TO: ADCI General Member Companies

Subject:
Variance Request Process for Comparable Levels of Safety for Operations outlined in the Consensus Standards for Commercial Diving and Underwater Operations

Date: 20 February 2013

Purpose: This announcement is to formally outline the process for obtaining a variance request to perform operations outside of the guidelines contained in the ADCI Consensus Standards for Commercial Diving and Underwater Operations. Variance requests with comparable levels of safety will be utilized as a way for the ADCI to better understand all of the challenges associated with a particular operation. If there is an equally safe and efficient method to perform an operation, outside of what is currently stated in the Consensus Standards, then the ADCI welcomes the opportunity to be educated on it. Companies explaining the comparable levels of safety they intend to exercise could very well factor into future revisions/recommendations submitted to the Consensus Standards Review Committee from the Safety and Technical Committees.

Background: The ADCI has received several requests to perform surface diving off of dynamically positioned vessels, without the required deployment of an open bottom bell with emergency onboard gas and an in-water tender. The rationale for this request was based on the shallow water depth where operations are conducted. The ADCI has now put into place a process to vet such requests through its Safety, Technical, and Executive Committees.

Process: Companies wishing to submit variance requests must first provide the below listed information to the ADCI office:

1) USCG Regulations/ADCI Standards the Diving Contractors will provide comprehensive JHEA’s for:

2) The equipment and/or operational guidelines that have exceeded the requirement of 46 CFR 197/ADCI CS

3) Scope of Work Details

4) Drawing(s) to support the variance request

5) Identify in detail the known hazards associated with the proposed alternative

6) Specify the date(s) and times during which the operation is intended to be conducted

7) Specify the number of dive teams, the number of divers per team, the mode of diving for each team, and include the estimated number of dives per day.

8) Indicate the deepest depth and time at depth planned for each dive.

9) Specify Diver(s) total in-water time, and any decompression times

10) Indicate the number of non-diving topside support personnel aboard the vessel including medical specialists and chamber technicians.

11) List the PVHO’s to be used including the type of treatment chamber(s) available for immediate use aboard the vessel. Identify a shore side hyperbaric medical facility designated for use in the event of an emergency.

12) Specify the name(s) and official number(s) and country of registry of any vessels involved with the operation.

13) Dive site location detail.

14) Environmental conditions and operational limits.

Once the above information has been received by the ADCI office, it will be forwarded to the ADCI Safety, Technical, and Executive Committees for review.

All requests should be submitted to info@adc-int.org