CoP 45.0 - Underwater Activities

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Abu Dhabi Occupational Safety and
Health System Framework
(ADOSH-SF)
Code of Practice
CoP 45.0 – Underwater Activities
Version 4.1
February 2026

ADOSH-SF – Codes of Practice
CoP 45.0 – Underwater Activities - Version 4.1 – 16th February 2026 Page 2 of 20
Table of Contents
1. Introduction ....................................................................................................................................................... 3
2. Training and Competency ............................................................................................................................. 4
3. Requirements .................................................................................................................................................... 6
3.1 Roles and Responsibilities ................................................................................................................. 6
3.2 Planning and Assessment.................................................................................................................. 7
3.3 Recreational Diving Operations and SCUBA Diving Training Centers ............................... 8
3.4 Commercial Diving Operations ....................................................................................................... 10
3.5 Cylinders and Compressed Air ........................................................................................................ 13
3.6 Warning Notices and Signals .......................................................................................................... 14
3.7 Safety of Navigation ......................................................................................................................... 15
4. Record Keeping .............................................................................................................................................. 17
5. Document Amendment Record ................................................................................................................. 18

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1. Introduction
(a) This Code of Practice (CoP) applies to every place of employment within the waters of
Abu Dhabi, UAE. It covers all diving and related support operations conducted in
connection with all types of work and employments, including general industry,
construction, recreational diving, commercial diving, ship repairing, shipbuilding, ship-
breaking, and long-shoring.

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2. Training and Competency
(a) Employers shall ensure that OSH training complies with the requirements of:
(i)
ADOSH-SF – Element 5 – Training, Awareness and Competency.
(ii)
ADOSH-SF – Mechanism 7.0 – Occupational Safety and Health Practitioner and
Service Provider Registration.
(b) Employers shall ensure all relevant employees and other persons have:
(i) appropriate training to ensure they acquire the understanding, knowledge, and
skills necessary for the safe performance of all duties;
(ii) valid Commercial Diving Certification if they perform underwater work that
includes, but is not limited to welding, pipeline construction and/or repair, rig
construction and/or repair, bridge construction and/or repair, or other similar
activities;
(iii) a valid Commercial Diving Certification if they collect criminal evidence or
scientific samples, locate bodies, and/or photograph or film underwater.
(iv) a valid diving qualification/certification from one of the following, or equivalent,
diving organizations if they are providing recreational diving services or
instruction:
1. Professional Association of Diving Instructors (PADI);
2. British Sub-Aqua Club (BSAC);
3. Sub-Aqua Association (SSA); or
4. SCUBA Schools International (SSI).
(v) diving qualifications/certifications and training equivalent to the depth of the
dives performed and operations performed while diving;
(vi) training on risks associated with activities they will perform;
(vii) training on control measures implemented to address identified risks;
(viii) annual refresher training on the employer’s Occupational Diving Program;
(ix) training on what work can and cannot be performed while diving; and
(x) specific emergency procedures to follow if an incident occurs.
(c) Employers are to ensure managers and supervisors of Diving Operations shall have:
(i) a valid Commercial Diving Certification and training equivalent to the work being
performed if they manage or supervise commercial diving operations;
(ii) the following minimum qualification/certification, or equivalent, if providing
recreational diving services:
1. PADI – Dive Master;
2. BSAC – Advanced Diver;
3. SSA – Dive Supervisor;
4. SSI – Dive Control Specialist; or
5. equivalent from a recognized diving organization.

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(iii) diving qualifications/certifications equivalent to the depth of the dives
performed and operations performed while diving;
(iv) current first aid training in accordance with SCUBA diving certification
requirements and
ADOSH-SF – CoP 4.0 – First Aid and Medical Emergency
Treatment;
(v) training on risks associated with tasks their staff will perform;
(vi) training on control measures implemented to address identified risks;
(vii) annual refresher training on the employer’s Occupational Diving Program;
(viii) training on what work can and cannot be performed while diving; and
(ix) specific emergency procedures to follow if an incident occurs.
(d) Divers shall have:
(i) a valid Commercial Diving Certification and training equivalent to the work being
performed if they manage or supervise commercial diving operations; and
(ii) a valid diving qualification/certification when providing recreational diving
services from one of the following, or equivalent, recognized diving certification
organizations:
1. PADI;
2. BSAC;
3. SSA; or
4. SSI.

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3. Requirements
3.1 Roles and Responsibilities
3.1.1 Employers:
(a) Employers shall undertake their roles and responsibilities in accordance with the
general requirements of
ADOSH-SF – Element 1 – Roles, Responsibilities and Self-
Regulation Section 3.2.5.
(b) Employer shall be responsible for performing a risk assessment in accordance with
ADOSH-SF – Element 2 – Risk Management to determine the risks associated with dive
activities and develop an Occupational Diving Program that implements the
appropriate control measures.
(c) Employers shall ensure that there are appropriate divers who are competent in both
diving and the actual work to be undertaken and possess valid diving certifications as
required by this CoP.
(d) Employers shall ensure that diving operations shall not take place without a
competent appointed diving supervisor.
(e) Employers shall provide appropriate plant and equipment and ensure that it is
correctly certified and maintained.
(f) Employers shall ensure all divers have a medical evaluation to assess their fitness to
perform work prior to starting work and annually thereafter. Medical evaluations shall
be performed by a physician familiar with the hazards of diving operations (e.g. HSE –
UK – Approved Physician).
(g) Employers shall maintain insurance coverage for all divers that shall cover treatment
of injuries and illnesses associated with underwater activities, to include medical
evacuations and treatment of decompression illnesses.
(h) Employers shall implement the employer’s Occupational Diving Program which
includes reviewing risk assessments and consulting their staff to ensure all relevant
hazards are identified and appropriate control measures are implemented.
(i) Employers shall assess divers prior to any operations for obvious changes in their
medical fitness, if such changes have occurred; they shall not allow the diver to
perform work until assessed and found fit by a medical professional.
(j) Employers shall ensure there are appropriate arrangements for firefighting on-board
vessel(s).
(k) Employer shall ensure there are appropriate arrangements for recovery of injury
divers, first aid and medical treatment, including contract or service agreement with
medical facilities with the appropriate specialist hyperbaric medical equipment and
practitioners.
(l) Employers shall ensure that diving project logbooks (including required stamp) /
records are appropriately maintained.

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(m) Employers shall ensure everyone in the diving operation is aware of the diving project
plan, and that the plan is kept up to date.
(n) Employers shall ensure there is appropriate communication with the divers in the
water.
(o) Employers shall check the site on the day of the dive, and when conditions change,
confirm that the risk assessment is still current.
3.1.2 Employees
(a) Employees shall undertake their roles and responsibilities in accordance with the
general requirements of
ADOSH-SF – Element 1 – Roles, Responsibilities and Self-
Regulation Section 3.2.7.
(b) Employees shall report any activity or defect relating to underwater activities which
they believe is reasonably foreseeable to endanger their safety or that of another
person.
(c) Employees shall use appropriate equipment or safety devices provided for underwater
activities by the employer in accordance with any training or instruction received in
the use of the work equipment or device concerned.
(d) Employees shall hold an approved qualification and experience for the diving
operations.
(e) Employees shall have a valid certificate of medical fitness to dive.
(f) Employees shall maintain a daily logbook / record of their dives, which shall be kept
for a minimum of five (5) years.
(g) Employees shall follow the requirements of their employers Occupational Diving
Program and maintain their diving certifications.
3.2 Planning and Assessment
(a) Employers shall ensure the following:
(i) an assessment of the various risks is undertaken, and systems of work are
established which are safe to all parties involved or affected including the public;
(ii) that appropriate control measures are implemented in order to manage activities
safely and without risk to health.
(iii) that for the Building and Construction Sector the management of underwater
activities requirements are included in the Pre-Tender Safety and Health Plan in
accordance with
ADOSH-SF – CoP 53.0 – OSH Management During Construction
Work; and
(iv) that associated safe systems of work, and site rules are included in the Safety
and Health Construction Management Plan (OSH-CMP) in the case of the
Building and Construction Sector in accordance with
ADOSH-SF – CoP 53.0 –OSH
Management During Construction Work.

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3.3 Recreational Diving Operations and SCUBA Diving Training Centers
(a) Employers shall perform a risk assessment in accordance with
ADOSH-SF – Element 2
– Risk Management, to determine the risks, control measures and training
requirements for employees performing diving and instruction operations.
(b) Recreational Diving Operations and SCUBA Diving Training Centers shall maintain
active membership with the Emirates Diving Association (EDA).
(c) Recreational Diving Operations and SCUBA Diving Training Centers shall maintain
current permit(s) and license(s) as required by the relevant authorities as well as any
other permits and licenses as required.
(d) Recreational Diving Operations and SCUBA Diving Training Centers shall meet the
following international standard requirements:
(i) recreational scuba diving businesses shall meet the requirements of
ISO
24803:2014, Recreational Diving Services – Requirements for Recreational
Scuba Diving Service Providers.
(ii) assistant scuba diving Instructors shall meet the requirements of
ISO 24802-
1:2014, Recreational Diving Services – Requirement for the Training of Scuba
Instructors – Part 1: Level 1.
(iii) scuba diving instructors shall meet the requirements of
ISO 24802-2:2014,
Recreational Diving Services – Requirements for the Training of Scuba
Instructors – Part 2: Level 2.
(iv) scuba divers using enriched air shall meet the requirements of
ISO 11107:2009,
Recreational Diving Services – Requirements for Training Programs on Enriched
Air Nitrox (EAN) Diving; and
(v) managers and supervisors of scuba diving operations shall meet the
requirements of
ISO 24801-3:2014, Recreational Diving Services –
Requirements for the Training of Recreational Scuba Divers – Part 3: Level 3 –
Dive Leader.
(e) Employers that have recreational diving operations shall develop an Occupational
Diving Program that shall at a minimum consist of the following:
(i) training for new employees, and refresher training as required.
(ii) process to ensure employees have been appropriately trained and maintain valid
diving qualifications/certifications.
(iii) communication system to inform/remind employees of the hazards of diving
operations and control measures that shall be implemented to reduce identified
risks.
(iv) pre-work assessment and job briefings that shall review work procedures to
ensure all risks have been identified and appropriately controlled.
(v) identify emergency procedures and contact information for emergency services,
medical clinics, hospitals, Coast Guard, and a physician that is competent and
capable of treating diving and decompression related injuries and illnesses.

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(vi) reporting and investigation of incidents occurring during diving operations as
required by
ADOSH-SF- Mechanism 11.0 – Incident, Notification, Reporting and
Investigation.
(vii) medical monitoring / surveillance program to ensure no medical condition exists
that makes employees unsuitable for performing recreational diving and
instruction work.
(viii) process for logging dives and maintaining safe diving operations as specified by
a professional diving organization (e.g. PADI or BSAC); and
(ix) process for maintaining, testing, and servicing all diving equipment.
(f) Work shall be planned so that employees do not work alone and medical assistance is
available when required while performing diving activities.
(g) Employers shall select one professional diving organization that their occupational
diving operations shall adhere to and follow the requirements set by that organization.
All divers shall maintain qualifications/certifications from that organization. New
employees with qualifications/certifications from another organization shall have six
months to obtain the qualifications/certifications from the employer selected
professional organization, but they shall have equivalent qualifications for the work
and depth of dives they will be performing for the employer.
(h) For any diving operations deeper than 35 meters, the employer shall ensure:
(i) employees and managers/supervisors performing the dive operations have the
equivalent commercial and/or technical dive certification/qualification for
performing the dives;
(ii) that all divers have the appropriate equipment to safely perform diving
operations. They shall also ensure all breathing gases have been tested to
ensure they meet required specifications as set by the professional diving
organization’s standards they are following; and
(iii) a decompression chamber or bell, with qualified medical staff, is available within
one hour of the dive operations.
(i) The maximum depth for recreational diving is 40 meters. Any diving operations
deeper than 40 meters shall follow the requirements for commercial diving operations.
(j) All diving equipment shall be maintained to manufacturer’s requirements.
(k) The minimum qualification/certification for the senior diver on a dive boat that is
providing recreational dive services shall be:
(i) PADI – Dive Master;
(ii) BSAC – Advanced Diver;
(iii) SSA – Dive Supervisor;
(iv) SSI – Dive Control Specialist; or
(v) equivalent from a recognized diving organization.

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(l) Personal Protective Equipment provided shall be in accordance with
ADOSH-SF – CoP
2.0 – Personal Protective Equipment; including specialized diving equipment (e.g.
wetsuits, diving knife, etc)
.
3.4 Commercial Diving Operations
(a) Employers shall:
(i) perform a risk assessment in accordance with
ADOSH-SF– Element 2 – Risk
Management, to determine the risks and training requirements for employees
performing diving operations;
(ii) have membership in and follow the practices of the International Marine
Contractors Association (IMCA) or any equivalent membership of an
internationally recognized organization (HSE-UK, Association of Diving
Contractors, etc);
(iii) maintain current permit(s) and license(s) as required by the Department of
Transportation – Maritime, Department of Economic Development as well as any
other permits and licenses as required;
(iv) require all diving operations to be carried out under appropriate work procedures
along with performing a task specific risk assessment; and
(v) identify a Competent Person for Diving Operations in writing.
(b) Competent Person for Diving Operations shall:
(i) ensure competency of divers and diving contractors;
(ii) coordinate diving team operations and prepare plans for diving operations;
(iii) ensure diving operations are in accordance with the CoP and team diving plans;
and
(iv) ensure that divers update and maintain their personal dive logbooks at the end
of each day.
(c) Facility/Site Manager or Ships Master shall:
(i) ensure that all interfaces are identified, the risks analysed and actions taken to
mitigate risks. Such interfaces resulting from concurrent activities include:
1. over side lifting, scaffolding or any other work that may cause objects to
drop in the diving zone;
2. over side disposal of effluent and/or waste (e.g. drilling mud/cuttings);
3. ship movements in the vicinity of diving location;
4. testing of firefighting facilities (e.g. start-up of fire pumps); and
5. special operations that may cause accidental loss of containment in the
vicinity of the diving operations. (e.g. pressure testing of subsea pipe
work, testing of subsea Emergency Shutdown Valves (ESDs).
(ii) ensure that, where reasonably practicable, concurrent operations are avoided.
However, if avoiding these is not an option, then Permit to Work (PTW) control
measures requirements shall be strictly applied;

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(iii) inform the Competent Person for Diving Operations of the location and exact
operational details of all interface items in writing and in appropriate time to
account for them in the risk assessments;
(iv) provide the Competent Person for Diving Operations in writing with details of
any substances that are reasonably practicable to be encountered by the diving
team that would be hazardous to their health;
(v) ensure appropriate lifting equipment is available, in compliance with
ADOSH-SF
– CoP 34.0 – Safe use of Lifting Equipment and Lifting Accessories; and
(vi) ensure that the competent Person of Diving Operations is kept informed of any
changes that may affect the diving operation.
(d) Divers shall:
(i) hold a diving qualification appropriate for the work they intend to do. They shall
have the original certificate in their possession at the site of the diving project
– copies are not acceptable; and
(ii) maintain one of the following qualifications, or an equivalent qualification:
1. Scuba Diving to 30 meters -
ADAS Part 1 (AS2815.1);
2. Surface Supply to 30 meters -
ADAS Part 2 (AS2815.2);
3. Surface Supply to 50 meters -
ADAS Part 3 (AS2815.3); and
4. Bellmen and lockout divers -
ADAS Part 4 (AS2815.4).
(e) Before the commencement of a diving project, the employer shall develop a diving
project plan that is updated as necessary during the diving operations if conditions
change or new hazards are identified. At a minimum, the diving project plan shall:
(i) include written appointment of a competent person to supervise the operation
that is appropriately qualified to perform the functions of diving supervisor;
(ii) list the risks identified during the risk assessment and control measures that will
be taken to remove or control the risks to an as low as reasonably practicable
level;
(iii) cover the general principles of the diving techniques to be used as well as the
needs of the particular operation;
(iv) identify emergency procedures and contact information for emergency services,
medical clinics, hospitals, Coast Guard, and experienced / competent physicians;
(v) include procedures for checking and testing air quality of compressed air used
in diving operations; and
(vi) include communication procedures during diving operations to include how
divers shall communicate with other divers and personal overseeing operations
at the surface.
(f) Commercial diving operations shall meet the following international standard
requirements:
(i) scuba divers using enriched air shall meet the requirements of
ISO 11107:2009,
Recreational Diving Services – Requirements for Training Programs on Enriched
Air Nitrox (EAN) Diving; and

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(ii) managers and supervisors of scuba diving operations shall at a minimum meet
the requirements of
ISO 24801-3:2014, Recreational Diving Services –
Requirements for the Training of Recreational Scuba Divers – Part 3: Level 3 –
Dive Leader.
(g) Employers that have commercial diving operations shall develop an Occupational
Diving Program that shall at a minimum consist of the following:
(i) training for new employees, and refresher training as required;
(ii) process to ensure employees have valid diving qualifications/certification;
(iii) communication system to inform/remind employees of the hazards of diving
operations and the required control measures they shall implement to reduce
identified risks;
(iv) pre-work assessment and job briefings that shall review work procedures to
ensure all risks have been identified and appropriately controlled;
(v) procedures for emergency response or medical treatment if an incident occurs
to include identifying a physician that is familiar with and capable of treating
decompression illnesses;
(vi) reporting and investigation of incidents occurring during diving operations as
required by
ADOSH-SF- Mechanism 11.0 – Incident Notification, Investigation
and Reporting;
(vii) medical monitoring / surveillance program to ensure no medical condition exists
that makes employees unsuitable for performing commercial diving operations;
(viii) process for logging dives and maintaining safe diving operations as specified by
a professional diving association; and
(ix) process for maintaining, testing, and servicing all diving equipment.
(h) Work shall be planned so that employees do not work alone and medical assistance is
available when required while performing diving activities.
(i) For any diving operations deeper than 35 meters, the employer shall ensure:
(i) employees and managers/supervisors performing the dive operations have the
equivalent commercial and/or technical dive certification/qualification for
performing the dives;
(ii) that all divers have the appropriate equipment to safely perform diving
operations. They shall also ensure all breathing gases have been tested to
ensure they meet required specifications as set by the professional diving
organization’s standards they are following; and
(iii) a decompression chamber or bell, with qualified medical staff, is available within
one hour of the dive operations, except where a decompression chamber is
required on site as specified below.
(j) Qualified medical staff and a decompression chamber capable of recompressing the
diver at the surface to a minimum of 165 feet of salt water (fsw) shall be available
within five minutes of the dive location (on-site) for:
(i) surface-supplied air diving to depth deeper than 100 fsw and shallower than
220 fsw; or

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(ii) mixed gas diving deeper than 150 fsw and shallower than 300 fsw; or
(iii) diving outside the no-decompression limits shallower than 300 fsw.
(k) Qualified medical staff and a decompression chamber capable of recompressing the
diver at the surface to the maximum depth of the dive shall be available within five
minutes of the dive location (on-site) for dives deeper than 300 fsw.
(l) The decompression chamber shall be:
(i) dual-lock;
(ii) multi-place; and
(iii) equipped with:
1. a pressure gauge for each pressurized compartment designed for human
occupancy;
2. a built-in-breathing-system with a minimum of one mask per occupant;
3. a two-way voice communication system between the occupants and a
dive team member at the dive location;
4. a viewport; and
5. illumination capability to light the interior.
3.5 Cylinders and Compressed Air
(a) All cylinders and valves shall be inspected for serviceability prior to use. All cylinders
shall have the inside of the cylinder visually inspected at a minimum annually and
pressure tested at a minimum every five years and the date of pressure testing
stamped on the cylinder.
(b) Compressed air shall meet the requirements of the
Compressed Gas Association (CGA),
Table 1, Level E Standards for Scuba Diving Air.

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3.6 Warning Notices and Signals
(a) Diving signals shall be displayed in the most conspicuous position relative to the
diving operation and visible to all vessels at all times. The area of the diving operation
shall be clearly defined with the international “A” “Diver Below” (see Figure 1) and
where applicable mast head lights (see Figure 2) or mast head symbols (see Figure 3)
shall be used.
(b) In no wind situations a rigid replica of the International Flag “A,” with a minimum
dimension one square meter shall be displayed adjacent to the diving site.
Figure 1: International Flag “A” (Diver Below)
Figure 2: International Mast Headlights
Figure 3: International Mast Head Symbols
(c) During conditions when a wind exists and a non-ridged International Flag “A” is
displayed, the dimensions shall not be less than 750 millimetres in length and not less
than 600 millimetres in width when displayed on a vessel and 300 millimetres in
length and 300 millimetres in width when displayed from a buoy.
(d) When using International Mast Headlights and International Mast Head Symbols, they
shall be clearly visible for a distance not less than 200 meters.
(e) When diving is taking place during the hours of darkness, a yellow or orange flashing
light with a visibility of not less than 200 meters and visible to all vessels shall be
used.

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(f) When diving operations occur from locations other than a vessel (eg. beach, bridge,
platform, etc.) the following safety signage (see figure 4) shall be posted at all times
and visible to all vessels within 100 meters. During diving activities, the International
Flag “A” shall also be displayed.
Warning
Divers
operating in
area
تحذير
غواصون
يعملون في
المنطقة
Figure 4: Warning Sign
3.7 Safety of Navigation
(a) Personal Flotation Devices of the appropriate size shall be made available to all
personnel on the vessel (boat).
(b) Vessels shall not exceed a speed of 6 knots when:
(i) within 100 meters of any diving operations;
(ii) within 100 meters of a vessel or buoy on which a “diver below” signal
corresponding to the international code flag “A” (figure 1) is displayed;
(iii) within 60 meters of a designated swimming area;
(iv) within 60 meters of a person in the water;
(v) within 60 meters of any fixed or floating structure, either on or in the water;
except where that structure is an Aid to Navigation and the width of the
Navigable Channel prevents such distance off to be maintained;
(vi) within 200 meters of the water’s edge; and
(vii) passing through an arch of a bridge.
(c) Operators of vessels shall have training on the appropriate operation of the vessel
and associated rules and regulations on the safe operations of a vessel.
(d) Operators of vessels shall have the appropriate training certificates and licenses as
required by the Department of Transportation.
(e) Employers with vessels shall comply with the requirements of the authorities
regulating the marine transport and operations sector in Abu Dhabi emirate
.
(f) Vessels engaged in commercial underwater operations shall exhibit:
(i) International Mast Headlights (Figure 2) or International Mast Head Symbols
(Figure 3);

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(ii) two all-round red lights or two ball in a vertical line to indicate the side on which
the diving operations are occurring; and
(iii) two all-round green lights or two diamonds in a vertical line to indicate the side
on which another vessel may pass.
(g) Whenever the size of a vessel engaged in commercial diving operations means it not
reasonably practicable to exhibit all lights and shapes prescribed in Section 3.7(f), the
following shall be exhibited:
(i) three all-round lights in a vertical line where they can best be seen. The highest
and lowest of these lights shall be red and the middle light shall be white; and
(ii) a rigid replica of the International Code Flag “A” not less than 1 meter in height
and width shall be displayed and visible to all vessels at all times.

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4. Record Keeping
(a) All medical evaluation records and training records shall be maintained in accordance
with
ADOSH-SF – Element 9 – Compliance and Management Review.
(b) All diving logs, end of job reports, and associated paperwork shall be maintained for a
minimum of five (5) years.
(c) A log of equipment maintenance, servicing, and testing shall be maintained for a
minimum of five (5) years.

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5. Document Amendment Record
Version Revision Date Description of Amendment
Page/s Affected
4.0
15th July 2024
System acronym updated from OSHAD-SF
to ADOSH-SF to accurately reflect
document title
Throughout
Change from OSHAD to ADPHC
Change of Logo
Minor editorial changes throughout the
document without changing requirements.
Title of Mechanism 7.0 updated to ADOSH-
SF – Mechanism 7– Occupational Safety
and Health Practitioner and Service
Provider Registration.
OSHAD-SF - Mechanism 8.0 - OSH
Practitioner Registration deleted
4.1
16th February
2026
Minor editorial changes throughout the
document without changing requirements
Throughout

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