Commercial Diving JSA

Commercial diving is regulated apart from the rest of this library, and a JSA for it should say so on its face: the governing standard is 29 CFR Part 1910 Subpart T (1910.401–1910.441), the commercial diving operations standard. Subpart T sets out the dive team, the procedures, the equipment and the records for every mode of diving.

Diving done as part of construction work is not an exception to that. It reaches the same requirements through the construction standards' own diving subpart — 29 CFR 1926 Subpart Y (1926.1071–1926.1076) — which applies the Subpart T requirements to construction diving. So the citations on this page are 1910 citations whichever kind of project you are on. (Not to be confused with 1926 Subpart T, which is Demolition.)

A dive JSA therefore sits beneath a formal dive plan written by the designated person-in-charge. What it adds is the task — the specific underwater work, the structure, the current, the hazards that this dive has and the last one did not.

What the work involves

• Dive planning, safe practices manual and pre-dive briefing
• Equipment checks — breathing supply, umbilical, communications
• Entering the water and performing the underwater task
• Standby diver readiness and surface support throughout
• Ascent, decompression, post-dive checks and records

Hazards and controls

Controls are listed in hierarchy order — the further down the list a control sits, the less it should be carrying on its own.

1. Loss of breathing gas supply

• Engineering: primary and reserve breathing gas, with the reserve sized for the depth and the planned decompression; umbilical secured against snagging.
• Engineering: continuous two-way voice communication between the diver and a dive team member at the surface.
• Administrative: equipment inspected and tested before each dive; abort criteria agreed and absolute.

29 CFR 1910.430 sets the equipment requirements for commercial diving, including air supply, reserve breathing gas and the condition and testing of diving equipment. 29 CFR 1910.422(b) requires a means of two-way voice communication between the diver and a dive team member at the dive location.

2. Diver incapacitated with no one able to reach them

• Administrative: a standby diver available at the dive location, ready to assist throughout — the single control that most changes the outcome.
• Administrative: a dive team of adequate size, with a designated person-in-charge at the location who knows the procedures.
• Engineering: diver-carried reserve, lifeline or umbilical tended so the diver can be located and recovered.

29 CFR 1910.421(e) requires a dive team member to be available at the dive location during diving operations to provide assistance to a diver — the standby diver. 29 CFR 1910.410 sets the qualifications of dive team members, including training, experience and the designation of a person-in-charge at the dive location.

3. Decompression sickness or barotrauma

• Administrative: dive profile planned to published decompression tables for the mode and depth, with the tables available at the dive location.
• Engineering: decompression chamber available as the standard requires for the depth and mode of diving.
• Administrative: recompression and emergency medical arrangements identified before the dive — which chamber, how the diver gets there, who calls.

29 CFR 1910.423(c) sets the requirements following a dive, including decompression, recompression and the conditions requiring a decompression chamber to be ready for use at the dive location. 29 CFR 1910.422(f) requires a decompression chamber to be available at the dive location in the circumstances the standard specifies.

4. Entrapment, entanglement or differential pressure (delta P)

• Eliminate: isolate, lock out and tag every pump, intake, valve and gate that could create a pressure differential — a delta P hazard gives no warning and is unsurvivable.
• Administrative: confirm isolation physically and in writing before the diver enters the water; a hazard assessment specifically for openings, intakes and penetrations.
• Administrative: tended umbilical, cutting tool carried, and a plan for entanglement.

29 CFR 1910.421(f) requires, where a diver is exposed to the hazard of entrapment or to moving parts of machinery, that the equipment be locked out or otherwise secured before the diver enters the water.

5. Surface traffic, vessels or plant above the diver

• Engineering: dive flag and signals displayed; exclusion zone on the water around the dive location.
• Administrative: notify vessel traffic and the harbour authority; no plant or lifting over the dive site while a diver is in the water.
• Administrative: propellers secured and engines isolated on the support vessel during the dive.

29 CFR 1910.421(d) requires the dive location to be assessed for hazards, including surface and underwater conditions and activities, before diving operations begin.

A worked example row

This is how one line of the finished JSA reads, with the risk bands scored on the same 4-band matrix the generator prints:

Related work activities

• Work Over or Near Water JSA
• Confined Space Entry JSA