JSP 433

MOD Diving Safety Policy

Part 1: Directive

JSP 433 Pt 1 (V2.0 Jan 15)

JJSPJSP 507 Pt.1 (V6.0 Jan 14)
Foreword
The Secretary of State for Defence (SofS) through his Health, Safety & Environmental
Protection (HS&EP) Policy Statement requires each Top Level Budget Holder or Trading
Fund Agency Chief Executive to be the Senior Duty Holder for the safety of defence
activities conducted in their area of responsibility in addition to their wider HS&EP
responsibilities. They are required to set down and implement HS&EP management
arrangements for activities in their area of responsibility. The policy statement also
requires there to be organisational separation between those who conduct defence
activities and those who provide regulation, so that the latter are independent whilst being
part of the Department.

As Director Defence Safety & Environmental Authority (DSEA), I am responsible for

providing defence regulatory regimes for HS&EP in the Maritime domain where there are
exemptions, derogations or dis-applications from legislation or where UK legislation does
not apply. The regulations set out in this JSP are mandatory and full compliance is
required. It is the responsibility of commanders and line managers at all levels to ensure
that personnel, including contractors, involved in the management, supervision and
conduct of defence activities are fully aware of their responsibilities.

The Defence Maritime Regulator Team leader (DMR TL) is empowered to develop and
promulgate the regulatory regime for the Defence Maritime domain and enforce these
regulations.

JCS Baker
Director Defence Safety and Environment Authority
Defence Authority for Health Safety and Environmental Protection

1 JSP 433 Pt.1 (V2.0 Jan 15)

Preface
How to use this JSP

1. JSP 433 sets out the Defence Regulations to be adopted for diving activity
conducted under the auspices of the Ministry of Defence. It is to be used by staff
responsible for such activity. This JSP contains the regulations, policy, direction and
guidance on the governance structures, risk responsibilities and safety management
system and guidance on the processes involved and best practice to apply safe
procedures for diving activity. This JSP will be reviewed at least annually.

2. The JSP is structured in Two Parts:

a. Part 1 – Directive. Directive which provides the direction that must be followed in
accordance with Statute, or Policy mandated by Defence or on Defence by Central
Government.

b. Part 2 - Guidance. Which provides the Defence Codes of Practice (DCoP), that
provide an acceptable means of compliance with the Defence Regulations. These
Diving Manuals describe the way that MOD diving activies are regulated to conform
to the statutory regulations (Diving at Work Regualtions 1997) and are consolidated
in BRd2806 as follows:

Related MOD
Title
Publications
BRd 2806(1) Regulations, Guidance, Training and the Theory of Diving
BRd 2806(2) Air Diving
BRd 2806(3) Mixture and Oxygen Gas Diving
BRd 2806(4) Theraputic and Medical Management of DivIng
BRd 2806(5) Joint Service Sub-Aqua Diving Regulations
BRd 2806(6) Special Forces
JSP 430 Regulations for Management of Ship Safety and Environmental
Protection
JSP 319 Joint Regulations for the Control and Storage of Gases

Further Advice and Feedback- Contacts

3. The owner of this JSP is the Director Defence Safety and Environment Authority.
For further information on any aspect of this guide, or questions not answered within the
subsequent sections, or to provide feedback on the content, contact:

Job Title/E-mail Project focus Phone

MOD Superintendent of Diving Diving Regulation and 938324143
[email protected] Assurance
Defence Maritme Regulator TL All Maritime Regulation 967935132
DSEA-DMR [email protected]

2 JSP 433 Pt.1 (V2.0 Jan 15)

 Record Of
Authority Date Key Changes
Change Issue
JSP375, Leaflet 29 SSB Jan 2002 Pelly Report to Ship Safety Board
Formation of Defence Maritime
JSP433, Issue 1 DSEA-DMR Apr 2014
Regulator
JSP433, Issue 2 DSEA-DMR Jan 2015 Annual Review

3 JSP 433 Pt.1 (V2.0 Jan 15)

Contents
Foreword.........................................................................................................1

Preface ............................................................................................................2

Contents ........................................................................................................4

1 Regulatory Principles and Application................................8

Scope ..............................................................................................................8

Leadership......................................................................................................8

Independent Regulatory Authority ...............................................................9

People Empowered with Delegated Authority.............................................9

Simplicity ........................................................................................................9

Coherence with Other Defence Authority Policy and Guidance ..............9

Intelligent Customer Capability ..................................................................10

2 Introduction..........................................................................11

3 Policy ....................................................................................12

4 Definition of Terms ..............................................................14

Diving and Related Activities......................................................................14

Military Diving Operations ..........................................................................14
Recreational and Vocational Diving ...........................................................14

Civilian Diving Projects ...............................................................................15

MOD Civilian Diving .....................................................................................15

Diving Plant and Equipment .......................................................................16

Duty Holders.................................................................................................17

4 JSP 433 Pt.1 (V2.0 Jan 15)

Diving Standards Officers ...........................................................................17

5 Conduct of Diving Operations and Projects .....................18

Military Diving Operations ..........................................................................18

MOD Civilian Diving Projects......................................................................18

Joint Service Sub-Aqua Diving...................................................................18

Acquiring Third Party Diving Services.......................................................19

Diving Plant Used in Diving Operations ....................................................20

Obtaining Technical Advice ........................................................................20

Reporting of Accidents and Incidents .......................................................20

Acquisition of Diving Plant for Military and Civilian Operations .............22

Acquisition of Diving Equipment for Military and Civilian Operations ...22

Use of Foreign Diving Equipment for Military Operations .......................23

Diving Medicals............................................................................................23

6 Responsibilities for Diving .................................................25

MOD Policy Sponsor ...................................................................................25

General Responsibilities .............................................................................25

Senior Duty Holders Responsibilities ........................................................26

Operating/Intermediate Duty Holders Responsibilities............................27

Operating Outside the Safety Case ............................................................28

Equipment Authorities Responsibilities ....................................................28

Commanding Officer/Delivery Duty Holders Responsibilities.................30

Senior Managers Responsibilities..............................................................30

5 JSP 433 Pt.1 (V2.0 Jan 15)

Diving Standards Team Responsibilities...................................................31

MOD Civilian Duty Holders (Civilian Diving Projects and Acqusition of

Third Party Diving Services) .......................................................................32

Client Responsibilities ................................................................................32

Civilian Diving Contractor Agents..............................................................33

User Requirement Sponsors ......................................................................33

Training Authority ........................................................................................33

MOD Superintendent of Diving ...................................................................34

Service Level Agreements ..........................................................................35

7 Certification..........................................................................37

ODH Diving Safety Certification .................................................................37

CODH/DDH Diving Safety Certification ......................................................38

Renewal of Defence Maritime Regulator Certification..............................38

8 Diving Safety Management System ...................................40

MOD Diving Safety Management Panel .....................................................40

Diving Safety Management Working Groups Panel..................................41

Military Diving Safety Management Working Group.................................41

Joint Service Sub-Aqua Diving Policy Advisory Committee ...................42

Commercial Diving Safety Management Working Group.........................43

Safety Management Structures ..................................................................44

MOD Policy Approval and Control .............................................................45

Diving Manual Approval and Control .........................................................45

Policy Implementation .................................................................................45

6 JSP 433 Pt.1 (V2.0 Jan 15)

MOD Policy Review......................................................................................45

Audit..............................................................................................................46

9 References ...........................................................................47

10 List of Abbreviations ...........................................................48

11 Glossary ...............................................................................50

Appendix 1 MOD Diving Safety Management Structure ...........56

Appendix 2 Military Diving Safety Management Structure.......57

Appendix 3 MOD Recreational Diving Operations Structure ...59

Appendix 4 MOD Civilian Diving Operations Structure ............60

7 JSP 433 Pt.1 (V2.0 Jan 15)

1 Regulatory Principles and Application
Scope
1. This JSP is the principal safety policy document for MOD Diving and Diving
Related Activities, the Regulations in this JSP take precedence over all other documents
relating to MOD diving safety management policy, unless they are enshrined in law and
supersedes previously issued diving safety policy statements.

2. When used within this JSP, the term “Line Manager” refers to the person (Service
or civilian) with direct responsibility for the safe conduct of the work activity. For military
activities this will usually lie within the chain of command. These Reglations apply to all
Ministry of Defence (MOD) staff, (Service and civilian), who are involved in any capacity
with diving under MOD control.

3. The Objectives of the Policy Are:

a. to ensure that the highest practicable levels of safety performance are achieved
across all MOD Diving and related activities and.

b. to ensure that hazards which may result in death, injury, ill health to divers or
other parties, and damage to diving plant are identified and that corrective action is
taken to reduce the residual risks to at least ALARP

c. to foster a just safety culture that seeks continuous safety improvements by

learning from experience guided by safety performance management.

4. The Aims of this Policy Document Are:

a. to ensure that all MOD personnel engaged in diving and related activities are
aware of the MOD policy and the requirements placed upon them in this regard.

b. to define individual and organisational responsibilities, including the

requirement that the Department identifies appropriate levels of Duty Holders for
diving operations and Diving Plant acquisition.

c. to guide senior managers and other Duty Holders in the discharge of their
responsibilities to implement statutory requirements.

Leadership
5. Under United Kingdom law, all employers owe a duty of care to their employees,
others who may be affected by their activities and the wider environment. The MOD has
an obligation to manage the safety and environmental protection requirements associated
with delivery military effect (design, construction and operation of military systems) when
at peace and in war. A strong and just safety and environmental protection culture is key
to achieving this and requires effective leadership, a positive attitude, clear accountability
and commitment to safety and environmental protection at all levels of management. All
employees and service personnel shall take reasonable care of their own health and
safety and to take reasonable care not to put other people at risk by what they do or don't
do in the course of their work.

8 JSP 433 Pt.1 (V2.0 Jan 15)

Independent Regulatory Authority
6. The Secretary of State’s policy statement imposes specific requirements in the
areas of safety and environmental protection, which are discharged through a delegation
to the Defence Safety & Environment Authority (see note), to establish departmental
policy, standards, rules and, where appropriate, regulations for the management of safety
and environmental protection. The Defence Maritime Regulator is part of the Defence
Safety & Environment Authority, and sets safety and environmental protection regimes for
all maritime activities, including MOD Diving, shipping, ports and harbours and water
safety. The regulatory regime for MOD Diving is set by these regulations.

Note. Joint Service Publication (JSP) 815, Defence Health, Safety and Environmental
Protection. Leaflet 01

People Empowered with Delegated Authority

7. Everyone involved in this Regulatory Regime shall be suitably resourced,
developed to have the right competencies to discharge their role and, where appropriate,
authorised through a safety and environmental protection delegation. Overall
responsibility for safety and environmental protection within the MOD rests with the
Secretary of State for Defence who has delegated authority to the Permanent Under
Secretary the duty of ensuring that effective management arrangements are in place to
comply with the policy. Top Level Budget Holders shall discharge their authority from the
Secretary of State and their Permanent Under Secretary by cascading this authority as
appropriate throughout their organisation, so that the safety of personnel and protection of
the environment will be ensured.

Simplicity
8. When managing safety and environmental protection every opportunity shall be
taken to target action on the highest risks and to simplify and sharpen documentation and
advice so that it is clear and remains so. Recognised means of compliance with these
regulations include compliance with the applicable policies of other safety and
environmental regimes. It is important to ensure the occupational safety of people within
the maritime domain (for whom a ship or harbour may provide a safe working
environment) in compliance with JSP 430 and with JSP 375, the MOD Health and Safety
Handbook, with environmental protection broadly addressed in JSP 418, the MOD
Corporate Environmental Protection Manual. JSP 815 Chapter 2 shows the overarching
relationship between policies and regulations.

Coherence with Other Defence Authority Policy and Guidance

9. Where applicable, this document contains links to other relevant JSPs, some of
which may be published by different Defence Authorities. Where particular dependencies
exist, these other Defence Authorities have been consulted in the formulation of the policy
and guidance detailed in this publication. JSP 433 is a regulatory regime, set by DMR,
within the policy set by JSP 815 and takes precedence over all other MOD documents
relating to safety management and environmental protection for MOD Diving. JSP433
Part 1 presents clear regulations, complemented by these established codes of practice.

9 JSP 433 Pt.1 (V2.0 Jan 15)

Intelligent Customer Capability
10. The MOD is subject to duties embodied in Sections 2 to 9 of The Health and Safety
at Work etc. Act 1974, and other legislation, relating to the safety of a given undertaking.
Therefore, the Secretary of State for Defence requires that health and safety risks are
reduced to as low as reasonably practicable (ALARP). In order to declare risks are
ALARP, the MOD must demonstrate an inherent and appropriate knowledge and
understanding of the conduct of MOD diving activities.

11. Discharge of a part of MOD’s duties through contractors does not in any way
diminish the ultimate responsibility of the MOD. Therefore the MOD must remain a
sufficiently intelligent customer, within the duty holder chain of delegation to be suitably in
control of the undertakings assigned to each organisation and of staff under contract so it
is able to assert that these regulations are met. This organisational capability will include
the ability to understand and accept a Safety or Environmental Case, to authorise the risks
and hazards identified within it, taking account of applicable evidence from contractors
and, appropriate assurance from 2nd parties or Regulators. The required size of the
organisational capability to be the controlling mind will depend on several factors, including
the magnitude and severity of the hazards being managed, the complexity of the
equipment, system, its novelty and the extent to which it might be used to the assessed
limits or even beyond the standard operating limits

10 JSP 433 Pt.1 (V2.0 Jan 15)

2 Introduction
1. The MOD conducts diving and related activities including the acquisition of diving
plant and equipment and the conduct of diving operations undertaken by MOD personnel,
both military and civilian, and by sub-contractors.

2. A sound and effective diving safety management system is key to achieving

successful, harmonised diving safety performance across the organisation and to nurture a
robust, inclusive safety culture. Under the overarching MOD Safety Strategy aim of
preventing fatalities and minimising injury and ill-health to MOD personnel and those
affected by MOD activities, the aim of the MOD Diving Safety Management System
(DSMS) is to achieve the safest practicable operational and business performances that
ensure that key operational capabilities are not lost, that morale is sustained, and that the
costs of ownership are reduced. This in turn leads to increased operational availability and
effectiveness.

3. The Defence Safety and Environment Authority (DSEA) has been charged with the
responsibility for regulating safety and environmental protection regimes within the MOD.
As the majority of MOD diving activity is conducted in the maritime domain, it is included in
the DMR’s area of responsibility. All MOD Diving activity safety performance will be
monitored and regulated by SofD who is delegated authority as the Diving Regulator by
the DMR. The Diving Standards Team (DST) will be part of this group under the direction
of SofD. In the role of Regulator, SofD regulates military diving which is exempt from the
DWR 97 and all other diving being conducted under MOD auspices outside the UK.

4. To satisfy the requirement of the Diving at Work Regulations 1997 (DWR), SofD is
the Diving Contractor Focal Point, nominated to the Health and Safety Executive (HSE).
In this role, SofD assures that MOD's obligations as a ‘Diving Contractor’ or ‘Client’, as
defined in the DWR are being met. This includes leading in all Health and Safety aspects
related to diving and being responsible for the maintenance of diving standards throughout
the MOD. This assurance of compliance role, gives SofD responsibility to oversee the
entire domain, thereby ensuring MOD corporately has a systematic and comprehensive
policy for the safety of personnel undertaking this activity.

5. To ensure that MOD diving standards are coherently applied and adhered to
throughout the Department, a DSMS configured to the specific area of diving activity is to
be employed by all those involved in MOD diving operations. Each Senior Duty Holder
has responsibility to provide an effective link to individual Service Unit and MOD
commercial diving agency safety management committees and groups. Three MOD
Diving Safety Management Working Groups will coordinate safety issues in Military,
Commercial and Joint Service sub-aqua diving, (Adventurous Training), MOD sponsored
Cadet Forces, Enhanced/Standard Learning Credit Scheme and Resettlement) diving
activities. Each of these sub-Working Groups will report its assessment of the health of its
SEMS to the overarching MOD Diving Safety Management Panel (DSMP).

11 JSP 433 Pt.1 (V2.0 Jan 15)

3 Policy
1. MOD will manage its diving and related activities in an integrated manner across
the organisation by complying with applicable United Kingdom (UK) legislation as far as
practicable and by applying best practice principles in the conduct of these activities.
Overseas, MOD will apply UK standards where reasonably practicable and if a condition of
the Status of Forces Agreement, Memorandum of Understanding or other inter-
governmental agreement, will in addition comply with host nations’ standards.

2. All employers owe a duty of care to their employees, to the general public and the
wider environment. Each employee has a duty of care to themselves and each other. The
MOD discharges its obligations to manage the greater safety risks associated with military
operations through its Duty Holders. Under the authority of the Secretary of State it is
required that all MOD civilian and military personnel comply with this document when
conducting Diving and Diving Related Activities.

3. All those with health and safety responsibilities for Diving activities should be aware
of their legal obligations under UK statutory safety and common law including those
obligations arising from International Maritime Organisation (IMO) treaties. Breaches or
omissions may result in prosecutions and/or disciplinary action.

4. Applicable law includes, but is not limited to, compliance with the Health and Safety
at Work Act 1974, the DWR, the Merchant Shipping (Diving Safety) Regulations and all
subsequent Statutory Instruments so far as reasonably practicable. In addition, MOD
diving activity shall comply with all appropriate European Union (EU) directives ratified by
the UK Government, where they apply to any MOD diving operations.

5. DWR Regulation 3, exempts operations in which members of the Armed Forces of

the Crown or of a visiting Force are engaged in ‘warfare or training for warfare’ and this is
detailed in the MOD/HSE General Agreement. The Secretary of State directs that where
MOD has been granted exemptions from specific regulations, health and safety outcomes
will be, so far as reasonably practicable, at least as good as those required by statute.
Risk during Operations, exempted from DWR, shall be ALARP and the levels of safety
performance shall be duly determined. The SofD shall determine whether diving activities
are ‘exempt’ or if military diving activity constitutes “Warfare or Training for Warfare”, and
where practicable will appraise the HSE. All military diving operations shall have due
regard for both military effectiveness and safety.

6. In the development of this policy, due consideration has been given to satisfying
relevant national and international standards for managing safety systematically. Diving is
classed by the HSE as hazardous activity and considers the MOD to be a significant
employer of divers with commensurate expertise and maturity, to operate an effective and
robust diving safety management system. Consequently, it is deemed appropriate that
each implementation of MOD diving safety management policy shall aim to satisfy the
requirements of the British Standard for Occupational Health and Safety Management
(OHSAS 18001).

7. Deviation from this policy shall not occur unless agreed by the Defence Maritime
Regulator (DMR) and promulgated by the Superintendent of Diving (SofD).

12 JSP 433 Pt.1 (V2.0 Jan 15)

8. This policy applies to any diving and related activities undertaken by or on behalf of
the MOD in pursuit of its business, including:

a. diving operations conducted by MOD staff worldwide on MOD military and

civilian operations.

b. MOD sponsored Joint Service sub-aqua diving activity.

c. acquiring the services of third party divers and contractors.

d. acquisition of Diving Plant.

13 JSP 433 Pt.1 (V2.0 Jan 15)

4 Definition of Terms
Diving and Related Activities
1. Diving and related activities are all those that comprise the conduct of diving as
defined in the Diving at Work Regualtions 1997 (DWR), the Acquisition of Diving Plant
and/or diving services from third parties.

2. Diving is defined in the DWR as follows:

“For the purposes of these Regulations a person “dives” if they both-

a. Enters:

(1) Water or any other liquid.

Or

(2) A chamber in which they are subject to pressure greater than 100 millibars
above atmospheric pressure.

b. And in order to survive in such an environment they breathe in air or other gas
at a pressure greater than atmospheric pressure.”

Note. Short Term Air Supply System (STASS) is a short endurance underwater
escape breathing apparatus regulated by DES Aircraft Support and Aircraft
Commodities (DES-AS-AC) and is therefore not covered by this JSP.

Military Diving Operations

3. Military diving operations are those undertaken by UK Armed Forces military
personnel (AFMP), anywhere in the world and to any visiting foreign AFMP within UK
jurisdiction. These operations shall have DWR applied to them with the exception of
operations in which members of the Armed Forces of the Crown or of a visiting Force are
engaged in ‘warfare or training for warfare’ (see Chapter 3, Para 3). The Commanding
Officer of a Unit must satisfy the legal responsibilities of a Diving Contractor where these
apply to the diving being conducted.

Recreational and Vocational Diving

4. Joint Service sub-aqua diving under MOD auspices, is non-operational ie.non-
military diving activity, conducted when ‘on duty’ (therefore ‘at work’) and authorised by a
MOD authority. It includes diving conducted under the Joint Services Adventurous
Training (JSAT) scheme by Service military personnel, diving conducted by MOD Joint
Service sub-aqua diving instructors and standards inspectors or diving undertaken by
Service personnel or employed civilians as part of MOD approved Cadet Forces’ activities.

5. Service personnel or civilian staff participating in authorised AT, conducting

authorised competency and currency training in recreational diving or when in
assignments in the Cadet Forces or employed in paid positions in the Cadet Forces, are
classed by MOD as being ‘on duty’ and subsequently by the HSE as being ‘At Work’.
Therefore, DWR shall be applied in full without exception in the UK and as far as
reasonably practicable overseas.

14 JSP 433 Pt.1 (V2.0 Jan 15)

6. Young persons, who are members of the MOD sponsored Cadet Forces are not
deemed to be ‘At Work’ and therefore are not subject to the provisons of DWR. This does
not mean that appropriate safety precautions can be omitted or ignored and in all
circumstances where the safety of young persons is in doubt, the diving activity must be
immediately stopped or the dive aborted.

7. Vocational diving includes that undertaken by Service personnel on civilian diving

courses as part of their resettlement entitlement or under the Standard or Enhanced
Learning Credit (S/ELC) scheme for personal development purposes. Personnel attending
these courses are classed as being ‘on duty’ and therefore considered by the HSE to be
‘At Work’. DWR must be applied in full in the UK with regard to the requirements for
professional training courses and therefore MOD authorities enabling this activity overseas
must as far as reasonably practicable ensure that the provisions of DWR are met at
overseas MOD Aproved Centres (MAC). Within the UK the HSE already executes the
regulatory oversight of such courses and of young person’s training centres. Overseas,
the DST will ensure that the protection is afforded to these individuals through a robust
due diligence processes.

8. Any vocational diving conducted by personnel undertaking resettlement or ELC

activity must be managed as in the civilian commercial or recreational diving field and must
comply with the HSE ACOP for the particular type of diving being conducted.

9. Because diving activity is often undertaken overseas, where conditions and

circumstances are different to those existing in the UK for which the HSE ACOPs were
written, additional MOD specific instructions are contained in BRd 2806(5) (see note)
Adventurous Training, Vocational and Recreational Diving Manual (AVRDM). MOD AT
and Resettlement Authorities shall be able to demonstrate when challanged that the
facilities used by MOD personnel overseas meet the standards required to ensure that
MOD’s responsibilities for duty of care, as an employer are fulfilled.

Note. Superceeds JSP 917 with effect from 1 January 2015

Civilian Diving Projects

10. Civilian Diving Projects are those undertaken by or on behalf of the MOD by civilian
divers and DWR must be applied in full, without exception. This includes all diving
undertaken by commercial divers carrying out diving under an approved MOD contract,
whose conduct may be anywhere in the world. For MOD commercial, media or
scientific/archeological diving projects, the appropriate HSE Approved Code of Practice
(ACOP) must be used as the guidance document.

MOD Civilian Diving

11. MOD civilian diving organisations shall have diving safety standards systems as
part of their internal safety assurance processes and these will be subject to regulation by
the HSE in the UK. Additionally, under DWR MOD shall discharge its responsibilities as a
’client’ and/or ‘diving contractor’ by each ODH ensuring so far as reasonably practicable,
that any civilian diving taking place on MOD property or under a MOD contract complies
with statutory requirements.

15 JSP 433 Pt.1 (V2.0 Jan 15)

12. A Civilian Diving Contractor Agent is to be appointed by a Duty Holder (this may be
the MOD Civilian Diving Organisation) and is responsible through the MOD Diving
Contractor Focal Point vested in SofD ensuring that diving operations within their area of
responsibility comply with legislation and MOD policy.

13. A ‘Client’ is an organisation that places a task or contract with a contractor to

deliver a diving project, and as such has health and safety responsibilities with regard to
the diving project in accordance with Regulation 4 of DWR. The guidance for the
responsibilities of the Client are described in the relevant ACOP appropriate to the type of
diving activity being conducted. A number of MOD authorities are authorised by DMR-
DST to raise contracts with commercial diving agents and are by definition the MOD’s
‘client representatives’ with the associated responsibilities.

14. In some circumstances a MOD authority will act as a ‘Client’ for contracted diving
activity and hold Duty Holder responsibilities for military or MOD civilian diving operations.
The legal requirements of a ‘Client’ under the DWR should not be confused with the MOD
policy requirements of Duty Holders.

15. A Diving Contractor is an organisation or individual responsible for the conduct of a

diving project or task. The legal responsibilities of the Diving Contractor are laid down in
DWR and the HSE ACOPs provide detailed guidance on the scope and requirements of
these responsibilities.

16. SofD shall act as the MOD Diving Contractor Focal Point (see Chapter 6, Para 34)
to ensure that the responsibilities of the Diving Contractor are being met. Any MOD
manager directly responsible for employing divers shall be able to provide SofD, when
challenged, with objective evidence that the responsibilities of a Diving Contractor are
being fulfilled for all MOD diving operations. This will provide SofD with the necessary
assurance that any MOD manager directly responsible for employing divers in the MOD
civilian diving context is being fulfilled by an authorised MOD SQEP.

Diving Plant and Equipment

17. Diving Plant includes all Diving Equipment and support systems necessary that are
acquired for the conduct of a diving operation. This includes any support vessels, cranes,
winches and client specific tools. Diving Plant shall be demonstrated as materially safe to
operate, in accordance with JSP 430 Management of Ship Safety and Environmental
Protection, whether intended for shipboard use or not.

18. Diving Equipment is a sub-set of Diving Plant and covers all Personal Protective
Equipment (PPE) and safety equipment worn and required by a diver to undertake a diving
intervention. This includes any life support systems (self-contained, sub-surface and
surface supplied), thermal protection, communications equipment, diving dedicated
surface compression chambers, portable gas storage, portable compression facilities,
chemicals and general-purpose tools.

19. The Acquisition of Diving Plant is any activity that comprises of the management of
Diving Plant acquisition, including requirements capture, procurement, in service support
and disposal, and the discharge of safety responsibilities with respect to the plant
throughout the acquisition cycle. (See Chapter 5, Para 36).

16 JSP 433 Pt.1 (V2.0 Jan 15)

Duty Holders
20. Duty Holders shall be apointed for each diving activity, where there is a risk to life
and any wherever a SDH judges a specific management focus is required (see note). In
accordance with the principles in JSP815, each chain of accountable Duty Holding shall
define each nominated person responsible for coordinating any undertaking where the
MOD owes a duty of care such that it can be demonstrated, on behalf of MOD, that parties
affected do not suffer unreasonable harm or loss.

21. Duty Holders shall manage risk in line with the goals of MOD Safety Strategy (JSP
815), within a chain of accountability. Senior Duty Holders have responsibility for diving
safety delegated to them by the Secretary of State. They are to devolve this responsibility
to lower levels of risk owning Duty Holders. The Commanding Officer Duty Holder (or
other military or MOD civilian equivalent) shall carry the responsibility for the final approval
for authorising a diving project to commence including situations concerning the
acquisition of services from third party diving contractors and/or military divers. For MOD
diving activity, an Equipment Authority shall be identified and shall hold responsibility for
the design and material state of MOD supplied diving and related equipment.

22. Management of risk shall follow the principles set out in JSP430 and the main
statutory baseline of Health and Safety at Work etc 1974 and Merchant Shipping Act 1995
and the associated International Maritime Organisation Conventions. This Defence
regulatory regime for Diving requires maritime Duty Holders to focus on the management
of all sources of potential harm from maritime activities affecting people, the environment
and property. The nominated Duty Holders within this regulatory framework are the
Senior Duty Holder, Operating Duty Holder, Platform Duty Holder, Delivery Duty
Holder and the Commanding Officer Duty Holder.

Note. JSP 815, Chapter 3 draws its main statutory baseline from the Health and Safety at
Work Act 1974 and the Environmental Protection Act 1990 etc.

Diving Standards Officers

23. Diving Standards Officers (DSO) shall be responsible for monitoring the practices
and procedures of diving and related activities, and to assure that it is being carried out in
as safe and efficient manner as the nature of the task will allow. These functions are
carried out by separate domain related DSO positions for the Royal Navy, Army,
Commercial and Joint Service sub-aqua diving.

24. DSOs are authorised by SofD to monitor diving standards at any venue or location
where MOD diving activity is taking place. They shall be delegated authority by SofD to
take immediate action where diving safety standards are found to be unsatisfactory and
this may include the serving of sanction Notices to formally record safety shortcomings.

17 JSP 433 Pt.1 (V2.0 Jan 15)

5 Conduct of Diving Operations and
Projects
Military Diving Operations
1. Military Diving Operations shall be conducted in accordance with BRd 2806 (1-4 &
6) UK Military Diving Manual. These may be supplemented by additional instructions and
regulations issued by the SofD. BRd 2806 is a DCOP in accordance with the principles
set by JSP815 and is recognised by the HSE as the authorised guidance for UK military
diving, such that compliance with it satisfies the statutory diving regulations.

2. BRd 2806 applies to all UK Military Diving Operations including those outside UK
territorial waters. In these instances, each Duty Holder shall also comply with the Merchant
Shipping (Diving Safety) Regulations and any local or IMO treaty legislation that pertains,
as far as reasonably practicable.

3. Any deviation is to be fully justified to and approved by SofD. SofD may delegate
authority to the relevant DSO to approve such deviations and such delegations will be
recorded in standing or temporary orders as required.

MOD Civilian Diving Projects

4. MOD Civilian Diving Projects must be conducted in accordance with the DWR in
the UK and shall be met overseas. The appropriate HSE ACOP must be used within UK
waters and shall be used as the standard guidance for operations in waters overseas.
These ACOPs may be supplemented by other HSE and industry guidance as appropriate.
Where conflicts arise with other documents, the HSE ACOP shall take precedence unless
a condition of international agreement described in Chapter 3, Para 1 is in effect.

5. Duty Holders shall also comply with the Merchant Shipping (Diving Safety)
Regulations and any local or IMO treaty legislation that pertains as far as reasonably
practicable.

6. The ODH responsible for ensuring relevant Duty Holders are involved in the risk
assessment of the Diving project shall justify any deviation from these ACOPs for MOD
Civilian Diving Operations. SofD shall be authorised to approve such deviations if the
circumstances of the case admit, and consult with the DSMP prior to sanctioning any such
deviation. Any deviation from an ACOP shall be reported to the HSE as soon as the
circumstances (including security considerations) allow.

Joint Service Sub-Aqua Diving

7. All diving activity, when ‘on-duty’ must be conducted in accordance with the HSE
ACOP for Recreational Diving Projects or the appropriate Commercial Diving Projects
ACOP (see Chapter 4, Para 9). Due to the worldwide nature of Service Sub-Aqua activity,
additional measures shall be complied with overseas as the MOD deems necessary to
mitigate the accepted increased risk that diving overseas involves, and are contained in
BRd 2806(5).

18 JSP 433 Pt.1 (V2.0 Jan 15)

8. Any deviation from HSE ACOPs and BRd 2806(5) shall only be approved by SofD.
Such an intention to deviate from the Regulations shall be through an application to the
lead Adventurous Training Authority for Joint Service Recreational Diving (see note) or for
Service Sub-Aqua that is not an AT activity through the Unit CO.

Note. The lead Senior Manager for Joint Service Sub-aqua AT activity is Captain Naval
Physical Development based at HMS TEMERAIRE.

9. Diving by personnel employed as Joint Service sub-aqua diving instructors or

Diving Standards Inspectors, for the purpose of individual continuous professional
development or Group/Team capability development in recreational diving, shall be in
accordance with the HSE ACOP. Therefore, such diving shall adhere to the guidance in
BRd 2806(5) which is aligned to the HSE ACOP.

10. Diving by military personnel qualified in Joint Service sub-aqua diving, when ‘on
duty’ conducting diving operations, other than for AT, using recreational diving equipment,
shall follow guidance in BRd 2806(5). Depending on the nature of the operation being
conducted and the familiarity of the supervisors and divers involved with these diving
manuals, will determine which manual is most appropriate. Such diving shall be
authorised in writing by the Unit CODH and when necessary, advice sought from SofD
regarding the application of the manuals.

Acquiring Third Party Diving Services

11. When acquiring diving services, the MOD Client responsibilities must be
discharged by competent staff in a manner that meets the requirements of the HSE ACOP
appropriate to the diving operation. The requirement to comply with the Merchant
Shipping (Diving Safety) Regulations must be considered whenever such diving services
are being acquired.

12. In the event that the Duty Holder or MOD authority acting as a ‘Client’ does not
possess the competency required, guidance shall be sought from the Salvage and
Mooring Operations (SALMO) organisation which is part of the DE&S who are the
Department’s nominated lead for such activity.

13. When a MOD civilian business unit requires military divers to undertake non-
military diving operations on their behalf, such as diving required for equipment
commissioning trials, the ODH responsible for the military divers shall inform SofD. The
conduct of such diving shall be with due regard to the requirements of DWR and may
involve measures not required in normal military diving operations.

14. Any MOD Duty Holder or Client shall halt a diving operation if there are concerns
regarding the safety and/or conduct of the operation.

15. Combined operations involving both MOD and third party civilian divers shall be
conducted in accordance with DWR. Prior to commencing operations it shall be defined
which organisation is the 'diving contractor' for the operation. SALMO or other non-military
MOD contracted divers shall only be supervised under the relevant HSE ACOP and not
BRd 2806.

19 JSP 433 Pt.1 (V2.0 Jan 15)

Diving Plant Used in Diving Operations
16. Maintenance. All Diving Plant must be maintained in safe working order, in
accordance with authorised maintenance procedures and appropriate HSE and industry
guidance.

17. Diving Plant for Civilian, Joint Service Sub-Aqua and Military Operations

a. Diving Plant shall not be used outside of any configuration or operating

envelope specified in the safety case without agreement from the appropriate Duty
Holder for the plant and based on a re-evaluation of the safety case.

b. In the event of an urgent operational requirement, when time does not allow
agreement by the Duty Holder/Equipment Authority for the plant, the decision
mechanism and justification for a course of action shall be documented and
forwarded to the relevant Duty Holder as soon as practicable. The documentation
shall include risk assessment in accordance with JSP 375 Volume 2 Leaflet 39.

c. Diving Plant shall only be supplied to a third party providing it is in a safe

working order, that all supporting documentation is provided, and that the third
party has provided assurance to the Duty Holder that they can be reasonably
considered to be competent to operate the plant.

d. Diving Plant for Joint Service Sub-Aqua Diving. Diving Plant shall not be
used outside of any configuration or operating envelope specified in the safety
case or, in the absence of a safety case, by the manufacturer.

Obtaining Technical Advice

18. All technical advice relating to Diving Plant acquired by the MOD shall be sought
from the appropriate Equipment Authority (EA).

19. In the event that a Commanding Officer or MOD Civilian Duty Holder is required by
the circumstances to authorise the use of any plant, in a configuration not specified in the
safety case and/or outside the operating envelope specified in the safety case, advice
must be sought and agreement obtained from the appropriate Operating Duty Holder as
the circumstances allow, and from SofD prior to any such operation

20. All other technical and operational advice shall be sought from a demonstrably
competent organisation.

21. All technical medical advice relating to diving plant shall in the first instance be
sought from the Institute of Naval Medicine (INM). Other medical specialists shall be
consulted when INM are unable to provide SME or reference to alternative specialists.

Reporting of Accidents and Incidents

22. Accidents, incidents and near misses shall be reported in accordance with the
requirements of BRd 2806, MOD civilian diving regulations, Service Incident Reporting
Cell instructions and the Reporting of Injuries, Diseases and Dangerous Occurrences
Regulations (RIDDOR) when not managed by single Service Incident reporting
procedures.

20 JSP 433 Pt.1 (V2.0 Jan 15)

23. Those related to MOD acquired Diving Plant, including any plant shortfalls shall be
reported to the appropriate Equipment Authority as well as the ODH.

24. The Operating Duty Holder shall ensure that an accident, incident and near miss
reporting system exists. The reporting system shall:

a. Ensure that all accidents, incidents and near misses are reported.

b. Ensure trends are identified and corrective action taken to prevent

reoccurrence.

c. Ensure that the organisation learns from experience in a timely manner.

d. Put in place control measures to prevent the recurrence of any serious

accident, incident or near miss. and

e. Include a closed loop feedback mechanism.

25. All accidents and incidents shall be reported to the DST in order that any pan-
department equipment related issues can be addressed as quickly as possible.

26. The Commanding Officer Duty Holder shall ensure that the reporting system
mandated by the Operating Duty Holder is fully implemented.

27. Accidents involving death or serious injury, significant damage to property or the
environment shall be reported to the Defence Maritime Regulator.

28. Such accidents shall be investigated by the Diving Standards Team with the aim of
finding out the root cause and to inform learning.

29. Accident investigations shall examine, in a timely manner, all Defence Lines of
Development and identify, as a minimum, any relevant:

a. Design issues.

b. Material failures.

c. Shortfalls in risk assessments.

d. Shortfalls in operating procedures.

e. Shortfalls in organisational arrangements, competence and training.

30. Recommendations identified during investigations shall be passed to the relevant

Duty Holders, Training Authorities or other stakeholders who have the authority to enact
improvement and prevent recurrence.

31. All lessons identified during investigations shall be appropriately disseminated by

the Duty Holders as part of a continuous improvement process.

21 JSP 433 Pt.1 (V2.0 Jan 15)

Acquisition of Diving Plant for Military and Civilian Operations
32. The acquisition of all Diving Plant shall be conducted in a manner that satisfies the
requirements of JSP430 and, where applicable, the HSE ACOP appropriate to the diving
operations for which the plant is to be used. In addition, the requirements of the IMO Code
of Safety for Diving Systems and appropriate EU directives shall be complied with as far
as reasonably practicable.

33. The Acquisition of Diving Plant, other than Diving Equipment, shall be assessed by
the Duty Holder, with the relevant competency and for which this activity forms part of their
Area of Responsibility.

34. Safety cases shall be prepared for all such Diving Plant in accordance with the
requirements of JSP430, including all legacy plant. Safety cases for rudimentary pieces of
diving equipment such as fins, weight belts and knives may be assessed as part of the
assessment of the diving activity so long as they are of good quality and are clearly fit for
purpose.

35. The System Requirement Document (SRD) shall be reviewed and agreed by all
potential users, a demonstrably competent technical authority, and the appropriate
acquisition Duty Holder.

Acquisition of Diving Equipment for Military and Civilian Operations

36. In addition to military requirements, all appropriate regulations, directives,
standards and guidance issued by appropriate international bodies, the EU, the HSE and
industry bodies relating to Diving Equipment shall be adopted as far as reasonably
practicable and justified in the Safety Case using the required Risk Control Systems. Any
deviation shall be fully justified and approved by the ODH.

37. The acquisition of all Diving Equipment for military and MOD civilian commercial
diving operations within the MOD shall be conducted by, or with the agreement of the
Underwater and Electronic Warfare (UEW) Project Team – Diving and Life Support
Capability Manager, who is the authorised DE&S lead for diving equipment procurement.
The SofD shall exceptionally permit ODHs to purchase diving equipment for specialised
military operations.

38. Military equipment, with a specified performance requirement and that contains
risks that cannot be justified as ALARP, shall have a full justification proposition sent to the
ODH by the EA before in-service procurement activities commence.

39. Diving Equipment Project Safety Case Committees shall be chaired by the EA for
Diving Equipment or ODH representative and shall report to the ODH on the status of all
safety cases.

40. Safety cases shall be prepared for all such Diving Equipment and shall
demonstrate that safety risks are ALARP. All legacy equipments shall have safety cases
in place or approved management programmes for their completion.

41. All Diving Equipment must be supplied to users with clear and concise instructions
for its use and maintenance.

22 JSP 433 Pt.1 (V2.0 Jan 15)

42. Equipment safety bulletins shall be published and promulgated across the user
community by the EA and shall include emergency notices when equipment is no longer
considered to be fully compliant with user requirements and/or current regulations.

43. The management, provision and quality control of breathing gases shall be
considered as part of the diving equipment acquisition activity. Assessments shall include
management of breathing gases which is regulated by the Fuel and Gas Safety Regulator.
Regulations governing diving gases and the control of gases are contained in JSP 319
Joint Regulations for the Control and Storage of Gases.

Use of Foreign Diving Equipment for Military Operations

44. Military Divers are sometimes presented with the opportunity to dive using the
equipment in use with another nation’s Armed Forces. In these circumstances approval to
use foreign equipment lies with the respective ODH and shall be formally given through
recognised means. SofD (or DSO) shall be consulted prior to such approval being given.
The final authority to conduct diving operations using such equipement shall rest with the
CODH. Due regard must be taken wih regard to the experience, competency and
currency of the supervisor and divers using the equipment, as well as the different
operating practices and procedures of the nation providing the equipment.

45. Personnel in Loan Foreign Service or Exchange Assignments shall, under the
terms of Memoranda of Understanding authorising their position in the host nation’s Armed
Forces, be expected to use the equipment in use and operate it in accordance with host
nation procedures and practices. The requirement for individuals in such circumstances to
use foreign diving equipment rests with the appropriate ODH. In these circumstances,
SofD shall be asked to provide a letter of authorisation for the individual concerned to
deviate from BRd 2806.

46. In all cases where diving equipment is supplied by foreign government sources,
appropriate and effective training in the use of the equipment and procedures required to
operate it safely shall be conducted, using suitably qualified instructors. It is accepted that
the maintenance practices and standards of the equipment provided, will not always align
or be compatible with UK standards. Appropriate Duty Holder scrutiny of the standards
used shall be necessary before any approval is given to use foreign supplied diving
equipment. Where any doubt exists SofD shall be consulted for advice and a
recommendation on the most appropriate course of action.

Diving Medicals
47. It is fundamental that diving conducted at work, requires divers involved to be
medically ‘in date’ for diving. MOD divers shall either hold a valid medical Certificate (HSE
MA2 or MOD Leaflet 12-03) or, for military divers, have an endorsement in their S1627
Military Diving Log Book showing the date of their diving medical. Only the most pressing
of operational circumstances shall justify the validity of a diving medical to be extended by
INM or a diving dispensation to be authorised by SofD.

48. The responsibility for ensuring divers are in-date for a diving operation is the legal
responsibility of individual divers. Duty Holders must also consider their responsibilities
under the DSMS and the consequences of personnel conducting diving when out of date
for medical fitness to dive.

23 JSP 433 Pt.1 (V2.0 Jan 15)

49. UK law requires diving medicals as stipulated by the HSE and this is currently a
validity period of 12 months. MOD divers will fall into the following categories of diving
medical standards:

a. Military Divers. Diving medical standard defined in BR 1750A applies to all

military personnel including those in the Reserve Forces and serving personnel
conducting Service Sub-Aqua diving. Military Divers deploying on operations are
liable for ensuring that they remain medically in-date for the duration of the
deloyment.

b. Military Divers in Overseas Assignments. Personnel shall arrange to

undergo a Service Diving Medical as close to their departure date as possible.
They shall attempt to ensure they remain medically in-date by returning to the UK
or by using deployed UK Service medical facilities and staff on an opportunity
basis. Where no such opportunity is available they shall contact INM and seek
guidance. If the host nation or other nation’s medical standards are compatible
with those of the UK, INM may sanction the conduct of a diving medical by foreign
medical staff using an agreed medical standard for the diving medical.

c. MOD Civilian Divers Based in the UK. Diving medical standard defined by
the HSE and administered by HSE Approved Medical Practioners (AMED)
including SANMO, civilian diving instructors and standards inspectors.

d. MOD Civilian Divers Based Overseas. HSE has agreed that for MOD
Civilian Diving Instructors, including locally employed civilian instructors, the
requirement to undergo an HSE AMED can be impractical to achieve, as it requires
attendance at an HSE AMED in the UK. Exceptionally, Civilian Diving Instructors
unable to travel to the UK for this purpose, may have the option of undergoing a
Service diving medical, conducted by a suitably qualified Medical Officer (MO) in
the base location. Where the MO does not hold this qualification the Head of
Diving Medicine at INM shall be consulted. INM will determine if the Diving Medical
can be conducted under these circumstances. The validity of the medical
Certificate is restricted to the base location or, if acting as essential civilians for an
AT Diving Expedition originating from their base location, for the duration of the
Expedition provided it is not taking place in the UK. A Service diving medical
certificate held by a civilian is not recognised in the UK.

e. Cadet Force Civilian Adult Volunteers. As agreed with the HSE, these
personnel shall be subject to the AMED or Service medical procedure, depending
on whether they are serving Service personnel or not. (In the former case the
Service medical and for the latter the AMED apply.)

f. Foreign Service Personnel. In general, under the terms of the MOD

exemption from DWR, ‘for warfare and training for warfare’, Foreign Service
personnel will be expected to remain within their own national medical
requirements for diving while operating with UK Armed Forces. Manning
Authorities responsible for the oversight of these personnel shall confirm with the
donor nation the medical requirements for diving in the UK or as part of the UK
Armed Forces. Only if diving shall be conducted for recreational purposes under
the Joint Service AT scheme, will a UK Service Diving Medical be required to be
completed before undertaking this kind of diving.

24 JSP 433 Pt.1 (V2.0 Jan 15)

6 Responsibilities for Diving
MOD Policy Sponsor
1. The sponsor of this document is Responsible for:

a. Maintaining an effective diving policy to manage compliance with diving

legislation and regulations.

b. Resolving policy issues and disputes as required.

General Responsibilities
2. The authority for implementing this Diving safety and environmental regime is
placed with Duty Holders as defined in JSP815 and shall be devolved down the
management chain.

3. Where authority flows via Senior Managers, who are not themselves Duty Holders,
they will be responsible for ensuring that their staffs are properly able to carry out the
requirements of the safety policy defined in this JSP. Line Managers at every level shall
ensure that all posts with safety management and environmental protection responsibilities
have appropriate letters of delegation or terms of reference that specify the duties and
levels of competence required for the post. Delegation shall not be imposed until the post
holder is deemed competent to discharge their safety and environmental protection
responsibilities:

While everyone holds a duty of care for safety and environmental protection but a Defence “Duty Holder”,
is a formally appointed role delegated to key staff with responsibility for the people put at risk by the
operation of MOD Diving. These are defined in a three-tier structure, at the top of the organisation
(Senior Duty Holder), the operational management level (Operating/Intermediate Duty Holder), a separate
responsibility for material support (Equipment Authority), and the delivery level (Commanding
Officer/Delivery Duty Holder).

These precise terms make it easier to demonstrate compliance with policy. It is important is that
individuals are identified that carry out the responsibilities laid out for Duty Holders.

Although particular organisations may be responsible for particular Defence Lines of Development, the
products delivered by each line must take into account the other lines. E.g. Equipment must be designed
take into account assumptions about the level of Training required and Infrastructure available, Training
must make assumptions about the Equipment available and the Doctrine for its use. These assumptions
should be made explicit and managed appropriately.

4. People nominated to hold Duty Holder or Equipment Authority roles shall be given
the resource necessary to meet their safety and environmental protection responsibilities.

5. Every individual to whom this policy applies shall exercise due care and diligence,
by ensuring that:

a. they understand and comply with their legal obligations, applicable safety and
environmental policies and objectives.

b. immediate action is taken to remedy any concern or shortfall in safety that

could pose imminent danger or compromise safety. If the action is outside the
individual’s control, they shall inform their line management or those with the
authority to take appropriate action.

25 JSP 433 Pt.1 (V2.0 Jan 15)

 c. they request adequate resources, including funding and people, for the safety
tasks they are responsible for, so that they are achieved in reasonable timescales.

d. tasks are understood and carried out in accordance with appropriate

procedures.

e. they do not undertake tasks for which they are not suitably competent or allow
a third party to undertake tasks on their behalf for which the third party is not
competent.

f. they maintain their competence for their post including an adequate level of
currency in diving where necessary.

g. they take reasonable care of their health and safety and exercise their duty of
care to other persons affected by their acts or omissions at work.

h. they understand their organisation’s diving safety management system and its
relationship with the other management systems it interfaces with, both within and
external to their organisation.

i. they seek continuous improvement in safety performance.

Senior Duty Holders Responsibilities

6. The Senior Duty Holder shall be accountable and responsible for the safety and
environmental protection of MOD diving throughout the acquisition cycle and are key
leaders of its safety and environmental culture. They shall set the direction for safety and
environmental management and, when challenged, shall be able to demonstrate that their
organisation and arrangements enable the requirements of the regulations to be met.

7. The Senior Duty Holder shall ensure that the safety and environmental protection
implications of any organisational changes are analysed and appropriately reported in
advance through a documented process.

8. The Senior Duty Holder shall ensure that it is made clear which individuals hold the
following roles and what the scope of their accountability and responsibility is:

• Operating Duty Holder.

• Platform Duty Holder.

• Equipment Authority.

• Commanding Officer Duty Holder.

9. At all stages of the acquisition cycle, for all MOD diving, the Senior Duty Holder
shall ensure that nominated Duty Holders or those with Equipment Authority roles clearly
understand who they are accountable to, and are given the resource necessary to meet
their safety and environmental protection responsibilities.

26 JSP 433 Pt.1 (V2.0 Jan 15)

Operating/Intermediate Duty Holders Responsibilities
10. The Operating Duty Holder shall be accountable and responsible to the Senior
Duty Holder for ensuring that the requirements detailed below are complied with to an
extent and to a level of detail that is appropriate to the platform’s or equipment’s stage in
the acquisition cycle:

a. An effective regime is established and maintained so that the safety and

environmental aspects of MOD diving activities are managed as part of a Diving
Safety Management System throughout the life of the systems, ensuring that
interfaces with other regimes are also managed effectively.

b. Safety Cases and Environmental Cases exist that justify the operation of MOD
diving activity, and are maintained for the operation of each diving system,
demonstrating that it is safe to operate, that it is operated safely, and in an
environmentally sound manner. and people with sufficient competence are
available to assist those charged with developing and maintaining valid arguments
and evidence.

c. Assurance is obtained from an Independent Safety Auditor and an Independent

Environmental Auditor that management activities across the whole safety and
environmental regime comply with planned arrangements, are implemented
effectively and are suitable to achieve objectives. and that related outputs are
correct, valid and fit for purpose.

d. Platform Duty Holders and Equipment Authorities understand the level of safety
and environmental information to be provided by them to enable the Operating
Duty Holder to make informed and timely decisions about safety risks and
environmental aspects associated with a system.

e. Formally manage the integration of those elements and activities within the
Defence Lines of Development that directly affect safety risks and environmental
aspects associated with a system.

f. Valid Each Safety Case Reports and Environmental Case Reports are
authorised and available for each diving systems.

g. Formally indicate their acceptance of the Safety Case Report, Environmental

Case Report and the supporting evidence.

h. Obtaining Defence Maritime Regulator Certification as described in Chapter 7.

i. Diving systems are operated and maintained by adequate numbers of

competent personnel. where sufficient competent personnel cannot be provided,
the safety and environmental implications of this shortfall are assessed and
suitable mitigation put in place.

j. Systems and procedures are not modified in a way that prejudices safety or
environmental protection.

k. Diving systems are tasked and operated in accordance with their Safety Cases
and Environmental Cases.

27 JSP 433 Pt.1 (V2.0 Jan 15)

 l. Emergency arrangements are put in place, documented, followed, understood,
tested, monitored and subject to regular review and improvement.

m. Ensuring that all accidents, incidents, near misses and hazards are reported,
analysed, investigated and acted upon.

11. If the authority to direct the command of diving project or place tasks on its
Commanding Officer Duty Holder shall be passed outside the Operating Duty Holder's
organisation, the Operating Duty Holder shall ensure that arrangements and
responsibilities for safety and environmental protection remain clear and documented.

Operating Outside the Safety Case

12. If exceptional circumstances require the operation of any system outside of the
Safety or Environmental Case, such operation shall be strictly in accordance with JSP 430
Part 1 para 2.1.2. If the operational circumstances allow SofD shall be consulted prior to a
final decision being made.

13. Deviation from Diving Regulations shall only be approved by SofD.

14. Deviation from HSE Approved Codes of Practice for Diving Projects - MOD diving
projects which are not being conducted by Military Divers must be conducted under the
provisions of the DWR 97 and the relevant HSE Approved Codes of Practice (ACOP) for
commercial, scientific, media and recreational diving. These ACOPS are legally applicable
inside UK Territorial Waters and deviation from them would need to be justified in the
event of an incident. Prior consultation wth the HSE must be carried out if the need to
deviate from an HSE ACOP is identified. SofD is the MOD focal point for contact with the
HSE and any application to deviate from an ACOP shall be via SofD. Outside the UK,
under the Secretary of State’s direction, the provisions of the apropriate ACOPs shall be
applied as far as reasonably practicable. Where this is not possible SofD shall be
consulted before such a diving project is commenced.

Equipment Authorities Responsibilities

15. The Equipment Authority shall be responsible for ensuring that the requirements
detailed below are complied with to an extent and to a level of detail that is appropriate to
the platform’s or equipment’s stage in the acquisition cycle:

a. Implementing and maintaining an effective regime to control the safety and

environmental aspects of the design and material state of a diving system or
equipment throughout the acquisition cycle, ensuring that interfaces with other
regimes are managed.

b. Identifying safety, environmental protection and combat safety requirements,

standards and tolerability criteria for the diving system or equipment, in
consultation with the Sponsor and Operating Duty Holder and, where appropriate,
the Naval Authority or relevant subject matter experts.

c. Advising on balance of investment decisions to the Sponsor or Operating Duty

Holder as required to ensure the necessary resources are available to address
safety and environmental protection through the whole acquisition cycle.

28 JSP 433 Pt.1 (V2.0 Jan 15)

 d. Identifying, planning and defining funding for through life maintenance activities
essential to make sure that the upkeep of the platform or equipment meets the
Goal.

e. Ensuring feedback processes are in place to confirm that risk control measures
are effective.

f. Ensuring that suitable arrangements, in conjunction with the Operating Duty

Holder, are in place to manage material defects in the platform or equipment and
that analysis of the safety and environmental protection implications of defect data
is carried out.

g. Ensuring that where a safety or environmental argument makes assumptions

that those assumptions are validated, and where those assumptions are about
actions or risk control measures which are the responsibility of other organisations
(e.g. Operating Duty Holder, Training Authorities), those responsible have
acknowledged and agreed their responsibilities.

h. Authorising of key documents that contribute to Safety Cases or Environmental

Cases, irrespective of whether their production is contracted out or not, to confirm
that their contents are comprehensive, credible and coherent. Before
authorisation, the document shall, where required by the Operating Duty Holder or
another Duty Holder, be endorsed by an Independent Safety Auditor and
Independent Environmental Auditor.

i. Providing comprehensive operating, maintenance and long term storage

instructions to the relevant Duty Holder.

j. Issuing safety and environmental documentation when needed, particularly

before trials.

k. Escalating to the Operating Duty Holder, Senior Managers and, if necessary,

the Defence Maritime Regulator, any risk that threatens the Goal where control is
beyond the control of the Platform Duty Holder or Equipment Authority.

16. The Equipment Authority shall also be specifically responsible for:

a. Generating and maintaining the argument and evidence about the equipment
or sub-system necessary to support the Safety Case and Environmental Case for
its use independently or when fitted to a platform. The arguments shall
demonstrate compliance with the Goal, unless a more stringent requirement is
appropriate.

b. Providing safety and environmental documentation to the Platform Duty Holder,

at the level of detail and in the timescales set by the Platform Duty Holder. Where
the equipment is used independently of a platform, the Operating Duty Holder shall
specify these requirements and receive the documentation directly.

29 JSP 433 Pt.1 (V2.0 Jan 15)

17. The Equipment Authorities may formally delegate all or part of the Design Authority
function held by them to a suitably competent design organisation. They shall, however,
retain responsibility for ensuring the safety of the equipment through-life, minimising the
environmental harm caused by the equipment through-life, authorisation of key documents
that contribute to the Safety Case or Environmental Case, and ensuring that the
organisation that has received the delegation is competent and is fulfilling their delegated
duties. In these circumstances the Equipment Authority shall ensure the adequacy of
design and that the design organisation is aware of their responsibilities and is suitably
contracted to support them.

18. The Equipment Authority shall ensure that safety and environmental protection is
not compromised when transferring a system between authorities during its life, or by
implementing (or failing to implement) design changes, modifications, updates or
upgrades.

Commanding Officer/Delivery Duty Holders Responsibilities

19. Commanding Officer Duty Holders shall be accountable and responsible to the
Operating Duty Holder for:

a. Establishing and maintaining effective Safety and Environmental Management

Systems for their diving team that reflect the requirements of the Operating Duty
Holder's Safety and Environmental Management Systems and are detailed in
Standing Orders and operating instructions.

b. Operating their diving teams in a way that meets the Goal in accordance with
the requirements for Certification specified in Chapter 7, and exercising a duty of
care to the divers, any third parties that could be affected, and the environment.

c. Ensuring that systems and procedures are not modified in such a way as to
prejudice safety or environmental protection.

d. Ensuring that all accidents, incidents, near misses and hazards are reported,
analysed, investigated and acted upon.

e. Ensuring emergency arrangements are in place, followed, understood and

tested.

f. Ensuring that shortfalls in the safety or environmental performance of the diving

systems design, material state or procedures are notified to the appropriate
authority in a reasonable timescale.

20. If exceptional circumstances requires the operation of any system outside of the
Safety or Environmental Case, such operation shall be strictly in accordance with JSP 430
Part 1 para 2.1.2 and, if within the scope of Certification, para 6.1.1a

Senior Managers Responsibilities

21. Senior Managers shall be held responsible for ensuring that the resources
allocated to Duty Holders or Equipment Authorities and the directions or advice given,
meet the requirements of the regulations at all times. The Senior Managers’
responsibilities shall include:

30 JSP 433 Pt.1 (V2.0 Jan 15)

 a. Ensuring that JSP 430 and lower-level safety and environmental protection
policies are widely available, understood and applied and that appropriate safety
and environmental Management Regimes exist, including formal delegations for
safety and environmental protection.

b. Making available adequate resources, including funding and people, for the
safety and environmental tasks that they delegate, so that they are achieved in
reasonable time scales.

c. Ensuring adequate arrangements exist to capture feedback and resolve

shortfalls relating to safety or environmental issues in management systems,
design performance, materiel or operational aspects through-life.

d. Ensuring adequate arrangements are in place for learning from experience.

e. Reporting safety and environmental performance to the Defence Safety &

Environment Authority.

22. When decisions about a safety or environmental protection risk have been
escalated to a Senior Manager, the Senior Manager shall take advice (e.g. engineering,
safety, environmental and legal) from the Operating Duty Holder, Platform Duty Holder and
appropriate specialist areas.

Diving Standards Team Responsibilities

23. On behalf of the Defence Maritime Regulator the Diving Standards Team shall
audit Defence diving compliance with these regulations and assure compliance with
applicable statutory legislation.

24. Following satisfactory assurance, the Diving Standards Team shall, provide
certification for shore based and shipboard safety and environmental management areas
specified in Chapter 7.

25. For the MOD diving regulatory regime, the Diving Standards Team shall be
responsible for:

a. Setting safety and environmental policy, specifying duties and outputs so that
the MOD is enabled to meet its legal duties and setting performance standards
where legislation does not apply.

b. Providing advice and guidance on compliance with policy, including advice on

risk control systems and leadership role in driving corporate understanding of risk.

c. Providing assurance to Director Defence Safety and Environment Authority

regarding Duty Holder compliance with policy.

d. Scrutinising and providing advice on concessions from Diving regulations and

staffing exemptions, derogations or disapplications of diving from statutory
legislation where required.

e. Auditing and authorising Duly Authorised Persons or Organisations (including

the Naval Authority and other independent assurance bodies).

f. Providing assurance of the resilience of systems during change.

31 JSP 433 Pt.1 (V2.0 Jan 15)

MOD Civilian Duty Holders (Civilian Diving Projects and Acqusition of
Third Party Diving Services)
26. The duties of a DDH shall apply to a MOD civilian holding executive authority and
to any MOD diving activity where the Unit is in a non-operatonal state, e.g. an RN warship
in non-fleet time. Additionally where any Platform Duty Holder or other MOD manager with
equivalent “safe to operate” duties, instructs their own staff to conduct Civilian Diving
Projects or commission agents to acquire the diving services of third party contractors or
military divers, they shall ensure their duties are fulfilled to the satisfaction of the ODH.

27. Where MOD authorities engage a prime contractor who arranges third party diving
services the delivery of the diving activity shall comply with these Regulations. When
MOD authorities contract their own diving services, the process being used shall assure,
the contracted diving service provider is operating to standards of practice which conform
to UK standards or are recognised by the HSE as being equivalent. Assurance shall be
provided when challanged that the competence of those involved meets HSE published
guidance on the comparability of international diving qualifications in its ‘Approved List of
Diving Qualifications’. Any intention by a MOD authority to engage the services of a diving
contractor, who uses diving procedures not conforming to these standards or declares that
the diving qualifications held by its divers or not recognised by the HSE must be
authorised by SofD. Advice and guidance on the selection of compliant overseas diving
contractors is available from SANMO.

28. Preference shall be given to major diving contractors who are members of
recognised industry bodies, such as the International Maritme Contractors Association
(IMCA) and/or the Association of Diving Contractors (ADC). These organisations have
adopted standards to which their members must adhere to and in general these align with
UK statutory requirements, and have worldwide application. While membership of such
industry bodies does not automatically assure compliance with UK statute, it can be part of
the body of evidence by which MOD’s responsibilities as a client can be demonstrated to
have been fulfilled.

Client Responsibilities
29. When commercial diving projects are being conducted appropriate Duty Holders
and managers are responsible for:

a. Appointing a Civilian Diving Contractor Agent in writing, and taking reasonable

steps to ensure that any diving contractor selected is capable of complying with the
Diving Regulations.

b. Making available to the diving contractor the results of any risk assessment
undertaken by other persons under other statutory legislation that could affect the
health and safety of the dive team.

c. Providing facilities and extend all reasonable support to the supervisor or diving
contractor in the event of an emergency.

32 JSP 433 Pt.1 (V2.0 Jan 15)

 d. Considering whether any known underwater or above-water items of plant
under their control may cause a hazard to the dive team. The diving contractor
should be informed of the location and nature of such hazards. They should also
provide the diving contractor, in good time, with details of any change to this
information occurring before or during the course of the diving project.

e. Considering whether other activities in the vicinity may affect the safety of the
diving project.

f. Ensuring they have a formal control system in place to cover diving activities.

g. Providing the diving contractor with details of any possible substance likely to
be encountered that would be hazardous to the dive team. Such information shall
be provided in writing in sufficient time to allow the diving contractor to carry out a
risk assessment.

h. Keeping the supervisor informed of any changes that may affect the diving
operation in so far as they have control over or knowledge of such changes.

i. With regard to the acquisition of third party services, the DH is responsible for
ensuring that the MOD’s ‘Client’ responsibilities are discharged by competent staff
in accordance with this policy.

j. Reporting any diving safety management issues or incidents to SofD.

Civilian Diving Contractor Agents

30. Civilian Diving Contractor Agents, as appointed by an appropriate DH, are

responsible for ensuring that diving processes, manuals and working practices relating to
diving operations within their area of responsibility, comply with legislation and this policy,
and are enforced.

User Requirement Sponsors

31. Those formulating diving capability requirements shall consider diving operating
safety at all stages of the acquisition cycle and make investment decisions as required and
in accordance with departmental safety policy.

Training Authority
32. A Training Authority Shall be Responsible For:

a. Ensuring that training meets the requirements of the activity Training Needs
Analyses and relevant MOD and statutory standards.

b. Ensuring that the training delivered matches any assumptions made about it in
the equipment safety case.

c. Updating training where appropriate to take account of changes to the role,

operating environment or material state of systems and the implications of
incidents that are reported as a result of their use.

33 JSP 433 Pt.1 (V2.0 Jan 15)

MOD Superintendent of Diving
33. As the MOD Diving Contractor Focal Point, SofD shall act as the liaison between
the MOD and HSE on all diving matters. SofD shall ensure that all MOD managers
responsible for diving activities satisfy the responsibilities of the Client and Diving
Contractor described in the DWR in so far as it is reasonably practicable to do so and with
respect to the MOD exemptions from DWR.

34. The MOD Diving Contractor Focal Point is responsible for:

a. Acting as focal point for diving safety within the MOD.

b. Ensuring that an effective and efficient Diving Safety Management System

(DSMS) is employed for all MOD diving activity.

c. Ensuring that Diving Contractor responsibilities or the military equivalent are

delegated to appropriate diving managers.

d. Assuring that Civilian/Commercial Diving Contractor Agents and MOD

authorities with responsibility for commissioning commercial diving under MOD
contract, comply with statutory requirements when conducting such diving
operations.

e. Monitoring diving technical and procedural developments and legislation.

f. Ensuring that lessons are learnt in the event of a reported breach of legislation
or accident and that processes are improved where necessary.

g. Auditing the performance of Duty Holders in ensuring that personnel

conducting MOD diving activities are suitably qualified and experienced and that
their diving currency is at an appropriate level.

h. Monitoring and reporting on the Department’s performance in the

implementation of Diving Safety Policy to the DMR.

35. SofD is the MOD Diving Regulator with authority delegated via the DMR from the
Director DSEA. The authority of MOD Regulators is described in JSP 815 and includes
the power to serve non-conformance Notices where failures to comply with MOD safety
policy, procedures and regulations have been identified. With the agreement of the HSE,
SofD will serve such Notices on MOD agencies where non-conformance with statutory
regulation has been identified as part of the MOD assurance process within the UK.
Outisde the UK SofD is authorised to serve Notices without agreement of the HSE. All
DMR Notices carry the delegated authorityof the Director DSEA and while they are not
legally ‘enforceable’ in the same way as a sanction issued by the HSE, they do constitute
the removal of MOD authority for the diving activity concerned. Any continued diving
activity shall be at the personal liability of the Duty Holder responsible, until the identified
safety shortcoming has been addressed as required by SofD. In common with other
DSEA Regulators warning and sanction Notices used are as follows:

34 JSP 433 Pt.1 (V2.0 Jan 15)

 a. Defence Warning/Advisory letter regarding legislation, Defence Regulations
policy compliance or good practice. Where the recipient believes they are meeting
the legislative requirements in an alternative way the onus is on them to prove this.
Advice may be provided verbally and/or in writing but to avoid possible conflicts of
interest with further enforcement action, the regulator will only give advice on the
standards required to achieve regulatory compliance or examples of good practice.

b. Defence Improvement Notice where there is an issue of non-compliance with

legislation or Defence Regulations and policy. In such circumstances advice will
be provided as to how the recipient can become compliant and they will be given a
time period in which to achieve compliance.

c. Defence Prohibition Notice where there is an immediate risk of serious

personal injury. This Notice will direct that the activity is ceased immediately and
direction will be provided to the recipient on remedial actionsrequired. Any risks to
safety or environmental impacts remain the responsibility of the recipient and non-
compliance with a Prohibition Notice will leave the recipient personally liable for the
risk posed.

36. Appeals against the decision of the MOD Diving Regulator with regard to the
serving of a sanction Notice or the provisions contained within such a Notice, which are
considered necessary to address the safety non-conformance, can be made first to the
DMR. The appeal shall be made in writing within 21 days. If the appeal is unresolved a
further appeal can be made to the Director DSEA. Where the matter is still unresolved
appeal can be made to the PUS and ultimately SofS.

37. SofD directs the Diving Standards Team (DST) in its role in monitoring diving
safety. The nature of the existing provisions of DWR and SofS Safety Policy requires the
DST to deliver both regulatory and assurance outputs for MOD diving and related
activities.

38. SofD delegates the day to day management of MOD diving domains to a
nominated Diving Standards Officer (DSO). The DST is resourced to manage the military
and recreational diving domains and DSO Navy, Army and Adventurous Training are the
nominated Officers. Currently, DSO Army also manages the MOD Commercial Diving
domain, but SofD will utilise any spare capacity from within the whole of the DST to meet
the requirements of this task until additional resources are made available.

39. SofD and DST personnel are required to possess extensive professional diving
and MOD safety management knowledge and experience as a minimum requirement for
their roles. Additional training in safety system management is specified by DMR and
recorded in individual Terms of Reference Competence Requirements. Continuous
professional development of DST staff in safety assurance procedures shall be adopted.

Service Level Agreements

40. Service Level Agreements (SLA) between the DSEA and domain DHs shall define
the effective and efficient use of the available SQEP resources in the MOD. Such SLAs
will be reviewed as part of the Department’s routine business and will be terminated when
resources allow.

35 JSP 433 Pt.1 (V2.0 Jan 15)

41. Service Level Agreements arranged between Duty Holders and the DMR, shall not
absolve DH of their responsibility to ensure commensurate levels of diving SQEP are
managed and developed within their organisations. They shall manage the required diving
safety management systems, procedures and structures. The objective of an SLA is to
achieve “lean regulation” by avoiding duplication of assurance effort where resources are
limited and sustain the overarching safety goal of continuous improvement in safety
performance.

42. Work shall be prioritised according to the following hierarchy:

a. Accident investigations involving death or serious injury, significant damage to

property or the environment.

b. Level 3 CODH/DDH Diving Safety Certification.

c. Level 3 ODH Diving Safety Certification in support of DMR.

d. Support to Level 2 ODH lead Intermediate Verifications.

e. ODH NLIM technical investigations, support to MOD Duty Holders (Civilian

Diving Projects and acqusition of Third Party Diving Services)

36 JSP 433 Pt.1 (V2.0 Jan 15)

7 Certification
1. Validity of Certification. Diving shall not be undertaken by any unit without a valid
certification as required by these regulations

2. Defence Maritime Regulator Certification:

a. Defence Maritime Regulator Certificates shall be required for the Safety and
Environmental Management Systems for shore side and shipboard diving activity.
These certificates are Diving Safety Certificates.

b. The Diving Standards Team shall, on behalf of the Defence Maritime

Regulator, following satisfactory audit, issue certification for the Safety and
Environmental Management Systems established by the Operating Duty Holder.
The issue of a Diving Safety certificate shall follow demonstration by an Operating
Duty Holder and Commanding Officer Duty Holder that appropriate safety and
environmental protection arrangements are in place for shore based and shipboard
diving operations. Diving Safety Certification shall be issued in accordance with
the application of the regulations.

ODH Diving Safety Certification

3. The Diving Safety Certificate shall be issued by the Diving Standards Team to any
Operating Duty Holder complying with the requirements of these regulations for a period
specified by Defence Maritime Regulator which shall not exceed six years. Diving Safety
Certification shall routinely be undertaken as an integral part of the Defence Maritime
Regulator audit programme however, they can be undertaken in isolation if the timing of
the Defence Maritime Regulator audit programme would lead to an unacceptable break in
Diving Safety Certification.

4. Diving operations shall only be undertaken by an Operating Duty Holder who has
been issued with a Diving Safety Certificate.

5. Compliance of the Operating Duty Holder with the requirements of the regulations
shall be reflected through the issue of a Diving Safety Certificate issued in accordance with
the following:

a. The Diving Safety Certificate shall only be valid for the diving operations
explicitly indicated in the document. Such indication shall be based on the types of
diving which the initial verification was based. Other diving operations shall only be
added after verification of the Operating Duty Holder’s capability to comply with the
requirements of the regulations.

b. The validity shall be subject to periodic verification by the Diving Standards

Team. The periodicity shall be set by the Defence Maritime Regulator.

c. The Document of Compliance shall be withdrawn by the Defence Maritime

Regulator when the periodic verification required in sub para b above expires or if
there is systemic evidence of major non-conformities with the requirements of the
regulations.

37 JSP 433 Pt.1 (V2.0 Jan 15)

CODH/DDH Diving Safety Certification
6. The compliance of the diving safety management system arrangements with the
requirements of these regulations shall be reflected through the issue of a Diving Safety
Certificate. The Diving Safety Certificate shall be issued in accordance with the following:

a. It is verified that the CODH/DDH has demonstrated the diving safety

management system arrangements operate in accordance with the approved
Safety and Environmental Management System.

b. The Operating Duty Holder or, exceptionally, the Defence Maritime Regulator,
is satisfied those arrangements align with operational planning requirements.

c. The validity shall not exceed a period of two years with the following
exceptions:

(1) AT Diving:

(a) MOD Approved Centres. 12 months.

(b) Naval Cadet Force Training Team. 12 months.

(c) Dive Branches. 3 years.

d. Validity shall be subject to at least one intermediate verification by the

Operating Duty Holder, the ODH may, exceptionally, use the Diving Standards
Team Inspectors to assist with intermediate verifications but must provide the
supervising officer to lead the team (see note). The intermediate verification shall
be carried out between 9 and 16 months of the date of the Diving Safety
Certificate.

e. The Certificate shall be withdrawn by the Diving Standards Team when the
intermediate verification required in sub para d above is not undertaken or if there
is evidence of major non-conformity with the requirement of the regulations.

Note. The Diving Standards Team (Adventurous Training) will conduct all
certification IAW with sub para c (1) above, there is no requirement for ODH’s to
conduct intermediate verifications on AT organisations

Renewal of Defence Maritime Regulator Certification

7. Notwithstanding the requirements of Paras 5 and 6 above, when the renewal audit
or supporting verification evidence is completed within three months before the expiry date
of the existing certification, the new certification shall be valid for a period two years from
the date of expiry of the existing certification.

8. When the renewal verification is completed more than three months before the
expiry date of the existing certification, the new certification shall be valid from the date of
completion of the renewal verification for a period of two years from the date of completion
of the renewal verification.

38 JSP 433 Pt.1 (V2.0 Jan 15)

9. When the renewal verification is completed after the expiry date of the existing
certification, the new certification shall be valid from the date of completion of the renewal
verification for a period of two years.

39 JSP 433 Pt.1 (V2.0 Jan 15)

8 Diving Safety Management System
MOD Diving Safety Management Panel
1. Formed in response to the Crown Censure placed on the MOD by the HSE in
2003, following a series of fatal diving accidents, the Diving Safety Management Panel
(DSMP) shall advise the DMR on the development of diving safety policy and
management across the MOD. It is comprised of representatives from the key MOD diving
activity stakeholder groups and draws experience from all Duty Holders (DH) responsible
for ensuring that diving safety management is compliant with the DMR policy. It is for each
DH to ensure that diving is managed in a co-ordinated and informed manner and to ensure
that safety in diving is in accordance with the objectives of the MOD Safety Strategy. he
DSMP supports the Maritime Stakeholders Safety and Environment Committee (MSSEC)
as and when required.

2. The DSMP will comprise of standing representatives from the following

organisations:

a. DMR Team Leader (Chairman).

b. SofD.

c. Operating Duty Holder Safety Representatives (Navy/Army/DES/JFC/DIO/Dstl).

d. Training Authority (FOST).

e. HSE.

f. INM.

g. MOD Scientific Advisor (Dstl).

h. Chairman of the MDSMWG (DSO DSO(N)/(A).

i. Chairman of the JSSADPAC (NAVY PERS SO1 AT).

j. Chairman of the CDSMWG (DSO (C)).

k. DSO (AT).

l. Equipment Authority Representative.

m. Secretary (Non-Chair of the MDSMWG DSO(N)/(A).

3. The Tasks of the DSMP are as Follows:

a. Make recommendations to change MOD Diving Safety Management Policy and

associated Diving Regulations. (This will normally be as a result of issues
contained in sub-Working Group Reports to the DSMP).

40 JSP 433 Pt.1 (V2.0 Jan 15)

 b. Review changes to statutory regulations and industry best practice and advise
stakeholders on implication of such changes to MOD diving activity.

c. Review the diving safety performance of all MOD diving activity, as an indicator
of policy and regulatory performance.

d. Provide SME advice to the DMR.

e. Provide SME advice to the MSSEC.

f. To meet at least at six monthly intervals so the Defence Maritime Regulator is

appraised of the state of Duty Holder performance in diving safety in the MOD.

Diving Safety Management Working Groups Panel

4. The nature of and wide range of diving activity within the MOD requires an ability to
ensure all such activity has safety management oversight. While SofD is the Regulator it
is incumbent upon each Duty Holder to maintain sufficient oversight of the areas within
their Area of Responsibility and support the DSMP. Therefore individual Diving Safety
Management Working Groups, formed from within the groups stakeholder community will
coordinate the safety issues emerging from their particular areas of diving activity. There
are three Working Groups:

Military Diving Safety Management Working Group

5. Military Diving Safety Management Working Group (MDSMWG):

a. The MDSMWG shall convene 6 monthly to review safety performance or when

necessary as directed by an appropriate Duty Holder or SofD. It is chaired by
DSO(N)/(A) and the Secretary will be the non-Chair DSO(N)/(A). Meetings shall be
called in sufficient time before the DSMP sits to provide military diving domain
input. Records of the DST audits, FOST(MPV) and CAA&I reports shall be
reviewed as necessary.

b. Membership. DSO(N), DSO(A), DST(N/A) staff, SEO(FDS), FOST(MPV),

DDS DTO(N)/(A), INM, FDS, NDG (inc NSRS), SDG, CHALFONT, HMNB, Gib
CDE, RNR, UETU, Equipment Authority, RM Poole, Divisional and Unit ADS
(Army), SALMO Sponsored Reserves, ODH Desk Officers.

c. Tasks:

(1) To review safety performance indicators and make recommendations to

improve performance.

(2) To follow up action items from ship/unit DIRs/Near Miss Returns.

(3) To implement actions arising from meeting of the DSMP.

(4) To review impending safety legislation.

(5) To advise on issues arising from other MOD diving forum.

41 JSP 433 Pt.1 (V2.0 Jan 15)

 (6) To advise the DSMP on diving safety high-risk areas.

(7) To identify equipment safety issues.

d. Agenda. The agenda is raised by DSO(N)/(A) in consultation with SofD.

Standing items are described in the Military Diving Manual.

e. Actions. Action items will be closed out at each subsequent MDSMWG

meeting or passed to the DSMP for consideration.

f. Records. The findings, conclusions and recommendations reached as a result

of the reviews shall be recorded as minutes and retained on file for a period of 6
years within the DST.

Joint Service Sub-Aqua Diving Policy Advisory Committee

6. Joint Service Sub-Aqua Diving Policy Advisory Committee (JSSADPAC)

a. The JSSADPAC is a Working Group that shall convene 6 monthly to review

safety performance or when necessary as directed by an appropriate Duty Holder
or SofD. It is Co-Chaired by NAVY PERS SO1 AT, SofD (For DSMP issues) and
the Secretary is SO2 AT. Meetings shall be called in sufficient time before the
DSMP sits to provide the recreational diving domain input. Records of the DST
audits, single Service Sub-Aqua Diving Association reports shall be reviewed as
necessary.

b. Membership. SO1 AT, SO2 AT, SofD, DSO(AT), DSI(AT), OIC JSSADC
Devonport, Representatives from single Service AT Authorities, Single Service
Sub-Aqua Diving Association Chairmen, INM, BSAC representative, Cadet Forces
Diving Authority Representatives.

c. Tasks:

(1) Ensure all personnel taking part in JSAT sub-aqua diving are aware of and
comply with BRd 2806(5) and, through adherence to the HSE ACOP for
Recreational Diving, comply with DWR97.

(2) Seek advice and feedback from the OIC JSSADC.

(3) Seek regular updates on sub-aqua diving assurance issues, incidents and
lessons identified by the Diving Standards Officer (AT).

(4) Seek advice from the sub-aqua diving medicine specialist.

(5) Seek input from the single Service AT policy desk officers.

(6) Seek input from the single Service sub-aqua Association Chairmen/
Secretaries.

(7) Seek input from the Cadet Forces sub-aqua representative.

42 JSP 433 Pt.1 (V2.0 Jan 15)

 (8) Ensure that rapid notification of changes to sub-aqua diving policy are
achieved through a cascade messaging system utilising JSSADPAC
Committee members and the Bovisand Bulletin.

(9) To advise JSATSG of actions arising from the JSSADPAC.

(10) To ensure through DSO(AT) the DMSP is advised of any safety concerns
in the sphere of JSAT sub-aqua diving activity. This will include advising the
DMSP on any diving incident or near miss reported.

(11) Agree the list of MOD Aproved Centres for the following 2 seasons.

d. Agenda. The agenda is raised by NAVY PERS SO1 AT in consultation with

stakeholders.

e. Actions. Action items will be closed out at each subsequent JSSADPAC

meeting or passed to the DSMP for consideration.

f. Records. The findings, conclusions and recommendations reached as a result

of the reviews shall be recorded as minutes and retained on file for a period of 6
years at HMS TEMERAIRE.

Commercial Diving Safety Management Working Group

7. Commercial Diving Safety Management Working Group (CDSMWG)

a. The CDSMWG shall convene every 6 months to review safety performance or

when necessary as directed by an appropriate Duty Holder or SofD. Meetings
shall be called in sufficient time before the Diving Safety Management Panel
(DSMP) in order to submit a safety performance report in sufficient time to enable
the DSMP to report to the Maritime Stakeholder Safety and Environment
Committee (MSSEC). The Chairman of the Working Group is DSO(C) and the
Secretary is DSI(C).

b. The membership of this Working Group shall comprise representatives from

NBC Diving Safety Organisations (Faslane, Portsmouth, Devonport), Commercial
Diving Contractor Agents (BAE, UMC, SERCO, Babcock, Shearwater etc.), DE&S
SANMO and DIO. Representatives with responsibility for authorising Diving
Projects, DST, HSE (if available) and representatives from other MOD
establishments which routinely undertake MOD commercial diving activities.
Additional members shall be included in order to ensure MOD responsibilities for
commercial diving safety are met:

c. Tasks:

(1) To review safety performance indicators and make recommendations to

improve performance.

(2) To ensure there is a coherent and common approach to diving safety

management in MOD commercial diving.

43 JSP 433 Pt.1 (V2.0 Jan 15)

 (3) To ensure lessons identified from MOD commercial Diving Incident
Reports/Near Miss are disseminated to all stakeholders and follow up actions
as required.

(4) To consider implications on MOD commercial diving of impending safety

legislation.

(5) To advise on issues arising from other MOD diving forums.

(6) To advise the DSMP on diving safety in high-risk areas.

(7) To implement actions arising from meeting of the DSMP.

(8) To identify common equipment safety issues.

(9) To produce the MOD Commercial Diving safety performance report to the
DSMP.

d. Agenda. Agendas shall be issued prior to the meeting by the Chairman.

Stakeholders shall submit particular items for discussion as required.

e. Actions. Action items will be closed out at each subsequent CDSMWG

meeting or passed to the DSMP for consideration.

f. Records. The findings, conclusions and recommendations reached as a result

of the reviews shall be recorded as minutes and retained on file for a period of 6
years within the DST.

Safety Management Structures

8. The MOD safety management structures for Diving and Diving Related Activities
are detailed in the following Appendices:

a. Appendix 1. MOD Diving Safety Management Structure

b. Appendix 2. Military Diving Safety Management Structure

c. Appendix 3. MOD Recreational Diving Operations Structure

d. Appendix 4. MOD Civilian Diving Operations Structure

9. An appropriate DSMS shall be used in every area of MOD diving activity to

facilitate and manage diving safety processes and procedures.

10. Service Sub-Aqua diving safety management utilises BR 2806(5) which endorses
the procedures and processes in use by the British Sub Aqua Club (BSAC), the
Recreational Diving National Governing Body and provides additional MOD specific
guidance. All Service sub-aqua branches and clubs are required to be enrolled members
of BSAC.

44 JSP 433 Pt.1 (V2.0 Jan 15)

MOD Policy Approval and Control
11. The MOD Diving Contractor Focal Point shall be responsible for maintaining the
MOD diving safety policy and advising the Policy Sponsor of all diving issues that require
their attention.

12. The DSMP, chaired by DMR Team Leader, shall report upon the safety state of all
MOD diving activity to the Director DSEA and inform the future DST inspection
programme. The DSMP shall be the forum used for advising other Departmental
stakeholders on current diving legislation and regulations.

Diving Manual Approval and Control

13. The authority responsible for BRd 2806 UK Military Diving Manual is SofD. As the
HSE recognised guide to military diving, any significant changes shall be made in
consultation with the HSE.

14. The authority responsible for the BRd 2806(5) Joint Service Sub-Aqua Diving
Regulations is SofD. Any significant changes shall be made in consultation with the HSE.

Policy Implementation

15. SofD will assure compliance with this policy by all MOD management and staff
responsible for or involved in Diving and Diving Related Activities.

MOD Policy Review

16. This policy document shall be reviewed every year, or sooner at the discretion of
the Policy Sponsor or if events that impact on this policy, including:

a. Changes in legislation and/or regulation.

b. Changes in the MOD organisation/roles.

Audit
17. Each Duty Holder shall ensure that the requirements of this policy are being
maintained through regular internal audits. The principles of MOD audit procedures are
detailed in JSP 375 Volume 4. Duty Holders shall support DSEA Level 3 audits carried out
by the Diving Standards Team as directed by the Defence Maritime Regulator. The audit
should seek to:

a. Provide assurance that activities are being performed in accordance with the
SEMS.

b. Identify opportunities to improve the management system.

c. Identify opportunities to raise awareness of safety and environmental protection

issues.

d. Identify any training needs and competency requirements.

45 JSP 433 Pt.1 (V2.0 Jan 15)

 e. Provide assurance of compliance with applicable safety standards, both
statutory and non-statutory.

f. Recognise good practice.

g. Inform the management review process.

h. Inform policy development.

i. Improve procedures for the management of safety and environmental

processes.

18. The audit programme shall consider at all levels:

a. Compliance with MOD policy.

b. Compliance with DWR.

c. Compliance with relevant JSPs.

d. Safety assurance.

e. Competencies, currency and training.

f. Equipment procurement, operation and maintenance.

g. Third Party independent audit.

19. Internal audits shall be conducted at least every 12 months by MOD diving
organisations, and at least every three years for the acquisition of Diving Plant, or at a
more frequent periodicity set by a Duty Holder.

20. Level 3 audits by the DMR shall be conducted at a frequency commensurate with
the circumstances and level of risk of the area being monitored according to their
programme. The audit procedures used by the DST will conform to ISO 19011 (see note).

21. In order to accredit the assurance effort conducted by the DST, the HSE shall be
requested to monitor DST audit procedures and examine audit assessments on a
frequency which can demonstrate confidence in MOD’s diving safety management system.

Note. ISO 19011 Guidelines for auditing management systems.

46 JSP 433 Pt.1 (V2.0 Jan 15)

9 References
1. The Health and Safety at Work Act 1974.

2. The Diving at Work Regulations 1997.

3. The Merchant Shipping (Diving Safety) Regulations 2002.

4. The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations

1995.

5. IMO Code of Safety for Diving Systems 1995.

6. JSP375 Health and Safety Handbook.

7 JSP430 Ship Safety Management.

8. JSP442 Accident Reporting System.

9. HSE Approved Codes Of Practice for Diving Projects.

10. OHSAS 18001 Occupational Health and Safety Management Standards.

11. ISO 19011 Guidelines for Auditing Management Systems

12. BRd 2806, UK Military Diving Manual, Vols 1 - 6

13. The Acquisition Handbook.

14. BR 9147 Navy Command Safety and Environment Management System.

15. Army Code 71815 A Commander’s Guide to Safety and Environmental Risk
Management.

47 JSP 433 Pt.1 (V2.0 Jan 15)

10 List of Abbreviations
2SL Second Sea Lord
8FEB 8 Force Engineer Brigade
ACNS Assistant Chief of Naval Staff
ACOP Approved Code Of Practice
ADS Army diving Supervisor
ALARP As Low As Reasonably Practicable
AMED Approved Medical Practioner
AT Adventurous Training
ATVRDM Adventurous Training Vocational and Recreational Diving Medical
BSAC British Sub-Aqua Club
CAS Chief of the Air Staff
CDE Clearance Diving Element
CDM Chief of Defence Materiel
CDSMWG Commercial Diving Safety Management Working Group
CDTT CHALFONT Diving Training Team
CGS Chief of General Staff
CNPD Captain Naval Physical Development
CNS Chief of Naval Staff
CO Commanding Officer
CODH Commanding Officer Duty Holder
DDH Delivery Duty Holder
DDS Defence Diving School
DE&S Directorate of Engineering and Support
DESB Defence Environment and Safety Board
DH Duty Holder
DIO Defence Infrastructure Organisation
DLSE SRC Diving and Life Support Equipment Safety Review Committee
DMR Defence Maritime Regulator
DNPTS Director of Naval Physical Training and Sport
DSEA Defence Safety and Environment Authority
DSM Diving Safety Memorandum
DSMC Diving Safety Management Committee
DSMP Diving Safety Management Panel
DSMS Diving Safety Management System
DSO Diving Standards Officer
DST Diving Standards Team
DSTL Defence Science and Technology Laboratories
DWR Diving at Work Regulations
EU European Union
FDS Fleet Diving Squadron
FLEETCMDR Fleet Commander
FOST Flag Officer Sea Training
HSE Health and Safety Executive
IMCA International Marine Contractors Association
IMO International Maritime Organisation
INM Institute of Naval Medicine
IOSH Institute of Occupational Health and Safety
IPT Integrated Project Team
IPTL Integrated Project Team Leader

48 JSP 433 Pt.1 (V2.0 Jan 15)

IRCA International Register of Chartered Auditors
ISM In-service Submarines Project Team
ISO International Standards Office
JSAT Joint Services Adventurous Training
JSP Joint Services Publication
JSSADC Joint Services Sub-Aqua Diving Centre
JSSADPAC Joint Services Sub-Aqua Diving Policy Advisory Committee
JSSADR Joint Service Sub-Aqua Diving Regulations
MCMV Mine Countermeasures Vessel
MDSWG Military Diving Safety Working Group
MOD Ministry Of Defence
MSSEC Maritime Safety Stakeholder Executive Committee
NDG Northern Diving Group
NLIMS Naval Lessons Identified Management System
NSRS NATO Submarine Rescue System
OC Officer Commanding
ODH Operating Duty Holder
OIC Officer-in-Charge
PDH Platform Duty Holder
PPE Personal Protective Equipment
PDEV Physical Development
RIDDOR Reporting of Injuries, Diseases and Dangerous Occurrences Regulations
SADS Sub-Aqua Diving Supervisors
S&MO Salvage and Marine Operations
SDG Southern Diving Group
SOFD Superintendent of Diving
SQEP Suitably Qualified and Experienced Person(s)
SRD System Requirement Document
SUMC Standard Underwater Medical Course
URD User Requirements Document
UEW Underwater and Electronic Warfare

49 JSP 433 Pt.1 (V2.0 Jan 15)

11 Glossary
Note. This policy uses the terms defined here to talk about generic roles. The names of
the particular posts carrying out those roles will vary across the organisation.

An unintended event, or sequence of events, that causes

Accident harm.
(Def Stan 00-56 issue 4)

As Low As Reasonably Practicable. A risk is ALARP when the

cost of any further risk reduction (in terms of money, time or
ALARP trouble including the loss of defence capability), is grossly
disproportionate to the benefit obtained from that risk
reduction.

(ACOP) The HSE Provides legal guidance on the application

of the Diving at Work Regulations under different operating
circumstances. The ones most likely to be applicable to MOD
diving activity are as follows:
Approved Code of
Practice
ACOP for Commercial Diving Projects Inland/Inshore
ACOP for Commercial Diving Projects Offshore
ACOP for Recreational Diving Projects
ACOP for Archeological and Scientific Diving Projects

Adequate confidence and evidence, through due process, that

Assurance safety and environment requirements have been met.
(JSP 815)

The process of endorsing and giving authority to a document

Authorisation (of a
and becomes accountable for its contents. Authorisation is
document)
indicated by a signature.

An organisation that places a task or contract with a contractor

to deliver a diving project, and as such has health and safety
Client
responsibilities with regard to the diving project in accordance
with Regulation 4 of Diving at Work Regulations 1997.

(CODH) The person charged with the Military Command and

consequently the responsibility for safe diving operations in all
Commanding Officer
units engaged in any diving under MOD auspices and
Duty Holder
including the conduct of defined associated diving plant
maintenance activities.

50 JSP 433 Pt.1 (V2.0 Jan 15)

 (DMR) The maritime component of the Defence Safety &
Environment Authority. Headed by the Maritime Regulator,
the body that sets maritime safety and environmental policy
Defence Maritime provides advice and guidance on compliance. The DMR is
Regulator required to independently check and audit Duty Holders’
assurance that safety and environmental protection is being
delivered and where necessary to censure non-compliance or
scrutinise requests for exemptions.

(DDH) used in some MOD safety management structures

broadly equating to a safety risk owner level equating to a
military CO Duty Holder and includes any Project Team
Delivery Duty Holder Leader or other MOD manager with equivalent duties. It can
also be any Project Team Leader or other MOD manager with
equivalent responsibilities, whose staff acquire the diving
services of third party contractors or military divers.

1. The authority vested in an individual or organisation to

ensure the fitness for purpose of a design and to make or
Design Authority approve changes to the design.

2. The individual or organisation that holds Design Authority.

Secondary legislation under the Health and Safety at Work Act

1974, the Diving at Work Regulations 1997 (DWR) places a
duty on 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, to take such measures as
Diving at Work
it is reasonable for a person in his position to take to ensure
Regulations 1997
that these Regulations are complied with.

MOD has an exemption to comply with the DWR for

operations conducted by members of the Armed Forces of the
Crown or of a visiting force engaged in warfare or training for
warfare.

An organisation responsible for the conduct of a diving project

or task as legal responsibilities laid down in DWR and the HSE
Approved Codes of Practice (ACOPs) provide detailed
guidance on the scope and requirements of these
responsibilities. For military diving operations the Diving
Diving Contractor
Contractor equates to the Commanding Officer of the Unit
conducting the diving operation or project and these
responsibilities are defined in BRd2806 Military Diving Manual.
For MOD civilian diving the Diving Contractor is the Team
Leader of the department conducting the diving operation.

(DSMP) The overarching management body responsible for

Diving Safety advising on diving safety policy set by DMR throughout the
Management Panel MOD and acting as the focal point for the various diving safety
management systems used within the MOD.

51 JSP 433 Pt.1 (V2.0 Jan 15)

 (DSMS) A system of comprehensive, coherent and practical
processes, procedures and organisational structures which
facilitate the required level of checks and balances in MOD
diving activity, designed to meet safety requirements and
Diving Safety
safety policy objectives.
Management System
(Adapted from Def Stan 00-56 issue 3)

Such a system must enable operating safety to be an integral

part of Diving Operational Capability.

(DST) The DST is the component of the DMR responsible for

monitoring diving safety standards in all areas where this
activity is conducted under MOD auspices. There are three
sub-divisions each responsible for a particular field of MOD
Diving Standards diving and these are:
Team
Diving Standards Team (Navy)
Diving Standards Team (Army)
Diving Standards Team (Adventurous Training)
Diving Standards Team (Commercial)

A key person appointed to discharge a duty of care for a

Defence undertaking such that others do not suffer
unreasonable harm or loss from a Defence Activity. They shall
have sufficient control to supervise operations that significantly
affect the safety and environmental protection of Diving
activities. They shall hold responsibility and accountability
beyond normal managerial duties to coordinate DLODs that
cross line management responsibilities.

There are different titles for duty holders in the MOD, in

Duty Holder general the following Duty Holder titles are used across the
spectrum of MOD diving and will be nominated in department
management arrangements as having responsibilities for
diving:

• Senior Duty Holder (SDH)

• Intermediate or Operating Duty Holder (ODH)
• Delivery Duty Holder (DDH)
• Commanding Officer Duty Holder (CODH)
• Platform Duty Holder (PDH)

To assert that a document meets the requirements of relevant

policy, procedures and good practice.
Endorse (JSP 520)
Endorsement may be provided either by signature of the
document or by provision of a separate statement.

Environmental Prevention of harm to the natural environment.

Protection (JSP 815)

52 JSP 433 Pt.1 (V2.0 Jan 15)

 An item that is designed to provide one or more services or
functions to the user or the system of which it forms a part.
Equipment e.g. pumps, motors, valves, air conditioning plant, radar, gun,
etc.
(JSP 520)

(EA) The person charged with the development and

maintenance of the safety regime for an equipment or a sub-
Equipment Authority
system of a ship.
(JSP 430)

The generic term for those standards for controlling risk which
have been judged and recognised by HSE or another
Good practice authoritative body as satisfying the law when applied to a
particular relevant case in an appropriate manner.
(Adapted from HSE ALARP guidance)

Death, physical injury or damage to the health of people, or

Harm damage to materiel or the environment.
(Def Stan 00-56 issue 4)

A physical situation or state of a system, often following from

Hazard some initiating event, that may lead to an accident.
(Def Stan 00-56 issue 4)

The continually updated record of the hazards, accident

sequences and accidents associated with a system. It
Hazard Log includes information documenting risk management for each
hazard and accident.
(Def Stan 00-56 issue 4)

The occurrence of a hazard that might have progressed to an

Incident accident, but did not. Sometimes referred to as a near miss.
(Def Stan 00-56 issue 4)

An individual or team, from an independent organisation, that

undertakes audits and other assessment activities to provide
assurance that safety activities comply with planned
Independent Safety
arrangements, are implemented effectively and are suitable to
Auditor
achieve objectives. and whether related outputs are correct,
valid and fit for purpose.
(Def Stan 00-56 issue 4)

The exposure arising from a specific risk before any action

Inherent risk has been taken to manage it.
(JSP 892)

The risk posed by a system independent of its interaction with

Intrinsic risk
other systems.

Near miss See incident.

53 JSP 433 Pt.1 (V2.0 Jan 15)

 1. The authority vested in an individual or organisation to
conduct the administration of MOD Diving (e.g. manning,
maintenance of operating instructions, learning from incidents
and accidents).
Operating Authority
2. The individual or organisation that holds Operating
Authority.
(JSP 430)

(ODH) The person charged with the safe administration and

Operating Duty
employment of MOD Diving at the operational level. In the
Holder
MOD this will typically be the Operating Authority.

The total set of all external natural and induced conditions to

Operating
which a system is exposed at any given moment.
Environment
(Def Stan 00-56 issue 4)

The exposure arising from a specific risk after action has been
taken to manage it, and making the assumption the action is
Residual risk
effective.
(JSP 892)

Combination of the likelihood of harm and the severity of that

Risk harm.
(Def Stan 00-56 issue 4)

The systematic application of management policies,

procedures and practices to the tasks of hazard identification,
Risk management hazard analysis, risk estimation, risk and ALARP evaluation,
risk reduction and risk acceptance.
(Def Stan 00-56 issue 4)

Safety and The overarching structure for managing safety and

environmental environmental protection and discharging associated
regime responsibilities.

A structured argument supported by a body of evidence that

provides a compelling, comprehensible and valid case that a
Safety/Environmental
system is safe or environmentally sound for a given
Case
application in a given operating environment.
(Adapted from Def Stan 00-56 issue 4)

A report that summarises the arguments and evidence of the

Safety/Environmental Safety Case/Environmental Case, and documents progress
Case Report against the safety programme.
(Adapted from Def Stan 00-56 issue 4 and POEMS v2.2e)

A group of stakeholders that exercises, oversees, reviews and

Safety/Environmental endorses safety/environmental management and safety
Committee engineering/environmental protection activities.
(Adapted from Def Stan 00-56 issue 4)

54 JSP 433 Pt.1 (V2.0 Jan 15)

 A document that defines the strategy for addressing safety or
Safety/Environmental environmental protection and may document the Safety
Management Plan Management System for a specific project.
(Adapted from Def Stan 00-56 issue 4)

A requirement that, once met, contributes to the safety or

Safety/Environmental environmental performance of the system or the evidence of
Requirement the safety performance of the system.
(Adapted from Def Stan 00-56 issue 4)

The person with overall responsibility for undertaking an

element or elements of MOD Diving by an organisation. In
Senior Duty Holder
the MOD this will typically be a Top Level Budget Holder or
agency Chief Executive.

A person with responsibility for allocating resources or

Senior Manager providing direction or advice to Duty Holders, the Naval
Authority or other Authorities.

(SofD) SofD is the MOD Diving Regulator with authority

delegated from the DMR and specifically responsible for
Regulating MOD Diving activity under the ‘exemption’ from
Superintendent of
DWR 97. This person is also the MOD Diving Contractor
Diving
Focal Point, a legally recognised position, nominated to the
HSE in accordance with the DWR and responsible for
monitoring diving safety assurance across the MOD.

A combination, with defined boundaries, of elements that are

used together in a defined operating environment to perform
a given task or achieve a specific purpose. The elements may
System
include personnel, procedures, materials, tools, equipment,
facilities, services and/or software as appropriate.
(Def Stan 00-56 issue 4)

An organisation supplying suitable training for the

Training Authority development of competent personnel to the levels specified in
Training Needs Analyses.

55 JSP 433 Pt.1 (V2.0 Jan 15)

 APPENDIX 1
MOD DIVING SAFETY MANAGEMENT STRUCTURE

56 JSP 433 Pt.1 (V2.0 Jan 15)

 APPENDIX 2
MILITARY DIVING SAFETY MANAGEMENT STRUCTURE
(NAVY)

57 JSP 433 Pt.1 (V2.0 Jan 15)

MILITARY DIVING SAFETY MANAGEMENT STRUCTURE
(ARMY)

58 JSP 433 Pt.1 (V2.0 Jan 15)

 APPENDIX 3
MOD RECREATIONAL DIVING OPERATIONS STRUCTURE

59 JSP 433 Pt.1 (V2.0 Jan 15)

 APPENDIX 4
MOD CIVILIAN DIVING OPERATIONS STRUCTURE

60 JSP 433 Pt.1 (V2.0 Jan 15)

Ministry of Defence. © Crown Copyright 2015

61 JSP 433 Pt.1 (V2.0 Jan 15)