Snorkelling fatalities in Central and North Queensland

Guidance on control measures to prevent similar incidents

The Recreational Diving, Recreational Technical Diving and Snorkelling Code of Practice 2024 (the Code) (PDF, 0.61 MB) provides practical guidance to dive operators on how to comply with their health and safety duties when providing recreational water activities, in particular snorkelling.

The Code outlines control measures which can be used to manage risks related to snorkelling.

Dive operators must undertake risk management at their own workplace to ensure the control measures chosen are suitable for the workplace and the tasks and activities being undertaken.

A dive operator must consult with its workers about risk management and any changes that may affect health and safety. During the consultation, workers must be given a reasonable opportunity to express their views, raise matters and contribute to the decision-making process.

Snorkelling procedures should be documented along with the responsibilities of lookouts, the snorkelling supervisor and other workers with respect to health and safety. It is important that responsibilities are clearly allocated and the snorkelling procedures to be followed are known to all parties.

The SRWA Reg requirement to have a lookout on duty when one or more people are diving or snorkelling, is a primary risk control.

Dive operators need to consider the following to ensure the safety of their customers:

• Ensure the lookout is solely engaged in being the lookout.
• Based on conditions and participants, increase the number of dedicated lookouts and in-water guides.
• Enhance lookout scanning techniques by rotating duties and ensuring lookouts are able to focus on supervision without distractions. Lookouts should:
  • be in close proximity to the activities and preferably in an elevated position.
  • be able to easily differentiate between a snorkeller who is conscious and floating, and a snorkeller unconscious in the water.
  • be able to easily identify who is an at risk snorkeller by using a visual indicator such as a red snorkel or other coloured equipment.
  • observe snorkellers including when they are entering and exiting the water or are on the surface.
  • have access to binoculars and polarised sunglasses so that visibility across and into the water can be improved.
  • continually monitor the positions of the snorkellers, look for hazards or changes which may lead to problems and identify problems so that the operation can be adjusted as required, (for example, tides, currents, marine animals, people skylarking, fatigue).
  • wear a brightly coloured shirt, wet suit or other identifying clothing or equipment so the lookout can be recognised easily by snorkellers.
  • be part of a communication system which is relevant to the site and which allows for necessary communication with people snorkelling and any other appropriate personnel so that effective and efficient transfer of information can occur. A communication system may include, for example, ordinary voice communication, a loud hailer, two-way radios, whistles or signalling.
  • be aware which snorkellers in the group intend to breath hold dive during the activity and provide them with increased supervision given the associated risk.

The dive operator should:

• assess and identify at-risk snorkellers (age, health, swimming ability, ability to understand instruction), and provide them with additional supervision.
• consider requesting at risk snorkellers complete a written medical declaration.
• ensure at-risk snorkellers use a flotation device to reduce physical exertion, snorkel with a buddy or as part of a guided tour, stay close to supervising staff or other support and are advised to signal early if help is required.
• train workers so that they are familiar with emergency plans.
• emergency plans should be developed for emergency situations including first aid, rescue, evacuation, missing persons, and non-agreed headcounts.
• conduct a risk assessment of the environmental conditions, that is confirmed in water by a staff member, and adjust operations accordingly.
• continuously monitor environmental conditions and implement further controls if conditions deteriorate.

Identifying individuals at risk

Before snorkellers enter the water, they should be assessed to determine whether they are at-risk. The assessment is not designed to stop potential snorkellers from participating in snorkelling activities. Identifying which individuals are at-risk and providing them with additional attention is a vital part of ensuring their safety by providing them with appropriate advice, equipment, and supervision. If a person is identified as an at-risk snorkeller, the dive operator should:

• increase supervision
• use specifically coloured equipment or other markings so the at risk snorkeller can be easily supervised and monitored in the water
• encourage them to participate in guided snorkelling activities
• keep them close to lookouts and supervisors
• ensure they snorkel with a buddy
• ensure they use or wear a flotation device.

If the at-risk snorkeller refuses to comply with any reasonable instruction to use control measures for their safety, the tour operator can refuse to allow them to enter the water.

Persons who speak a language other than English

People who speak a language other than English are at greater risk due to the barriers in understanding instructions.

Having a one size fits all communication approach can expose people who speak a language other than English to an unacceptable level of risk.

Information and advice should be given to a person who speaks a language other than English in a manner that the person can understand.

Dive operators should consider –

• using images and videos to enhance communication.
• translating activity specific information.
• providing cultural training to staff.
• providing training to workers to ensure workers are aware that people who speak a language other than English are at greater risk in some circumstances due to cultural differences in swimming abilities, familiarisation with the ocean and water safety knowledge.
• developing systems that check for understanding with consideration of language barriers and cultural differences.
• providing guides or interpreters at the snorkelling sites to help with advice and queries.
• preparing and distributing translated information on snorkel safety. WHSQ has translated advice for divers and snorkellers in 15 languages including both simplified and traditional Chinese, Korean and Vietnamese.

In many cases, a combination of control measures will be required to minimise the risks to health and safety.

The control measures put in place should be reviewed regularly to make sure they work as planned.