Hazard Identification & Risk Assessment

The DAN-SA Hazard Identification and Risk Assessment programme promotes a culture of safety at diving businesses. Here is an overview of the programme.
 
After being summoned to stitch up yet another finger mangled by the ladder hinges on a local diving boat, one of our colleagues, a diving doctor, notably said “That is it! I have had it with these sliced fingers!” The words echoed with frustration and a plea for intervention. And they were heeded, as DAN responded. This is the result of that response: a programme that is able to focus the attention of all parties invested in the diving industry on reducing avoidable and repeated accidents called the DAN Hazard Identification and Risk Assessment (HIRA) programme.

The idea of hazard identification and risk assessment is not new. These are well-established principles for most industries. The challenge, though, was not to simply create a new programme, but to establish a proactive culture of diving safety. This required buy-in and implementation; in a word: “participation”. So, how did we achieve this?

DAN has been working on improving the safety and efficacy of recompression treatment facilities around the world since 1999 with the DAN Recompression Chamber Assistance and Partnership Programme (RCAPP). The need for having access to reliable recompression facilities is obvious. However, following the appeal from our finger-stitching colleague, DAN decided to expand the chamber safety initiative toward diving operations. The question, however, was how to start?

The first step was to establish collaborative relationships with diving operators based on mutual trust. So, with this in mind, DAN began to actively acknowledge those diving operators who were willing to partner on issues of diving safety by demonstrating their compliance with established industry norms, including staff readiness, first aid training, emergency equipment and  protocols. Then, as the interactive dialogue between DAN and the respective diving operators evolved, the HIRA programme was formally introduced in 2008, following the same core principles employed in RCAPP.

In this article, Francois Burman, the CEO of DAN Southern Africa (DAN-SA), provides an overview of the HIRA programme. This will be followed by regular contributions discussing specific operating aspects of the typical diving business and its interaction with clients – recreational scuba divers. The goal is to make a real difference to diving safety through the creation and promotion of a culture of safety at all scuba diving schools, charters and operations around the world. That is what DAN is all about.

The primary mission of DAN-SA is to offer assistance to injured recreational scuba divers. An important secondary mission is to prevent diving injuries. As part of a global campaign to reduce injuries and fatalities related to recreational scuba diving, DAN‑SA intends to fulfil its vision that every dive be accident and injury free by identifying and mitigating risks associated with diving operations.

The primordial prevention of injuries or losses implies the active prevention of accidents from happening, which in turn requires a programme that generates awareness, establishes control and ultimately mitigates health and safety risks.

So, how does one create, promote and then build such a preventative programme? After much deliberation and engagement with our diving Industry Partners, the following overall objectives were formulated:

• To provide risk and safety awareness education to all participants.
• To offer guidance on risk mitigation and control, based on actual operational aspects of a business.
• To initiate and then grow participation by all diving service providers.
• To monitor accidents and incidents so that we can continually assess the status of progress toward our vision of diving safety.  
• Achieving these objectives has required inclusion and co‑operation at all levels, primarily through the empowerment of facilities to understand and then accept their responsibilities toward safety.

Before describing the process, it is important to state, for the record, that DAN-SA does not represent any regulators, nor does it serve a statutory role. As such, DAN-SA is not the “scuba police”. We believe that the best way to encourage a diving safety culture is by role-modelling and through positive engagement with all the parties involved. Secondly, DAN-SA will only engage in this process if specifically invited to do so by a diving business. This is crucial for complete buy-in and full engagement on a voluntary basis.

The extensive, 16-year experience with the RCAPP has clearly shown that there is great value in providing a structured, methodical and consistent process. The DAN Risk Assessment Guide is available in multiple languages and used around the diving world and has been instrumental in this regard.

This same concept is now extended to diving businesses by means of a structured, documented process – the DAN HIRA Guide.

This DAN HIRA Guide offers the means for realistic assessment of actual operational hazards and safety solutions over the whole spectrum of diving business activities from the welcome to the water! The focus is on identifying the real and present risks, not theoretical or merely superficial ones. We refer to this as identifying the potential hazards, followed by a risk assessment.

DAN-SA also backs this process up by providing practical measurement tools and resources to quantify the risks. In addition to obvious elements, like compressed air quality testing, DAN-SA also includes several less familiar concerns, such as the assessment of harmful environmental noise exposure and ensuring adequate lighting measurements are used for safety purposes.
After identifying the potential hazards, risk mitigation follows. This implies that the source of the risk should be clearly identified and isolated, so that it can then be addressed in a meaningful way. 

When approaching any risk associated with an interface between man and machine, there is a tiered approach. By this we mean that the options for risk mitigation begin by trying to eliminate them at the source, using some form of technical or engineering control, like a barrier. If this is not possible or feasible, then operational methods are employed, such as providing instruction through policies or procedures to prevent any hazardous interaction with the risk. An example of such policies or procedures is teaching people how to use the ladder. If neither of these are possible, then physical protection is required, like supplying hearing protection to compressor workers.

As with any programme, monitoring or measurement is required to confirm its effectiveness. This also allows feedback on the success of the risk assessment and mitigation steps over a period of time and for a wider range of operational situations.

For the purpose of establishing a lasting safety culture, however, personal on-site discussion with diving business staff is required and all parties need to appreciate the risks and agree to the mitigation and monitoring strategies.

In terms of the actual implementation of a risk mitigation strategy, there are two primary concepts that need to be established.

Firstly, we need to determine the key or critical control points, namely the main sources of the hazards, so that we can be sure to address the root causes and plan for routine safety assessments and interventions to ensure optimal risk reduction.

Secondly, not all risks are of the same importance or magnitude. As such, a risk measurement system helps to focus the priorities of a business and to provide some degree of assurance that resources and efforts are directed appropriately. The assessment tool used is encapsulated in an accepted definition of the term “risk”: The probability that the exposure to a hazard will lead to negative consequences.

By establishing these two primary concepts we can consider all the potential hazards and then determine the chances or likelihood that people or equipment could actually be exposed to these hazards and whether the potential harm would be severe (namely unacceptable) or not. This turns the theory into practice: It allows us to identify the real issues over those that can be dealt with at a later stage or even disregarded.

The concepts of probability, exposure and consequence can all be quantified using a relatively easy-to-use, one-to-five scale. The actual risk can thus be calculated by multiplying these three scores by each other and by comparing the total score with a typical risk score table.

Statutory and industry-regulating documents vary depending on national-, local- and industry-specific requirements. It is, however, essential that all parties know which of these apply to them and what their relevant responsibilities are.

The following documents apply to the South African recreational diving industry and there will be equivalents of these in all countries:

• Occupational Health and Safety (OHS) Act of 1994, together with the applicable regulations such as the Noise, Driven Machinery, Electrical Installations, Environmental Safety, General Safety, General Machinery and Hazardous Chemical Substances Regulations;
• Compensation for Occupational Injuries and Diseases Act (COIDA);
• National Conservation Act;
• Employment Equity Act;
• Labour Relations Act;
• South African Maritime Safety Authority (SAMSA) directives which are applicable to boating and diving operations; and
• South African National Standards (SANS) 10019 (compressed gas cylinders) and SANS 532 (gas quality).

There are many additional documents which provide guidance, instruction and recommendations on gas cylinder valves, cylinder markings, medical gas cylinders, equipment testing and cylinder filling requirements, to name a few.

The simple answer is just ask! Upon receiving the initial invitation, DAN-SA sends an experienced team of assessors to the diving business site to take a detailed look at their diving operation. This should include actual day-to-day activities, covering the full scope of the business and may include:

• Staff health and safety;
• Client health and safety;
• Staff training and certification;
• Training pool area;
• Training room;
• Diving retail shop;
• Diving boat operations;
• Live-aboards;
• Compressor and cylinder filling area;
• Equipment storage area;
• Small instrument workshop;
• Vehicle safety;
• Travel and health advice for clients; and
• Recompression chamber dives.

Then, after the observation period, the team discusses their findings and impressions with the business management representatives. The DAN-SA team will descibe the assessed risks together with the possible mitigation recommendations and possible ongoing monitoring or measurement techniques.

To capture the outcome of the assessment, a detailed, customised report is generated by the team and shared with the particular diving business and the key members of staff.
The final report is an invaluable document: It not only provides a baseline of the current safety status, but also offers a roadmap toward ongoing safety improvements according to importance. Specific recommendations are offered where existing mitigation strategies are lacking or incomplete. It is then up to the business management to review, accept and apply the recommendations.

Established industry standards are followed as the general guideline, but the DAN-SA HIRA programme is about something far more than rote compliance to a norm. The ultimate intention is for the DAN HIRA Guide to be the signature of a safety-aware diving operation.