Richard Sanders

DSB 

BRITISH DIVING SAFETY GROUP 
Working together to  make recreational scuba diving safer 

Regulation 28  report - H.M.  Senior Coroner for Gloucestershire - BDSG  response 

This document is  prepared  by the British  Diving Safety Group ("BDSG" through  its 
members) in  response to  a Regulation 28 report issued by HM Senior Coroner for 
Gloucestershire,  Ms Katy Skerrett, dated  5 January 2022. 

Members include: 

Training Agencies: 

Other Diving Organisations: 

•  BSAC (British Sub-Aqua Club) 
• 

IANTD (International Association 
of Nitrox and Technical Divers) 
•  PADI  (Professional Association of 

Diving Instructors) 

•  PSAI  (Professional Scuba 
Association International) 
•  SAA (.Sub Aqua Association) 
•  ScotSAC (Scottish Sub-Aqua 

Club) 

•  551  (Scuba Schools International) 
•  TOI/SDI  (Technical Diving 
International/Scuba Diving 
International) 

•  BDSG  (British Diving Safety 

Group) 

•  DDRC  (Diving Diseases Research 

Centre) 

•  DOST (Defence Diving Standards 

• 

Team) 
IDEST (Inspectorate for Diving 
Equipment Servicing &  Testing) 
•  MCA (Maritime and Coastguard 

Agency) 

•  RNLI  (Royal National Lifeboat 

Institution) 

•  SITA (Scuba Industries Trade 

Association) 

•  UKDMC (UK Diving Medical 

Committee ) 

What is the  BDSG?: 
The BDSG was formed  in  2002 to promote and  improve safety for amateur sub-aqua 
divers in the UK and when diving abroad.  The  BDSG is made up of representatives 
from organisations involved  in  training,  regulatory,  governance, diving medicine and 
support of amateur sub-aqua diving. 

Immersing yourself in  a body of water is a hazardous activity,  however,  risks can  be 
mitigated to  reasonable and  acceptable levels with  proper training, well  maintained 
equipment and an  appropriate level of mental and  physical fitness for the activity 
being  undertaken. 

In  spite of a great deal of work undertaken by BDSG and others to  promote an 
understanding of the symptoms of Immersion Pulmonary Oedema (IPO) and  how it 
tends to manifests itself in  diving incidents, the overall impression of the BDSG 
members is that there exists a significant disparity between  recreational divers' 
awareness of DCI  (Decompression Illness) and  their awareness of IPO. 

 Regulation 28  report 
H.M.  Senior Coroner for Gloucestershire - BDSG response 

IPO: 

UKDMC - What is Immersion Pulmonary Oedema (JPO) 

IPO can occur whenever a person  is  immersed  in  a body of water.  Some studies 
show that even very fit individuals such as tri-athletes,  can  suffer with  IPO during the 
swim phase of their competitions.  US  Navy Seals have been found to  suffer with  IPO 
when they carry out long strenuous surface swims and  in their cases,  they often 
suffer the effect only in  one lung  because they swim "side-stroke",  and the centroid 
of one lung  is  lower in the water than the other. 

When did the BDSG begin discussing the risks of IPO?: 
The BDSG and  its members first discussed IPO on  10th  November 2016.  At that 
meeting, the  BSAC officer responsible for preparing the National Diving  Incident 
Report presented the report which  raised  concerns based on the research 
undertaken by Dr 
inquest in which the Regulation 28 report arises), that IPO may have been a 
significant factor in  diving fatalities.  We agreed  at that time that further investigation 
and  monitoring was necessary. 

 (who we understand gave evidence at the 

Pre-testing for IPO: 
There is  no screening test that can definitively determine whether an  individual will 
suffer from  IPO,  but there are a number of known factors which  increase the 
likelihood of an  individual being subject to  IPO.  Completing either the UHMS 
(Undersea and  Hyperbaric Medical Society) or UKDMC (UK Diving  Medical 
Committee) medical declaration form  prior to  any training/diving taking  place helps in 
identifying the known  risk factors. 

With  respect to diving medicals,  assessments and  the self-declaration tools,  the UK 
diving population, who are members of a club or training organisation are divided 
into two groups,  BSAC/ScotSAC and  SAA,  use the  UKDMC  medical self­
assessment, while everyone else uses the UHMS tool. 

Given that physical  health is an  important factor when diving, the two  medical 
assessment forms have been updated  in the past 2-3 years to  include sections 
specifically to  screen for a person's susceptibility to  IPO. 

Page 2 of 9 

 Regulation  28  report 
H.M. Senior Coroner for Gloucestershire - BDSG  response 

The  Matter of Concern #1: 
"Whether there is sufficient awareness of the risks & affects of Immersion Pulmonary 
Oedema (/PO) by those engaged and/or participating in  the activity of diving?" 

Report #1: 
IPO was first discussed at the BDSG on  10th November 2016.  It was agreed  at that 
meeting, further investigation and  monitoring was necessary. 

Since 2016,  almost every meeting has included further discussions and  updates on 
IPO, with specific action points for members. Those members tasked with action 
points are then required to  report on their progress at the following meeting(s). 

The BDSG members believe that whilst IPO presents a significant risk to  divers, 
fatalities can  be prevented.  However,  it is difficult to build a convincing case to  show 
the dangers of IPO and  get people to  acknowledge and  take the risk seriously, 
without evidence to  properly quantify the risk and the sheer scale of the issue. 

Furthermore, the BDSG members believe IPO has been the cause of death, or the 
provocative factor (the trigger that leads to  death),  in  a number of diving fatalities,  but 
may have been misdiagnosed as drowning or barotrauma.  Dr 
shares this view. 

 certainly 

BDSG's concern 
The BDSG  is concerned that the number of IPO cases has been greatly understated. 
A review of historic incidents is  being carried out and the "IPO implicated" number 
shown below are cases where there is a clear indication of IPO involvement.  That 
review is continuing,  so the  number where  IPO was implicated  is likely to  increase. 

From the  National Diving Incident Reports compiled since 1964:-
Total incidents: ............. .... .. ... .. ... ..... ...... ..... ...... .. ..... ....... ... .... ... ..... ........................ 8725 
Confirmed  IPO (not only the fatal case): ................................................. ...... .... ..... ... 30 
IPO implicated (undiagnosed,  but show the  key features of IPO): .. .. ............ .. ....... . 183 

In order to  properly quantify the risk of IPO,  it is  imperative that the Police,  who often 
take primacy of diving investigations,  properly preserve and  collate the necessary 
evidence to help Pathologists and  Coroners make more accurate diagnoses and 
conclusions. Whilst the HSE (as they have a specialist and dedicated diving team) 
know how to preserve evidence properly in diving cases e.g.  diving equipment, the 
Police do not have the requisite knowledge to do this and the BDSG  members fear 
that vital  evidence is often not gathered or overlooked. 

More accurate statistics will  help build a convincing case that IPO is a significant and 
real  danger- which  in turn  should  make people take IPO much more seriously. 

Page 3 of 9 

 Regulation  28  report 
H.M.  Senior Coroner for Gloucestershire - BDSG  response 

BDSG - Preservation of Evidence: 
The BDSG has created,  and  is continuing to compile a pack for use at an  incident to 
help preserve evidence: 

BDSG Serious Accident Guide for Divers v1. 0 
BDSG - General handling equipment post-incident 
General - Rebreather post-incident investigation guidelines 
Ambient Pressure (AP)  - post-incident inspection guidelines 
RESA  - Hollis Explorer SR Lockdown 
RESA  - Hollis Prism2 - post-incident Jockdown 
RESA  - KISS - post-incident procedure 
RESA  - rEvo - post-incident investigation guidelines  V1 . 1 
RESA  - Shearwater - post-incident guidelines 

The pack uses instructions drafted  by the equipment manufacturer to describe how 
to  shut down specific diving equipment safely and  what information to  collect and 
preserve. 

Safely shutting down complex closed  circuit rebreather systems and  interrogating the 
electronic monitoring devices is  beyond the scope of a normal Police Officer.  The 
pack also describes the types of evidence from  witnesses that would  be  relevant to a 
Pathologist and  Coroner in their determinations. 

E.g. 

" ... incident began at depth and the casualty gave an out of gas signal ... ", 
" ... the casualty rejected their primary and alternate air supplies ... ". 
" ... casualty made a rapid  ascent to the surface after an out of gas signal..", 
" ... we found  N bar of gas in the system ... ", 
" ... checks showed gas was available and  no equipment faults ... " etc. 

BDSG "lookback test": 
We've used this report as an opportunity to audit and  review the work undertaken by 
BDSG members to  promote the risks of IPO.  The members have made an 
outstanding effort to  raise awareness of the  risks of IPO and those members who 
operate internationally,  have made it clear,  how far ahead the UK is with  reference to 
the  rest of the world  in  raising  awareness of the risks.  This is something BDSG 
members are extremely proud  of,  although it acknowledges there is more work to be 
done. 

Actions taken to  increase the awareness of IPO: 
There are too many individual  items to  list here so the individual responses from 
members can  be made available,  but in  more general terms activities include but are 
not limited to: 

• 

In  2017 at the National Diving Conference,  Dr 
of several presentations to  raise awareness among the most influential 
members of the diving community. 

 made the first 

•  Every year,  the Annual National  Diving  Incident Report mentions IPO 

specifically and  its possible involvement in  diving incidents and fatalities. 
•  Multiple articles appear in  diving magazines and  periodicals e.g.  Diver,  Scuba 

and  X-Ray magazines. 

•  Frequent references to  IPO on  social  media and  websites. 
•  Engagement with the National Water Safety Forum (NWSF) to  raise 

awareness of IPO as it is  not exclusively a sub-aqua issue. 

Page 4 of9 

 Regulation  28  report 
H.M.  Senior Coroner for Gloucestershire - BDSG  response 

•  Guidance materials produced by the BDSG members targeting divers and 

• 

instructors. 
IPO has been  raised  in  safety bulletins issued by the training agencies, trade 
bodies and other interested parties. 

•  All training agencies have either amended or appended  sections of their 
training  materials to focus on  both the causes and  presentation of the 
condition, focussing on the 'gas hungry at depth' to differentiate IPO from 
other forms of ascent related  conditions. 

•  Webinars and  online seminars either specifically on  IPO or including  IPO. 

Most of these are still available online for further access. 

•  Most training agencies have either produced their own or refer to the BDSG 

• 

materials available online. 
"Return to diving - safely" material has been created  and  shared  by the 
training agencies and the BDSG which  includes an  abundance of refresher 
material and  references to  IPO as a risk. 

•  The medical questionnaires have both been  updated to included  specific 

• 

reference to  IPO. 
IPO is discussed at all  levels of training.  More emphasis is made where dives 
are deeper or using either closed circuit equipment or mixed gases. 

Page 5 of 9 

 Regulation  28  report 
H.M. Senior Coroner for Gloucestershire - BDSG  response 

The Matter of Concern #2: 
"Whether sufficient consideration has been given to  the requirement for a  'fitness to 
dive' medical certificate as a prerequisite to participation in  diving activities?" 

Report #2: 
In  an  "at work" environment there are regulations which govern the type and 
frequency for medical examinations.  This response  refers to amateur diving where 
other arrangements are in  place. 

Current arrangements: 
All the significant training agencies and  the sports' governing body,  use one of two 
self-guided questionnaires to  screen for medical conditions which require referral to 
a Diving  Medical Referee for consultation and  advice e.g.  epileptics requiring 
medication or diabetics with  recent hypoglycaemia are advised  not to dive because 
of the risk of unexpected  loss of consciousness which could  be fatal  underwater. 

The UKDMC explain the reasons why there was a change from  periodic diving 
medical examinations to  a self-declaration  screening tool and the study which was 
carried  out which  recommended the change can  be found  here:  UKDMC Medical 
self-declaration system explanation 

UKDMC questionnaire: 
UKDMC Recreational diver medical declaration  form 

BSAC/ScotSAC and SAA use the UKDMC screening tool.  IPO is specifically covered 
at question  15. 

UHMS questionnaire: 
UHMS Recreational diving medical screening system (available in  27 languages). 

Most of the other training organisations,  use the medical screening tools listed on the 
UHMS site.  IPO is covered  in these tools,  particularly in the Diver Medical Participant 
Questionnaire (page 2,  Box A) and  in the Cardiovascular Systems section of the 
Diving Medical Guidance. 

Previous arrangements: 
Prior to the introduction of self-assessment questionnaires between 2000-2002, 
medical examinations were carried out based on these age bands,  <40, 40-50 or 
>50 at 1,  3 or 5 year intervals respectively.  The examinations were carried out by 
GPs using guidance supplied  by the relevant medical committee. 

Why the change from  periodic medicals to screening questionnaires: 
A detailed study,  Medical supervision of sport diving in  Scotland: reassessing the 
need for routine medical examinations, was carried  out on  3,000 ScotSAC members 
and published  in the British Journal for Sports Medicine in  October 2000. 

The study's conclusion: 
"Diving is  a safe sport requiring  medical supervision,  but routine clinical examination 
of all  divers is unlikely to  detect significant abnormalities relevant to their fitness to 
dive. A carefully designed questionnaire will  allow most relevant conditions to  be 
identified and  save unnecessary expense for both divers and doctors." 

Page 6 of 9 

 Regulation  28 report 
H.M. Senior Coroner for Gloucestershire - BDSG  response 

There was  a 3 year follow-up study: 
The follow-up  study was to assess the effect of the new medical system on medical 
referee workload, diver exclusion rates,  and diving  incident frequency. 
Here is the link: 
Three  year follow up of a self certihcation system for the assessment of fitness to 
dive  in  Scotland 

The follow-up studv's conclusion: 
"In  summary,  the introduction of a self-administered questionnaire appears effective 
after three years of follow up,  and there has been a reassuring increase in failure 
rates for divers,  confirming the  safety of the  new screening system.  Divers now have 
the benefit of direct assessment by doctors with diving medicine experience." 

Other benefits of a self-certification questionnaire: 

•  Screening for medical abnormalities and  changes is carried out much more 
frequently than would  be the case with  a periodic medical examination. 

•  The screening tool can  be modified quickly and  easily e.g.  specific questions 
are asked  about IPO and the screening tools were recently changed to check 
for the impact of COVID. 

•  UKDMC list 58  UKDMC Medical Referees, but some only carry out HSE 

diving  medicals and  in  some parts of the UK there are very few Diving Medical 
Examiners ("DME") so  access is further limited and  long distances may be 
involved  e.g.  in Scotland, the only two  DMEs are both  located  in the extreme 
SE of Scotland.  The questionnaire removes the need to  see a DME except 
where an abnormality has been highlighted  by the questionnaire. 

There were concerns: 
The questionnaire is usually completed  in  isolation by the diver which has raised 
concerns that some divers may conceal information that is relevant to their fitness to 
dive. 

There is guidance within the questionnaires which assists the diver complete the 
form accurately.  A diver who does not answer the questions on the questionnaires 
accurately,  is just as likely to do the same with a DME. 

It is emphasised that the questionnaires are legal declarations, and if a diver is found 
to  have been fraudulent in  its completion, then his/her insurance is not valid. 

Throughout a divers' training, they are encouraged to take responsibility for their own 
safety and their diving partner so  it is hoped they would  recognise the responsibility 
they have and will  answer the questions accurately. 

Information about IPO: 
UK Diver Medical Committee paper on IPO for UK divers is made available  by the 
training agencies to  pass on to their GPs and  Diving  Medical Examiners. 

UKDMC - What is Immersion Pulmonary Oedema (!PO) 

Page 7 of 9 

 Regulation  28  report 
H.M . Senior Coroner for Gloucestershire - BDSG  response 

BDSG recommendations: 

•  The current assessment questionnaires do ask about the diver's history of 

IPO,  but  embedded in a more complex question.  A recommendation might 
be that both  medical assessment questionnaires ask a simple binary question 
relating to  IPO only e.g. 
"Have you  had  IPO (Immersion  Pulmonary Oedema) before. YIN?" 

o  UKDMC question 15: 

"Have you ever had or suffered from:  Decompression illness, 
immersion induced  pulmonary oedema or other diver related problem?" 

o  UHMS current question is on page 2,  Box A: 

"I  have/have had: a problem or an illness that involved my heart such 
as:  angina,  chest pains on exertion,  heart failure,  immersion pulmonary 
edema, heart attack or stroke OR am taking any medication for any 
heart condition." 

•  Coroners and  Pathologists are furnished with  Dr 

 short 

guide to diagnosis of IPO as a factor in  diving fatalities.  More detailed 
explanations and  materials are also available. 

•  Chief Constables pass on guidance to Police Officers about how to preserve 
and gather evidence at a diving incident and which  key pieces of information 
would  assist the Pathologist and  Coroner in their diagnoses and conclusions. 
•  There should  be  a clear reporting  pathway between Coroners and BSAC who 
are the custodians of the National Diving  Incident database.  The objective 
being to  improve the quality of the information regarding the cause and 
contributary factors relating to diving fatalities. 

•  BSAC, the BDSG and/or the Coroner's Service should  keep the National 
Water Safety Forum  informed as IPO can affect all water users and is  not 
limited to  scuba diving. 

•  Within the diving community,  Dr 

 is recognised  as the 

leading authority on  IPO.  He has offered to assist Coroners and  Pathologists 
if they feel they would  benefit from his expertise in  explaining the possible 
links in diving fatalities to  IPO.  There are other diving medical experts on the 
UKDMC and at the  DDRC who have offered their assistance in explaining 
those links too. 

Summary: 
The awareness of IPO in  the UK is significant greater in the UK compared to the rest 
of the world. 

This,  in  part,  is due to considerable efforts made by BDSG  and  its members in 
promoting the risk. 

The BDSG  members would very much welcome the assistance of the Coroner's 
Service and others (as outlined above) to help show the true extent/scale of the 
problem so that divers not only fu lly appreciate the risks associated with  IPO but take 
the risks seriously. 

As outlined above, there is no screening test that can definitively determine whether 
an  individual will  suffer from  IPO,  but there are a number of known factors which 
increase the likelihood of an  individual being  subject to  IPO. Completing either the 

Page 8 of9 

 Regulation 28 report 
H.M . Senior Coroner for Gloucestershire - BDSG  response 

UHMS or UKDMC medical declaration form prior to any training/diving taking place 
helps in  identifying the known risk factors. 

Whilst BDSG  members fully appreciate the Coroner's concerns,  it is not felt that a 
'fitness to  dive'  medical certificate,  as a prerequisite to  participation in  diving 
activities,  is required. 

A detailed study shows the value of the assessment form in the UK and  other studies 
abroad  support the same conclusion of the UHMS questionnaire. 

Page 9 of 9

HM Senior Coroner for Gloucestershire 
Ms Katy Skerrett 
Gloucestershire Coroners Court 
Corinium Avenue 
Bamwood 
Gloucester 
GL4 3DJ 
ENGLAND 

26.02.2022 

Dear Ms Skerrett, 

-=-----~ 

the national 
diving&activity 

centre 

The National Diving & Activity Centre 
Tidenham  Quarry
Tidenham, Chepstow 
Gloucestershire NP16  7LH 

Email  info@ndac.co.uk 

www.ndac.co.uk 

Regulation 28 Report to Prevent Future Deaths - Richard Paul Victor Sanders 
(the "Report") 

I refer to the above referenced  Report which was addressed to (among others) me in 
my capacity as the Managing Director of the National Diving and Activity Centre 
("Diving Centre"). 

In section 7 of the Report, you have requested that I respond to the third  matter of 
concern identified in paragraph 5 of the Report,  namely: 

"Whether more efficient methods and techniques of diver removal from the 
water could be employed at the diving centre." 

Until 23 December 2021, the Diving Centre was operated by N.D.A.C. Limited 
(NDAC) at Dayhouse Quarry (also known as Tidenham Quarry).  However,  in 
connection with the sale of Dayhouse Quarry to a third party, NDAC's rights to 
operate the Diving Centre at the quarry were terminated as from 23 December 2021. 

Under the new ownership,  Deep Training Services Limited ("DTSL"), a company 
incorporated under the laws of England and Wales, with registered number 
13796545, now offers limited access to the quarry for diving activities. 

DTSL have asked that I confirm to you that they are implementing a requirement 
that, when any diving activities are being conducted at Dayhouse Quarry, there must 
be safety boat capability available to assist with the removal of a diver from the 
water. 

If you require further information regarding the current operation of dive training 
activities at Dayhouse Quarry, please contact DTSL directly, at either of the following 
addresses: 

1.  Dayhouse Quarry 

Tidenham 
Chepstow NP16 7LQ 

2.  Central Court 

N.D.A.C. Ltd trading  as  The  National Diving  & Activity Centre 
Registered  in  England  and  Wales.  Company Reg  No:  05439080 VAT  No: 862282910 

 
 
 
 
 25 Southampton Buildings 
London WC2A 1AL 

If you any further questions regarding the operation of the Diving Centre before 23 
December 2021, please do not hesitate to contact me. 

Many thanks 

Director 
NDAC Ltd 

/

  fl~(;lt~

 HM Senior Coroner for Gloucestershire 
Ms Katy Skerrett 
Gloucestershire Coroners Court 
Corinium Avenue 
Barnwood 
Gloucester 
GL4 3DJ 
ENGLAND 

26.02.2022 

Death of Mr Sanders 

Dear Ms Skerrett, 

--=-----◄--------

the national 
diving&activity 

centre 

The National Diving & Activity Centre 
Tidenham  Quarry
Tidenham,  Chepstow 
Gloucestershire NP16 7LH 

Email  info@ndac.co.uk 

www.ndac.co.uk

Many thanks for your prevent further deaths where I was directed to respond to point 
3 in of number 5 of the report. 

The requirement for any party conducting a diving operation at the former quarry at 
NDAC Ltd. 

The site has now been sold to DEEP/DTS) prior to Christmas who wish for the 
following information to be passed onto your office. 

Moving forward any 3rd Party will have a suitably crewed safety boat in attendance 
which would derive from the diving operation risk assessment control measures, to 
provide a quick response to an incident and an efficient means of transferring a 
casualty to a suitable place of safety for treatment, if the incident location was 
appro  riate to do so. 

Many thanks 

Director 
NDAC Ltd 

N.D.A.C. Ltd  trading  as  The  National  Diving  & Activity Centre 
Registered  in  England  and Wales.  Company Reg  No:  05439080 VAT  No:  862282910

Hyperbaric Medicine Unit 
St Richard's  Hospital 
Spitalfield Lane 
Chichester 
West Sussex 
P019 6SE 

Date:  31  January 2022 

Ref: 

Yr Ref: 

Ms K Skerrett 
HM Senior Coroner for Gloucestershire 
Gloucestershire Coroner's Court 
Corinium Avenue 
Barnwood 
Gloucester 
GL4 3DJ 

Dear Ms  Skerrett, 

I am  replying on  behalf of the United Kingdom Diving  Medical Committee (UKDMC) to the 
Matters of Concern raised in  your Report to Prevent Further Deaths dated 5 January 2022. 

Question  1 asks "Whether there is sufficient awareness of the risks & affects of Immersion 
Pulmonary Oedema (/PO) by those engaged and/or participating in  the activity of diving?" 

Although IPO was first described 40 years ago medical  research into the causes,  prevention 
and management is incomplete. As a result, there is incomplete awareness of the risks and 
effects of this condition amongst doctors (including medical referees for diving and 
pathologists), Coroners and divers. 

Members of the UKDMC were the first to report IPO and have worked to promote awareness 
of the latest information about it in all communities engaged and/or participating in the 
activity of diving. 

•  We continue research into IPO and publish our findings in the medical literature to 

educate doctors throughout the world. 

•  We educate our own medical referees via our Google-group and at our conferences. 
There have been lectures on IPO at every diving medicine conference we have held 
in  the last 1 Oyears. 

•  We also provide information directly to diving organisations and articles are published 
on the UKDMC website and in  magazines for divers, including several in the last 
year. 

•  We have provided lectures at conferences for amateur divers and some of those 
were recorded and can be accessed free of charge on the internet (some are on 
YouTube) 

•  We work with the British Diving Safety Group and its sub-committee that has the 

specific purpose of increasing awareness of IPO 

•  We have spoken to the Royal College of Pathologists in order to publish an  article on 

diving related diseases, including I PO,  in the College's magazine to increase 
awareness of IPO amongst pathologists. 

o 

this was prompted by concern that some inquests have reached inappropriate 
findings in  the case of diving deaths because Home Office pathologists and 
Coroners have insufficient knowledge of diving related illness including IPO. 
o  we  sent the Chief Coroner a one page information sheet which explains some 
of the difficulties in determining causes of diving related deaths when there is 

Page  1 of 2 

 
 IPO and post-mortem decompression artefact but were disappointed that it 
was  not distributed to all Coroners. 

We will  continue with these and similar activities in  future. 

Most divers will,  by now,  be aware of the symptoms of IPO and that it can be fatal  but we 
note that awareness of serious risks in  other activities such as smoking or mountain climbing 
does not necessarily prevent individuals from  participating  in them. 

Question 2 asks "Whether sufficient consideration has been given to  the requirement for a 
'fitness to dive' medical certificate as a prerequisite to participation in diving activities?" 

The UKDMC sets the medical requirements for diving for several national amateur diving 
organisations in the UK.  Its members also advise the  Health and Safety Executive on the 
medical  requirements for commercial diving. The committee meets about 4 times per year 
and at every meeting it considers new information that might affect our guidance on fitness 
to dive. 

Unlike flying,  vocational driving or commercial diving, there is no legal requirement to have a 
medical examination for recreational diving.  As a result,  although some organisations insist 
that people diving with them satisfy the UKDMC requirements,  people can dive 
independently without any medical examination. 

The UKDMC fitness assessment depends on  a health declaration which determines whether 
a UKDMC Medical  Referee (who will  have received  updates on IPO and its known  risk 
factors) should be approached for advice or a physical  examination. The health declaration 
asks specifically about IPO and also asks about other aspects of health which can  influence 
risk of IPO.  Routine annual physical examination  has not been  required for many years as  it 
added no benefit to the assessment of divers who did not declare any problems. Some 
divers have not declared problems, sometimes leading to fatality,  but re-introduction of 
routine physical  examination would not capture those who choose to dive independently 
and,  due to lack of a specific test for susceptibility to IPO, would still  miss individuals at risk. 

We do not condone dishonest declarations, not least because such  behaviour endangers 
the diver's buddy. We have considered ways that we can  reduce dishonest declaration but 
even access to General Practitioner records has been  unhelpful in  some cases. This 
situation is not unique to diving.  For instance, applicants make false medical declarations 
about eyesight,  blackouts etc in  order to retain  a driving licence. 

Finally,  more cases of IPO occur during open water swimming than in  divers each year 
because there are more open water swimmers than divers. As a result,  we  believe that a 
requirement for a medical certificate for diving based on the risk of IPO could only be 
reasonably justified if the same was  required for open water swimming. 

Yours sincerely, 

Dr 

Chair, United Kingdom Diving  Medical Committee 

Page 2 of 2