ABS REGULATORY

NEWS
No. 02/2024

INTERNATIONAL CODE OF SAFETY KEY NOTES

FOR DIVING OPERATIONS, 2023 Application

(2023 IMO DIVING CODE) The 2023 IMO Diving Code applies to:

• Ships over 500 GT that have diving

This regulatory news update provides guidance on the new systems installed on or after 01
IMO Diving Code that will enter into force on 01 January January 2024.
2024.
• The Administration may also apply the
code to ships of less than 500 GT, and
other diving platforms to which SOLAS
BACKGROUND does not apply.
In the 1990s, the International Maritime Organization (IMO) adopted • Ships that have diving systems
the Code of Safety for Diving Systems, 1995 (Resolution A.831(19)), installed prior to 01 January 2024 to be
certified as “Diving Units” by the next
and the Guidelines and Specifications for Hyperbaric Evacuation Safety Construction Renewal Survey.
Systems, 1991 (Resolution A.692(17)). The 1995 IMO Diving Code
New Certification Scheme
was developed to provide an international standard for the design,
construction and survey of diving systems to enhance the safety of Diving support vessels or platforms to carry
the following certificates:
divers and support personnel. The 1991 IMO Hyperbaric Evacuation
Guidelines were developed to promote the safety of divers in • DUSC-Part I for the integrated diving
saturation and to achieve a standard of safety for divers which platform and diving system

corresponded to that provided for other seagoing personnel. • DUSC-Part II for the stand-alone
diving system
Since the adoption of the code and guidelines, there have been
numerous technological advancements in the offshore diving industry,
such as the development of dedicated dive support vessels, development of self-propelled hyperbaric lifeboats
(SPHLs) and greater reliance on automation for diving operations. Additionally, the industry experience gained
from the operation of diving systems, as well as the lessons learnt from diving related accidents or incidents,
have led to the publication of updated class society requirements and industry standards / guidance for diving
such as the ASME Safety Standard for Pressure Vessels for Human Occupancy (PVHO-1 and 2), IMCA
Guidance Notes and IOGP Recommended Practices.
Considering these industry developments, the IMO Maritime Safety Committee (MSC) approved a new work
output at the MSC 99 meetings for updating the 1995 Code and 1991 Guidelines. The intent of this effort was to
update the Code and Guidelines to address technological developments in the diving industry and to reflect
current industry requirements and best practices. However, as this work progressed, it became clear that simply
updating the existing code and guidelines would not achieve the goal of enhancing commercial diving safety
since the existing code was limited to the diving system itself and did not address the platform from which the

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diving operations were being conducted. Additionally, the existing code did not address all types of diving
systems. Hence, MSC approved the development of a new code that would holistically address various types of
diving systems, diving platforms and the integrated diving platform – diving system (i.e., the diving unit).

Following a multi-year work effort by the IMO Experts Group on Diving Systems, a new code was developed and
finalized at the IMO SSE 9 meetings in March 2023. Subsequently, the MSC adopted the International Code of
Safety for Diving Operations, 2023 (Resolution MSC.548(107)) on 5 June 2023, with an entry into force date of
01 January 2024. This new code, known in short as the “2023 IMO Diving Code”, follows a goal-based standard
approach and addresses various types of diving systems (e.g., fixed, temporary, surface oriented, mixed-gas
and saturation systems).

The goal of the 2023 IMO Diving Code is to:

1. Provide a minimum international standard for the design, construction, installation and survey of diving
systems installed on diving platforms, such as ships, floating structures, and MODUs, that are engaged
in diving operations;

2. Facilitate safe diving operations from diving platforms and achieve a level of safety equivalent to that
required by SOLAS for ships engaged on international voyages; and

3. Enable the international movement and safe operation of diving units.

APPLICATION
• The 2023 IMO Diving Code is a non-mandatory code. Compliance with the same is voluntary unless
otherwise required by the Flag or Coastal State Administration.

• The 2023 IMO Diving Code applies to ships over 500 GT that have a diving system installed on or after 01
January 2024.

• The Administration may also apply the 2023 IMO Diving Code as far as reasonable and practicable to ships
of less than 500 GT and other diving platforms to which SOLAS does not apply.

• Ships that have a diving system already installed prior to 01 January 2024 should be certified as “Diving
Units” per the 2023 IMO Diving Code by the due date of the next Safety Construction Renewal Survey or
equivalent.

• The 2023 IMO Diving Code does not apply to Pressure Vessels for Human Occupancy (PVHOs) or the
associated equipment that is being used for medical care or treatment of patients (i.e., the 2023 IMO Diving
Code does not apply chambers and equipment being used for medical hyperbaric).

• The existing instruments (1995 IMO Diving Code (Resolution A.831(19)) and the 1991 Hyperbaric
Evacuation Guidelines (Resolution A.692(17)) will co-exist along with the new code (Resolution
MSC.548(107)). Their application is as follows:

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 Diving System Applicable Code / Guidelines

Existing 1995 IMO Diving Code and

1991 IMO Hyperbaric Evacuation Guidelines

New 2023 IMO Diving Code

Diving Unit Applicable Code / Guidelines

Existing 2023 IMO Diving Code

New 2023 IMO Diving Code

KEY CHANGES
Existing text of the 1995 IMO Diving Code (Resolution A.831(19)) and the 1991 IMO Hyperbaric Evacuation
Guidelines (Resolution A.692(17)) has been updated and incorporated in the 2023 IMO Diving Code (Resolution
MSC.548(107)) under the sections titled “Preamble” and “Introduction”, as well as in Chapter 4 (see table below).
The remaining chapters and appendices of the 2023 IMO Diving Code address aspects that were not covered
in the 1995 Code and 1991 Guidelines.

The table below summarizes the key changes between the 2023 IMO Diving Code, the previous 1995 IMO Diving
Code and the 1991 IMO Hyperbaric Evacuation Guidelines.

2023 IMO Diving Code Status Key Changes

Updated the Preamble of the 1995 Code and 1991 Guidelines:

Preamble Updated • Clarified that the intent of the 2023 Code is to provide an
equivalent level of safety as the SOLAS Convention.
• Clarified that the 2023 Code applies to all types of diving
systems (e.g., fixed, temporary, surface-oriented,
saturation, etc.).

Updated Chapter 1 of the 1995 Code to include:

• Goal of the 2023 Code.
Introduction Updated • Provisions regarding application of the 2023 Code.
• Additional definitions.
• Provisions addressing alternative arrangements.
• Updated provisions regarding survey, certification and
control.

• Included provisions for a new two-part certification scheme

that addresses the stand-alone diving system (Diving Unit
Chapter 1: General New Safety Certificate - Part II), as well as the integrated diving
platform and diving system (Diving Unit Safety Certificate
- Part I).

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 2023 IMO Diving Code Status Key Changes

Chapter 2: Diving Unit • Added provisions regarding redundancy, as well as

Principles - Redundancy and New integration of the diving system with the diving platform.
Integration

Chapter 3: Operational • Included provisions addressing stability and position

Capabilities and Limitations of keeping of the diving platform, as well as fire safety and
Diving Platforms for New electrical power.
Conducting Safe Diving
Operations

Updated the 1995 Code and 1991 Guidelines to include:

Chapter 4: Diving System • Provisions for surface-oriented diving systems.
Design, Construction, Updated • Provisions for Hyperbaric Survival Craft based on the IMO
Installation, Testing and Survey LSA code.
• General updates to reflect current industry practice.

• Included provisions for aligning the diving platform’s safety

management system (per IMO ISM Code) with the diving
Chapter 5: Diving Operations New system’s safety management system.
and Safety Management • Added provisions for manning, training, emergency
preparedness and voyage planning.

Appendix 1: Additional New • Added guidance to further clarify the provisions of Chapter
Guidance 3 of the 2023 Code.

Appendix 2: Model Forms New • Included templates for the Diving Unit Safety Certificate
(DUSC) – Parts I and II.

Appendix 3: Guidance on • Added guidance regarding the implementation of the 2023

Implementation of the Code of New Code.
Safety for Diving Operations

New Certification Scheme

The 2023 IMO Diving Code introduces a new, two-part certification scheme that addresses the stand-alone
diving system (i.e., Diving Unit Safety Certificate (DUSC) – Part II), as well as the integrated diving platform and
diving system (i.e., Diving Unit Safety Certificate (DUSC) – Part I).

• The DUSC-Part I intends to confirm that the diving unit (i.e., integrated diving platform and diving system)
is in compliance with the 2023 IMO Diving Code.

• The DUSC-Part II intends to confirm that the stand-alone diving system is in compliance with the 2023
IMO Diving Code. This certificate permits portable diving systems to be mobilized and demobilized on
different platforms where the diving system and platform may be owned, operated and classed by
different entities.

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Certification of Existing and Previously Uncertified Diving Systems

Appendix 3 of the 2023 IMO Diving Code includes guidance on the certification of existing diving systems that
were not previously certified. Such systems may be certified to the 1995 IMO Diving Code and 1991 Hyperbaric
Evacuation Guidelines and subject to verification by the administration or an RO acting on behalf of the
Administration. This certification process should be completed within five years of the 2023 IMO Diving Code
coming into effect.

Oxygen-Enriched Environments

The 2023 IMO Diving Code lowers the threshold concentration for oxygen-enriched environments from 25
percent oxygen (1995 Code) to 22 percent oxygen (2023 Code). This would have the following impact on diving
systems:

• Life-support piping would need to be designed for oxygen service starting at an oxygen concentration of
22 percent, instead of 23.5 percent or 25 percent as required by other industry standards, such as ASME
PVHO, IMCA D031, IMCA D048, CGA G-4.1, and ISO 10156. This would entail the use of specialized
valves, fittings and other piping components that are designed for oxygen service. Additionally,
specialized procedures for oxygen cleaning and handling would need to be followed.

• Non-metallic materials within PVHOs (e.g., paints, lubricants, adhesives and furniture coverings) would
need to be suitable for oxygen-enriched service starting at an oxygen concentration of 22 percent instead
of 23.5 percent or 25 percent as required by other industry standards.

Hyperbaric Toilets

The 2023 IMO Diving Code lowers the occupancy time threshold for the installation of fixed hyperbaric toilets in
diving chambers from 12 hours (1995 Code) to 8 hours (2023 Code). Consequently, hyperbaric toilets would
need to be installed in diving chambers occupied for 8 hours or more, irrespective of whether the diving system
is saturation or non-saturation.

ACTIONS FOR COMPLIANCE

Where compliance with the 2023 IMO Diving Code is required by the administration, the following actions are
recommended:
1. For vessels or other platforms that have, or intend to install, diving systems, it is recommended that
vessel owners / operators develop a plan to comply with the 2023 IMO Diving Code and carry DUSC-
Part I and DUSC-Part II certificates on board. In this regard, ABS can assist with the compliance
verification process, including the design review and surveys, and issuance of the DUSC-Part I and Part
II certificates where authorized by the Administration.

2. For diving systems that are in the process of being designed and constructed, it is recommended that
the diving system designers / builders develop a plan to comply with the 2023 IMO Diving Code and
obtain the DUSC-Part II certificate. Note that paragraph 4.3 of the 2023 IMO Diving Code requires diving
system components to be designed, constructed, installed and tested in accordance with international or
national standards or proprietary specifications. In this regard, diving components that are designed,
constructed, installed and tested to the requirements of the ABS Rules for Building and Classing
Underwater Vehicles, Systems and Hyperbaric Facilities would be in compliance with the above
referenced requirement of the 2023 IMO Diving Code. ABS can assist with the compliance verification

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 process, including the design review and surveys, and the issuance of the DUSC-Part II certificate, where
authorized by the Administration.

3. For existing diving systems that were not previously certified, the guidance under Appendix 3 of the 2023
IMO Diving Code recommends their certification within five years of the 2023 Code coming into effect.
Such systems may be certified to the 1995 IMO Diving Code and 1991 Hyperbaric Evacuation Guidelines.
In this regard, ABS can assist with the compliance verification process for existing diving systems,
including the design review and surveys, and issuance of the DUSC-Part II certificate, where authorized
by the Administration.

REFERENCES
Document Title
Resolution MSC.548(107) International Code of Safety for Diving Operations, 2023

ABS Publication No.7 ABS Rules for Building and Classing Underwater Vehicles, Systems and Hyperbaric Facilities

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