• Section 1 - Purpose and Scope
• Section 2 - Process and Key Controls
• Section 3 - Key Requirements
• Supervision of in-water activities
• Snorkel Supervisor
• Snorkel Guide
• Snorkel Lookout
• Ratio of supervisory personnel
• Competency
• Minimum competency requirements for all snorkellers
• Physical fitness for snorkelling
• At-Risk snorkellers
• Risk Management
• Risk Assessments
• Emergency Response Plan
• First Aid capabilities
• Snorkelling at night
• Drift snorkelling
• Management of risk from non-associated vessel traffic
• Breath-hold snorkel diving following compressed gas diving
• Conditions under which snorkelling should not be undertaken
• Section 4 - Roles, Responsibilities and Accountabilities
• Boating and Diving Officer (BDO)
• Group Manager
• Snorkel Supervisor
• Snorkel Guide
• Snorkel Lookout
• Snorkellers
• Section 5 - Monitoring, Review and Assurance
• Section 6 - Recording and Reporting
• Section 7 - Appendix
• Definitions, Terms, Acronyms

Section 1 - Purpose and Scope

(1) This Procedure outlines The University of Queensland's (UQ’s) requirements for snorkelling activities for groups of 6 or more snorkellers and supports the UQ Health, Safety and Wellness Policy.

(2) The purpose of this Procedure is to provide for, as reasonably practicable, the health, safety and well-being of snorkellers, and compliance with relevant legislative requirements.

(3) This Procedure applies to all persons participating in snorkelling activities at UQ.

(4) The scope of this Procedure includes:

1. documentation required by UQ prior to approval of planned activities
2. supervisory requirements for group snorkelling activities including the minimum number of appropriately qualified persons required for supervising any given snorkel activity
3. competency requirements and responsibilities of the various participants
4. information on the risk management process for snorkelling activities
5. responsibilities of personnel managing and supervising group snorkelling activities
6. documentation required during and after the planned activities.

Section 2 - Process and Key Controls

(5) Supervisors of UQ personnel undertaking snorkelling activities at any location, and senior officers of non-UQ organisations undertaking snorkelling activities at a UQ facility must ensure the following processes be completed before snorkelling activities are permitted to proceed:

1. A Group Manager is appointed to oversee all aspects of the group’s administrative procedures.
2. Where the snorkelling activity will be undertaken from a UQ research station, the Group Manager will be the primary point of contact between any UQ facility and the visiting group.
3. The Group Manager must appoint a Primary Snorkel Supervisor. The Primary Snorkel Supervisor must liaise with the relevant UQ Boating and Diving Officer (BDO) to outline the proposed in-water activities.
4. The Group Manager may also be a Snorkel Supervisor.
5. The Primary Snorkel Supervisor will ensure a Snorkel Plan, including details of risk management and emergency procedures, is submitted to a relevant BDO for review at least four weeks prior to the planned activity’s date. Where this is not feasible, the Group Manager must liaise with the relevant BDO and agree upon a timeframe whereby the BDO can access the snorkeller questionnaires.
6. Prior to the commencement of any snorkelling activity, the Primary Snorkel Supervisor must receive affirmation from a UQ BDO that the Snorkel Plan is approved.

(6) A Snorkel Plan (either Snorkel Plan - Heron Island Research Station or Snorkel Plan - Moreton Bay Research Station) must include:

1. date(s) and location of planned activities,
2. tasks and duties of supervisory personnel,
3. procedures to be used,
4. anticipated time(s) in the water
5. reference to relevant hazard management strategies including Risk Assessments and Emergency Response plans.

(7) In accordance with the UQ Work Off-Campus and Fieldwork Procedure, where the snorkelling group is a UQ group, the Group Manager will ensure a completed Work Off-Campus (WOC) plan is submitted. The approved Snorkel Plan must be attached to the WOC plan.

(8) The Primary Snorkel Supervisor will ensure:

1. duties are assigned to personnel responsible for supervising snorkelling activities who are competent to undertake the role assigned in accordance with the ‘Competency’ provisions of this Procedure
2. the competency of all snorkelling personnel has been assessed in accordance with the ‘Competency’ provisions of this Procedure
3. the following controls have been considered in the planning and preparation of snorkelling activities:
   1. screening of all persons for adequate fitness and medical condition
   2. verification of competency levels of persons undertaking the activity
   3. ensuring minimum supervision levels for the proposed activity
   4. assessment of feasibility of planned work tasks.
   5. access to first aid personnel and equipment, including oxygen resuscitation equipment.
   6. a means of verification that all snorkellers have returned at the conclusion of the activity is implemented
   7. development of effective emergency procedures for the activity.
4. records relating to the snorkelling activities are complete, accurate and submitted to the relevant BDO as soon as practicable after the snorkelling activity has concluded.

(9) The UQ BDO will maintain snorkelling records in accordance with the Records Management Procedure.

Section 3 - Key Requirements

Supervision of in-water activities

(10) All snorkelling activities must involve the following personnel, who undertake the processes detailed in this section:

1. Snorkel Supervisor(s)
2. Snorkel Guide(s)
3. Snorkel Lookout(s).

Snorkel Supervisor

(11) A Primary Snorkel Supervisor is a person appointed per the relevant Snorkel Plan and must have appropriate experience for the activity and area supervised. It is advisable that an alternate Snorkel Supervisor is also named on the Snorkel Plan. Snorkel Supervisors are responsible for all aspects of snorkelling safety whilst on-site.

(12) The Snorkel Supervisor(s) must be present during snorkelling operations.

(13) The Snorkel Supervisor(s) must:

1. Meet the following requirements:
   1. Hold a current qualification in the delivery of oxygen for first aid treatment
   2. Meet the competency requirements of a Snorkel Guide,
   3. Have appropriate experience relevant to the specific activity and location.
2. Be familiar with the contents of the approved Snorkel Plan, Emergency Response Plan and risk assessment
3. Be familiar with the characteristics of the proposed snorkel location and be able to:
   1. Assess weather conditions and obtain accurate information on tides, currents, depths and other expected water conditions prior to undertaking the activity.
   2. Recognise hazards and risks associated with the specific activity and location.
4. Determine the equipment necessary for the safe conduct of the planned activity.
5. Have overall responsibility for managing the snorkelling operation while it is underway and be able to:
   1. Hold the authority to suspend or cancel any snorkelling operation if necessary.
   2. Recognise changes to risks because of snorkeller abilities and behaviour and/or environmental conditions.
   3. Effectively initiate an emergency response.
   4. Provide clear and effective instruction to snorkellers and other personnel to ensure understanding and compliance with safety directions.
   5. Help and advise snorkellers as they enter and exit the water.
6. Maintain a log of all snorkellers who enter the water and when they return from the water.
   1. At the conclusion of EACH snorkelling activity, the Snorkel Supervisor must confirm that a ‘Count of all persons’ is completed as soon as practicable.
   2. At the conclusion of ALL snorkelling activities, the Snorkel Supervisor must confirm that a ‘Count of all persons’ is completed prior to leaving the snorkelling site.

(14) The Snorkel Supervisor may also perform the role of Snorkel Lookout or Snorkel Guide.

Snorkel Guide

(15) Under the direction of a Snorkel Supervisor, Snorkel Guides are responsible for the co-ordination and in-water supervision of an allocated group of snorkellers.

(16) Snorkel Guides must:

1. be identified in the Snorkel Plan.
2. wear highly visible attire.
3. maintain currency in the following certifications;
   1. Provide First Aid,
   2. CPR.
4. hold a qualification that incorporates the recognition of snorkelling hazards and relevant emergency response techniques. Examples include:
   1. Surf LifeSaver Bronze medallion,
   2. Rescue SCUBA Diver,
   3. Dive Instructor,
   4. Dive Master.
5. maintain currency in the following skills:
   1. be able to recognise relevant hazards;
   2. be able to recognise when a snorkeller is in difficulty; and
   3. be able to:
      1. rescue a snorkeller in difficulty and provide first aid; or
      2. direct a person who is immediately available and capable to rescue a snorkeller in difficulty and provide first aid,
6. have a level of fitness so their own health and safety are not compromised if required to carry out or assist in a rescue.

(17) Where a Snorkel Guide is appointed to supervise At-Risk snorkellers, the Snorkel Guide must, through relevant training and experience, have the capacity to manage the specific needs of the at-risk snorkeller(s) they have been assigned. Examples of qualifications that include training in management of at-risk snorkellers include:

1. Dive Instructor,
2. Dive Master, or
3. an equivalent SCUBA Diver supervisor qualification.

(18) A person with relevant industry experience may apply to the UQ Boating and Diving Manager for recognition of their credentials, in lieu of holding one the above qualifications.

(19) All Snorkelling Guides must receive a Snorkel Guide induction relevant to the specific activity and location. The Snorkel Guide induction will be provided by the relevant BDO or a delegate appointed by BDO.

Snorkel Lookout

(20) A Snorkel Lookout is a person appointed to visually monitor the activities of an allocated group of snorkellers. The Snorkel Lookout must be familiar with relevant emergency response procedures and must be named on the Snorkel Plan.

(21) Personnel performing the role of Snorkel Lookout must maintain currency in the following certifications:

1. Provide First Aid,
2. CPR, and
3. Advanced Resuscitation, or a similar certification for the provision of 100% oxygen.

(22) A person who acts as the Snorkel Lookout for the snorkelling activity must:

1. be solely engaged in being the lookout during the activity
2. be positioned outside the water in a location that provides a clear view of the entire snorkelling area
3. be present for the entire duration of the snorkelling activity including during entry and exit from the water.
4. be part of a communication system which is appropriate to the site, and which allows for necessary communication with people snorkelling and any other appropriate personnel:
5. be able to recognise relevant hazards and look for changes which may lead to problems e.g. tides, currents, vessels, marine animals, people skylarking, fatigue,
6. continually monitor the positions of the snorkellers.
7. be able to keep people within the boundaries of the snorkelling site.
8. be aware of which people are ‘At-Risk’ snorkellers.
9. be aware of the risks of silent drowning and monitors snorkelling participants for movement that indicate they are actively snorkelling, be able to recognise when a snorkeller is in difficulty.
10. be able to:
    1. rescue a snorkeller in difficulty and provide first aid or;
    2. direct a person who is immediately available and capable to rescue a snorkeller in difficulty and provide first aid.
11. have a level of fitness so their own health and safety are not compromised if required to carry out or assist in a rescue.
12. take a break from lookout duties periodically and not conduct the duty for extended periods of time.
13. wear identifying clothing or equipment so the lookout can be recognised easily by snorkellers.
14. have access to binoculars and polarised sunglasses so that visibility across and into the water can be improved.

(23) At the discretion of the BDO, a Snorkel Lookout may also act as the master of a vessel providing that those duties do not interfere with the provision of adequate supervision or adversely affect the capacity to respond to an emergency.

Ratio of supervisory personnel

(24) The Snorkel Supervisor will allocate roles to suitably competent personnel at ratios no lower than:

1. one (1) Snorkel Supervisor per 32 snorkellers (Snorkel Supervisors may also act as a Snorkel Guide or a Snorkel Lookout).
2. one (1) in-water Snorkel Guide per 8 snorkellers.
3. one (1) Snorkel Lookout per 16 snorkellers.

(25) The above ratios are for nominal low risk conditions.

(26) Minimum ratios of competent persons to snorkellers must be reduced where snorkellers are mostly inexperienced, at night, or according to the environmental conditions.

Competency

(27) Prior to the commencement of snorkel activities, the Primary Snorkel Supervisor must verify the competency of all persons undertaking snorkelling activities.

(28) The Primary Snorkel Supervisor must provide to the UQ BDO documented evidence of competency for all snorkelling personnel, including the Snorkel Supervisor(s), Snorkel Guide(s) and Snorkel Lookout(s).

Minimum competency requirements for all snorkellers

(29) All personnel undertaking snorkelling activities must be competent in all the following:

1. Swim 50m non-stop, without swimming aids and using any stroke or combination of strokes
2. Fitting and clearing a mask.
3. Fitting and clearing a snorkel.
4. Breathing effectively via a snorkel.
5. Effective fin technique.
6. Swimming 200m effectively using a mask, snorkel and fins.
7. With no fins, the ability to stay on one location (tread water) for at least 2 minutes.
8. Removal of a cramp.

(30) In addition to the Minimum Competency requirements for all Snorkellers, all personnel planning to undertake breath-hold diving snorkelling activities must also be competent in the following:

1. Clearing a snorkel while or after surfacing from a breath-hold dive.
2. Equalising the middle ear and sinus gas spaces.

Physical fitness for snorkelling

(31) The Group Manager must advise all snorkellers that snorkelling can be a strenuous activity and may increase health and safety risks to persons with the following conditions:

1. With a medical condition that may be made worse by physical exertion. (For example, asthma, heart disease and some lung complaints.)
2. With a medical condition that can result in a loss of consciousness. (For example, some forms of epilepsy or diabetes.)
3. With asthma that can be triggered by cold water or saltwater mist.
4. Who are unable to meet the requirements of the Minimum Competency for all Snorkellers section

(32) Each snorkeller must complete the UQ snorkeller questionnaire. The snorkeller questionnaire will assist the Snorkel Supervisors determine the appropriate Snorkel Guide requirements for the group.

(33) The Snorkeller Questionnaires must be provided to the relevant UQ BDO.

(34) Prior to arrival on-site, the Group Manager is required to instruct all persons planning to undertake snorkelling to notify the Group Manager of any concerns they may have with respect to their fitness to undertake the activity. Concerns may include a medical condition that was not included in the snorkeller questionnaire but has arisen since its submission (for example, recent development of cold/flu symptoms, a recent injury, development of nervousness/anxiety of the pending tasks).

(35) The Snorkel Supervisor must determine whether any newly declared concerns warrant the snorkeller to be declared as an at-risk snorkeller, or if any other appropriate management strategy is required.

At-Risk snorkellers

(36) A Snorkeller that has a medical, mental health or physical condition that may impede their ability to undertake snorkelling activities safely will be considered an At-Risk snorkeller.

(37) A snorkeller that is unable to demonstrate competency in accordance with the ‘Minimum competency for all snorkellers’ section will be considered an At-Risk snorkeller.

(38) The Group Manager and Snorkel Supervisor must ensure that all At-Risk snorkellers have:

1. adequate supervision by reducing the guide-to-snorkeller ratio according to the needs of the At-Risk snorkeller(s).
2. any additional snorkelling equipment deemed necessary to ensure their safe participation in the activity (for example, Personal Floatation Devices (vests), Life Rings, Carley Floats, Mermaid lines from the vessel, etc.).
3. direct in-water supervision provided by a Snorkel Guide, who holds current skills in accordance with clause 17.
4. where deemed necessary by the medical questionnaire, submitted a medical clearance to undertake snorkelling activities from an appropriately qualified medical professional.

Risk Management

Risk Assessments

(39) For all snorkelling activities, the Primary Snorkel Supervisor must prepare a risk assessment and submit it with the Snorkel Plan. For UQ Snorkel Groups, the risk assessment must be submitted via UQSafe and reviewed by the BDO prior to receiving final approval.

(40) As part of the risk assessment, the Snorkel Supervisor must ensure that:

1. All snorkelling personnel are appropriately briefed on their allocated roles for the duration of the snorkelling activity.
2. All snorkellers are allocated a buddy
3. All snorkeller buddy-pairs are allocated to a guide.
4. All snorkellers are briefed on standard snorkelling procedures including;
   1. to remain with their allocated buddy
   2. to remain within the specified area
   3. to remain with their allocated guide
   4. standard communication methods including hand signals
   5. where breath-hold snorkel diving is permitted, to only engage in one-up, one-down diving
   6. how to attract the attention of the guide and/or lookout
5. all personnel are consulted regarding the risk assessment prior to activities commencing; and
6. all the controls nominated in the risk assessment have been implemented.

Emergency Response Plan

(41) For all snorkelling activities, the Primary Snorkel Supervisor must prepare an Emergency Response Plan and submit it with the Snorkel Plan.

(42) Emergency Response plans must be in writing and provide procedures for:

1. the recall of all snorkellers,
2. lost or overdue snorkeller/s,
3. recovery of a snorkeller to the vessel or shore or another place where first aid can be effectively provided,
4. the minimum number of persons with first aid training and the minimum level of first aid training of those persons,
5. transfer of an injured snorkeller to:
   1. the emergency services; or
   2. a facility that administers medical aid.

First Aid capabilities

(43) During every snorkelling activity, an adequate number of suitably qualified persons (as determined by a risk assessment), with training in first aid relevant to the proposed activity considering any known hazards, must be present.

(44) The Snorkel Supervisor and every Snorkel Guide must hold current qualifications in First Aid and CPR.

(45) Every designated Snorkel Lookout must hold current qualifications in First Aid, CPR and Oxygen Delivery.

(46) Where a Snorkel Lookout is performing the dual role of Lookout and Vessel Master, the responsibility of Oxygen Delivery must be delegated to another suitably qualified person.

(47) As a minimum, for every 12 in-water snorkellers (Snorkel Guides are to be included in this count), there must be present a person that holds a current qualification in Oxygen Delivery.

(48) Any Snorkel Guide that is supervising at-risk snorkellers must hold a current qualification in Oxygen Delivery.

Snorkelling at night

(49) Prior to the commencement of any night snorkelling activities, the Snorkel Supervisor must discuss the planned activities with the BDO to determine the viability of the proposed activity.

(50) A detailed pre-snorkel brief must be delivered to all participants of the night snorkel activity. The pre-snorkel brief must, in addition to standard snorkelling procedures, include information pertaining to snorkelling procedures that are specific to snorkelling at night, including;

1. How to identify other in-water personnel, including their buddy and their guide
2. night-time methods of communication between:
   1. members of the group itself (e.g. Guides & snorkel buddy/other snorkellers) and
   2. the group and the vessel crew (if any)
   3. the group and the surface watch/lookout

(51) All snorkellers undertaking snorkelling at night must carry a minimum of two light sources. One of these light sources should be a chemical light stick attached to a highly visible part of the snorkeller (e.g. their snorkel) which provides light at all times.

(52) During night snorkelling activities, Snorkel Guides must utilise a highly visible device to distinguish themselves from other snorkellers, and to indicate their location in the water

(53) Snorkel Guide-to-snorkeller ratios should be reduced.

(54) The Primary Snorkel Supervisor must develop an emergency plan that accommodates the additional challenges of managing an emergency scenario at night prior to commencement of night activities.

Drift snorkelling

(55) The Primary Snorkel Supervisor must discuss the planned drift snorkelling activities with the BDO to determine the viability of the proposed activity prior to the commencement of any drift snorkelling activities.

(56) A detailed pre-snorkel brief must be delivered to all participants of the drift snorkel activity. The pre-snorkel brief must, in addition to standard snorkelling procedures, include information pertaining to snorkelling procedures that are specific to drift snorkelling, including;

1. Entry and exit procedures
2. Recall procedures
3. Boundaries to the snorkelling areas

(57) During drift snorkelling activities, Snorkel Guides must carry highly visible floatation devices to indicate their location in the water

(58) Snorkel Guide-to-snorkeller ratios should be reviewed according to the prevailing conditions and reduced if required.

(59) The Primary Snorkel Supervisor must develop an emergency plan that accommodates the additional challenges of managing an emergency scenario in a current prior to commencement of drift snorkelling activities.

Management of risk from non-associated vessel traffic

(60) At all times a snorkeller is in-water, a dive flag in compliance with local regulation must be flown in a way to maximise visibility. In most waters, this is the International Code Of Signals Code A flag.

(61) Where snorkelling is conducted from a vessel at night, the vessel must display restricted in ability to manoeuvre lights in accordance with Rule 27 of the International Regulations for Preventing Collisions at Sea 1972 (COLREGs).

Breath-hold snorkel diving following compressed gas diving

(62) Breath-hold snorkel diving must not be undertaken following compressed gas diving until the diver has off-gassed the residual inert gas. Using DCIEM tables, the diver should have a repetitive factor of 1.0 before undertaking any breath-hold Snorkel dive.

Conditions under which snorkelling should not be undertaken

(63) Snorkel diving must not be conducted where:

1. the working depth exceeds 3m,
2. the work requires moderate or prolonged exertion whilst underwater,
3. moderate or higher residual risk of entanglement exists,
4. emergency response procedures are not viable
5. low visibility exists (<3m).

(64) At the discretion of the BDO, snorkelling activities in areas of low visibility may be permitted if the planned tasks are low risk and can be conducted safely.

Section 4 - Roles, Responsibilities and Accountabilities

(65) All persons managing and undertaking snorkelling activities have duties relating to workers under Queensland Work Health and Safety legislation to take reasonable care for their own health and safety, and for the health and safety of other persons. The responsibilities below list the activities done to ensure reasonable care is taken and complement the requirements in Section 3.

(66) A flowchart of reporting lines is included in the Appendix.

Boating and Diving Officer (BDO)

(67) The Boating and Diving Officer is responsible for:

1. providing advice for compliance and safety for snorkelling operations,
2. assisting Snorkel Supervisors to complete Snorkel Plans, Emergency Response Plans and Risk Assessments,
3. act as the UQ point of contact with external organisations planning activities to be undertaken at a UQ facility,
4. provision of advice on the scheduling of snorkelling activities to be undertaken at a UQ facility,
5. verifying the required records for snorkelling operations are complete,
6. act as the UQ point of contact with relevant regulators, including the report of notifiable incidents,
7. undertake timely audit activities and where appropriate undertake incident investigations.

Group Manager

(68) The Group Manager is responsible for the management of all personnel that are part of their group and will ensure all activities undertaken by their personnel comply with this Procedure.

(69) For Groups visiting a UQ Research Station, the Group Manager’s responsibilities remain in effect at all-hours during their booking with the research station.

Snorkel Supervisor

(70) Snorkel Supervisors are responsible for all aspects of snorkelling safety.

(71) Snorkel Supervisors are responsible for ensuring compliance with the processes detailed in the Snorkel Supervisors section of the Key Controls of this Procedure.

Snorkel Guide

(72) Under the direction of the Snorkel Supervisor, Snorkel Guides are responsible for the coordination and in-water supervision of an allocated group of snorkellers.

(73) Snorkel Guides are responsible for ensuring compliance with the processes detailed in the Snorkel Guides section of the Key Controls of this Procedure.

Snorkel Lookout

(74) Snorkel Lookouts are responsible for:

1. Being solely engaged as the lookout whenever people are in the water unless engaged in an emergency response.
2. Providing appropriate levels of supervision to participants who were assessed by the Snorkelling Supervisor as being an At-Risk snorkeller.

Snorkellers

(75) Snorkellers must:

1. Submit a completed UQ Snorkeller questionnaire,
2. participate in snorkelling induction and training programs, as directed by the Group Manager or Snorkel Supervisor,
3. confirm they are fit to snorkel prior to each activity,
4. limit snorkelling to the approved, specified activities detailed in the Snorkel Plan,
5. comply with control measures indicated in the risk assessment and in this Procedure,
6. consult with the Snorkel Supervisor if the nature of the work changes and new risks are identified or a Snorkel Plan proves inappropriate,
7. report any injury, illness or near-miss event to the Snorkel Supervisor,
8. comply with legislative requirements and the University's policies and procedures.

Section 5 - Monitoring, Review and Assurance

(76) Where a snorkel plan is in development, the relevant BDO should be invited to conduct a peer review of the snorkel plan and associated risk assessments prior to their final approval.

(77) At suitable intervals, the Boating and Diving manager will review compliance practices, health and safety management performance, and the ongoing effectiveness of the described controls associated with snorkelling activities undertaken by UQ personnel, or at a UQ facility by non-UQ personnel.

Section 6 - Recording and Reporting

(78) The records created and collected as part of snorkelling activities (Snorkel Plans, Emergency Response Plans, Risk Assessments, snorkeller questionnaires, records of persons entering and returning from the water, etc.) are kept in accordance with the Record Management Procedure.

(79) If an incident occurs, relevant Snorkel Plans, snorkeller questionnaire forms and snorkel records must be attached to the incident report.

Section 7 - Appendix

Definitions, Terms, Acronyms