Dive Operations Manual (Updated April 2023) PDF
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2023
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Dive Operations Manual updated in April 2023, containing details on emergency procedures, equipment, safety management, and contact information.
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DIVE OPERATIONS MANUAL 1 Contact Phone Emergency Services 111 Dunedin Hospital 03-474-0999 DES (Diver Emergency Services) 0800-4DES-111 Dive Otago 0800-DIVE OTAGO Harbour Control Channel VHF 14 Distress Channel VHF 16 Dan Anderson - Director 021-0263-8340 Virginia Watson - Directo...
DIVE OPERATIONS MANUAL 1 Contact Phone Emergency Services 111 Dunedin Hospital 03-474-0999 DES (Diver Emergency Services) 0800-4DES-111 Dive Otago 0800-DIVE OTAGO Harbour Control Channel VHF 14 Distress Channel VHF 16 Dan Anderson - Director 021-0263-8340 Virginia Watson - Director 021-2661868 Emma Young Training Director / PADI Course Director 027-5295275 Broadway Medical Centre 03-477-4335 Version 27.0 2 Version Amendments Approved Date 1.0 ● ● ● ● ● Formatting updated Drug and Alcohol segment amended to reflect SMP Significant Hazards added to Risk Matrices Elimination control added to Risk Matrices Version control added 2.0 ● Delay Before Exposure to Altitude Table Added to Section 26. Driving or Flying After Altitude 05.11.2014 3.0 ● Added a reference to the quick reference guide (Emergency Procedures) which is now attached to dive slates. Refer to section 14(1) and 28(12). 18.11.2014 4.0 ● Boat diving - If three boat dives are scheduled on one day, only two tanks per customer can be loaded on the boat at one time. 15.01.2015 ● Key contact directory added to start of Section 2. 6.0 ● Carriage of Petrol rules added to Boat Diving Section 21.08.2015 7.0 ● Time in and Time Out (section 33) added 20.06.2016 ● Added most GPS coordinates to Site Management Plans. Added written procedures for Assessing New Dive Sites, Transport to Dive Sites and Diving with Other NZ operators. Minor corrections as recommended by the Tertiary Manager. 5.0 8.0 ● ● 9.0 10.0 Version 27.0 ● Updated RAMS to align with AAR: Hazard is now the activity. Risks come from the activity. RAMS also include a risk level prior to controls being applied and following. ● Added section on Freediving and updated the RAMS 28.08.2014 15.04.2015 01.08.2017 3.09.2017 18.06.2018 3 11.0 19.06.2018 ● Section 14 updated. Incident Register is now electronic on Drive ● Orore Point and Lookout Bluff RAMS added. ● Spearfishing Protocols and RAM added. 14.0 ● Section 15 updated. Risks and Hazards to align with Support Adventure recommendations to manage hazards and risk. 10.09.2019 15.0 ● ● Changed accident to incident Removed ‘Isolate’ as a risk management strategy 22.10.2019 16.0 ● Removed Tracey Channon from Contact Details, Added Virginia Watson and Emma Young 07.08.2020 ● Added SMP for Deepstream 12.0 13.0 17.0 18.0 19.0 20.0 21.0 22.0 Version 27.0 ● Added RAM for Otakau Wharf ● Added Ram for St Bathans ● Updated descent procedures during deep dives #16 Depths ● Added Ram for Selwyn Pool - Rolleston ● Added local contact number for Fish Reef Moreaki for staff to contact before diving. 16.08.2019 23.08.2019 05.02.2021 10.02.2021 16.03.2021 16.03.2021 05.07.2021 17.03.2022 4 23.0 ● ● 24.0 25.0 26.0 27.0 Added RAM for Goat Island and Quarantine Island Updated Cape Saunders & Tow Rock with Sea Lion info. ● ● Added to Deep Stream the need to use torches Added to Deep Water Basin that snorkeling is prohibited due to presence of sharks ● Moreaki Shore Dive RAM ● ● Updated Stewart Island - Leask Bay RAM Updated Stewart Island - Horseshoe Bay RAM ● ● ● ● ● Updated Fit-to-Dive Updated Night Diving RAM Added Deep Diving section Added Shark Protocols Reformatted document 13.08.2022 Emma Young 15.10.2022 Emma Young 01.12.2022 Emma Young 05.04.2023 Amelia Saxby 13.04.2023 TABLE OF CONTENTS Section 1: General Operating Procedures 1. Safety Management System 2. Dive Operations Manual 3. Standards and Guidelines 4. Diving Equipment and Clothing 5. First Aid Equipment and Oxygen 6. Trip Sheets 7. Recall Procedures 8. Site Selection 9. 9. Fit-to-Dive 10. Paperwork 11. Communication 12. Estimated Time of Return 13. Ratios and Supervision 14. Incident Management and Reporting 14.1. Authority 14.2. First Aid and Assistance 14.3. Notifiable Incidents 14.4. Non-Serious Incidents 14.5. Incident Register Version 27.0 5 14.6. Reporting and Review 14.7. Near Misses 15. Hazards and Risks 15.1. Identification of Hazards and Risks 15.1.1. Operational Environment 15.1.2. Equipment 15.1.3. Staff 15.1.4. Clients 15.1.5. Public 15.2. Assessing Hazards and Risks 15.3. Managing Risks 15.3.1. Eliminating Hazards 15.3.2. Minimising Hazards 15.3.3. Trigger Points 15.4. Communicating, Recording and Monitoring 15.5. Changing Hazards and Risks 16. Depths 17. Safety Stops 18. Emergency Ascent Training 19. Shore Diving 20. Currency of Certifications 21. Cold and Strenuous Activity 22. Dive Flag 23. Snorkelling 23.1. Organisation 23.2. Equipment 23.3. Preparation 23.4. Ratios 23.5. Documentation 24. Legislation 25. Logbooks 26. Deep Diving 27. Night Diving 28. Driving or Flying to Altitude after Diving 29. Missing Diver Procedures 30. Changing Conditions 31. Boat Diving 32. Shark Protocols: Increased Shark Activity Area - Guidelines 32.1 General Principals Version 27.0 6 32.2 What attracts sharks the most? 32.3 Dive Site Selection 32.4 Pre Dive Protocols 32.5 Briefing 32.6 Dive Protocols 32.7 Encounters Scuba Divers Free divers and snorkelers 32.8 First Aid 33. SMS Improvements and Changes 34. Time In and Time Out 35. Assessing New Dive Sites 36. Transport to Dive Sites 37. Diving with Other NZ Operators 38. Freediving and Freedive Training 38.1. Definitions 38.2. Instructor Qualifications and Certifications 38.3. Instructor Judgment and Risk Assessment 38.4. Certified Assistants 38.5. Instructor Equipment 38.6. Student Equipment 38.7. Minimum Ages Limits 38.8. Student Materials and Forms 38.9. Freediving Fitness 38.10. Ratios 38.11. Supervision and Control 38.12. Float and Safety Equipment 38.13. Confined Water 38.14. Open Water Sites 38.15. Depth Ranges 38.16. Incident or Near Miss Management 39. Spearfishing 39.1. Briefing 39.2. Supervision 39.2.1. Ratios 39.2.2. Buddy Protocols 39.3. Collection Procedures 39.3.1. In Water Procedures 39.3.2. Out of Water Procedures Version 27.0 7 39.4. Condition Limitations 39.5. Float and Safety Equipment 39.6. Emergency Procedures 39.7. Missing Diver Procedures Section 2: Risk Assement Matrices 1. Risk Assessment Matrix (RAM) 2. Determining Risk Levels 2.1. Likelihood 2.2 Consequences 2.3. Risk Level 3. Confined Water Training (Pool) 4. General Diving 5. Wreck Diving 6. Search and Recovery Diving 7. Night Diving 8. Drift Diving 9. Deep Diving 10. Boat Diving 11. Freediving 12. Spearfishing Risk Matrix Section 3: Site Management Plans 1. Akatore Reef 2. Anita Bay 3. Aramoana Beach Wall 4. Aramoana Mole 5. Bayfield High School 6. Blackhead Beach 7. Cape Saunders 8. The Chimneys 9. Copper Point 10. Cromwell Bridges 11. Customhouse Quay 12. Danger Reef 13. Deborah Bay 14. Deep Stream 15. Deepwater Basin Boat Ramp Version 27.0 8 16. Dive Otago Pool 17. Drydock Door 18. Fairway Beacon 19. Fish Reef - Moeraki 20. Fox Bay 21. Green Island 22. Greenstone Point 23. Harrington Point 24. Hayward Rock 25. Helicopter Pad 26. Horseshoe Bay, Stewart Island (Right and Left Dive Sites) 27. Karitane 28. Lake Alta 29. Lake Mahinerangi 30. Lake Marian 31. Lake Wanaka 32. Latham Bay 33. Leask Bay, Stewart Island 34. Lookout Bluff 35. Macandrew Bay 36. Marine Maid 37. Mikhail Lermontov 38. Milford Sound - General 39. Moana Pool 40. North Dale Point 41. North Taieri Reef 42. The Nuggets 43. Orore Point 44. Otakou Wall 45. Otakou Wharf 46. Outram Glen: River Crossing 47. Penguin Cove 48. Portobello 49. Post Office Rock 50. Queen Charlotte Sound 51. The Rock 52. Round House Reef 53. Saint Anne’s Pinnacles 54. Saint Anne’s Point Version 27.0 9 55. Seal Rock 56. Shag Point 57. Shark Alley 58. Sinbad’s Gully 59. St Martin, Quarantine Island 60. Stewart Island - General 61. Taieri Reef 62. Tow Rock 63. Waikouaiti Beach 64. Wellers Rock 65. Salt Water Pool 66. St Clair and Seconds Beach 67. Blue Lake - St Bathans 68. Selwyn Pool - Rolleston - Canterbury 69. Allan’s Beach 70. Goat Island 71. Quarantine Island General - (Kamau taurua) 72. Moeraki Shore Diving Version 27.0 10 SECTION 1 GENERAL OPERATING PROCEDURES 1. Safety Management System Dive Otago’s Safety Management System (SMS) is a documented management system used to direct, control and improve operations in regard to safety. It was developed specifically for the company’s scuba diving activities and enables Dive Otago to maintain an agile and proactive health and safety environment and achieve its commercial objectives in a manner which complies with the relevant professional standards, codes of practice and health and safety legislation. The purpose of the SMS is to direct and control Dive Otago operations in regard to health and safety. It includes: ○ ○ ○ Dive Otago’s overarching commitment to focus and improve health and safety and explanations as to how this commitment will be upheld Clear allocation of safety roles and responsibilities Well-defined and practical health and safety management systems and processes The SMS consists of the following core documents: ○ ○ ○ ○ Safety Management Plan (SMP) Dive Operations Manual (DOM) Employee Handbook Forms, Checklists and Tools The Directors are ultimately responsible for the SMS however the coordination and management of the SMS is the General Manager’s delegated responsibility. 2. Dive Operations Manual The DOM contains General Operating Procedures and Risk Plans and Risk Analysis Matrices (RAM’s) for each dive site. The General Operating Procedures detail specific operational and administrative processes staff must follow. The Risk Plans and the Risk Analysis Matrices are activity site specific and include control tactics used to identify and manage risks. 3. Standards and Guidelines All diving and snorkeling training must comply with the following: ○ Version 27.0 AS/NZS 2299.3:2003 Australian/New Zealand Standard Part 3: Recreational industry diving and snorkeling operations 11 ○ ○ 4. PADI Standards NZQA requirements where NZQA unit standards are being assessed Diving Equipment and Clothing All divers must have equipment as per the PADI Standards with the following additions: ○ All certified divers - cutting device and timing device Timetables are carefully written to ensure there is fit-for-purpose equipment available for the day’s activity. However, it is the responsibility of the instructor on the day to ensure they have all the necessary equipment prior to leaving Dive Otago. If required equipment is unavailable this should be reported to the Training Director or a Director to arrange alternatives. To ensure that all equipment is in proper working order for the day’s activities, regardless of whether the equipment is owned by Dive Otago or not, it must be checked by the student or customer (if trained to do so) or by a staff member prior to leaving the building. The student or customer will initial each column in the Equipment and Fit-to-Dive Roster and sign the sheet to acknowledge that the equipment they will be using is fit-for-purpose. The checklists are stored in the bound Equipment and Fit-to-Dive Roster located in the main workshop. Students and customers hiring equipment must complete and sign a Hire Form. A spares kit for all training and dive trips must be taken to the dive site. The spares kit must include: ○ ○ ○ ○ ○ ○ ○ ○ BCD Regulators/computer Mask Snorkel Fins Weight belt Weights Accessories and parts (clips, mask straps, fin straps, o-rings etc) All student and customer equipment must be checked prior to each dive during the pre-dive safety check. This must be recorded on the Fit to Dive Checksheet. It is the instructor's responsibility to check that everything is returned to the correct place and signed off on the trip sheet at the end of the day. Staff must use appropriate exposure protection at all times, particularly in winter when the water temperature can be cooler. This may be a wetsuit, semi-dry or drysuit but must protect the staff member from cool temperatures. It is the individual staff member’s responsibility to ensure the equipment they are using is serviced regularly and in proper working order. Note that all staff equipment and servicing due dates also Version 27.0 12 need to be recorded on the Reminders Calendar. It is also recommended that in the winter months warm hats, gloves, jackets etc are used between dives and in summer sun protection is worn. Students and customers are informed of the clothing requirements prior to the day’s activity. It is their responsibility to follow the directions of the staff in terms of appropriate clothing. If a client is deemed to be inappropriately dressed for the day’s activities or their equipment is not up to standard, they can be asked to abstain from diving if alternative clothing/equipment can not be arranged. 5. First Aid Equipment and Oxygen All Dive Otago vehicles including the boat contain first aid kits. The first aid kits are checked and restocked quarterly by the Tertiary Manager for expired products and used items. However, if a staff member uses the last of an item, they must inform the General Manager who will arrange the purchase of more items. An oxygen kit is always taken whenever diving or snorkeling is part of the day’s activities. The minimum oxygen levels are located in the Risk Plans for each dive site. For all dive sites that do not require driving to altitude post dive, the oxygen level must be 1500 psi or higher For any dives north of the Northern Motorway (e.g. Shag Point, Karitane or Moeraki) and in Milford Sound, the oxygen level must be 1800 psi or higher It is the instructor's responsibility to check these levels and ensure there is enough oxygen relative to the dive site. This must also be noted on the Trip Sheet. 6. Trip Sheets All staff must ensure the Trip Sheet requirements are followed with regards to required equipment, recording of dive data, and risk management. All information including weather details, dive objectives, dive plan, full names of all divers and non-divers and equipment, ETA, and oxygen must be completed at the start of each day. The instructor is responsible for ensuring the Trip Sheet is filled in completely and accurately at the end of each outing. This includes ensuring all dive details have been added and the Trip Sheet is filed appropriately in the Trip Sheet Folder. If diving at Wellers Rock, the Monarch operator is to be informed and recorded on the Trip Sheet. If diving within the Otago Harbour, the shipping times must be noted on the Trip Sheet. Version 27.0 13 7. Recall Procedures Instructors must carry a tank banger or underwater horn as a recall device at all times when diving in the open water. Tank bangers are stored in the hire area and must be checked off the trip list. Instructors must brief students on the recall procedures relevant to the site including the sound to listen for prior to getting into the water. In addition the procedures will include instructions to ascend safely after hearing the recall and what students should do once at the surface. Instructions will be dependent on the reason for the recall. 8. Site Selection Staff are to follow PADI Standards and Guidelines and factor in dive capabilities, objectives and weather when selecting a dive site. Instructors may only use approved sites as indicated by completed Site Management Plans and RAMS. If in doubt, staff must consult their line manager or a Director to come to the right decision. 9. 9. Fit-to-Dive Before leaving Dive Otago all students, customers, staff and assistants need to sign that they are fit to dive on the digital “Fit to Dive and Equipment Check” form (sent out by the Instructors). When not based at Dive Otago, all students, customers, staff and assistants need to initial each “Fitness to Dive” column on the Fit-to-Dive Sheet (bound Equipment and Fit-to-Dive Roster) and sign the final column indicating that they are fit to dive. Each person must also sign the Trip Sheet (including non-divers and skippers). During pre-dive safety checks (conducted before every dive) students, customers, staff and assistants must be asked if they are “fit-to-dive” by their buddy. This is indicated on the Trip Sheet by a tick in the column prior to the second dive details or a second signature if prior to a third dive. Where there is doubt regarding a diver’s fitness to complete a dive, that diver must be advised not to dive. The reason for this decision may include psychological fitness, physical health or evidence regarding alcohol or drug consumption. Instructors have the authority from Dive Otago Management to make decisions on a student or customer’s fitness-to-dive. 10. Paperwork Prior to any in water activity, participants must sign liabilities, standard safe diving practices and medicals as stipulated by PADI standards (e.g. RSTC Medical Statement, Release of Liability / Assumption of Risk / Non-Agency Acknowledgement Form, Standard Safe Diving Practices Statement of Understanding, PADI Membership Agreement and Licence Agreement for PADI Version 27.0 14 Members). Any participant under the age of 18 years also requires their parent or guardian to co-sign these documents. The instructor taking the students or customers is responsible for checking these forms, ensuring they are filled in correctly and also taking note of any medical conditions on the forms. 11. Communication At most of the local dive sites cellphone communication is possible and therefore a cell phone must be carried by at least one staff member. It is the responsibility of the instructor to ensure that they take a phone which is charged and in working order. When diving at Aramoana or at the Quay, a VHF radio must be taken. These are kept in the Hot Office and are to be placed back on charge upon their return. If the boat is used, in addition to the cellphone, the marine radio will also be available along with the EPIRB. Milford Sound has no cellphone reception and therefore the marine radio will be the primary source of communication. All skippers must hold a current VHF certification and the instructor on board should also have a basic understanding of how to use the marine radio in case the skipper is unable to do so. When boat diving within the Otago Harbour, the skipper must notify Port Otago on Channel 14. When diving in Milford Sound the skipper must notify Milford Harbour Control on Channel 14. 12. Estimated Time of Return Before leaving Dive Otago the instructor in charge must put an estimated time of return (ETR) on the Trip Sheet and fill in the ETR section of the shop whiteboard. If the return is likely to exceed the ETR, the instructor in charge must notify Dive Otago reception via text or phone and a new ETR will be added to the shop whiteboard. The exception to this rule is when diving on Sundays or when night diving. If a group has not returned within 1 hour of their ETR, the Dive Otago reception staff must attempt to make contact with a member of the group to establish their location. If contact cannot be made, a Director must be informed. If an instructor is diving on a Sunday or night diving they are to text their trip details to Virginia Watson (0212661868) or Daniel Anderson (02102638340). The Instructor will then text the same number when all divers have returned to Dive Otago. If a case of serious harm occurs on a Sunday or while night diving and there are no additional Version 27.0 15 staff on site at Dive Otago, a phone call must be made to the General Manager. ETR’s for boat diving must include the location(s) and POB. If you change locations, you must inform both Dive Otago and Harbour Control of your new location. 13. Ratios and Supervision PADI stipulates the maximum ratios that must be adhered to so all instructors must consult their current PADI Instructor Manual for ratios. Maximum ratios will be decreased when conditions (weather conditions, visibility, staff experience, student or customer experience, type of activity etc) make it prudent to do so. It is the responsibility of the lead instructor to identify when this is appropriate. This might be with their own group or they may have seen a customer who poses a risk to another group. In this instance, instructors need to inform the Training Director so a suitable strategy for a customer can be implemented. The dive supervisor must either be in the water or on shore ready to enter the water immediately at all times. When students are around the higher risk areas of the building (pool and workshop) they are to be supervised by a staff member at all times. 14. Incident Management and Reporting Staff must adhere to the first aid and risk management processes outlined below and in the Safety Management Plan (SMP) prior, during and after an accident or incident. A PADI Accident Management Workslate and Diving Accident Management Flowchart Slate is kept in all first aid kits. When managing an incident staff must adhere to the following steps: 14.1. Authority ○ If an accident or incident occurs the staff member on site needs to take charge and manage the situation by following the correct processes. If there are two or more staff members on site, the staff member with the highest PADI rating needs to take charge of the situation and use other staff as assistants. In the instance where two staff members are on site with the same PADI rating the staff member who has been employed for the longest period of time will be in charge. 14.2. First Aid and Assistance ○ Version 27.0 When an incident occurs, in the first instance staff must deal with immediate injuries and first aid requirements as trained and if required contact emergency services (111) and/or Diver Emergency Services (0800 4 DES 111). During and following an accident or incident staff must: - Not apportion blame for incidents 16 - Ensure bystanders are treated respectfully Avoid diagnosing injuries. 14.3. Notifiable Incidents ○ ○ ○ If the incident is considered notifiable, staff must call a Director or the highest ranking staff member on site at the same time as the call to emergency services (if two phones available) or immediately after. If staff have any doubt about the correct emergency protocols they must call a Director or the highest ranking staff member on site immediately. If possible, also quarantine the victim’s dive equipment. All notifiable incidents require reports and supplementary information. Refer to the SMP for guidance on what information is required. 14.4. Non-Serious Incidents ○ ○ If the incident does not meet the threshold of a notifiable incident, staff must still enter the incident into the Incident Register. The Directors will advise if a written report of the non-serious incident is required. 14.5. Incident Register ○ All incidents must be recorded in the Dive Otago Incident. This is electronic and all staff have access to this in Drive. Refer to the SMP for additional information. 14.6. Reporting and Review ○ Refer to the SMP for the full incident reporting and review process. 14.7. Near Misses ○ 15. A near miss is an unplanned event that did not result in injury, illness, or damage but had the potential to do so. Only a fortunate break in the chain of events prevented an injury, fatality or damage; in other words, a miss that was nonetheless very near. Near misses that could have caused a Notifiable Event must be recorded in the Incident Register. When a new near miss is recorded, A Director is automatically notified via email and will assess the near miss to determine if action is required. All near misses will be discussed at the next staff meeting and the annual SMS review Hazards and Risks It is the responsibility of all staff to prevent accidents where possible. A comprehensive set of known hazards and risks and how to manage them are detailed in Section 2 of this manual and staff must remain familiar with these at all times. However, new hazards and risks will eventuate Version 27.0 17 overtime and staff must be confident in their ability to manage these. Hazard and risk management involves four components: - Identify the hazards and risk which can be: - Assess the risk (before and after deciding on risk management methods) - Manage the risk - Ongoing monitoring and communication 15.1. Identification of Hazards and Risks Hazards and risks can appear in any context. A lot of new hazards and risks will be captured via our systematic assessments (e.g. audits, self-checks, check-lists and reminders) but it is vital that all staff are constantly thinking about potential hazards and risks. Below are examples of where to look: 15.1.1. Operational Environment - Locations (e.g. dive sites and boat ramps) The operational base (e.g. power failures, yards, workshop and pool) Unique environmental factors (e.g. rock falls, traffic on roads, avalanche risk, river levels Health risks (e.g. harbour water quality) Evacuation routes Communication black spots Weather (e.g. wind, swell, current, tidal variation and surface temperature) Natural disasters (e.g. earthquakes or floods) 15.1.2. Equipment - Is equipment fit for purpose, does it meet industry standards? Potential for incorrect equipment use and its implications Potential for equipment failure and its implications 15.1.3. Staff - Experience, e.g. in total and/or within your operation Competency in both hard and soft skill sets Implications of incapacitation, e.g. solo guide becomes ill or injured Numbers needed to adequately supervise clients, i.e. staff to client ratio Health and behaviour, e.g. fatigue, unpredictable behaviour Senior staff off sick or otherwise unavailable 15.1.4. Clients Version 27.0 Technical skill ability 18 - Age Fitness and general health Language and cultural issues Social and behavioural issues 15.1.5. Public Examples of things to consider: - Who else (commercial and non-commercial) could be in the area where you operate? What impact could other users have on the safety of your activity? What impact could your activity have on the safety of other users? 15.2. Assessing Hazards and Risks Once a risk and its associated hazard has been identified, staff can assess its seriousness. The Risk Assessment Matrix on page 30 of this manual should be used to assess risks and hazards. A full explanation of how to use these tables is provided. If in doubt, always call a Director, Manager or Course Director to obtain guidance and support. 15.3. Managing Risks The purpose of the risk assessment is to ensure you are focusing on managing the risk to an acceptable level and by the hierarchy of control. This means the first priority must be to eliminate the risk, and if that can’t reasonably be achieved then the risk should be minimised. 15.3.1. Eliminating Hazards Examples include not taking people under a certain age or without a certain skill set, or keeping people away from the hazard e.g. establish a no-go zone behind a barrier or portage a rapid and deciding to cancel diving. 15.3.2. Minimising Hazards An example of minimising is to reduce the likelihood and consequence of hyperthermia by providing appropriate exposure equipment and hot drinks during surface intervals. Often a combination of controls are used to minimise a hazard. Examples include the use of competent staff, supervision levels, briefings and safety equipment. 15.3.3. Trigger Points Dive Otago has ‘trigger points’ that are particularly helpful as safety management controls. They give clear direction and remove the need to make a judgment call in critical situations and can be set for people, environmental and equipment factors. Trigger points are particular circumstances Version 27.0 19 and situations that cause an action to happen, for example: - No boat diving in 25 knot winds Minimum age to participate Ratios All significant hazards and issues must be reported to a Director as soon as possible. All hazards and risks must also be recorded in the Hazards and Risks Register so the appropriate hazard and risk management steps can be activated. Further information about hazards and risks is contained in the SMP and in Section 2 of this manual. 15.4. Communicating, Recording and Monitoring The Hazards and Risk Register is an electronic tool for staff to add new hazards, risks and issues. When the Register is updated, a Director is automatically notified via email. The Director will assess the new entry, determine its severity and if action is required, allocate the appropriate resources. If action is undertaken, it will be re-assessed to determine if further action is required. Once the new entry has been appropriately managed, the SMS may be updated. If the SMS is updated, the changes will be reported to staff. Regardless of the outcome, all risks and hazards are discussed at the next staff meeting. The Register has three tabs: - Known Hazards and Risks (as contained in the Site Management Plans and RAMs) New Hazards, Risks and Issues Near Misses. Refer to: Safety Management Plan Appendix D: The Hazard and Risk Management Process details how hazards and risks must be managed. 15.5. Changing Hazards and Risks An ongoing assessment of the hazards and risk during an activity must be made throughout the activity. If at any stage conditions change and the activity is no longer safe, all divers must exit the water and return to Dive Otago with the full support of management on this decision. 16. Depths All PADI standards in relation to depth limits must be adhered to. In addition, for Tertiary training: ○ ○ Version 27.0 No tertiary training dive is to be conducted at a depth of more than 30 metres. Exception - conducting Specialty Instructor training for deep experience. In this case the Course Director or IDC Staff Instructor conducting the dive may conduct the dives to a maximum of 40m as per PADI standards. The Course Director or IDC Staff Instructor must be present and in control of all activities below 30m. 20 ○ ○ ○ ○ Dives planned below 30 metres must have prior approval from a Director and meet the requirements of the RAMS plan for the dive site. Divers should have logged at least 10 dives between 18 and 30m prior to undertaking this training as per PADI standards. Instructors are reminded to exercise caution and conservatism when making decisions and applying judgment in your training During descents instructors are to regroup at at least 3 depths before reaching 19m; i.e. 6m, 12m & 18m checking buoyancy, air and student ok. Any dive planned in excess of 18m or more must be approved by the Recreation Manager, a Senior Tertiary Tutor or a Director and signed on the Trip Sheet. 17. Safety Stops All dives will have a safety stop where appropriate and safe to do so. All activities will have a safety stop as appropriate as indicated by PADI standards or by the computer each individual is using. 18. Emergency Ascent Training Staff should follow good dive practice and risk management when conducting emergency ascent training which may include: spreading out the CESA training across dives 2, 3 and 4. Conducting CESA early in the dive and on the dive day if practical to do so. 19. Shore Diving Staff are to take a rope and float appropriate for the retrieval of divers in an emergency situation. 20. Currency of Certifications All renewal dates for staff certifications are in the Staff Renewals Calendar. However, staff must ensure they keep any agency qualifications current. These include but are not limited to: ○ ○ ○ ○ ○ ○ ○ ○ 21. Certificate of Competency Fitness to Dive Basic First Aid Certification First Aid Instructor rating (if applicable) Air Fillers Certification Skippers qualification Cylinder Testing PADI Instructor rating Cold and Strenuous Activity Staff are to account for cold and/or strenuous conditions by adding 4m on the PADI RDP for all dives conducted in June, July, August or on any dive where it is likely that the divers will get excessively cold or exert themselves. Version 27.0 21 If diving on a computer, the computer should be set to a conservative mode to account for this addition. If a diver becomes excessively cold, staff must advise the diver to discontinue diving, get out of the water, dry off and get themselves warm. Staff are to practice sound risk management by ensuring divers do not dive in conditions that are likely to cause hypothermia. 22. Dive Flag An alpha flag must be clearly visible during all diving activities and divers are to be kept within 200m of the flag. 23. Snorkelling 23.1. Organisation - All snorkeling activities must have a supervisor. Snorkeling can only be conducted at locations with Site Management Plans. Snorkelers will sign a liability release prior to undertaking any snorkeling activity. This includes a statement regarding their medical fitness. 23.2. Equipment All students or customers must have the appropriate sized: ○ ○ ○ ○ Mask Wetsuit Snorkel Fins 23.3. Preparation Site selection will be based on weather, topography and participant capability. A pre-dive briefing will be provided and must include a summary of the: ○ ○ ○ ○ ○ ○ ○ Version 27.0 Hazards Environmental considerations Location Safety procedures Buddy system Emergency procedures (recall, rescue, first aid and oxygen) Entry and exit 22 Staff must be in-water or ready to enter the water immediately in the case of an emergency. 23.4. Ratios The maximum instructor to student ratio for in-water snorkeling activities should be determined by instructor judgment taking into account variables such as (but not limited to) weather conditions, location, client experience and instructor experience. The supervisor will have at least one land-based lookout when there are 8 or more participants. The lookout’s task is to supervise the activity for its duration. Including entries and exits. 23.5. Documentation Trip Sheets must be completed when snorkeling in the open water. 24. Legislation Staff must ensure that they and the students and customers they lead comply with the relevant legislation. This includes personally observing and measuring any seafood gathered. The key legislation that impacts Dive Otago is listed in the SMP. Staff are to promote Aramoana Mole as a voluntary Marine Reserve and ensure no divers collect seafood from Aramoana Mole during Dive Otago training activities. Staff are to ensure any seafood collection is done in accordance with sound resource conservation: e.g. take only what you eat, do not harm one organism to feed another. 25. Logbooks Logbooks must be completed by the student for every dive with site, depth, time, training objective and correct pressure group (or designate if it was a computer dive). Instructors must sign all training dives (including dives for experience) and it is the instructor's responsibility to check that pressure groups are correctly filled in before signing. 26. Deep Diving The instructor must carry two torches on any deep dive Student divers must carry one primary torch each and have one backup per buddy pair (minimum) on all deep dives Instructors are to brief students on hand signals, light failure procedures and checking each torch prior to the dive. Version 27.0 23 27. Night Diving All divers must have a light source in the form of a Flashy LED Dive Light or equivalent attached to their equipment for all night dives. The instructor must carry two torches on any night dive Student divers must carry one primary torch each and have one backup per buddy pair (minimum) on all night dives It is recommended that open water training be conducted at a dive site where the student has dived during daylight hours. Instructors are to brief students on hand signals, light failure procedures and checking each torch prior to the dive. 28. Driving or Flying to Altitude after Diving Staff must follow the Guidelines Regarding Exposure to Altitude Following Diving as listed in AS/NZS 2299.1:2007 Appendix H. The standard in its entirety is located on Drive. These guidelines provide recommendations regarding the period which should elapse after diving and before a diver ascends to altitude or is otherwise exposed to reduced atmospheric pressure. The minimum delays should be as set out in the table below. These recommendations are for divers who find themselves in normal health following diving. If any signs or symptoms of illness or injury are present, advice should be sought regarding the need for either emergency medical evacuations or a prolonged stay at sea level. Legend: ○ ○ Version 27.0 Category 1: A single dive to <50% of the DCIEM no decompression limit or two short dives within 18 hours with a total, combined bottom time of <50% of the no-decompression limit for the depth of the deeper dive. No decompression diving or repetitive dives in previous days. Category 2: Dives exceeding Category 1 but not included in Category 3, e.g. one or more dives to >50% of the no decompression limits or a single decompression dive a day. 24 ○ Category 3: Repetitive deep diving over multiple days, multiple decompression dives on one day, extreme exposures; omitted decompression; or other adverse events. Note that the Kilmog (Northern Motorway) is 300m above sea-level, Lookout Point (SH1 heading south towards Taieri Mouth) is 120m above sea-level and that the highest point between Dunedin and Milford Sound is 900m above sea-level just south of Milford Sound. It is the lead instructor's responsibility to ensure that divers adhere to these guidelines. If there is any doubt, instructors must seek advice from a senior staff member. 29. Missing Diver Procedures - - Have someone call for emergency help. Dial 111 and or DES (0800 4DES 111). Establish where the last person saw the missing diver. Assign spotters to look in that area for bubbles and direct rescuers to the area. Use binoculars if available. Try to determine if the missing diver may have left without telling anyone. Have someone look for the diver’s clothes, gear bag, car etc. Immediately assign qualified divers to don scuba equipment and head to the area where the diver was last seen to begin an underwater search. If available, send two or more skin divers to mark the search areas with buoys. If commercially made buoys are not available - improvise with dive floats, bottles etc. Have a way to recall divers when the victim is found. Search only in buddy teams and make sure that searchers are within safe air and decompression limits. Rescuer safety takes priority - search until safe air limits are reached. Currents don’t usually move an unresponsive diver on the bottom, so begin the search where someone last saw the diver. If you think the diver lost consciousness on the surface and then sank, have rescuers descend from that point without swimming to simulate sinking the unresponsive diver. If diving in currents, staff must be aware that the missing diver is more likely to be drifting on the surface. Staff may need to consider widening the surface search area and if necessary advise Marine Search and Rescue (through the Police or Maritime radio). Staff must only use qualified divers. If there are no qualified divers present for the search, staff may need to choose a buddy and begin the search themselves. Refer to the quick reference guide to Emergency Procedures attached to dive slates. 30. Changing Conditions All training staff must be familiar and comfortable with the risks and hazards associated with the activity they are conducting and the location in which they are conducting the activity. Prior to leaving for the day all hazards (including but not limited to weather, activity, client competence, Version 27.0 25 instructor competence) must be considered. The Instructor taking the activity must make the decision as to whether the risks are acceptable for a given activity on the given day. At any stage if the conditions are not as what was expected or change, the instructor in charge of the activity can cancel the activity and return to Dive Otago with the full support of management. This also includes if any individual exhibits behaviours or attitudes which could be detrimental to safety of the individual, staff member or group. If this occurs, the individual can be asked to stay out of the water. In the case where more than one staff member is present, both staff members must be confident that the risks and hazards to do with the day’s activities are acceptable. It is possible that a less experienced staff member will not be as comfortable as an experienced staff member on a particular day and this is to be expected. However, if the more senior staff member decides the conditions are unacceptable the junior staff member must not continue with the activity. 31. Boat Diving The Sea Horse has a Safe Operational Plan and Certificate of Compliance. For detailed information about the boat, refer to these documents. Hard copies are held in the Tertiary Office and in the Workshop document area. The Master of the day must ensure that all pre-departure, pre-launch, pre-retrieval and return processes are completed in accordance with the checklists in the Boat Sheet Folder. This includes a briefing to passengers in all aspects of: ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ Boat launching Equipment preparation Equipment storage Passenger positioning Passenger safety equipment Boat safety equipment Emergency procedures Sea conditions Accounting procedures Pre-dive safety checks Water entry technique Water exit technique Boat retrieval A trip report must be logged with Harbour Control. The trip report must include the location(s), POB, intention and estimated time of return. If the skipper changes locations, they must inform Harbour Control. If three boat dives are scheduled on one day, only two tanks per customer can be loaded on the Version 27.0 26 boat. The Master will drop off the two empty tanks and collect the remaining tank for each customer after the second dive. If additional fuel is being transported the Master must: ○ ○ ○ secure petrol canisters when in transit only carry marked canisters (all Dive Otago canisters are marked correctly) carry a copy of the Initial Emergency Response Document - A copy resides in the Prado with. A copy of NZTA Factsheet 68: Dangerous Goods is stored on Drive. 32. Shark Protocols: Increased Shark Activity Area - Guidelines These protocols have been written with Stewart Island/Rakiura dive sites in mind but apply to any site where there is increased shark activity. Despite the odds being low that you will encounter a white shark while diving or swimming, any marine recreation activity along the New Zealand coastline carries the risk of an unplanned encounter with a Great White Shark, Mako or other predatory shark species. No fatal shark attacks have ever occurred in Stewart Island, Rakiura. One scuba diver has been bitten (non-fatal) by a Mako at the Titi Islands. While the risk is low, it does exist and it is important to understand the risks and then make decisions about the activities you wish to engage in. A list of basic principles has been provided that, if followed, will not only decrease your chances of encountering a Great White Shark but increase the odds of a safe ending for both shark and humans, should you ever meet. These guidelines have been created from freely available international guidance as well as specific advice from Clinton Duffy. Clinton is one of New Zealand's leading Great White scientists who has spent over 10 years researching Sharks in Rakiura. 32.1 General Principals - - If you are not fully aware of all of the risks of being in the ocean and are not prepared to take these risks, do not go into the ocean. White sharks, like all predators, are more likely to identify a solitary individual as potential prey, so try to remain in a group. White sharks are primarily visual hunters which would normally allow them to correctly distinguish you from their preferred prey species. Therefore, avoid entering the ocean when it is murky, during darkness or twilight hours when sharks rely on their other senses to locate potential prey rather than their vision. When encountering a white shark, remain as calm as you can. Assess the situation. Do Version 27.0 27 - not panic! Panicked, erratic movements are likely to increase the shark’s curiosity, draw it closer to you and possibly send signals similar to an injured or distressed prey. Use any equipment (camera, surfboard, pole etc.) you may be carrying to create a barrier between yourself and the shark. If you see a shark, calmly alert other ocean users around you. Remain in or create a group, and leave the water in a calm and swift, but smooth, manner. Alert nearby vessels 32.2 What attracts sharks the most? Blood Sharks are blessed with a very strong sense of smell, allowing them to detect potential prey from hundreds of metres away. They can detect any bodily fluids e.g. urine, not just blood. Menstrual blood in the water could be detected by a shark, just like any urine or other bodily fluids. However, there is no positive evidence that menstruation is a factor in shark bites. Additionally, evidence suggests when swimming the water pressure will temporarily stop the flow of menstrual blood decreasing the chances any blood is released into the water. If you wish to maximise reduction of risks, staying out of the water during menstruation is one step that can be taken. However, many people safely dive while menstruating, and ISAF have not seen any obvious pattern of increased shark encounters. Sharks are more likely to be attracted to the blood of their prey such as small fishes, sea lions, squids, crustaceans, and other sharks. Food Food is a basic necessity for every living being either on the land or in the water. Like most other animals, sharks are attracted to the smell of food. Many people use chums (the chunks of food) or bloody parts of the fish as bait to attract sharks by throwing the rope tied to their favourite prey. Colour Most sharks are colour blind but they see contrast particularly well so bright and highly contrasting dive gear is more likely to attract attention than darker colours. Jewellery The reflection of light off jewellery and watches can mimic the glint of light off fish scales in the water so you should avoid wearing metal jewellery where possible. Sound Despite having a good sense of smell, sharks tend to use sound to travel in the oceans. Sounds made by splashing of water, e.g. swimmers in trouble or injured fishes attract sharks more than Version 27.0 28 the smell of the prey. 32.3 Dive Site Selection - - Avoid areas with known effluents or sewage and those being used by sport or commercial anglers, especially if there are signs of bait fishes or feeding activity. Diving seabirds are good indicators of these fishes’ presence. Avoid water being used by recreational or commercial anglers. When picking a dive site have a look around and make sure there aren't any seal pups or sea lion colonies around that may increase the risk. When deciding on a dive site, think about your entry and your exit points. Where possible try to descend and ascend close to a wall or along a sloping bottom. Use extra caution when waters are murky, some shark species will have just as much trouble seeing as you. Do not enter the water if sharks are known to be present. Do not wander too far from shore. Being far from shore also isolates you from any emergency assistance. Exercise caution when occupying the area between sandbars or near steep drop offs, these are favourite hangouts for sharks. Avoid being in the water during low light hours (dawn or dusk) and at night when many sharks are most active and feeding. 32.4 Pre Dive Protocols - - - Scan the water and look for any sharks that could already be in the water When traveling by boat, have someone on the back deck as you are traveling to the site, assessing whether any sharks have followed the vessel and then scan the water before putting divers in. Remind divers to remove any shiny jewellery or shiny accessories that may be attached to their equipment. Dive leaders should carry two surface marker buoys that are of different colours. The skipper should be aware that when you put up a certain colour you have had an encounter. This will alert the skipper to ready the tender for a quick pickup. Where practical, all divers should complete a shore dive before completing a dive off a boat on a dive trip. Pre-dive safety checks need to be thorough and complete to ensure there are fewer adjustments to be made at the surface after entering the water. 32.5 Briefing - Version 27.0 When diving in more shark-prone waters students should be briefed on the increased risk of shark encounters and they need to accept the risk if they would like to dive. Nobody should dive if they are extremely anxious or unhappy with or unwilling to follow these protocols. 29 - - Nobody under any circumstances should be pressured to dive. Recall procedure - Skippers should have clear protocols for alerting divers to the presence of a shark nearby and all divers need to know what this is. All divers need to know the hand signal for a shark and a specific signal for a great white or other predatory shark should be communicated before the dive begins. Exit and entry points need to be clearly communicated to all. Brief divers on making a controlled descent straight to the bottom (only to max depth). Emphasise the need to stay as a group and deal with any equalisation issues should they arise. Brief divers on refraining from excess splashing, particularly in a single spot. Sharks can hear the low-frequency sounds from splashing and may investigate to see if there is a fish/prey in distress. 32.6 Dive Protocols - - - When entering the water, where possible, lower yourself into the water to avoid splashing. Follow all safe driving practices as normal. Stay in buddy pairs, ascending slowly from every dive, breathing continuously and never holding your breath. Although extended periods at the surface are not advised, it is still important that all divers complete a weight check, if they are unsure of their weight requirements or wearing any new equipment. This is why a shore dive prior is helpful. Descents should be timely to minimise time spent floating at the surface or in the water column. Divers are advised to dive as a group. There should be a designated leader who will lead the dive and all other dive buddy pairs will be instructed to stay close to the leader. Dive leaders should be carrying two surface marker boys of different colours. Dive leaders can choose to dive with a pole to fend off an approaching shark if they wish Dive Leaders should carry an underwater audible device to get divers attention underwater. Do not congregate at the back of the dive boat as this is a known area of interest for sharks. When waiting to exit, stay in a group, do not splash at the surface and keep alert with eyes in the water until it is your turn to board. 32.7 Encounters Scuba Divers Version 27.0 If you encounter a white shark while scuba diving, stay motionless on the bottom until the shark has satisfied its curiosity and moves on. It appears that the water column is the most dangerous place to be and surfacing 30 - quickly in close proximity to a great white could put you in danger. If you are mid-water and a shark approaches you, the general advice is that if you swim towards the shark it is more likely to turn away. If in a group, stick together. The dive leader should alert the other group if they are able and send up the DSMB of the designated colour. Divers should hold hands with their buddy to maintain contact and calm each other. If a diver looks in distress or panicked, follow normal protocols to calm the diver. On a shore dive, swim back to the land by hugging the seabed and using your compass or natural contour lines for navigation. If on a boat dive, surface as a group, back to back. If there is a wall or a structure, use that for protection If a shark is in the water and a student bolts to the surface the instructor should try and slow the ascent if it does not place the instructor in immediate danger. It is up to the instructor to decide what is the best course of action under the circumstances that are presented to them. Free divers and snorkelers - Free divers and snorkelers are most vulnerable when on the surface or when ascending from a dive. It is better to dive when the water is clear enough to see the bottom but always be vigilant. Remain within the confines of the kelp bed whenever possible. White sharks are unlikely to enter dense kelp growth. 32.8 First Aid Management of Bleeding https://www.resus.org.nz/assets/Uploads/anzcor-guideline-9-1-1-bleeding-april-2021-4.pdf The Australian and New Zealand Committee on Resuscitation (ANZCOR) makes the following recommendations: - 33. Firm pressure on or around the wound is the most effective way to stop most bleeding. [Good Practice Statement] In life-threatening bleeding, control of bleeding takes priority over airway and breathing interventions. [Good Practice Statement] We suggest using an arterial tourniquet for life-threatening limb bleeding that is not controlled by direct wound pressure. SMS Improvements and Changes Version 27.0 31 All staff can have input into all components of the SMS, including the Dive Operations Manual. If staff identify changes that could be made, they should notify the General Manager. Staff will be advised of all changes to the SMS either via the next staff meeting or the staff discussion board. 34. Time In and Time Out Time in and out must be recorded accurately on the trip sheet and the student’s/staff member's log book. Time in is the time the diver physically enters the water and time out is the time the diver exits the water. These need to be recorded accurately on both the trip sheet and divers log book. Surface Interval times for pressure group calculations, use the surface interval time as recorded on individual dive computers. 35. Assessing New Dive Sites The characteristics, risks and prevailing conditions of any new dive site need to be determined before it can be included in the Dive Operations Manual. This analysis will be used to identify site suitability and develop controls to address risks. Assessing new dive sites must include the following: ○ ○ ○ ○ ○ Advice and input on the suitability, parameters and risks. Advice can be sought from Dive Otago staff, other commercial operators, reputable and experienced local users and authorities, groups or bodies. A physical in water trial and assessment is required if there are no neighbouring sites with authorised Site Management Plans and comparable characteristics. A review of the corresponding maritime chart A review of the satellite imagery A review of weather data pertinent to the location Once a Dive Site Assessment Form has been completed, it must be submitted to management for review. If approved, a Site Management Plan will be developed and included in the Dive Operations Manual. Following the initial implementation, a review of hazard management effectiveness will occur. Please note the exceptions to these rules and responsibilities when diving with other New Zealand operators. 36. Transport to Dive Sites Dive Otago generally supplies transport to and from dive sites unless pre-arranged. All vehicles used to transport participants will be registered, insured, hold a current COF and have diesel mileage if applicable. These are maintained via the Workshop Calendar. Other rules include: ○ ○ ○ Version 27.0 Drivers must hold a full and clean New Zealand drivers license. Vehicles will not exceed maximum occupancy. Staff must abide by all road rules and NZTA regulations. 32 ○ ○ 37. All equipment is to be appropriately secured. Staff and students are not to eat within vehicles. Diving with Other NZ Operators Occasionally Dive Otago staff and customers dive with other commercial operators. If Dive Otago staff are not undertaking training or guiding customers, then all participants will be entirely subject to the safety management system of the host operator. If Dive Otago staff are undertaking training or guiding customers, then they are required to work collaboratively with the host operator to ensure the training and guiding is consistent with the local safety management system and vice versa. In this instance, the local operator will provide staff with a local orientation which will include a site description, equipment requirements, entries and exits, risks and hazards, prevailing conditions and emergency procedures. Staff will use this information in conjunction with their own safety expectations and judgement to plan their dives and deliver their training. 38. Freediving and Freedive Training Freediving activities as opposed to snorkeling and skin diving are defined as are those activities that include apnea. Apnea is sustained concentrated breath holding. When conducting any freedive activity staff must adhere to all standards set out in the PADI Freediver Program Instruction Guide. 38.1. Definitions Term Definition Static Apnea Fully at rest, floating face down in the water holding the breath. The objective is apnea duration. Dynamic Apnea Swimming horizontally on a single breath. The objective is distance, it may be conducted with or without fins. Free Immersion Descending and ascending along a line by pulling along a vertical line. The objective is depth. Constant Weight Descending or ascending by swimming vertically along a line wearing the same amount of weight. The objective is depth. This may be conducted with or without fins. Version 27.0 33 The objective is depth by holding your breath, with devices assisting you. Assisted Disciplines Variable weight - Descending assisted by a weight and ascending under your own power. No limits - no restrictions on the method used for descents or ascents. Loss of motor control - series of muscle twitches or convulsions at the surface following apnea. It can happen after returning from depth, or at the surface following apnea. LMC Neutral Buoyancy Open-Water Activities for Floating comfortably at the surface after exhaling. 38.2. Instructor Qualifications and Certifications All Instructors must be qualified PADI Freediving Instructors in current teaching status. Instructors can only deliver the level of courses they are certified to teach. 38.3. Instructor Judgment and Risk Assessment Instructors must adhere to PADI Standards and the Dive Otago SMS at all times. However, as part of their initial and ongoing risk assessments they must also apply good judgement when considering variables throughout the activity. Variables that can change include temperature, visibility, water movement, entries, exits, student abilities and limitations. For example, maximum depth limits or ratios should be reduced if it is in the best interests of safety to the students and the instructors. 38.4. Certified Assistants Certified Assistants must meet the standards laid out in the PADI Freediver Program Instruction Guide. - Option 1: PADI Divemaster with Freediver certification to the course level or Higher, or with qualifying certification from other training organization. Option 2: PADI Master Freediver* with current Emergency First Response Primary Care (CPR) and Secondary Care (First Aid) course completion. 38.5. Instructor Equipment Equipment must be appropriate for freediving, which may differ from the equipment used f