Insights from Derek Beddows, Director of Diving Safety & Service
Recently, whilst assisting a client during an HSE annual visit, an intriguing point was made that has resonated with me since, especially in the context of the renewable energy sector construction and installation of interconnecting cable network.
Historically, the distinction between Inland/Inshore diving and the Offshore Approved Code of Practice (ACOP L103) was an invisible line: the 12 Nautical Mile Limit. However, the landscape of diving operations, particularly those related to renewable energy structures like wind farms, is evolving rapidly, and with this evolution comes a pressing need for compliance that exceeds the Inland/Inshore ACOP (L104) requirements.
The 1997 Diving at Work Regulations; Commercial Diving Projects Offshore (ACOP) (L103/2014 Revision) extends its reach beyond traditional boundaries. It clearly states that the Code applies to all diving projects, including those undertaken in connection with offshore installations and energy structures, such as wind farms and emerging energy technologies. This inclusion is significant because it includes operations where closed bell or saturation diving techniques are used, as well as operations from vessels maintaining station through dynamic positioning, regardless of their proximity to shore. The HSE’s emphasis on dynamic positioning (DP) based diving operations falling within the Offshore Code, irrespective of location, was a pivotal moment. It underscored a crucial realisation for constructors of offshore wind farms that their operations, no matter where they are situated, are captured within the Offshore ACOP (L103) requirements for compliance.
What does this mean for renewable operators? The current regulatory framework necessitates a rigorous and regulatory compliant diving safety management system. Ensuring alignment with HSE standards is no longer a matter of geographical demarcation but of operational scope and technique. This expanded interpretation of the regulations means that renewable energy operators, particularly in the offshore wind sector, are expected to adopt the same stringent subsea safety protocols akin to those in traditional offshore oil and gas projects.
The Approved Code of Practice (L103) and associated supporting guidance (IMCA D 014) provides a framework of practical advice to ensure compliance with the Diving at Work Regulations 1997. This Code spans diving projects at sea outside the UK territorial waters adjacent to Great Britain, diving operations in UK designated areas of the continental shelf connected with offshore installations, and energy structures like wind farms. It also includes operations where closed bell or saturation diving techniques are used and those from vessels using dynamic positioning.
The implications of the 2014 Edition of the L103 ACOP are far-reaching, signalling a challenging era of regulatory compliance for the renewable energy industry. It's a critical moment for transitional energy operators to reassess their diving and subsea safety management systems, ensuring they are robust, comprehensive, and aligned with the highest standards of diving safety, as mandated by the Diving at Work Regulations 1997 and expectations of HM UK HSE Inspectors of Diving Health and Safety Executive, Energy Division. This alignment is not just about legal compliance; it's about safeguarding the lives of those who work in these challenging environments and ensuring the sustainable growth of the renewable energy sector in a structured and conformant way.
Derek Beddows, Director of Diving Safety & Services at Energy Maritime Associates, is a trusted leader in commercial diving safety and technical advisory, renowned for extensive experience and a solid track record spanning over five decades.
EMA serve Operators, prime EPIC Contractors, and service companies, providing technical guidance for diving subcontracted services, enhanced by our specialised Diving Technical Authority (TA) ongoing support.
Our commitment to safety, efficiency, and technical excellence makes us the preferred partner for complex underwater operations, ensuring reliable outcomes for our clients in the challenging maritime and subsea landscapes.
If you’re a renewables operator working in the UK and you would like to know more about how Energy Maritime Associates can assist you in ensuring your diving and subsea safety management system is fit for purpose, feel free to contact us at derek.beddows@energymaritimeassociates.com