bunker vessel are established, lock-out-tag-out and other safety measures in place amongst others and that he or she is satisfied that diving operations can be safely conducted before commencing such works.

There are several diving doctors in Singapore that provide medical examination for divers. What is the requirement during the examination? Is the standard in accordance to BR1750a and IMCA guidelines? What is the standard required in accordance to the Singapore SS511 and is there a stated standard in examination that is accepted by WSH/MOM? In this case, there is a list of approved hyperbaric doctors?

Requirements for Commercial Diving in Singapore are based on the SS511 Code of Practice for Diving at Work. This Code of Practice is in accordance with the Singapore Standards for Diving at Work and covers the practical aspect of the Diving job as well as the Medical Examination for Working Divers for divers working in Singapore. This SS511 Code of Practice for Diving at Work is recognised by MOM.

Approved Doctors performing the Diving Medical Examination in accordance with the SS511 Code of Practice for Diving at Work can be found on the CDAS website (https://www.cdas.sg/wp-content/uploads/2019/08/CDAS-GD-02-Diving-Medical-Practioners-rev-29-Aug-2019.pdf)

For full understanding of the SS511 Code of Practice for Diving at Work you can purchase your copy online - https://www.singaporestandardseshop.sg/Product/SSPdtDetail/6026442c-abd7-424c-ba74-182ce422410a

If I have never dived to deeper depths such as to 30m, and I do a dive to 30m, what are my chances of getting Decompression Sickness? Is there such a thing as individual susceptibility?

A tendency to suffer from decompression illness regardless of diving depth is primarily subjected to an individual's physical health for which a myraid of factors and variables come into play. Yes there are individuals who are more susceptible to DCI. Whenever in doubt, kindly seek medical clearance from a trained and approved diving physician before commencing any diving operations.