Return to Magazine Index

"Have I adequately assessed this diver's competence?"  Photo by J Whitehead


By Andrew Whitehead

Published in Dive Log Australasia
November 2000


Despite expert opinion to the contrary, it would seem that recreational diving is perceived to be unsafe.  Consequently, regulatory bodies have stepped in to look after us with the draft Australian/New Zealand Standard, DR 00219.  The response to this closed on 30/9/00.  The draft includes a subtle shift of responsibility from the individual diver getting properly trained, to dive supervisors assessing their competence.  These standards are unlikely to make diving safer because they do not appear to currently address the central issue of adequate training.  They are more likely to drive smaller operators out of business making it harder and more expensive for us to go diving.

Claytons Regulations

The following is quoted from my report on the “SAFER LIMITS 2000”, Hyperbaric Workshop, held at the Wesley Hospital, Brisbane, 5-6 September 2000.

“The general consensus of the panel of speakers was that diving is a very safe recreation these days compared with other activities. This opinion is based on the number of DCI cases treated in Australia compared with the total number of dives per year.  One of the main reasons for this is that most divers now use a dive computer, rather than tables or nothing at all.”

“Another point that was made was that the certification agencies are offering a high standard of training, however the delivery by instructors is highly variable.  Many open water divers know very little about DCI and how to avoid it.  A significant proportion of treated cases are open water (novice) divers or in the (so called) ‘advanced’ category.”

Based on this assessment by hyperbaric professionals, it would seem that the use of the DIVE COMPUTER, not regulations, has made diving safer, and that accidents are the result of inadequate training for the conditions encountered by the diver.

Consequently, the proposed standards are unlikely to have any significant effect on the number of diving accidents, as they do not appear to currently address the central issue of adequate training of recreational divers.

Assessment of Competence

The draft standards are based on the Queensland Compressed Air Recreational Diving and Recreational Snorkelling Industry Code of Practice.

The ominous section 2.11.5 (a) states that “The competence of each diver shall be assessed. Factors to be taken into account include the recency of the recreational certificate and of the last dive, the diving experience of the diver since the certificate was gained, e.g. as contained in logbooks, and current fitness to dive.”  There is no clear definition of what is an adequate assessment of competence.  In addition, the listed “factors” are notoriously unreliable.  Consequently, the clause is open-ended, extremely onerous and unfair to dive supervisors.  My recommendation was that it be re-worded as follows:

“The ability of each diver to make the particular dive should be considered.  Factors to be taken into account include the level of the recreational certificate, the recency of the recreational certificate and of the last dive, the diving experience of the diver, and current fitness to dive.

If the dive supervisor has doubts as to the training, experience or safety consciousness of the diver, the diver should be asked to complete a detailed questionnaire and sign an undertaking to perform appropriate safety activities when required.

If the dive supervisor has doubts as to the ability of a diver to make the particular dive, the dive supervisor or dive instructor should accompany the diver on that dive, or assess the diver during an assessment dive.”

The reason for this recommendation is that the proposed assessment of competence is probably the most difficult task for a dive supervisor, yet it is mandatory but with little detail.  Since there is no clear definition of what is an adequate assessment of competence, it should not be mandatory.

Factors to be taken into account

In order to comply with the proposed standard, dive supervisors would be required to exercise judgement based on their experience and the evidence that is placed before them.  However, assessment of competence based on judgement is inherently risky.

Unlike other clauses in these standards, this section is fairly vague.  The list of factors is not a full list, but includes some suggestions.  If there is a diving incident, a prosecutor might suggest that the dive supervisor did not adequately assess the competence of the diver.  The court might find that the dive supervisor should have done something else that is not on the list.

Recreational Certificates

It is difficult for dive supervisors to assess competence based on a certificate, because of the varying standards and terminology that are used by the certifying agencies.  Newly qualified Open Water Divers should expect to be buddied with a dive master to look after them.  At the other end of the spectrum, Master Scuba Divers should be able to look after themselves.  In between the Open Water Diver and Master Scuba Diver, there is a great gulf of uncertain capability.

Log Books

If a dive supervisor looks at a log book, they may be deemed to have read every word on every page.  The log book as evidence of competence is subjective, unreliable and unpredictable.


Divers cannot certify their own competence.  However, they can complete a questionnaire on relevant training and experience, and make an undertaking to abide by certain specific guidelines.  My wife and I have developed such a document which is currently being used by members of the Dive SQ Group.  The document is available for free on this website.

Assessment Dive

For the smaller operator, an assessment dive may not be practical.  In a boat that is surveyed for ten divers, there may not always be a dive master on board.  The skipper cannot act as the Lookout AND conduct a checkout dive at the same time.  It would seem that the standards are biased towards the big charter boat operators such as some of those in North Queensland.

Nitrox Diving

Clause 1.5.29 Definition of EANx dive supervisor.
This section is based on the DRAFT Queensland Industry Code of Practice for Recreational Technical Diving.  EANx stands for Enriched Air Nitrox (or oxygen enriched air), commonly known as “Nitrox”.

My suggestion was that it be optional (not mandatory) that an EANx diver supervisor “holds a certificate in EANx diving operations leadership issued by a SCUBA training organisation”.

Dive Supervision

The current clause implies that all dive supervisors will have to be trained as Nitrox Instructors just in case someone comes aboard with Nitrox equipment.  This would be windfall revenue for the training agencies, but is it essential?

It also implies that Nitrox is more dangerous than diving on air.  We use Nitrox because it is SAFER THAN AIR.  This is because you are not breathing as much Nitrogen in the mix.

The only additional task stated in the proposed standards is for the EANx dive supervisor to “review the maximum depths for the breathing gas”.  Simple charts are available to show the maximum operating depth of a dive based on the percentage of oxygen in the mix. Additionally, the dive supervisor cannot enforce the maximum depth of the dive.  It is the responsibility of the diver to do this.  Also, a maximum depth warning can be set on most dive computers prior to the dive.

The following procedures are already in place:

  • The diver must be a certified Nitrox diver.

  • The cylinder must be analysed and have a tag attached which documents the oxygen percentage and maximum operating depth of the gas mixture.

  • The oxygen percentage must be noted in the dive safety log.

The responsibilities of the dive supervisor are to act as lookout and perform rescues.  It is not essential that they be qualified Nitrox Instructors as well.

Implications for Nitrox Divers

Consider the following implications if the dive supervisor who holds “a certificate in EANx diving operations leadership issued by a SCUBA training organisation”, is unable to go on the trip.

  • The Nitrox diver cannot go on the trip and may get a refund. (say $120)

  • The Nitrox diver goes on the trip but cannot dive. (Waste $120 and $30 for 2 Nitrox mixes)

  • The Nitrox diver has to dive on air.  However, Nitrox is safer than air.

  • There may not be sufficient air cylinders on the boat.

  • Nitrox equipment usually has a different configuration to air equipment.  DIN valves are used instead of open face valves, requiring a special DIN/Yoke adaptor.

  • Nitrox equipment is oxygen cleaned.  The air cylinders may contaminate the oxygen-cleaned regulator.

One would have to conclude that these standards are unlikely to make diving safer.  They are more likely to drive smaller operators out of business making it harder and more expensive for us to go diving. The diving is very good in nearby countries: try New Caledonia, Vanuatu, Solomons, or Fiji.

Return to Magazine Index


Home News Scuba Diving Articles Author Contact Links