IMCA D 077 - Guidance On Prevention and Mitigation of Lost Bell Emergencies - Rev. 0 May 2023

Guidance on Prevention and Mitigation of
Lost Bell Emergencies
IMCA D 077
May 2023
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IMCA D 077
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IMCA D 077 – Version History

Date Reason Revision
May 2023 Initial publication

Guidance on Prevention and Mitigation of Lost Bell Emergencies
IMCA D 077 – May 2023
1 Introduction ...............................................................................................................1
2 Aims...........................................................................................................................2
3 Application.................................................................................................................3
4 The Prevention of Lost Bell Diving Incidents ................................................................4
4.1 Diving Bells and Bell Launch and Recovery Systems – Fitness for Purpose........................ 4
4.2 Primary Hazard ................................................................................................................... 4
4.3 Moonpool and Cursor Hazards ........................................................................................... 5
5 The Mitigation of Lost Bell Diving Incidents ................................................................6
5.1 Emergency Procedures and Preparedness ......................................................................... 6
5.2 Emergency Isolation of Gas Circuits in the Event of a Ruptured Bell Umbilical ............... 10
5.3 Emergency Location of a Lost Diving Bell ......................................................................... 13
5.4 Through-Water Communications ..................................................................................... 14
5.5 Bell Ballast Release Systems and Buoyant Ascent ............................................................ 15
5.6 Lost Bell Survival ............................................................................................................... 17
6 References ............................................................................................................... 24
Appendix 1 – Bell Mounted Acoustic Transponder Specification ...................................... 25
Appendix 2 – Diver Operated Interrogator/Receiver ........................................................ 26
Appendix 3 – Bell Emergency Communication ................................................................. 27
Appendix 4 – Bell Ballast Release Systems ....................................................................... 28
1 Introduction
A closed diving bell is any compression chamber which is capable of being manned and is used or
designed for use under the surface of water in supporting human life at a pressure greater than
atmospheric pressure during normal operation.
A potential risk when using closed diving bells is that the diving bell and its divers cannot be recovered
from depth to the surface, either because the main lift wire, secondary lift wire(s) and main umbilical
are severed, or because the bell is trapped. Such an incident is referred to as a ‘lost bell’ if supplies of
breathing gas or heating from the surface are lost.
It is recognised that a lost bell diving incident is a rare occurrence, but one which is life-threatening for
the divers. Previous lost bell incidents have indeed proved fatal.
There have been no documented lost bell incidents in recent years and very few recorded ‘near
misses’. However, there is no room for complacency as any lost bell diving incident has the potential
to cause multiple fatalities. The most pressing threats to the lives of divers in a lost bell are severe
hypothermia and the risk of carbon dioxide poisoning. It should also be noted that bell diving in warm
areas of the world may introduce problems with hyperthermia, which also need addressing.
All closed diving bells need to be capable of sustaining the lives of trapped divers for at least 24 hours.
This document collates material previously contained in a number of AODC and IMCA documents to
provide updated guidance on the prevention and mitigation of lost bell diving incidents.
This document supersedes the guidance previously contained in:

 AODC 009 – Emergency Isolation of Gas Circuits in The Event of a Ruptured Bell Umbilical;
 AODC 012 – Bell Emergency Location Equipment Trials;
 AODC 019 – Emergency Procedures – Provisions to be Included for Diving Bell Recovery;
 AODC 061 – Bell Ballast Release Systems and Buoyant Ascent in Offshore Diving Operations.
The above documents were withdrawn on publication of this document.
IMCA D 077 © IMCA Trading Ltd 1

2 Aims
The main aims of this document are to describe:

 the importance of emergency preparedness for a lost bell incident;
 means of preventing lost bell diving incidents; and
 means of mitigating the harmful effects of lost diving bell incidents should they occur.
2 © IMCA Trading Ltd IMCA D 077

3 Application
The advice given in this document applies to all closed bell diving operations.
This guidance is intended to apply internationally, but it is recognised that some countries will have
legislation that requires different standards or practices to be followed. Where local or national laws
are more stringent than the advice contained herein, they will always take precedence over this
guidance.

4 The Prevention of Lost Bell Diving Incidents
4.1 Diving Bells and Bell Launch and Recovery Systems – Fitness for Purpose
4.1.1 Diving Bell
Diving bells should be well insulated against the water and ‘cooling bridges’ (i.e., areas
of non-insulated steel and other materials with high temperature conductivity) should
be minimised.
Diving contractors undertaking saturation diving in very hot areas of the world should
ensure that the risk of bell occupants suffering from hyperthermia is estimated and
mitigated if necessary.
4.1.2 Bell Handling and Recovery Systems
The principal method of preventing lost bell incidents is to ensure that bell launch and
recovery systems (LARS), including the wire ropes, are suitably designed and built, and
that they remain fit-for-purpose and safe-to-use in operation.
All of the equipment comprising the bell launch and recovery system should be
included in a company planned maintenance system and serviced in accordance with
the manufacturers’ recommendations.
The guidance contained in the following IMCA documents should be scrupulously

followed.
 IMCA HSSE 022 / IMCA M 194 – Guidance on Wire Rope Integrity Management for
Vessels in The Offshore Industry;
 IMCA D 018 – Code of Practice for The Initial and Periodic Examination, Testing and
Certification of Diving Plant and Equipment; and
 IMCA D 024 – DESIGN For Saturation (Bell) Diving Systems.
4.2 Primary Hazard
The primary hazard to be considered when performing manned diving intervention from a DP
DSV is that in the event of a DP incident involving a loss of position in the ‘blow-on’/ ‘drift-on’
position, the DSV could drift across the mooring catenary and cause a lost diving bell incident.
Underwater obstructions include subsea structures, anchor cables etc. Provision for dealing
with subsea obstructions should be in place for all diving operations, and any such obstructions
that might impinge on the safety of the divers should be mapped in dive control.
During diving operations, it is vitally important to minimise the risk of the diving bell wires and
main umbilical coming into contact with underwater obstructions which may cause them
damage or sever them completely. Failure to do so could result in a lost diving bell incident.
In order to achieve this, it is important to ensure that:

 the bell is positioned a safe distance above subsea installations and other underwater
obstructions;
 if diving within an anchor pattern or in a location where safe vertical distance from subsea
installations cannot be achieved, the vessel should preferably be a DP-3 vessel operating
with open busbar.

When undertaking diving work within anchor patterns, or in close proximity to subsea
installations, the guidance on this subject set out in IMCA D 010 – Diving Operations from
Vessels Operating in Dynamically Positioned Mode should be followed.
4.3 Moonpool and Cursor Hazards
Dive planning and risk assessments should consider the risk of damage to bell wires, or more
likely bell umbilicals, by contact with the cursor or edge of the moonpool. This can occur during
bell transits or while the bell is deployed. Cursor design and build should recognise the
potential for sharp angles of steel work to chaff/abrade/cut bell umbilicals while subsea
currents displace the umbilical in the cursor or while the vessel moves. Midwater currents
may be of greater velocity or differing directions to that experienced by the divers at the
seabed, so while the current is workable on the bottom, higher up the water column the bell
umbilical could be moving in such a way as to damage it against the vessel/cursor.

5 The Mitigation of Lost Bell Diving Incidents
Despite all efforts at prevention, a lost diving bell incident may still occur. Observance of the guidance
on equipment design and emergency contingency planning contained within this document should
lessen the harmful consequences of such an event.
5.1 Emergency Procedures and Preparedness
All saturation diving projects must have documented emergency contingency plans, which
include lost bell contingency procedures that have been developed through a site-specific risk
assessment.
These plans/procedures should include details of the equipment and personnel required to
locate a lost diving bell and rescue the occupants in circumstances where:
 the stricken bell is still attached to its handling system, but is severed from its main lift
wire and/or umbilical; or
 the diving bell has become completely detached from the surface and is lost in open water.
The plan should identify the roles and responsibilities of all key stakeholders, and define the
provision of specific equipment, such as locators (see section 5.3).
All closed bell diving operations must have provision for deploying a surface standby diver in
an emergency unless a robust alternative plan has been developed to ensure assistance can
be rapidly given to a stricken or fouled bell at all depths. These procedures have to be proven
through exercises, and particular emphasis should be placed on the phases where the bell is
close to or inside the moon pool.
All personnel must be fully familiarised with the equipment and procedures relevant to their
roles and responsibilities, including marine crew, and this should be drilled regularly.
Relevant sections of the procedures must be provided in the bell and require suitable
protection against moisture or damage.
The emergency procedures should address, but not be restricted to the following.
5.1.1 Emergency Breathing Gas
IMCA D 024, section 5 – Diving Bell – requires that:
“Sufficient oxygen must be available for metabolic consumption by the maximum

number of divers at 0.5 litres/minute per diver for at least 24 hours at the end of a bell
run.
The pressure of all onboard gas (both oxygen and heliox) must be reduced to a
maximum of 30 bar over ambient before it enters the bell interior.”
5.1.2 Diver Emergency Heating
See section 5.6.

5.1.3 Emergency Connections
IMCA D 024, section 5 Diving Bell requires:
“A manifold should be provided on the bell for connection of basic supplies in an

emergency. As a minimum this should provide two connections as laid down by IMO:
 ¾’ NPT (female) for hot water
 ½’ NPT (female) for breathing gas”
A communications connection is also desirable.
The connections should be located at a centralised position with clear access and
should be clearly identified with suitable bright colour/glow paint markings.
Provision should be made for adjustment of the bell pressure where necessary during
an emergency.
Diving bells may be fitted with ROV intervention quick connect fittings and it is
recommended that each quick connect should be of different size to prevent incorrect
connections from being made (see also section 5.1.11.1). Further guidance is available
in NORSOK U-100 Manned Underwater Operations.
5.1.4 Bell Emergency Umbilical
IMCA D 024, section 7 – Main Bell Umbilical – requires that:
“Consideration should be given to carrying an emergency umbilical capable of being

connected to the emergency manifold ... The design and make-up should be as per the
emergency procedure manual.”
Documented verification of compatibility through trial fit up to the bell and the dive
control panel should be available. The emergency umbilical should be a minimum of
1.5 times the length of the planned working depth of the bell and should meet all the
requirements under IMCA D 018 Detail Sheet 28 and IMCA D 024, section 7 Main Bell
Umbilical.
5.1.5 Through-Water Communications
See section 5.4.
5.1.6 Checklist of Valves to be Operated in an Emergency
“A list of valve positions to be adopted in an emergency must be available in the bell.

This should duplicate the list kept in dive control.”
See section 5.2.2.
5.1.7 Emergency Tapping Code
“A copy of the AODC/IMCA bell tapping code must be mounted on the outside of the
bell in a clearly visible position.

A copy of the AODC/IMCA emergency tapping code must be easily accessible to the bell
occupants.”
A copy of the AODC/IMCA emergency tapping code is attached at Appendix 3.
5.1.8 Survival Inside a Stricken Bell
See section 5.6.
5.1.9 Bell Relocation Devices
See section 5.3.
5.1.10 Primary and Secondary Recovery
IMCA guidance recommends that for bell diving systems there must be:
 a primary means of recovering the diving bell to the surface, bringing it on board
and mating it to the chamber system; and
 a secondary means of recovering the diving bell to the surface and bringing it on
board in order to mate it to the chamber system that is independent of the main
recovery system.
The primary method is normally by means of the main lift wire and main bell winch.
The secondary method is normally by means of the secondary lift wire and secondary
winch.
The criteria governing the status of the secondary recovery system are fully addressed
in IMCA D 024, section 4 Bell Launch and Recovery System.
The following points should also be noted:

 Whether or not the umbilical and its handling system have been designed for
secondary recovery, there is a significant likelihood of damage to the umbilical if
used for this purpose. This method should, therefore, only be used if other more
appropriate diving bell recovery methods are unavailable.
 Where guide wires are attached to a fixed structure underwater and the system is
used without the use of a weight, consideration should be given to at least one of
the wires being fitted with a ‘weak link’ that will break if a sufficient load is applied.
A method should be available of preventing the wire from pulling free from the
bell to allow recovery of the bell.
5.1.11 Tertiary Recovery
In a lost bell situation where the main lift wire, secondary lift wire(s) and main
umbilical have been severed, the primary and secondary means of recovering the
diving bell to the surface, bringing it on board and mating it to the chamber system
will not be available. Tertiary recovery provisions should be in place for safe
emergency retrieval of the bell occupants to a surface compression chamber even if
the primary and secondary means of recovery have failed. This may be achieved, for
example, by through-water transfer of the divers to another diving bell or by
connection of emergency lift wires to the lost bell by ROV or rescue divers.

5.1.11.1 ROV Intervention
An ROV may be used to assist if available in the vicinity of the diving

operation. If the ROV is specified in the emergency procedures, then its role
must be defined, and all appropriate equipment must be available where
necessary.
5.1.11.2 Bell Ballast Release Systems and Buoyant Ascent
The use of a bell ballast release systems to enable the buoyant ascent of a
closed diving bell is generally regarded as the least desirable option available
for the safe recovery of a lost diving bell (see section 5.5 for detailed
guidance). Emergency procedures should consider all other available means
of bell or diver recovery in preference to the use of a bell ballast release
system. For example, by through-water transfer of the divers to another
diving bell or by connection of emergency lift wires to the lost bell by ROV or
rescue divers.
5.1.12 Additional Equipment/Facilities to be Provided
Diving Bell
 Provision should be made for disconnecting the bell wire and guide wires in the
event that this becomes necessary. Wire-cutters are one such provision.
 When working at an intermediate depth, consideration should be given to the
operating position of the door so as to prevent flooding of the bell in the event of
an uncontrolled descent.
Dive Control
 An up-to-date photographic record and/or drawings should be available of the
diving bell clearly indicating its features. In the event of an emergency, these
records should be made available to whoever is in charge of the rescue.
5.1.13 Instructions to Divers on Survival Inside a Stricken Bell
Bell internal emergency procedures should include precise instructions for the divers,
and these should be regularly drilled by every diver.
The site specific instructions should include the following guidance;

1) Thermal protection should not be donned too early in the emergency when the
bell internal atmosphere is still warm or else heavy sweating can occur leading to
dampness and cold. Once donned they should not be opened up unless absolutely
necessary, as every slight opening can cause significant heat loss.
2) No attempt should be made to lock out of a stricken bell unless instructed to do
so by the diving supervisor, either directly or via the rescue divers as per the
tapping code (see Appendix 3).
3) In warm water locations an assessment should be carried out on the prevention
of divers becoming overheated, and adequate provisions made.
4) Divers’ restraints must be sufficient to minimise injury during ascent and prevent
blockage of the bell hatch in the event of unconsciousness.

5) Ballast weights, where fitted, should not be released unless diver(s) are instructed
to do so by the diving supervisor, either directly or via the rescue divers or in
accordance with existing emergency procedures, as per the tapping code.
More information and guidance on lost bell survival may be found in section 5.6.
5.2 Emergency Isolation of Gas Circuits in the Event of a Ruptured Bell Umbilical
The industry has long considered how best to maintain/re-establish the pressure integrity
inside a diving bell following the sudden rupturing of the main bell umbilical.
Investigations of past incidents involving the rupture of bell main umbilicals have emphasised
the following:
1) there is likely to be an ingress of water if the external door is not closed;
[Castellate door if applicable or ensure external door is closed during launch and recovery.]
2) pressure loss can cause misting inside a bell and an attendant significant reduction in
visibility;
3) occupants often fail to shut off valves on some circuits (even when visibility inside the bell
remains adequate).
[Ensure critical valves are illuminated and equipment does not impede the diver’s ability to
close the valves in an emergency.]
5.2.1 Early Advice
In 1982 the UK Department of Energy issued Diving Safety Memorandum No. 8. The
Memorandum contained the following text:
“In order to improve diver safety when surface umbilicals are ruptured, the
following actions should be taken:
Wherever reasonably practicable, all gases and hot water circuits to diving bells
should be fitted with a type of non-return valve (non-return valve, flow fuse,
deadman handle, etc.) in addition to a hull integrity valve.”
Following the release of Diving Safety Memorandum No. 8 IMCA’s predecessor

organisation (the Association of Offshore Diving Contractors (AODC)) made the
following observations:
1) Non-return valves will operate only as long as the pressure inside the bell is higher
than the surrounding pressure.
2) Some circuits cannot be equipped with non-return valves, as doing so would
compromise their normal functions, such as:
− gas sampling to surface for analysis;
− pressure measuring circuits, pneumos, etc.
3) A ‘deadman’ valve on the bell pressurisation circuit could function, but would
present the following inconveniences:
− bell pressurisation would have to be done from the bell (it is often done from
the surface);
− in some cases of diving emergency this bell pressurisation line could not be
used for either blowing gas into or for bleeding gas out of the bell;
− some systems of gas recovery by ‘surface loop’ make use of this circuit.

4) Non-return valves inside the bell for water circuits could be fitted, but:
− they may present additional flow restriction;
− they may corrode rapidly;
− they could not be fitted on the hot water dump circuit.
5) Using non-return valves or other devices (on circuits where they are compatible)
in addition to ‘skin’ valves will increase the number of projections, sources of
injury and fragility.
6) Circuits such as bell decompression, bell flooding, trunking equalisation, etc.,
which are not connected to any umbilical circuit cannot be fitted with such devices
and must always be closed by hand in an emergency.
In light of these observations the AODC made the following recommendations:

1) Circuits supplying breathing gas to divers must be fitted with a means of
preventing the breathing gas from escaping out of a ruptured bell umbilical, e.g.,
by the use of appropriately positioned non-return valves or other devices.
2) As a principle, all gas or water circuits penetrating the bell should be equipped
with shut-off valves inside and outside located as close as possible to the hull.
These shut-off valves should be as unobstructed as possible. Such valves should
be of a type that clearly indicate if they are in the open or in the shut position
(‘quarter-turn’ or ‘ball’ type).
3) All valves should be clearly labelled by name as well as by a number. Labelling
valves with consecutive numbers helps occupants to positively identify valves and
reduces the risk of a valve being missed during an emergency.
4) An emergency waterproof list of all the valves that must be shut to ensure the
pressure integrity inside all bells is to be provided in the bell. The closing sequence
should be based on criticality, i.e., large bore valves causing large leaks to be
closed first. A duplicate must be kept on the surface, and the contingency plan
must provide for the shutting (and accounting for via through-water
communications) of all these valves. The list should also show those valves which
must be left open.
5.2.2 Lessons Learned from More Recent Experience
In 2013 an incident occurred on a modern diving support vessel (DSV) where a diving
bell suffered two uncontrolled descents whilst being lowered into the moon pool. The
bell umbilical was damaged during the second descent causing a loss of 18 metres
from an initial bell depth of 110 metres. It took approximately eleven minutes to close
all the internal valves and thankfully there were no injuries to the three divers.
The investigation into this incident noted the following points:

1) In a ruptured bell umbilical emergency involving a sealed (closed-door) bell, the
position of the bell is highly significant.
− When the bell is close to or on surface a rupture will result in a critical
emergency as the pressure differential is at its greatest which may result in a
rapid loss of bell internal depth.
− Intervention of surface crew may prove invaluable If they are in a position to
close the critical valves quicker than the divers inside the bell.
− If the bell is submersed and internal pressure is close to ambient water
pressure, the emergency is less critical due to the smaller differential in
pressure.

− If the bell is submersed midwater and the bell drops to the bottom the bell
will fill with water through any leak points unless the leaks are stopped, or the
bell interior is blown down to ambient pressure using onboard gas.
2) The use of a bell umbilical termination panel is the best arrangement for
connecting bell umbilical’s to diving bells and is recommended where practicable.
The main bell umbilical termination panel should be situated so as to provide a

clear path for any tightening of the main umbilical and for umbilical lines to tear
free from the bell surface without potentially damaging other equipment.
Primary justification:
− An overloaded main bell umbilical is likely to break at the bell when the
Chinese finger breaks.
− Strain will be transferred to the skin valves and as the lines tighten vital
equipment such as external piping, valves, hull stops, etc. may be damaged.
− As the strain increases it is most likely that the external skin valve fittings
themselves will break at the thread terminations.
− Bell onboard gas hard-pipe small bore lines on the outside of the bell will also
be at risk in an umbilical overload situation. This could render onboard gas
supplies useless to the divers in the bell and at the same time create additional
gas leakage conduits.
3) Flow fuses on large bore lines proved their worth during the incident and were
critical for slowing the loss of the bell internal depth. The flow fuses should be
placed at the back of the umbilical termination panel as this is where they are least
likely to be damaged. If the bell is not fitted with an umbilical termination the flow
fuses should be internal to the bell.
4) Drills and training sessions for ruptured bell umbilical scenarios should consider
small bore valves and pipes inside the bell as well as larger pipework. Where
practicable, small bore lines without non-return valves or flow fuses should be
grouped together and illuminated.
The early recommendations made by the AODC still stand but, in view of the lessons
learned from the above incident, this guidance makes the following additional
recommendations:
1) It is recommended that, so far as is reasonably practicable, all main bell umbilical
lines should terminate at a sturdy umbilical termination panel.
2) The routing of the bell umbilical from the termination plate to the attachment
point of the Chinese finger should be arranged to ensure that any subsequent
tightening of the umbilical will not endanger vital equipment such as external
piping, valves, hull stops, etc.
3) Flow fuses on all large bore gas pressurisation lines should be placed at the back
of the umbilical termination panel. If the bell is not fitted with a strong umbilical
termination panel any flow fuses should be internal to the bell.
4) Divers and surface crew should understand that rupturing of the bell umbilical on
or near the surface is a critical emergency situation.
5) Wherever possible, small bore lines without non-return valves should be grouped
together inside the bell and illuminated.
6) Placement and grouping of bell internal and external valves should be subject to
an ergonomic assessment and best practice should be observed when designing
the layout of pipework and valve positioning.

7) Critical valves should be clearly visible in light and in darkness, e.g., through the
use of glow-in-the-dark marking plates.
8) Regular exercises in emergency shut-in of all penetrations need to be executed in
order to avoid delays in a real event. Exercises should include “blind” drills
(internal lights off or divers blindfolded).
9) An up to date ‘Grab File’ which consists of checklists, procedures, and other
information must be immediately to hand in the event of a ruptured bell
umbilical/dropped bell situation. Checklists and drawings should correspond with
actual bell markings and valve numberings.
10) Bell internal isolation checklists for diving bells should prioritise valves to be closed
in order of criticality, i.e.:
− Valves connected to umbilical lines that are not equipped with non-return
valves and are open-ended inside the bell (larger bore first);
− Valves connected to umbilical lines that are equipped with non-return valves
and are open-ended inside the bell (in case the non-return valves leak);
− Valves connected to umbilical lines that are not equipped with non-return
valves and are not open-ended inside the bell;
− All other valves.
11) If applicable the procedures for deployment and connection of the emergency bell
umbilical should be available in dive control and inside the bell. An emergency
umbilical will normally only be attached to the bell once all leaks have been
brought under control. Caution should be exercised if use of the emergency bell
umbilical means that critical valves will need to be reopened. Consideration
should be given to opening these emergency umbilical valves early in case the
occupants become incapacitated.
5.3 Emergency Location of a Lost Diving Bell
For all bell diving operations those in control must have the capability of locating a lost diving
bell with the minimum of delay.
IMCA D 024, section 5 Diving Bell requires that:

 a strobe light with a minimum operating duration of 24 hours must be fitted to the bell;
 a transponder operating on 37.5 kHz must be mounted on the bell to aid in location in an
emergency; and
 a means of testing and interrogating the bell transponder at appropriate intervals, in
compliance with company procedures and in line with manufacturers’ recommendations,
must be readily available on the surface at the dive site.
The master of a DSV may also have other means of assisting in the search for a lost diving bell
at his disposal. For example:
 by use of the vessel’s ROV – the vehicle’s sonar may be capable of picking up the bell from
a considerable distance; and
 by conducting transponder array interrogations.
Vessels fitted with acoustic position monitoring should consider fitting a suitable secondary
transponder to the bell.

In addition to the above, all bell diving systems capable of being used in the rescue of lost
diving bells must have a portable, diver-operated relocation device available that is compatible
with the transponders on all diving bells. It is recommended that:
 the diver operated interrogator/receiver should be capable of detecting the bell mounted
acoustic transponder at a minimum range of 500 metres; and
 for ease of use, diver operated interrogator/receiver units should display the compass
heading and range on the same display panel.
Specifications for the Bell Mounted Acoustic Transponder and Diver Operated
Interrogator/Receiver are attached at Appendix 1 and Appendix 2 respectively.
It is important that equipment made available for the emergency location of a lost closed bell
is included in company planned maintenance systems and regularly serviced in accordance
with the manufacturers’ recommendations.
5.4 Through-Water Communications
All diving bells must be equipped with through-water communications to permit voice
communications with/from the diving supervisor in case of failure of the hard wire
communication system, for example during a lost bell emergency when the main bell umbilical
has been severed.
It is necessary to ensure that the through-water communications system is functional for all
diving operations.
5.4.1 Examination and Testing of Through-Water Communications Systems
Systems should be examined/tested in accordance with Detail Sheet 6 of IMCA D 018

– Code of Practice for the Initial and Periodic Examination, Testing and Certification of
Diving Plant and Equipment. In addition, they should also be operated, tested and
maintained in accordance with manufacturers’ recommendations.
5.4.2 Function Testing During Diving Operations
A function check should be carried out following every submersion of the bell and prior
to diver lock-out and diving operations should not proceed if communications cannot
be established.
5.4.3 Through-Water Communication Systems – Other Considerations

 Portability: Thought should be given to allowing the unit to be transferable to
another location which may be called upon to support the emergency, provided it
has been established that the two systems are compatible.
 Effects of environmental conditions: In some circumstances haloclines,
thermoclines etc. may reduce the performance of the through-water comms
system. This may be overcome by reducing the distance between the transmitter
and receiver units.
 Effects of outside interference: It should also be borne in mind that outside
interference from dynamic positioning systems, topside machinery and other
acoustic sources can cause interference.

5.5 Bell Ballast Release Systems and Buoyant Ascent
In a lost bell situation where the main lift wire, secondary lift wire(s) and main umbilical have
been severed, a bell equipped with a bell ballast release system could be made buoyant, and
ascend through the water column to the surface, if the divers inside the bell choose to operate
the ballast weight release mechanism.
Buoyant ascent of the bell is generally regarded as the least desirable option available for the
safe recovery of a lost diving bell (see section 5.5.1). Emergency procedures should consider
all other available means of bell or diver recovery in preference to releasing the ballast.
For example, by through-water transfer of the divers to another diving bell or by connection
of emergency lift wires to the lost bell by ROV or rescue divers.
5.5.1 Considerations on the Use, or Non-use, of a Bell Ballast Release System
Careful consideration should be given to the use of ballast release systems on diving
bells, taking the following problems into account:
1) Any failure of ballast release mechanisms and/or inadvertent release of ballast
weights could have very serious consequences, and these have resulted in diver
fatalities.
2) Bell ballast release systems add considerable weight to diving bells which can
cause buoyancy and handling issues. For example, it may be necessary to add
compensating buoyancy to allow the bell to float when the release system is
operated. The fitting of additional buoyancy to the bell may also result in the bell
becoming only weakly negatively buoyant – perhaps preventing it from sinking at
a safe and comfortable rate during normal operations. In addition, the extra
weight in air of any additional buoyancy will mean that extra loads are imposed
on bell handling systems.
3) In order for the ballast release to be performed successfully, certain conditions
must be established. For example, it would be essential to check that:
− the bell’s ascent will not be impeded or prevented by the proximity of debris
and associated lifting equipment (such as severed wires, umbilical etc.) and its
path to the surface will be free from obstructions;
− surface craft are cleared from the rescue area and an agreed time is specified
before the bell starts the ascent. This is particularly important in the event of
communications failure;
− there is pressure integrity inside the bell;
− there is a safe procedure for attaching a lift wire and recovering the bell once
on the surface.
It is likely that many other factors will also have to be taken into account.
In view of the above, reliance on buoyant ascent as a means of rescue is not normally
considered necessary:
 when operating with a two-bell system;
 in areas where diving support vessels are available and capable of providing rescue
by through-water transfer within the survival time of the bell;
 where ROV assistance is available, in which case this should be incorporated into
the rescue contingency plan with engineered and tested solutions for connection
of emergency lift wires and umbilical services.

For multi-bell operations, the emergency procedures should account for a
malfunction, such as DP failure, which may preclude the use of the second bell.
The decision on whether or not to use ballast release systems must take full
consideration of all relevant factors. Where operational considerations require that
buoyant ascent is to be used as a means of diver recovery, the guidance in section
5.5.2 on the design and configuration of bell ballast release systems should be
followed.
Where the decision is taken that a ballast release system will not be used as a method
of emergency recovery, it must be clearly documented and communicated clearly at
the work site. The emergency procedures must identify the alternative method
chosen (for example, by through-water transfer of the divers to another diving bell or
by connection of emergency lift wires to the lost bell by ROV or rescue divers). The
competent person will be required to carry out sufficient testing to ensure the
integrity of the weights and their support structures, but no testing will be required of
any release mechanisms. The weights themselves should be affixed in such a way that
they cannot come off accidentally or be released. All ballast release operating systems
should be removed or rendered inoperable. All certification issued should be
endorsed by the competent person clearly stating that the ballast release mechanism
is not operable. A notice to this effect should also be securely and conspicuously fixed
inside the bell.
5.5.2 Design Philosophy and Configuration of Bell Ballast Release Systems
The philosophy of ‘free ascent’ of a bell relies upon the ballast release system
(together with all other associated systems such as umbilical, main lift wire, and
secondary lift wires, etc.), being completely releasable. However, the design of the
bell ballast release system should be such that no single failure can result in the loss
of the ballast.
Bell ballast release systems should be configured as follows:

1) At least two independent actions should be necessary to effect release of the
ballast weights;
2) If operation of the primary and secondary release mechanisms relies on a common
structural component, then an independent means must be provided to retain the
ballast, i.e., no single component failure should result in buoyant ascent of the
bell. However, in cases where the release mechanism structure has been
specifically designed to withstand application of gross external force, then
provision of an independent means of retaining the ballast may be dispensed with
at the discretion of the competent person (e.g., a bell with two separately
releasable drop weights).
3) Allowance must be made for the bell tilting either before or during deployment,
in which case the weights must:
− be incapable of inadvertent release, e.g., falling off;
− remain capable of deliberate release.
4) Where hydraulic/pneumatic systems are used their design should be such as to
preclude accidental activation by means of hydrostatic pressure when the bell is
pressurised to either one atmosphere (such as during an observation dive), or to
the maximum foreseeable pressure to which the bell is likely to be subjected.

5) The design of new ballast systems should be such that either the secondary
system, or any independent system adopted in case of failure of primary and
secondary, should be capable of taking the ‘in-air’ weight of the ballast together
with appropriate factors for shock load.
5.5.3 Initial and Periodic Examination, Testing and Certification
Full details of the requirements for the initial and periodic examination, testing and
certification of bell ballast release systems are attached at Appendix 4.
The categories of competent person appropriate to carry out examination, test and
certification of equipment are defined in IMCA D 018 – Code of Practice for the Initial
and Periodic Examination, Testing and Certification of Diving Plant and Equipment. A
summary of the requirements for the initial and periodic examination, testing and
certification of bell ballast release systems is also included in IMCA D 018 as Detail
Sheet 30 Bell Ballast Release Systems.
Requirements for bell ballast release systems are also included in IMCA D 024, section
5 Diving Bell.
It is acknowledged that certain classification societies and certifying authorities may

have specific requirements concerning buoyant ascent and ballast release systems
which are out with the scope of this guidance.
5.5.4 Maintenance
Effective maintenance protocols should be carried out under a planned maintenance

system and the competent person should satisfy himself that the system is operable.
5.5.5 Diver Training
When ballast release systems are considered to be part of the emergency procedures
then the contractor should ensure that all divers are familiar with their operation.
5.6 Lost Bell Survival1
As noted in the introduction to this document the most pressing threats to the lives of divers
in a lost bell are:
 the risk of carbon dioxide (CO2) poisoning; and
 the loss of thermal balance. Usually severe hypothermia is the concern, although in some
parts of the world hyperthermia may be an issue.
Oxygen depletion is also a serious problem that must be considered, and so IMCA D 024,
section 5 Diving Bell requires that:
“Sufficient oxygen must be available for metabolic consumption by the maximum number
of divers at 0.5 litres/minute per diver for at least 24 hours at the end of a bell run.”
The overall aim for diving contractors is to ensure that all closed diving bells are capable of
sustaining the lives of trapped divers for at least 24 hours.
1 Much of the information and guidance in this section is based on material from IMCA D 059 – Diver Emergency Heating Report (1984) and
IMCA D 017 – Lost Bell Survival: Trainers’ Guide.

5.6.1 Strategies for Combating Heat Loss during Lost Bell Emergencies
The thermal conductivity of helium is six times that of air, and when diving in cold
waters it is logical that gas temperatures inside a stranded diving bell will decrease
rapidly if the bell is cut off from all external sources of heating.
This fact was tragically confirmed in the late 1970s and early 1980s when two lost bell
incidents in the North Sea (typical water temperature of 4°C to 6°C) caused the deaths
through hypothermia of a total of four divers. In two other incidents four divers
survived lost bell incidents but experienced severe hypothermia during the two to ten
hours they spent inside unheated diving bells before being rescued.
These incidents prompted the industry and regulatory authorities to take action.
Research and development (R&D) projects were initiated and the following strategies
for combating heat loss during lost bell emergencies were identified:
1) Improve the overall insulation of diving bells to reduce the rate of cooling inside
lost bells.
2) Insulate the trapped divers individually, and so minimise their personal heat loss
‘passively’, i.e., without heating the ambient atmosphere inside the bell or the
divers themselves.
3) Use active emergency heating systems inside the lost bell, i.e., devices which
generate heat. These can be used to keep the ambient internal atmosphere of the
diving bell at a suitable temperature or to keep the divers themselves warm.
Evaluations of survival systems kept in diving bells over several years of operation have
concluded that insulation material, and other parts of the systems, may show
deterioration, even when properly vacuum-packed. Repeated compression and
vacuum packing are a likely explanation for the observed reduction in the thermal
properties of the insulation materials used in such survival systems.
5.6.2 Survival Time versus Rescue Time
Manned verification dives and unmanned simulations show that survival time in a lost
bell at depths shallower than 180 msw should exceed a minimum of 24 hours without
the need for active heating systems provided passive survival systems are:
 of an acceptable standard (see reference 5);
 properly inspected and maintained;
 kept undamaged; and
 used correctly by the divers.
For depths deeper than 180 msw the use of passive survival systems may be
insufficient to ensure survival for 24 hours and systems with active heating are
required. These systems are coupled with passive individual insulation systems and
have heating wires forming an integral part of the thermal insulation suit/bag. Power
for this type of system is supplied from the bell emergency batteries.
Regular inspection and maintenance of the survival systems is critical, and it is

essential that survival systems are kept dry because:
 moisture dramatically reduces the insulation properties of the survival systems;
 moisture in the soda lime or channelling routes reduces the efficiency of the unit.

If survival systems are not kept dry the consequences are likely to be:
 marked reduced thermal insulation for the diver(s);
 heightened levels of respiratory heat loss;
 inefficient CO2 scrubbing;
 significant reduction in survival times.
The aim is for the divers to be able to assist with their own rescue, for example by
making a wet transfer, or at least be in a condition where rewarming in the bell can be
performed safely.
If a diver’s core temperature drops below 34°C their mental condition will be affected,
and they are unlikely to be able to respond effectively to the emergency. Once the
core temperature falls below 31-32°C, the diver’s own metabolic heat production
(mainly generated through shivering) is insufficient to regain a normal and safe
thermal status. It is critical that divers activate the means to preserve body heat as
soon as possible and for as long as possible. At a core temperature of 30°C or lower
the risk of unconsciousness is very high.
Rescue time will depend on the nature of the emergency and the time required to
mobilise rescue facilities. For example, a rescue team operating from a second diving
bell on the DSV will be substantially quicker than a support DSV. These factors should
be considered during the planning of the diving operation. The chances of survival will
be greatly enhanced if the diving contractor has provided the equipment, the
maintenance systems, the procedures and the training recommended.
5.6.3 Respiratory Heat Loss
Receptors on the body surface detect low temperatures and provide an important
early trigger to the brain to initiate shivering and increased heat production. Shivering
is an important response to reduce the rate of heat loss. In the heliox environment at
pressure a lot of the body heat is lost through the respiratory tract, which does not
trigger the shivering response. Heat is lost from the body core without the diver being
aware of it until central thermal sensors are activated. The diver may feel relatively
comfortable, but the slow drain of heat from his body could be the start of a life-
threatening situation.
If the bell is warm at the time when contact with the surface is lost, several hours will
pass before the bell gas cools close to the temperature of the surrounding seawater.
This will result in a significant respiratory heat loss for divers who breathe in the
increasingly cold gas without any means of heating it.
To minimise respiratory heat loss and to remove excess CO2, the survival equipment
needs to include:
 a thermal regenerator unit which acts as a small heat exchanger (the unit
conserves the heat of the diver’s expired gas and then uses this heat to pre-warm
the cold gas being inspired); combined with
 a lung powered CO2 scrubber which removes the CO2 from the divers’ exhaled
breath and uses the exothermic reaction of the chemicals to heat the inspired gas.
Together the combined CO2 scrubber/thermal regenerator assembly is very effective

in preventing respiratory heat loss. In lost bell incidents and in trials, divers who did
not have the benefit of such units became debilitated several hours sooner than others
who did use the equipment in an effective manner.

It is therefore essential that the divers know how to use the combined unit and
appreciate the need to put it on as soon as possible after the start of the emergency.
Figure 1 – A passive survival system incorporating an individual thermal

insulation bag and combined CO2 scrubber/thermal regenerator assembly.
The insulation bag is partially unzipped to show the soda lime canister.
5.6.4 Passive Thermal Protection – The Diver’s Insulation System
The rate of heat transfer from a diver’s body to the environment inside the bell is by
convection and conduction. Both can be reduced by increasing the thermal resistance
of the garments worn by the diver, and by providing insulation between the diver, the
cold gas environment, and the cold hull of the bell.
The specific emergency equipment provided by the manufacturers of diver insulation

systems will vary somewhat, but the survival kit containing the system will normally
consist of the following items:
 a towel to dry off any water before donning the dry thermal protection
equipment;
 dry underwear (wool);
 a thermal insulation suit/coverall;
 a thermal insulation bag;
 an inflatable mattress or cushion;
 a harness.
Harnesses are normally included as an integral part of the thermal insulation bags.
They are used to attach the insulated divers to suitable securing points. Harnesses
should support the divers in an upright sitting position even when asleep or possibly
unconscious, and thereby prevent them from falling across the access door to the bell
and hindering rescue.

Inflatable mattresses or cushions may be provided for the divers to lie or sit on and
may be an integral part of the thermal insulation bags. They can be used to help
reduce heat conduction where the divers are in direct contact with the bell hull or deck
plates.
It is important that divers recognise the need to take all possible steps to keep the
survival bag dry.
5.6.5 Other Considerations
For the body to continue to generate heat by shivering, it requires sources of

carbohydrate as a fuel. The bell emergency kit should therefore contain high-energy
carbohydrate bars and fluids.
Sanitary bags, including urine collection systems suitable for the divers to use when
inside their thermal bags, will need to be available.
It will be difficult for divers to put on the equipment due to restricted space and it is
essential that the divers work as a team as this will allow them to unpack and don the
emergency equipment properly.
To avoid a hazardous increase in CO2 levels, the bell scrubber should be run until the
divers are settled inside their survival systems. The thermal regenerator units should
be put on as soon as possible, mainly to preserve body heat and reduce CO2 levels.
Generic procedures for divers involved in a lost bell emergency are outlined below and
in the IMCA D 017 – Lost bell survival video.
5.6.5.1 Preparing the Bell

 Divers should dump unnecessary gear to create space.
 Excess water should be bilged to avoid the survival systems subsequently
becoming wet.
 The bell door should be closed.
 The umbilicals should be coiled to sit on ensuring the bell door is kept
clear so that rescuers can access the bell.
5.6.5.2 Emergency Equipment – Diver’s Insulation System

 The divers should get dry before opening the survival kits.
 After opening the thermal bag, the material of the bag should be shaken
to distribute the insulation material in the bag.
 If possible, the diver should urinate before getting into the thermal suit
and bag and then use the urine collection system provided.
 Insulation or hammocks should be provided to separate the diver and
the bell hull. The use of a hammock may provide easier access for rescue
divers.
 The integral harness should be tied off to the bell wall to prevent
occupants collapsing over the bell hatch and impeding access by rescuers
if they become unconscious.

5.6.5.3 Combined CO2 Scrubber/Thermal Regenerator
To ensure the systems works effectively the divers should:

 keep the unit on at all times;
 ensure that the oral nasal mask is a good seal, preventing cold bell gas
leaking into the mask;
 ensure that the oral nasal mask fits comfortably;
 know how to adjust the gas temperature if the gas becomes too hot,
instead of being tempted to remove the unit;
 know that even if the soda lime becomes exhausted, keeping the unit on
will still provide some protection from heat loss;
 keep the system in a position that will limit the risk of channelling in the
soda lime canister, and/or shake the canister at intervals to reduce the
same risk.
5.6.5.4 Emergency Rations
The emergency rations should include high-energy carbohydrates, preferably

in both solid and liquid form. One carbohydrate bar (21g) should be eaten
every hour. Dehydration may be prevented by taking 250ml of a
carbohydrate drink instead of a solid bar every six hours, or by drinking other
fluids provided such as water. Drinks should be kept warm by keeping them
close to the body inside the survival bag.
5.6.5.5 Inspection and Maintenance
IMCA D 018 – Code of Practice for the Initial and Periodic Examination,
Testing and Certification of Diving Plant and Equipment contains guidance on
the examination, testing and certification of diving bell survival systems. The
following Detail Sheets are relevant:
 Detail Sheet 21 – Diver Heating Systems
 Detail Sheet 33 – Emergency Survival Packs and Passive Scrubbers
The importance of regular inspection for diving bell survival systems should
be emphasised to both maintenance and dive crews. It is essential that
survival insulation systems are inspected in accordance with an agreed
schedule for evidence of:
 damage to the protective packaging e.g., broken zips, rips in the
packaging material; and
 moisture within the thermal suits and bags, e.g., wet feel, mould. Ideally,
bags should be checked for dampness by using a dampmeter probe
inserted into the bag material through the zipper.
Regenerator units should be inspected for:

 damage to the unit and soda lime scrubber, e.g., cracked container, split
hoses, spillage of soda lime;
 degradation of the soda lime due to ingress of moisture;
 suitably tight packing of the soda lime in the canister (to minimise the
possibility of channelling).

Where practical the Survival systems should be checked prior to each bell run
and damaged kits should be replaced immediately with a fully functional kit.
Company planned maintenance should include periodic inspections and

servicing. The procedures should be based on manufacturers’
recommendations and on experience gained in the field.
Actively heated diving bell survival systems should be regularly function

checked to ensure that broken wires do not cause malfunctions.
Diving bell survival systems will only be effective if they are maintained and
used correctly.
5.6.6 Other IMCA Guidance on Lost Bell Survival
In September 1984 AODC produced a report on the subject of ‘Diver emergency

heating’. This report is currently available as IMCA D 059. The 1984 report still
contains useful and relevant information on lost bell survival. It is therefore
recommended that IMCA D 059 should be read in conjunction with the guidance given
here.
In addition, IMCA and the UK Health and Safety Executive (HSE) have jointly produced
a video entitled ‘Lost bell survival’ and an accompanying ‘Trainers’ guide’ (IMCA D
017). Together the video and guide are designed to supplement in-house training for
dive teams, dive supervisors, life support technicians, maintenance personnel and
diving school trainees, in the use of the survival equipment provided in a diving bell or
welding habitat. The video and guide highlight the basic procedures which should be
followed by divers involved in a lost bell incident. Again, it is recommended that
persons reading this guidance document should also view the video ‘Lost bell survival’
and read the video’s accompanying ‘Trainers’ guide’ document.

6 References
1) IMCA D 014 – IMCA International Code of Practice for Offshore Diving
2) IMCA D 017 – Lost Bell Survival: Trainers’ Guide
3) IMCA D 018 – Code of Practice for the Initial and Periodic Examination, Testing and Certification of
Diving Plant and Equipment
4) IMCA D 024 – DESIGN for Saturation (Bell) Diving Systems
5) IMCA D 059 – Diver Emergency Heating Report (1984)
6) IMCA HSSE 022 / IMCA M 194 – Guidance on Wire Rope Integrity Management for Vessels in the
Offshore Industry.
7) NORSOK U-100 Manned Underwater Operations.
8) Hayes PA and Maddern T. 1996. Prediction of Lost Bell Survival Times. Health & Safety Executive
Offshore Technology Report OTO 96 802
9) Tipton MJ, Franks C, Meneilly GS and Mekjavic IB. 1997. Estimation of Diver Survival Time in a Lost
Bell. Health & Safety Executive Offshore Technology Report OTH 96 516
10) Williams K. 1992. A Review of Equipment and Procedures for the ‘Lost Bell’ Situation. Society for
Underwater Technology ‘Underwater Technology’ Volume 18 Number 3 pp 29-36
11) Recommended Requirements for Diver’s Emergency Systems; SINTEF Report STF 23 A91024 (Rev.
1); Sept. 1991
12) Thermal Survival Suits – Improvements and Testing; Thelma Report 01–04 (ISBN 82-8032-007-5);
June 2001

Appendix 1
Appendix 1 – Bell Mounted Acoustic Transponder Specification
A pressure housing capable of operating to at least 200 metres
Common emergency reply frequency: 37.5 kHz
Individual interrogation frequencies:

 channel A 38.5 kHz ± 50 Hz
 channel B 39.5 kHz ± 50 Hz
Receiver sensitivity + 15 dB re 1 microbar
Minimum interrogation pulse width 4 ms
Turnaround delay 125.7 ± 0.2 ms
Reply pulse width 4 ms ± 0.5 ms
Reply frequency 37.5 kHz ± 50 Hz
Maximum interrogation rate:

 more than 20% of battery life remaining: once per second
• less than 20% of battery life remaining: once per 2 seconds
Minimum transponder output power: 85 dB referred to 1 microbar at 1 metre
Minimum transducer polar diagram: -6 dB at ± 135° solid angle, centred on the

transponder vertical axis and transmitting towards
the surface
Minimum listening life in water: 10 weeks
Minimum battery life replying at 85 dB: 5 days

Appendix 2
Appendix 2 – Diver Operated Interrogator/Receiver
A pressure housing capable of operating to at least 200 metres with pistol grip and compass. This is to
be compatible with the transponders available on all other diving bells.
Front end – to contain the directional hydrophone array
Rear end – to contain the digit-led display readout calibrated in metres
Controls – on/off receiver gain

– channel selection
Common emergency reply frequency: 37.5 kHz
Individual interrogation frequencies:

 channel A 38.5 kHz
 channel B 39.5 kHz
Minimum transmitter output power: 85 dB referred to 1 microbar at 1 metre
Transmit pulse: 4 ms
Directivity: ± 15o
Capability to zero range on transponder:

 minimum detectable range: 500 metres

Appendix 3
Appendix 3 – Bell Emergency Communication
For use between the crew of a lost craft and rescue divers.
Tapping Code Situation
3.3.3 Communication opening procedure (inside and outside)

1 Yes or affirmative or agreed
3 No or negative or disagreed
2.2 Repeat please
2 Stop
5 Have you got a seal?
6 Stand by to be pulled up
1.2.1.2 Get ready for through water transfer (open your hatch)
2.3.2.3 You will NOT release your ballast
4.4 Do release your ballast in 30 minutes from now
1.2.3 DO increase your pressure
3.3.3 Communication closing procedure (inside and outside)

Appendix 4
Appendix 4 – Bell Ballast Release Systems
Note: This also includes lift wire, guide wire and umbilical release systems
When new, following a major refit or a material or design change which could affect the ballast
release system.
Category of
Competent
Examination/Test Person
In accordance with manufacturer’s specification and fit for the purpose it will be used for 3 or 4
Release systems should be function tested in air (see Note 1) 3 or 4
When in service:
Category of
Validity Competent
Examination/Test Period Person
Function test of all mechanisms to check that the weights will release. 6 months 2, 3 or 4
Visual examination of the structure including accessibility of emergency lift 6 months 2, 3 or 4

point.
Overload test to 1.5 times the static load of the ballast weight in air which 12 months 3 or 4
will be imposed on the release system/structure and the ballast weight
itself (see Note 3), or whichever of the release/support systems is designed
to take the in air weight of the ballast. NDE carried out on all critical items.
Dry function test of all components and release mechanisms involved in 12 months 3 or 4
each stage of the process required to make the bell buoyant. Where fitted
this might typically include the following:
1. Release ballast and demonstrate separation of weights from the bell,
including consideration of drop weight separation if bell resting on
bottom (weights should not be allowed to fall – see Note 4).
2. Release bell lift wire.
3. Release guide wire.
4. Release umbilical (see Note 5).
5. Visually check that retractable arrangements such as pins (if used) are
free of any defects which could prevent retraction with the system
under load.
Test bell positive buoyancy and confirm this is in line with original 12 months 3 or 4
requirement.
Test positive bell buoyancy using the following criteria:
1. The water should be of a known Specific Gravity.
2. The total weight of the bell assembly and occupants should include:
• the weight of a standard equipped bell
• 150 Kg per fully equipped diver, including umbilicals
• allowance for flooded bottom trunking
• allowance for tools
• allowance for special payload.

Relevant Notes and Guidance
1) If there is any reason to suspect that the effect of hydrostatic depth pressure may have a
deleterious effect on the release mechanisms, consideration should be given to conducting the
test in a simulated working environment – see point 4 of section 5.5.2.
2) Weights should not be dropped, nor the umbilical or wires cut. For systems which use load
shedding releasable ballast, sufficient quantity should be released during the in-service test to
ensure that all the weights can be shed in a real emergency.
3) It is acknowledged that some designs use the release mechanism to support the full weight of the
ballast whereas with others the majority of the weight is taken by the bump frame. In the latter
case the release mechanism and bump frame must be separately tested to the appropriate load.
4) It is appropriate to partially support the weight of the drop weights to simulate the in-water weight
as the release mechanism may not have been designed to release the in-air load.
5) Where a guillotine is used to effect release then it should be demonstrated that it can cut a sample
of wire or umbilical identical to that used on the actual bell. If any damage to, or potential loss of
effectiveness of the blade has been caused by the test, then it should be repaired or replaced.
6) Testing of lifting gear and appliances is normally carried out as part of the integral system. If,
however, individual components are to be replaced on a like for like basis e.g., shackles, strops,
etc., provided the component is supplied with an "As New" certificate, then only a function test at
working load will apply.

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Guidance on Prevention and Mitigation of

Lost Bell Emergencies

IMCA D 077 – Version History

May 2023 Initial publication

This document supersedes the guidance previously contained in:

The above documents were withdrawn on publication of this document.

IMCA D 077 © IMCA Trading Ltd 1

The main aims of this document are to describe:

2 © IMCA Trading Ltd IMCA D 077

IMCA D 077 © IMCA Trading Ltd 3

4.1.1 Diving Bell

4.1.2 Bell Handling and Recovery Systems

The guidance contained in the following IMCA documents should be scrupulously

4.2 Primary Hazard

In order to achieve this, it is important to ensure that:

4 © IMCA Trading Ltd IMCA D 077

4.3 Moonpool and Cursor Hazards

IMCA D 077 © IMCA Trading Ltd 5

5.1 Emergency Procedures and Preparedness

5.1.1 Emergency Breathing Gas

IMCA D 024, section 5 – Diving Bell – requires that:

“Sufficient oxygen must be available for metabolic consumption by the maximum

5.1.2 Diver Emergency Heating

See section 5.6.

6 © IMCA Trading Ltd IMCA D 077

IMCA D 024, section 5 Diving Bell requires:

“A manifold should be provided on the bell for connection of basic supplies in an

A communications connection is also desirable.

5.1.4 Bell Emergency Umbilical

IMCA D 024, section 7 – Main Bell Umbilical – requires that:

“Consideration should be given to carrying an emergency umbilical capable of being

5.1.5 Through-Water Communications

See section 5.4.

5.1.6 Checklist of Valves to be Operated in an Emergency

IMCA D 024, section 5 Diving Bell requires:

“A list of valve positions to be adopted in an emergency must be available in the bell.

See section 5.2.2.

5.1.7 Emergency Tapping Code

IMCA D 024, section 5 Diving Bell requires:

IMCA D 077 © IMCA Trading Ltd 7

A copy of the AODC/IMCA emergency tapping code is attached at Appendix 3.

5.1.8 Survival Inside a Stricken Bell

See section 5.6.

5.1.9 Bell Relocation Devices

See section 5.3.

5.1.10 Primary and Secondary Recovery

The following points should also be noted:

5.1.11 Tertiary Recovery

8 © IMCA Trading Ltd IMCA D 077

An ROV may be used to assist if available in the vicinity of the diving

5.1.11.2 Bell Ballast Release Systems and Buoyant Ascent

5.1.12 Additional Equipment/Facilities to be Provided

5.1.13 Instructions to Divers on Survival Inside a Stricken Bell

The site specific instructions should include the following guidance;

IMCA D 077 © IMCA Trading Ltd 9

5.2.1 Early Advice

Following the release of Diving Safety Memorandum No. 8 IMCA’s predecessor

10 © IMCA Trading Ltd IMCA D 077