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1.1 Introduction

Macquarie University conducts occupational snorkelling as part of its research and teaching activities. Macquarie University acknowledges the special work health and safety obligations associated with snorkelling and recognises its responsibilities under the NSW Work Health and Safety Regulation 2017. The purpose of this operations manual is to promote safe snorkelling practices. In the absence of specific Australian or New South Wales regulations, standards, or codes of practice, we have based this operations manual on the Queensland Code of Practice (Recreational Diving, Recreational Technical Diving and Snorkelling Code of Practice 2011) and the practices in place at similar Australian Universities. Macquarie University recognises its responsibility as a PCBU (Person Conducting a Business or Undertaking) under the WHS Act (2011) and Regulation (20112017).

The goal of this document is not to replace thoughtful trip planning, but to provide guidance to Macquarie University staff and students in planning their snorkelling operations and to help with the interpretation of the relevant legislation and to outline University specific procedures. This manual provides a basis from which operation specific risk assessments and plans should be derived. Where this manual does not state specific procedures, it is expected that the University Diving and Boating Safety Committee (DBSC), University Dive Officer (UDO), University Boating Manager (BM), Marine Fieldwork Manager (MFM), or other relevant fieldwork supervisor be consulted for advice and clarification.

Macquarie University is strongly committed to providing its staff, students, volunteers and visiting personnel a safe workplace as well an effective system for the management of all foreseeable risks associated with snorkelling. This document outlines the minimum requirements for snorkelling and free diving operations undertaken by all personnel involved in Macquarie University snorkelling and free diving operations ‐ notwithstanding any additional requirement that may be implied by other University procedures, policies and guidelines or relevant Australian standards and legislation.

1.2 Scope

This document is the Macquarie University Snorkelling Operations Manual. It is intended to provide information and guidance for all University employees, students, volunteers and visiting personnel involved in snorkelling operations conducted through Macquarie University. It provides the context within which specific snorkelling operations shall be evaluating and approved by the UDO or delegate. Variations to agreed procedures may only be permitted by the UDO or delegate in writing.

1.3 Obligations and legal responsibilities

The following points are designed to provide guidelines to snorkellers and snorkel teams while operating in the field.

    1. Under 'Obligations', each person has a responsibility for their own health and safety, as well as for the health and safety of other personnel working within the same environment. Reporting unsafe practices or equipment is the responsibility of every team member as part of their duty of care;
    2. Snorkelling can be a hazardous activity; however education, training and team cooperation will reduce the risks. This manual is to be used as an operations manual as well as a risk management document. If all procedures are followed, risks to health and safety will be significantly reduced;
    3. Individuals or groups participating in snorkelling operations under the auspices of Macquarie University must operate within their approved fieldwork notification, and must comply with appropriate regulations, standards and legislation;
    4. It should be noted that individuals or groups who fail to follow safe snorkelling practices as approved (in writing) by UDO or their delegate, may be found legally responsible and liable for their actions and/or inactions, as well as face internal disciplinary procedures;
    5. Snorkelling Coordinators are responsible for the safety of the entire dive team during the period in which that snorkelling team is under their control, however risk assessment and management is the responsibility of all team members. In the event that weather conditions, environmental factors, equipment or personnel are considered by any member of the team to create or contribute to an unsafe working situation, then the snorkelling operation must not continue until the situation is corrected to the satisfaction of the entire team;
    6. All tasks undertaken must be within the experience and training of the personnel concerned, and the capacity of the equipment available.

1.4 Definitions

Certain words in this document are used in instances where instructions or recommendations are given, and are to be interpreted as follows:
Snorkelling – swimming at the surface of the water with the aid of a snorkel – including descending below the water surface without a gas supply beyond that held in the lungs when leaving the surface.
Must/shall – there are no circumstances under which this instruction can be ignored;
Will – other than in exceptional circumstances this recommendation is always to be followed;
Should – a recommendation that is to be followed in normal practice;
Can/may – the snorkeller / diving operation may well benefit from employing this technique.

1.5 Referenced Material

The following publications were referred to in creating this manual:

  • Recreational Diving, Recreational Technical Diving and Snorkelling Code of Practice 2011. Workplace Health and Safety Queensland.
  • Work Health and Safety Regulation 2017 (NSW)
  • AS/NZ 2299.3:2003 Recreational industry diving and snorkelling operations

Macquarie University has an extensive list of Health & Safety Policies, Procedures and Risk Assessment Guidelines to cover foreseeable workplace situations. A full list of these can be found on the Macquarie University website at Various forms and registration documents are mentioned in this manual. To obtain the latest copy, please visit Snorkelling Forms. Hard copies of all current documents and forms are available from the UDO.

1.6 Reporting safety concerns and accidents/incidents

1.6.1 Safety concerns

Everyone involved in snorkelling must take their safety and the safety of other snorkellers seriously. Should anyone have concerns about snorkelling practices or operations that they feel are unsafe or could be made safer they should discuss the matter with the individuals involved and if they feel it is a broader or serious issue they should make their feelings known to the UDO and/or to a member of DBSC.

1.6.2 Incident / accident reporting

All incidents and accidents must be reported via the WHS online reporting system. Additionally, all accidents, incidents and injuries must be reported as soon as possible to the UDO or delegate who approved the operation. If requested by the UDO, all members of the field team should write separate reports as soon as is reasonably practicable and send them to the UDO who will collate the information and present it to DBSC. Depending on the severity of the incident, the UDO in conjunction with Macquarie University Health & Safety Unit (Risk and Assurance) may decide to write an investigation report.

1.7 Disciplinary Procedures

Should the UDO have concerns as to whether an individual has adhered to the approved fieldwork procedures, relevant standards, and/or relevant legislation, the UDO should discuss their concerns with the individual in the first instance. Should the person not be able to provide evidence that the concerns are unfounded, the UDO should advise and discuss the concerns with the individual’s academic or employment supervisor as well as DBSC.

The UDO and DBSC will then investigate the circumstances and refer the matter to the Risk and Assurance with a recommendation as to the appropriateness of suspension or cessation of snorkelling operations by the individual concerned. DBSC and Risk and Assurance will discuss the matter with the individual’s supervisor and the relevant Head of Department prior to any formal action being taken.

The relevant Head of Department / Risk and Assurance will then advise the employee in writing if suspension/cessation of snorkelling is necessary, and of any other remedial action that may be required. If any disciplinary procedures are taken against any person or persons they shall have the right of review by the DBSC. The UDO, UDO delegate or Snorkelling Coordinator have the authority to suspend any snorkelling operation they view as unsafe until a proper investigation can be conducted.