+61 (02) 4441 5255

WHS POLICY Company Risk Assessment and Statement of Responsibility


Diving in all forms is generally a safe and fun activity, Dive Jervis Bay has prepared this paper to demonstrate the actions and activities that are undertaken to minimise risk while diving with us at Jervis Bay.

Within this paper when we use the term ‘Diving’, we are referring to all activities from shore and boat snorkelling, scuba diving to technical and cave diving. We support all these activities and believe with the proper conditions and training, all forms of diving can be carried out safely.

Our insurance is through PADI Global, the Professional Association of Diving Instructors, and we are covered for all aspects of diving and dive related activities to a maximum on a single claim of $20,000,000. All our Instructors and other Dive Professionals are also individually trained and covered through PADI as well, so that you know our Dive Crew has the best skills knowledge and competency to look after you and yours while diving at Jervis Bay.

 WHS Policy Statement

 Dive Jervis Bay is committed to ensuring the safety of all staff, customers and visitors during dive operations, within the shop and while carrying out any activities in the workplace.

This includes ensuring that people are appropriately trained and certified to dive, medically fit to dive, that diving is conducted within appropriate conditions and that the equipment, including air provision, that is controlled by Dive Jervis Bay is regularly tested and maintained.

All persons diving, including staff are to read and sign an appropriate risk waiver and medical assessment as necessary.




What are the risks

Activities and tasks

Reducing the Risks

Site Assessment before diving

  • Current

  • Surface Activity

  • Waves

  • Visibility

  • Marine Life

  • Underwater Infrastructure

Current and swell increase the potential for divers to become fatigued, swept from the dive site / operational area. Waves and Swell can force divers into walls or other impact points.

 Surface activity can lead to the potential for boat or prop strikes

 Limited Visibility can lead to divers becoming lost, or unable to see each other.

Stings, Bites or cuts from marine life around the dive site

Any infrastructure or machinery underwater that can injure or stop a diver from surfacing.

  • Dive Master is to conduct a review of conditions from the surface to ensure the safety of any divers before anyone enters the water.

If there is any indications of risks the Dive Master is to assess if the dive is to proceed.

The Dive Master is to brief the surface support officer of any conditions that may need to be observed during the dive.

 The Dive Master is to write any noted hazards and risks on the Dive Master Sheet before the dive commences.

Pre - Entry

  • Strike from Object

  • Slips trips and falls

  • Gear failures


Potential for weight belts and other heavy items to fall onto people

 Divers will be gearing up and moving around the boat with the potential for slipping or dropping of items such as belts and tanks

Failure to identify potential for gear failures underwater.

  • Dive Masters are to issue weight belts

  • Ensure that clients are gearing up as necessary

  • Provide Dive Briefing on site


Weights to be issued one belt at a time.

Only to be done in calm area.

On arrival provide dive briefing on the site. Stress entry and exit and remind all participants that we are in a Marine Park and to respect the animals, we are in there home.

Remind all divers to conduct buddy checks before moving to the entry area.


  • Slips, Trips and Falls

  • Drowning

Potential for Slips when moving to the water.

Potential for incorrect entry technique causing injury to diver

  • Briefing on entry

  • Check air is turned on

  • Ensure divers are doing correct entry for conditions

  • Ensure that the diver is ok on entry and moves to the mermaid line

  • Record Dive Start time

Master / Skipper to assist divers on entry.

Dive Master to check and brief on Entry Technique

Check that the diver is OK before next diver enters

In Water support

  • Missing Divers

  • Boats

  • Collision / grounding

Divers may drift or swim out of the dive site area.

Potential for boats that may enter the dive area

  • Master / Skipper and or Surface Support Officer are to keep close watch on divers, either from the boat or shore for anything that may present a hazard.

Ensure Dive Flag or lights are up and visable during in water activities.

If off shore DM to carry a dive flag on a line.

Be prepared to recall divers if necessary.

Surfacing and Exit

Boat / Surface Strikes


Slips Trips and Falls

Hits from items or boats on surface

Divers may take fins off too early

Divers may fall off the ladder

Divers may be swept off feet by waves or current if they are shore diving

  • Observe the surface from below and surrounding area before ascent.

    Come up near a flag or surface float 

  • Have them take off fins before exiting water 

  • Have them move go to a safe area before taking off gear

DM to lead divers to a safe surface area

Skipper / Surface Support Officer to warn off boats or surface hazards.

Ensure that divers approach the ladder or shore with their fins on.

Have them hand their fins up or remove them before exiting.

Make sure that other divers or people are not in the way.

After Diving



Slips Trips and Falls


Gear Failure / falling

Decompression Illness / Sickness

Injury from falling, slipping due to swell, water or unstable uneven ground.

Hit or strikes from falling items equipment,

gear failure from changing tanks

  • Record bottom time and maximum depth of the dive 

  • Ensure that all items are properly stowed 

  • Support and assist divers moving from the water to the gear storage areas 

  • Check all gear and change tanks as appropriate

DM to check that all dive times are in normal parameters

Skipper / Surface Support Officer to assist DM as appropriate to store and change gear

Check all tanks after changing

Record Surface Interval to ensure it is within normal dive parameters.


Age Restrictions

The minimum age to undertake a trip on one of our Dive Boats is 8 years old. From 8 years children may take part in snorkelling and swimming activities from our boats. From 10 years old qualified Junior Open Water Divers may dive to 12meters under direct supervision.

All children under 12 must always be supervised by a parent or guardian.


The Likelihood of Injury while Diving

PADI is the worldwide authority on all forms of diving and peak industry body for Diving Instructors. It details within its 2017 post on the safety of diving, that Diving is generally safer than most other forms of outdoor activities.

“The most common medical issues associated with diving are sunburn, seasickness and dehydration (all of which are preventable). There are actually few injuries requiring any sort of medical attention associated with diving. In 2017, there were only 1092 scuba-related emergency room admissions in the US. Compared to other popular sporting activities, average annual ER admissions in the US were:

Diving – 1,092/year

Snowboarding – 4,438/year

Bowling – 19,802/year

Volleyball – 57,303/year

Fishing – 170,216/year

(PADI 2017 report on the safety of Diving Activities)

Overall this demonstrates that the likelihood of injury while diving is lower than many other outdoor activities.

Most of the medical injuries that occur are easily preventable, you can reduce these by having drinking water readily available to keep hydrated, wear sunscreen while in the sun, SPF 50 clothes and hats while on the surface and taking seasick tablets before going on boats to reduce the risk of getting sick.

Taking these simple precautions will significantly increase your enjoyment on the trip and ensure that the majority of injuries are preventable.

The Likelihood of Death

Like any activity or even as in life generally, there is a chance of a fatality occurring, as with the risk of injury the risk of death is significantly lower than with other activities. DAN (Divers Alert Network) keeps statistics worldwide on all diving accidents and provides the industry with an annual report on accidents every year.

DAN indicates that the fatality rate in diving has remained relatively stable over recent years at a rate of 2 per 100,000 participants.

This compares favourably to other forms of outdoor activity:

Swimming                           6 per 100,000 participants

Jogging                                 13 per 100,000 participants

Horseback riding               128 per 100,000 participants

Most of the fatalities within scuba diving are precipitated by a previous health related event or circumstance. The highest risk of fatalities is in people with pre-existing blood pressure or heart conditions and the most common age group for fatalities being the 55+ age group.

This is why a Dive Medical is essential for any person within these categories whether they are thinking of starting diving or have years of experience. It is important to ensure that you understand and dive within your personal limits, and head to the surface if you ever feel unwell.

What is the risk from Marine Life

The risk of attack or harm from any marine life is negligible as long as the Diver behaves responsibly. In fact there are no known incidences of a diver being harmed by Marine Life on a tour with Dive Jervis Bay.

PADI states unequivocally “Never Touch Marine Life”, the vast majority of recorded Marine Injuries throughout the world are the result of inappropriate attempts to touch marine life and the animal attempting to defend itself. It should be noted that fatalities from these injuries are counted in the numbers above.

There are a number of larger animals that are often encountered within and around Jervis Bay and each is dealt with below.


Swimming with seals is an awesome and fun experience, these playful animals have grown up with us and get excited when they see the dive boats, often rushing from the shore to be in the water with us. They are at least as intelligent as dogs and have been known to play specific games which your dive master can tell you about.

To reduce the risk of harm from a seal, we keep the boat away from the colony itself so they do not become stressed, we never swim at the groups on the surface and as with all marine encounters, we allow the animal to dictate the terms of the encounter.

There are no recorded incidents of harm from one of our seals, and there has never been an injury caused by one.


For a full and detailed brief of how the swim with whales encounter is managed, please see the webpage on Swimming with the Whales also you will be fully and specifically briefed on your trip regarding how this activity is managed.

There have been no recorded injuries from a Swim with Whales encounter at Dive Jervis Bay, we manage the risks of this activity by ensuring that there is adequate distance between the drop point and the whales, ensuring that there are no calves (whales under 5m) with the pod that the larger whales may want to protect and that they are not breaching, tail or fin slapping or other activities that could be harmful or show they are agitated.

Once again you will discover that the whales fully dictate the terms of the encounter and if they want to see you they will come to you. If they don’t they will simply swim away and disappear.


There are a number of Pods of dolphins that live in and around the bay, it has been known for them to come over to check out divers on occasions. We do not specifically offer swim with dolphin tours as they tend to move around a lot. On the rare occasions that they they do come over they tend to play, show off and swim around us.

There has never been any recorded incidents of harm, and as these encounters are initiated from the dolphins, it is not suspected that they pose any danger at all.

Are Sharks a Danger

Sharks are probably peoples biggest fear and Shark attacks are probably the greatest overrated threat to divers that there is. From 1989 to 2010 a period of twenty years, there were 2 recorded shark attack fatalities involving divers WORLD WIDE.

In Jervis Bay and surrounds, the only known shark attack occurred in 1997 when a spear fisherman was bitten by a wobbegong shark resulting in a minor injury. There are no recorded fatalities from sharks in the Jervis Bay area at all.

Statistically the ABS report “What Australians Die Of” indicates that the chance of a person dying from a shark attack in Australia is 0.125 in a million. Compare this to other normal activities that we do everyday without even thinking of the risk, such as driving 1.1 in a million, jogging or running 7 in a million, swimming 12 in a million or simply slipping and falling 13 in a million. The actual risk is extremely low, no one really considers sitting at home (1.3 chance in a million of dying from falling off a chair) to avoid these risks, yet people actually don’t Dive out of fear of sharks.

In fact there is more chance of being killed by bees, snakes, horses, tapeworm, cows, dogs or even kangaroos than there is of being attacked by a shark. The biggest killer of humans in the world is actually mosquitoes, closely followed by other humans.

Almost 77 people in the last 10 years in Australia died from horse related activities, compared to 22 from shark attacks. Therefore we at Dive Jervis Bay are big advocates of horse nets, and firmly believe they should be installed at each Pony Club and Race Tracks to protect us. However Governments have continued with a wasteful and statistically ridiculous project to attempt to kill sharks through nets, damaging and killing multiple other harmless marine animals such as whales, dolphins, turtles, rays, and harmless sharks.

Humans are much more of a threat to Sharks, than sharks to humans, with an estimated 70million sharks killed by humans every year for fins, teeth or even just sport.  

To reduce this risk even further, we do not support spear fishing actives, we do not dive in areas where they are occurring, we never feed sharks or attract them with burley, we ensure that all encounters with sharks are properly managed and that sharks are never approached or corralled into areas where they feel confined.

As with all our encounters with marine life it is up to the animal to dictate the terms of the encounter.

Why do Diving Accidents Occur   

Most accidents occur due to overconfidence on the part of the participants or attempting activities that are beyond their level of training. What is commonly referred to as diver error.

People who dive within their level of training, ensure that their gear is maintained and kept in proper working order, practice the skills that they have been taught and follow directions of the Dive Masters who they are diving with are unlikely to have any serious issues.

If you feel unsafe at all you should discuss the issue with the Dive Master. You should never dive if you feel unsafe, and if you are underwater and feel unsafe, you should pull the dive and ascend as per your dive profile requirements.

How Many Incidents Occurred at DJB

Within the last 12 months at Dive Jervis Bay there were 8 recorded WHS incidents that occurred. We had 2557 customers on boat trips and courses with 7,452 customers coming through our store. 3 of the incidents involved workplace injuries for staff, one of which required medical follow up and stiches. All of the other 7 incidents were minor events, none of them resulted in hospitalisation and none required medical follow up through a GP.

Of the incidents involving customers, all were either caused by diver error or panic.

 Training for the Dive Crew

The Dive Crew is made up of all staff and contractors employed or retained by MORCOR Pty Ltd to conduct, organise and support Dive Operations.

All staff have specific responsibilities under the Safety Management System and as a result must be provided with appropriate training. All Dive Crew, receive the following training as part of their role:

  • Safety induction training to the vessel’s risk assessment and management program,
  • The SMS and in particular its emergency plans and SWMS.
  • First aid
  • Customer Service
  • Environmental Practices

The crew training program ensures:

  • The Dive Crew is capable of competently fulfilling the duties and responsibilities of the role.
  • That any extra training necessary to maintain currency of competency or respond to opportunities for improvement is identified and delivered.
  • The owner is responsible for ensuring the delivery of crew induction safety training and ongoing learning and development opportunities.
  • The Safe Working Method Statements (SWMS) of the vessel’s SMS and information in its emergency plans provide a basis for crew training for normal operations and identified emergency situations


Risk Management Statement

I, Morgan Andrews, Director of MORCOR Pty Ltd t/a Dive Jervis Bay, am the Designated Person as per National Standard for Commercial Vessels (NSCV) and the WHS Act and associated regulations. I am also the principle owner and controller of the premises.

I have conducted an assessment of risks associated with the shop and its commercial dive operations as per the requirements of the WHS Act.

The Staff and Crew of Dive Jervis Bay (known collectively as the Dive Crew), have had the opportunity to review and comment on the draft of this document, the Safety Management Systems for the boats, the Safe Work Method Statements and their feedback has been assessed and utilized as appropriate to form the final version.

Dive Jervis Bay’s risk assessment and management process is modelled on requirements of AS/NZS ISO 31000:2009 and a risk register has been established to record identified risks and summarise measures taken to eliminate or effectively control them. The outcome of the assessments are included in the Safe Work Method Statements (SWMS) for the necessary operational tasks.

All current risks (At the time of writing) are recorded in the Boat Safety Management Systems, the store Safety Management System and make up the findings in the Diving Assessment of Risk. These have been individually assessed and controlled as possible and this process has been documented as part of our commitment to safety.

The on-going process for reporting hazards and incidents is included within the staff training processes document and is full accepted as a shared responsibility by all staff. This will form the basis of the on-going review process which will occur in response to any incident or near miss.

A formal review will be undertaken on an annual basis and be carried out in consultation with the Dive Crew as detailed within the Safety Management Systems for Dive Jervis Bay

Morgan Andrews

Director / Manager, Dive Jervis Bay 

Last Reviewed on 1 July 2020

1st Drafted January 2018.