It has become readily evident in recent years that efforts to secure political and commercial influence for economic gain have, in some instances, taken precedence over a true regard for safety. What is even more unfortunate is that, to obtain work for personnel and capital assets that might otherwise remain idle in Europe, certain practices and procedures developed to suit North Sea conditions are being promoted as the only vehicles by which safety can be achieved elsewhere and that all others are of little or no value.

Obviously, this approach denies the excellence of many commercial diver training schools merely because they do not follow the dictates of a particular organization. Likewise, it advances the premise that highly trained, experienced, and competent commercial divers of many nations are incompetent merely because they have not been "vetted" by a particular organization.

Can these efforts be viewed as anything other than an outright attempt to control the commercial diving industry around the world? To be fair, the organization touting this approach seems to be creating more consternation and confusion than generating proponents (other than among their captive member companies) and therefore their methods of doing business may ultimately fail.

However, in the interim, commercial diving companies throughout the world are being faced by contractual demands from some offshore oil and gas companies requiring that they follow procedures and utilize equipment that have no relationship to common sense, safety, job requirements, or regulations in the area of interest. Rather, they are being challenged to either comply with inappropriate and, in some cases, inadequate practices and procedures, or be considered ineligible for award of contract.

How Did This Happen?
Beginning in about the mid-1960s, our ability to work underwater longer and at greater depths was facilitated by a series of rapid and associated developments in terms of equipment, techniques, diving tables, and vessels able to be accurately positioned and maintained over the work site.

In the late 1960s, the Association of Diving Contractors (ADC) was formed to promote safety throughout the commercial underwater industry through communications and education. Almost simultaneously, a counterpart organization called the Association of Offshore Diving Contractors (AODC) was formed in the United Kingdom with similar goals and objectives. Each organization worked to enhance safety in its own sphere of influence and membership, while employing a somewhat different approach to resolving the issues with which it was faced. To some degree the approach of each organization was dictated by the traditional business practices, governmental controls, and best practices of the industrial sector in which they were involved.

The founders of these organizations realized a necessity to work toward mutually recognized goals and objectives to foster safety throughout their respective communities. They recognized that the commercial divers being served by the organizations were being trained in a somewhat different manner would not all use the same types of equipment, and would not all be required to accomplish the same types of underwater work tasks. They also acknowledged that each diver was a unique individual whose abilities would be proven by their actual performance at the work site, at the depth required to accomplish the designated task, and using systems and tables necessary to ensure their safety. That became the standard of measurement relative to the worth of the individual, and it made no difference where he or she was from or where they received their training - as long as the employer considered the diver competent to perform the work.

A Breakdown of Respect and Cooperation
For many years the processes and procedures of ADC and its UK counterpart, AODC, were recognized as being complimentary to each other. There was no effort by either organization to be the "ultimate authority." Each treated the other with respect and valued the input, cooperation, and participation of members who may have belonged to either organization. Cooperation was evident between the organizations and there was little hesitancy in using a commercial diver who "grew up" in either of these systems.

All of this began to change in 1995 when the Association of Offshore Diving Contractors of the United Kingdom was incorporated into the International Marine Contractors Association (IMCA) by the amalgamation of AODC and the Dynamic Positioning Vessel Owners Association (DPVOA). Since then, IMCA has devoted time, energy, and substantial funding in an attempt to hold itself out as the preeminent and singular authority for marine contracting activity throughout the world.

Unnecessary Trouble
What is unfortunate is the IMCA Diving Management division had a great deal to offer with respect to promoting safety, if one considers that the bulk of their information was originally prepared by AODC before its demise. Most of the former AODC and related documents were well-written and valuable to the industry.

However, the difference between the documents in existence when IMCA was created and those now being developed, adopted, or reissued by IMCA is that the former were guidance documents. The new documents appear more exclusionary and prescriptive.

In fact, one must question the IMCA documents that state on the cover page: "The information contained herein is given for guidance only and endeavors to reflect best industry practice."

Such a phrase was not included in the former AODC notes. Therefore, reissue of these documents with such a caveat is misleading. The phrase also raises the obvious question: Does IMCA propose that they speak for the entire worldwide commercial diving industry? Certainly, much of what they publish is not considered "best industry practice" by more than 450 ADC member companies in over 35 nations.

The Impact
It is quite obvious and appropriate that a major corporate entity based in a particular nation will be more familiar with the processes and practices of that nation or area of the world than another.

However, it is patently foolish to adopt those processes and practices for use in other areas of the world with an absence of factual and reasoned guidance. In an effort to make "one system fit all," the British Petroleum Executive Management Committee has issued a directive that, as of January 1, 2004, only contractors who "demonstrate compliance with the IMCA Code of Diving Practice" would be eligible for contract awards anywhere in the world.

Any company has the right to define the terms and conditions under which they will accept bids and award contracts, providing those terms and conditions do not violate existing law in the area where their operations are to take place. However, when those terms and conditions are effectively dictated by others to exclude a major portion of an industry sector because it does not follow the same processes and procedures, the action becomes highly suspect. One must wonder whether the decision cited above was made by an informed group of committee personnel, or whether the ramifications of such an edict were even fully considered.

ADC receives almost daily reports from member companies of other nations complaining about the activities of IMCA and/or their member oil or gas producers operating in the offshore environment. These complaints revolve around the fact that they, as citizens of their respective nations, are being forced out of the market unless they agree to comply with highly costly and unnecessary efforts to comply with what is essentially a British set of standards and are willing to contract IMCA "card-carrying" divers. The position of these companies is that they comply with the ADC Consensus Standards and the ADC Certification Card Procedures, and fail to understand why they should depart from adhering to procedures which have successfully contributed to a high degree of safety during the conduct of their diving operations.

Obviously, this cannot continue.

The impact of accepting that a British Petroleum (or any other overseas contractor working in the waters of another nation) can dictate the terms and conditions of who can be contracted for underwater work under the false premise that indigenous contactors are not properly equipped, trained, or competent should be viewed with great concern.

This approach could well allow British Petroleum to "buy" their way into a control position by agreeing to pay certain contractors to "upgrade" their equipment to IMCA standards. They could also state that much of the equipment (dynamically-positioned vessels for example) is not up to North Sea standards (it isn't and doesn't have to be). British Petroleum could state that US-trained, highly experienced, and competent commercial divers do not meet the IMCA Codes (what safety statistics justify that they should have to?).

Under either of these cases, British Petroleum could then claim a necessity to bring contracted assets and personnel in from the North Sea to accomplish the job.

It is interesting to note that, while the standards under discussion are being held up as representing the highest level of safety, commercial diving systems brought into the US from Europe are routinely downgraded by up to 30 percent of their rated depth to comply with US regulations. Does that mean that those systems from Europe are not safe? Certainly not. But it does validate the fact that differences exist and always will, and that the prudent course of action would be to recognize and accept those differences.

Companies of a nation must not be restricted from market entry because of artificial standards imposed by outside forces. In a similar manner, personnel must not be denied the right to pursue their profession because the system under which they gained recognized competency does not meet the bureaucratic and philosophical nature of another organization.

At the end of the day the contracting party should be free to select a service provider based on the financial and technical merits of the bid and the quantitative safety record of the bidder, rather than artificially imposed factors inappropriate to the area of intended operations.

It is obvious that our world is becoming one large economic enterprise, with companies operating in many nations other than that in which they were founded and/or are domiciled. While it is logical that multinational companies should be able to follow a reasonably standardized process for given tasks, due consideration must be given to the laws, customs, practices, processes, and procedures used in the various nations in which they operate. To do otherwise is just as ludicrous as saying that, because in England vehicles are driven on the left side of the road, so too should they be driven everywhere else.

ADC International's Position
Since 1995 ADC has made attempts to recreate the atmosphere of cooperation once prevalent between ADC and the former AODC (now IMCA). In each instance those efforts have been rebuffed and ADC has been advised it must change its manner of doing things if progress is to be achieved.

ADC is of the opinion that an organization with more than 450 member companies in over 35 nations does not need to be subservient to any other. These member companies have proven the value of the ADC Consensus Standards and ADC Commercial Diver Certification Card System - both through having achieved unquestionably high levels of safety, and by having been recognized and endorsed by the United States and other governments.

As part of its ongoing commitment to safety, ADC has executed an Alliance Agreement with the US Department of Labor's Occupational Safety and Health Administration (OSHA) to recognize many years of close cooperation between the two organizations. This relationship between government and industry has proven effective in reducing accidents and fatalities in the commercial diving and underwater workplace. This was publicly acknowledged in February 2002, when OSHA presented ADC with a Certificate of Exceptional Leadership and Achievement in recognition of reduced commercial diving employee fatalities from 20 in 1993 to none in 2001. Those results were achieved through the Consensus Standards and training products developed by ADC and implemented throughout the member companies within the United States and around the world.

The significance of the OSHA certificate is that the reduction of fatalities brought about by ADC does not relate to a relatively small number of commercial diving personnel employed in the "offshore" sector of the North Sea, involving perhaps a few handfuls of companies. Rather, it relates to an industry represented by more than 250 underwater contracting companies and nearly 4,000 commercial divers employed daily throughout the US and its territories.