WSHAsia: “Ask The Expert” Reviews The SS 511: 2018 Code of Practice for Diving at Work

The Workplace Safety and Health (Approved Codes of Practice) Notification 2019 was published in the Government Electronic Gazette on 6th of December 2019. The SS 511: 2018 Code of Practice for diving at work is updated to the latest revision as well.

World of safety & health Asia speaks to Mr. Darren Brunton, who is a renowned subject matter expert in commercial diving industry, to share with on this updated SS 511: 2018 Code of Practice for diving at work.

WSHAsia: Darren, could you tell us more about yourself relating to this industry?

Darren Brunton: I started my diving career while serving in the UK Military – Royal Engineers in 1979 training at the Royal Engineers Diving Establishment (REDE) then based at Marchwood, Southampton UK. During my military diving career I was fortunate to dive in Norway (under ice); the Caribbean (under the sun); rivers in Germany and UK waters training for construction, explosives / demolition, underwater cutting and salvage and survey tasks. My training advanced me to be an Army Diving Supervisor and my final 3 years of service was spent as a Military Diving Instructor at REDE training fellow military personnel from Basic Shallow Water Air Diver (18m working depth) through to Army Advance Diver (50m working depth) and Army Diving Supervisors. During my time at REDE I was a member of the Army Diving Inspectorate team; their role was to ensure all diving teams around the world followed safe diving practices. This involved visiting these dive teams in UK, Cyprus, Hong Kong, Northern Ireland conducting compliance inspections. One of the most memorial times was on my return from the Falklands War having served with 3 Commando Brigade, 45 Commando Group, I joined the dive team who where working on the salvage of King Henry VIII war ship, The Mary Rose, that sank in 1545, and on 11th Oct 1982 the historical moment of the Mary Rose being recovered for the seabed off Portsmouth (my home city) was televised around the nation and the world media.

I left the British Forces in 1991 and continued my career as a Commercial Diver – advancing my training as a saturation diver. Having spent a cold winter working around UK carrying civil engineers projects such as repairing Brighton Pier, in 1991, I gained employment with Fraser Diving Services based out of Singapore and travelled to Asia to work offshore Miri – Sarawak Malaysia, much happier in the warm climates. The following years I found myself working offshore around Asia – Thailand; Brunei; Indonesia; China; Vietnam; India; and as far as Mexico; Argentina; UK; Holland; Denmark on commercial air and saturation diving projects. After nearly being killed 3 times working subsea, it was time for a change. So I decided to ‘make the change’ in how things where being carried out, I would train as a International Marine Contractors Association (IMCA) Air and Saturation Diving Supervisor so when running the subsea projects I would be in charge and do things safely. This rapidly progressed on to setting up of a Diving Safety Management Consultancy company (KB Associates Pte Ltd) in 2002 based here in Singapore, the services of this company was as consultancy and audit service enhancing commercial diving projects both offshore and inshore/ inland. I have been a member of the International Marine Contractors Association (IMCA) Diving Division Management Committee since 2004, this committee writes guidance documents for safe diving operations; Vice Chairman of the Commercial Divers Association Singapore since it started in 2010 and I play an active role in each committee promoting safe diving methods, guidance and operations. My career has also allowed me to become a Chartered Safety Practitioner and I am a Chartered Fellow Member of the Institution of Occupational Health and Safety (IOSH) UK, and currently the IOSH Singapore Branch Chairman. Over the years I have acted as Expert Witness and Subject Matter Expert on-behalf of companies and authorities with regards commercial diving incidents and claims.

WSHAsia: When was SS511 being updated and in your views, what are the updates that are significance (safety aspect) to the industry?

Darren Brunton: The original SS511 was dated 2005; and revised in 2010; the 2018 revision included a realignment of the content and structure for use and reading; changes included clear definitions and limitations for the use of Commercial Self Contained Breathing Apparatus (CSCUBA) clearly making the use of recreational Self Contained Breathing Apparatus (SCUBA) not suitable for commercial diving works. Additional clarifications include roles and responsibilities of the client, diving contractor, diving supervisor and dive team. The 2018 version includes ‘sample’ diving plan and operations manual contents, some additional training requirements for diving supervisors, who need to understand and be trained in risk management and risk assessments. The training requirements for all team members are also very clear now, which is establishing a frame work for the organisations using commercial diving services and diving contractors conducting commercial diving projects a clear understanding of the training and competence requirements of the dive team. The SS511:2018 provides clear requirements on the Risk Management considerations to be taken when planning and conducting the diving operations, such as equipment to be used, environmental considerations, dive planning, lock out – tag out / isolation requirements, while sets clear understanding of expectations for safe work practices. Additionally the SS511:2018 covers the emergency planning and preparedness; historically emergency drills are not carried out, and when needed no one knows what to do or how to act. It is paramount to carryout emergency drills, injured diver recovery drills and the SS511;2018 has such aspects included.

WSHAsia: SS511:2018 is an Approved Code of Practice document. Do you think the industry had fully implemented it? Why?

Darren Brunton: The SS511:2018 is a Code of Practice; provides clear considerations and requirements that must / shall be taken prior to and during commercial diving projects. WSHC have recently issued a letter 28-08-2019 titled ‘Procuring safe commercial diving services’ which outlines the procuring of services of diving contractors and to ensure they have the necessary expertise to carry out work safely while ensuring that the user of such services has taken adequate safety and health measures. Highlighting three key areas that should be considered:

  • Dive team is trained, qualified and competent;
  • Site-specific risk assessment (RA) is conducted; and
  • Dive plan includes emergency and contingency plans.

Each of these key areas are very well included with in the SS511:2018.

Additionally on 8th July 2019, MP Ms Joan Pereira ask the Minister of Manpower Ms Josephine Teo a similar question ‘ (a) in the past five years, how many commercial divers have suffered accidents and death on the job; and (b) what is being done to ensure that commercial diving companies comply with the industry’s training guidelines and framework for the safety of their divers.


From 2014 to 2018, there were 20 non-fatal and three fatal workplace accidents involving commercial diving. The numbers are similar in the preceding five-year period.

In 2018, MOM stepped up inspections on commercial diving activities at anchorage waters, with the support of the Maritime and Port Authority of Singapore (MPA). The inspections focused on ensuring that diving companies have competent divers, proper risk assessment and planning prior to diving operations. Through these inspections, we have taken enforcement actions against 10 companies for safety lapses.

The WSHC is working with the diving community to update the commercial diving training curriculum and the Diving Technical Advisory for Inland / Inshore Commercial Diving Safety and Health. It has also stepped up engagements with diving companies, to drive home the message that it is their responsibility to ensure all their contracted divers are properly trained.

Implementing all aspects of the SS511:2018 across the local commercial diving community is now very achievable. There is nothing included with in the SS511:2018 that is unreasonable, outside the general principle of ALARP, or can be argued otherwise. The committee members involved in the review process where drawn from the industry, education sector, medical industry, WSHC and MOM which ensured any changes where reasonable, achievable and required. The DRAFT publication went out for two ‘public comment’ sessions, of which the committee where informed this is more than other SS codes of practice when being prepared. During the feedback, items where edited where applicable, the public review periods proved valuable for industry engagement.

However there are still diving companies not fully engaged and following the required safe diving practice’s, why when the risks are so high? The answer is because they can, they can ‘get away with it’ and although it’s cheaper to work not following the SS511:2018 the diving contractor potentially can make more revenue? in the short term while risking heavy fines and more if / when caught?

The SS511:2018 will not achieve this alone, only industry engagement, client education and awareness, working with the authorities such as Marine Port Authority, other national and international associations and sadly more incidents and enforcement actions will be the driving force to the SS511:2018 being fully engaged and reducing the likelihood of commercial diving incidents in the future.

The SS511:2018 is a Code of Practice and not a regulation. During a recent Industry Forum a question was asked to the MOM / WSHC Panel relating to the status of the Code of Practice and how enforceable is it. The response was clear, in the sense, IF a commercial diving incident occurs MOM will use the Code of Practice and the associated regulations to its written word to take any breach to ‘task’. It is understood that more recently MOM Inspectors have used the SS511:2018 Code of Practice when conducting company inspections or work site inspections and have issued Stop Work Orders when non compliance is evident. So the drive is there for full implementation of safe diving practices. But in the ideal world, client’s and diving company’s, diving supervisors should want to do ‘the right thing’ and not require legislation enforcement to ensure it is implemented?

I look forward to the day when all diving contractors, diving supervisors, and divers work safely aligned to the SS511:2018, or higher standards and safe work procedures as one day it will be the case.

WSHAsia: What do you think can be done to increase the awareness of the standard by implementing it in the industry?

Darren Brunton: Here in Singapore we have a strong group of diving contractors who are members of the Commercial Diving Association Singapore (CDAS); established around 2010; their mission is to promote commercial diving safety in Singapore. CDAS is establishing a more robust structure of industry engagement and promoting safe diving requirements to core clients of commercial diving projects such as PUB; Shipping Agents, Ship yards, Shipping companies, Oil and Gas Operators based on Jurong Island; Marine contractors; Marina Barrage; Reclamation projects; to name a few. CDAS hold an annual Commercial Diving Safety Seminar, and in 2019 it was attended by nearly 150 delegates, an increase of 3 x on previous years. There is also a FREE document published by WSHC 2009, Technical Advisory for Inland / Inshore Commercial Diving Safety and Health which is currently being revised, but provides explanations; the why’s and the how’s to ensure commercial diving activities can be carried out safely.

Since January 2020 CDAS has implemented a membership auditing framework, whereby all diving contractors who are members of CDAS must have successfully completed and passed a membership compliance audit. This will help clients select their diving contractor to engage for their works, knowing that a baseline audit of compliance against the SS511:2018 has been completed and passed. Only CDAS Members will have such audits, which eventually will guide clients to selecting only CDAS members for their projects and work, and providing a level of contracting assurance and ROI that the selected diving contractor has the safe systems of work in place to reduce the likelihood of a commercial diving incident.

From 2010 it has been a long and slow journey; the more recent two fatalities in 2018 reminding us all, we can not sit back, and not follow or promote and implement safe work practices. But there are always some who think it’s easier, quicker not to work safely, and it are these individuals, clients and companies that we need to engage and educate so that the SS511:2018 is not actually needed anymore! as all clients and diving companies will be implementing safe commercial diving practices and risk management processes that exceed any regulation or guidance documents. SAFELY IS HOW WE WORK HERE and it is how we live, it is not a ‘add on’ to what we do, but is an integral act of how we behave. This has to be led by business owners, managers, and supervisors and implemented across all levels of business.

WSHAsia: How can World of Safety & Health Asia, be the only independent online media on occupational safety & health news & articles, in this region help to play a part in spreading the awareness of this standard and other standards?

Darren Brunton: Thank you WSHAsia for asking me to be interviewed and allowing the Commercial Diving Industry a voice locally and internationally. This is exactly what is needed, a means to share and promote safety working practices, raising the awareness of the guidance and regulations in the different industry sectors, while allowing someone specialised in the particular area to break down and advise what is required is not rocket science and in fact is achievable, will enhance business development and growth and is a great value for return on investment, by caring for the people at work, the environment and the equipment we work with. ‘ How you do something; is how you will do everything’ Always be safe; work safe; play safe and we will all prosper in the challenges of today.

WSHAsia: World of Safety & Health Asia appreciates your time and effort in participating in this e-interview. We aim to raise awareness of the available safety & health solution through “Ask the Subject Matter Experts” e-interviews.

Thank you for the opportunity.

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