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AB

The International Marine Contractors Association

Responsibility for Underwater Inspection

www.imca-int.com

AODC 033
October 1985

the Underwater Inspection Contractor (the Contractor) and his subcontractors (if any) when carrying out underwater inspection. The divers carrying out the inspection tasks should be the employees of the Inspection Contractor. responsibility and relevant liability. Any diving subcontract personnel should be engaged in such a way that they are considered to be employees of the Inspection Contractor.Responsibility for Underwater Inspection There is some confusion regarding the respective roles of the Client (and his offshore representative. Diving Operations at Work Regulations. This guidance note aims to clarify the respective responsibilities and relevant liabilities. engineer or data controller) who directs the inspection divers or remotely operated vehicle or manned submersible and who collects and records the inspection data provided by these means.SI 399). Responsibility and Liability In order to maintain the independent status of the Contractor and his professional integrity. Normally a specialist Diving or Underwater Engineering Contractor is appointed to carry out the inspection. All diving operations are the legal responsibility of the Diving Supervisor who must be appointed by the Diving Contractor and is directly responsible to him for the safety of the operations as required by the Diving Operations at Work Regulations 1981 (SI 399). regular (normally annual) underwater inspection programmes of all or part of an offshore structure or installation are required to meet the requirements of the relevant Certification Authority and the statutory requirements of the Department of Energy. The inspection operation is additionally supervised by the Inspection Supervisor (or co-ordinator. both inferred by Client hereafter). the following should be clear for all underwater inspection projects. It is fundamental to the principle of these inspection programmes that they should be carried out by a specialist and expert organisation that is totally independent of the owner or operator of the installation. This is particularly the case where more than one Contractor is involved. 1981 . Should this not be the case. Background In the United Kingdom. It is important that the person on the surface who directs and supervises the inspection work and records the results should either be an employee. or be considered to be an employee of the Inspection Contractor. The Diving Supervisor is legally responsible for the divers' safety and must be an employee of the Inspection Contractor (Ref. reporting directly to the appointed Diving Supervisor. then the Inspection Contractor can have no control over the direction of the divers' inspection AODC 033 – October 1985 Page 1 .

In practice. In this case the responsibility of the Inspection Contractor is limited as he can only attest to the accuracy and independence of the raw data and not of the final report based on it. In this case he retains control of the final report and also therefore responsibility and relevant liability for it. Inspection Contractors and Clients should decide to what extent the Inspection Contractor is to be involved in supervising the inspection operation. in the same way as described in 2) above. The Inspection Contractor can sign the report attesting to its accuracy. Once the raw inspection data has been recorded then alternative situations exist: The Inspection Contractor may be required to process the data and produce a final report. In such cases. processing the data and producing final reports. integrity and independence. Page 2 AODC 033 – October 1985 . The Client may however wish to process the data themselves or by means of another specialist company that they may separately employ.work or the data being recorded and so cannot accept responsibility for the inspection information. thereby defining the limits of independent responsibility of the Inspection Contractor and hence his relevant liability for the inspection results. 3) a) and b) above are often not clear cut when the-Client requires more than one Contractor to be involved in the inspection report. If an ROV is used to carry out inspection work then the supervision of the collection of data should be carried out by an employee or sub-contractor of the Inspection Contractor who is responsible for the work. paragraphs 2).