Someone disappears to “go and pull the files together”. What follows is a scramble through a shared drive, a paper logbook in the site office, and a phone call to the supervisor who has the only copy of last month's inspection sheet.
Every fifth or sixth surveillance visit I do for a diving contractor, the same thing happens in the first ten minutes. Someone disappears to “go and pull the files together”. What follows is a scramble through a shared drive, a paper logbook kept in the site office, and at least one phone call to a supervisor who has the only copy of last month's equipment inspection sheet. None of this means the contractor is unsafe. It usually means their compliance evidence lives in six different places and gets assembled once a year, the week before I turn up.
That week-long scramble is the tell. It is not a sign of poor diving practice. It is a sign that “audit-ready” has been treated as an event rather than a condition.
The instinct to tidy up before an audit is completely normal, and I do not blame anyone for it. The problem is what the sprint actually produces. When a team spends a week pulling records together in April, what they are demonstrating is that the records existed somewhere in April. It tells me almost nothing about whether the equipment register was accurate in November, whether a diver's medical had quietly lapsed in January, or whether a planned maintenance task slipped by three weeks and nobody noticed until the audit forced a look.
I have sat across the table from contractors with genuinely excellent operational safety and a shocking evidence trail, purely because the evidence was never captured close to the point of work. A dive happens, the supervisor's notes go in a folder, and three months later nobody can reconstruct who signed off which competency check. The diving was fine. The paper trail was not, and under DWR 1997 the paper trail is not optional decoration. It is how a contractor demonstrates the diving project was actually planned, supervised and conducted the way the regulations expect.
Without reproducing the regulation's own wording, the shape of the duty is straightforward. A diving contractor has to ensure a diving project is properly planned before it starts, that a competent diving supervisor is in charge of each project, that risk assessments are carried out and acted on, and that dive records are kept for a minimum retention period after the project ends. The Approved Codes of Practice that sit alongside the regulations — L103 for offshore work, L104 for inshore and inland — set out what “properly planned” and “competent” look like in more practical detail. Neither the regulations nor the ACoPs specify a particular software system, a particular register format, or a particular way of storing a PDF.
That last point matters because it is the one people get wrong in both directions. Some contractors assume a spreadsheet satisfies the requirement because it technically contains the right fields. Others assume that buying a platform automatically satisfies it because the platform says it is “DWR compliant” on the homepage. Neither is true on its own. What satisfies the requirement is that the planning happened, the supervisor was competent and appointed, the risk assessment was live and specific to the task, and the records exist and can be produced. The format they live in is a means to that end, not the end itself.
The contractors who breeze through a surveillance visit share one habit: their evidence is current on an ordinary Tuesday, not just the week before I arrive. Certification expiries get flagged as they approach, not discovered when someone finally checks. Planned maintenance gets marked complete when it happens, with the next date rolling forward, rather than tracked on a spreadsheet that only gets opened under pressure. Dive logbook entries go in close to the dive, with supervisor, team, depth, bottom time and decompression detail intact, rather than reconstructed from memory afterwards.
None of that requires anything exotic. It requires the evidence-capture step to be small and routine enough that it actually happens every time, rather than large and dreaded enough that it gets deferred until the sprint.
This is the part where I have to be honest rather than persuasive. PICMS Diving Pack's weekly compliance digest lands Monday 08:00 UK and flags certificates that have expired or expire within 30 days, alongside planned maintenance tasks that are overdue or due inside seven days. The dive operations logbook holds the DWR 1997 Regulation 12 two-year retention and captures the per-dive fields the regulations expect.
The Commercial Diving Audit Readiness Report pulls that evidence into a single printable report, structured around the IMCA reference areas — D011, D018, D023 and D040. It is worth being precise about what that is and is not: the report is organised by those IMCA reference areas, not mapped clause-by-clause against ACoP L103/L104 or the DWR 1997 duties. It will save you the week of searching. Satisfying yourself that the evidence answers the regulatory duty is still your judgement to make, and I would rather you heard that from me than discovered it in front of an inspector.
Equipment modifications close a gap I see catch contractors out more than almost anything else: equipment going back into service after a modification with nobody re-checking the certificate. Log a modification as requiring re-certification and PICMS cascades it — the equipment is flagged re-certification pending, the superseded certificate is marked superseded, and a planned maintenance task is raised for the re-examination. The cascade is automatic. Deciding that a modification warrants re-certification is not, and it never will be.
What it will not do is make your supervisor competent, write your risk assessment for you in any meaningful sense, or turn a project that was not actually planned properly into one that was. RAMS drafting runs inside a diving project, drawing on that project's team, equipment and site for context; a supervisor still has to review the draft, correct it against the real conditions on site, and sign it off before it means anything. A tool can make record-keeping habitual instead of dreaded. It cannot make the diving safe. That still comes down to the people running the project, and no software claim should be allowed to suggest otherwise.
If your evidence trail currently depends on someone's memory and a week of goodwill before I arrive, the fix is not necessarily new software. It is making the small, unglamorous habit of capturing evidence at the point it is created a routine rather than an emergency. Whether that habit is supported by a spreadsheet with real discipline behind it, or by a platform that nudges you before things lapse, is a secondary question. The habit is the requirement. The tool is optional.
PICMS Diving Pack emails you every Monday with the certificates that have expired or expire within 30 days, and the planned maintenance that has gone overdue — so nothing waits for the pre-audit scramble to be discovered.