Dive System DESIGN Auditing – Industry Insight, Expectations & Best Practice

DESIGN Audit Framework

Dive system DESIGN auditing forms a fundamental component of diving system assurance, providing a structured and systematic approach to assessing equipment, system configuration and supporting documentation against recognised industry best practice.

The IMCA DESIGN suite establishes a detailed framework for the physical arrangement, equipment provision, and documentation of diving systems, forming the basis against which audits are undertaken. In parallel, IMCA D018 defines the requirements for the inspection, testing, and certification of diving plant and equipment, ensuring that all safety-critical elements are subject to appropriate examination and periodic control.

When applied collectively, these documents define a consistent methodology for demonstrating that a diving system:

• Is correctly configured and equipped in accordance with DESIGN expectations.
• Has been subject to appropriate inspection, testing and certification regimes.
• Is supported by a coherent and traceable documentation portfolio.

A DESIGN audit therefore represents more than a documentation exercise, it is a technical engineering assessment of system integrity, requiring:

• Complete coverage of all applicable DESIGN requirements
• Clear linkage between:

1. Equipment
2. Certification (IMCA D018)
3. Planned maintenance and records

• The application of competent technical judgement in assessing compliance, configuration and system condition.

In this context, the DESIGN document functions as a live technical record, reflecting the status of the system and providing a structured means of demonstrating alignment with IMCA expectations throughout the system lifecycle.

Fundamental Principles

A DESIGN audit is a comprehensive technical assessment of diving system equipment and associated documentation and must be completed in its entirety against the applicable IMCA DESIGN document.

The DESIGN process requires that the audit reflects a complete and accurate representation of the system, supported by clear and traceable evidence.

This includes:

• All applicable DESIGN line items are explicitly addressed, with no omissions.

Each response is supported by objective evidence, such as:

• Certification records (aligned with IMCA D018 requirements)
• System drawings and schematics
• Equipment registers and maintenance records.
• Physical inspection of installed equipment

The completed document forms a coherent and auditable technical record of system configuration, certification status, and maintenance condition.

In this context, the DESIGN document serves not only as an audit output, but as a controlled technical reference, linking equipment, certification, and maintenance into a single structured framework.

It is therefore essential to recognise that a DESIGN audit requires full technical coverage of the system and must not be undertaken using sampling techniques.

Sampling-based approaches, as commonly applied within quality management or ISO audits, are not appropriate for DESIGN audits due to:

• The system-specific characteristics and safety-critical nature of diving equipment
• The requirement to confirm complete system configuration and integrity.
• The need for direct traceability between all components and supporting documentation.

Accordingly, a DESIGN audit should always deliver a fully substantiated, evidence-based assessment, capable of supporting ongoing assurance activities and independent review.

IMCA D011 defines distinct audit types within the DESIGN framework, each with a specific role.

Baseline Audit

A baseline audit establishes the initial technical reference point for a diving system and defines the standard against which all future audits are measured.

It is typically completed:

• On newly commissioned systems
• Following system relocation or re-mobilisation
• Where no prior completed Baseline DESIGN audit exists

The baseline audit comprises a full, structured assessment of the system, covering:

• Equipment configuration, system interfaces, and dependencies
• Completion of the DESIGN document against all applicable requirements
• Certification and testing status, confirmed as current and traceable in line with IMCA D018
• Alignment with IMCA DESIGN suite expectations

The output provides a clear and consistent baseline, supporting:

• Ongoing annual audits
• Management of Change (MOC)
• Lifecycle tracking of system condition and configuration.

A robust baseline audit clearly defines the system at a point in time and establishes the foundation for all subsequent assurance activities.

Annual Audit

The annual audit maintains the DESIGN document as a current and accurate record of the diving system, ensuring continuity from the baseline while reflecting its present condition.

It is not a repeat of the baseline audit, but a systematic reassessment of the system, focused on capturing all changes to equipment, configuration, and certification since the previous audit. Where certification remains valid from the baseline (or previous annual audit), it does not require re-verification but should be confirmed as still in date and correctly referenced.

The annual audit is completed using the same approach as the baseline audit, and comprises:

• Completion of the DESIGN document against all applicable requirements
• Confirmation that certification remains in date, in accordance with IMCA D018
• Full update of the DESIGN document to reflect any changes to system configuration.
• All equipment replacements, ensuring:

1. Correct equipment identification
2. Updated traceability to certification

• All recertification activities, ensuring:

1. New certificates are recorded.
2. Expiry dates are updated.
3. Superseded certification is clearly replaced.

• Review and update of:

1. Drawings and schematics
2. Equipment registers and supporting records.

The annual audit ensures that the DESIGN document continues to represent the system as installed and maintained, providing a consistent and up-to-date record.

Verification Audit

A verification audit is a separate activity, typically undertaken by the operator or primary contractor who has engaged the diving contractor for their services.

It is not a full DESIGN audit, but rather an independent review of the completed DESIGN document and associated diving system, often forming part of a wider assurance or project-specific audit scope.

In practice, verification audits are commonly conducted as site-based assessments, with a defined scope set out in the operator’s or contractor’s Terms of Reference.

The verification audit typically includes:

• Review of the completed DESIGN document to confirm it has been carried out and is current.
• Sampling of certification and records, including selected checks in line with the IMCA DESIGN suite.
• Physical observation of equipment and system condition, where accessible

a limited review of:

1. Procedures
2. System arrangements
3. Key equipment functionality (where included in scope)

The depth and coverage of the audit will depend on the agreed scope and objectives and may vary between operators or projects.

It is important to recognise that:

• The verification audit relies on the completeness and accuracy of the underlying DESIGN audit.
• It does not replicate the full line-by-line assessment required by the DESIGN process.
• It is intended to provide confidence in the existing audit, rather than replace it.

A verification audit provides a sample-based, independent review and should not be considered a substitute for a fully complete DESIGN audit.

Audit Consistency and ADSI Scheme

In support of improving consistency and technical quality in DESIGN audits, particularly where different auditors may be engaged over time, IMCA has introduced the ADSI (Approved Diving System Inspector) scheme. The ADSI Scheme promotes consistency and high standard of technical assessment and aims to provide enhanced confidence in baseline audits completed by ADSI-accredited practitioners.

Diving contractors should ensure that any such baseline is maintained as an accurate, current, and verifiable technical reference that remains representative of the system. Where this is achieved, the baseline audit can be relied upon to effectively support subsequent audit activities, reducing unnecessary duplication while strengthening compliance, improving consistency, and contributing to increased assurance in system integrity and diver safety.

Preparing for an Audit

The diving contractor should ensure that the system is maintained in a constant state of audit readiness, without reliance on reactive or last-minute preparation. All equipment, documentation, certification, and records should be proactively controlled, maintained, and aligned to demonstrate compliance with IMCA DESIGN and IMCA D018 at any time.

On demand, the contractor should be able to present clear, accurate, and fully traceable evidence demonstrating that:

• The system is correctly configured and effectively maintained.
• All assets are accounted for and properly identified.
• Certification and maintenance are current, valid, and compliant.
• Documentation accurately reflects the installed system and its operation.

There should be no gaps, inconsistencies, or reliance on verbal justification in place of documented evidence. The physical system, records, and documentation should collectively present a coherent, structured, and defensible position that demonstrates control, discipline, and operational integrity, while supporting a logical and efficient audit process.

System Configuration

The diving contractor should ensure that the installed system accurately reflects the approved design and is clearly identifiable, accessible, and verifiable in its current condition. Consideration should be given to the following areas: –

• Equipment aligns with DESIGN suite requirements and operational requirements.
• System interfaces, and vessel integration points are clearly identified and documented.
• Equipment layout allows safe and practical access for inspection, maintenance, and operation.
• All assets are uniquely identified with durable, clearly legible ID markings.
• Identification is consistent across physical equipment, PMS System, supporting documents and asset registers.
• The system reflects the current as-built condition, with all modifications formally captured and controlled within the Management of change system.

This enables the auditor to confirm that the installed system matches the intended design, eliminating ambiguity and providing confidence in system integrity and control.

Certification and Maintenance

The diving contractor should ensure that certification and maintenance activities demonstrate compliance, traceability, and accuracy in line with IMCA D018, and are structured in a way that directly supports the DESIGN audit workflow.

The contractor should ensure that: –

• Certification is valid, in date, and clearly linked to the correct equipment.
• Certificates meet IMCA D018 expectations and are issued by competent person and where applicable witnessing authorities.
• Certification records are organised in a logical structure that mirrors the DESIGN audit approach (e.g., by system, subsystem, or equipment grouping), allowing step-by-step verification.
• Clear linkage is maintained between:

1. Asset register
2. Equipment ID/tag
3. Certification
4. Maintenance records

• Planned maintenance routines are defined and actively managed.
• Maintenance activities are completed as scheduled, with detailed evidence of execution.
• Maintenance records and certificates include key information:

1. Equipment ID and serial number
2. Description and scope of work
3. Execution and expiry dates
4. Certifying or competent authority (if applicable)

• Certification and maintenance records reflect the current condition and status of equipment.

This ensures that compliance can be demonstrated efficiently and logically during audit, enabling the auditor to follow a clear workflow from asset identification through to certification and maintenance evidence without delay or ambiguity.

Documentation and Asset Control

The diving contractor should ensure that all documentation and asset records are accurate, complete, current, and fully aligned with the physical system.

This should include: –

• Documentation packs are structured, complete, and readily accessible.
• Drawings and technical documents are current, accurate, and revision controlled.
• Traceability is maintained between equipment, asset lists, certification, and maintenance records.
• The asset register is fully populated and reflects installed equipment.
• Equipment descriptions, tag numbers, and locations are consistent across all records.
• Registers are maintained and kept up to date, including:

1. Lifting equipment registers
2. Hose registers
3. Pressure Relief Valve (PRV) registers.

• Register entries align with inspection records, certification, and physical asset identification.

This provides assurance that all assets are known, controlled, and correctly managed, reducing the risk of omission, duplication, or use of non-compliant equipment.

Supporting Documentation

The diving contractor should ensure that all supporting documentation required for operation, maintenance, and system integration is complete, current, and aligned with the installed system.

This would normally comprise of the following: –

• Operating procedures that clearly defines normal operating and emergency scenarios.
• Emergency response procedures being available and applicable.
• Safe Systems of Work (SSOW) and risk assessments that are defined and relevant.
• Electrical schematics and distribution diagrams that reflect the installed configuration.
• Vessel integration documentation being available, including:

1. Electrical plans
2. Fire and safety plans.
3. System layout drawings
4. Sea fastening engineering packages are approved and available.
5. FMECA reflects current system configuration and identified risks.
6. Seafastening and NDE certificates and reports are available and traceable to equipment.

This ensures personnel have the necessary information to operate safely and respond effectively, while demonstrating that system risks are understood and controlled.

Audit Readiness

The diving contractor should be able to demonstrate, without delay, that the system and its supporting information are fully aligned, accessible, and audit ready.

• Records, documentation, and registers are accurate, complete, and consistent.
• Physical equipment matches documentation, certification, and asset records.
• Information is readily accessible and can be clearly presented during the audit.
• Traceability is evident from design through installation, operation, and maintenance.
• No gaps, inconsistencies, or ambiguities exist across systems or records.

This provides immediate auditor confidence that the system is controlled, compliant, and managed in a structured and disciplined manner, with a clear and efficient audit trail.

Digital PMS and Audit Expectations

The diving industry has undergone a significant transition from traditional paper-based certification and spreadsheet-driven planned maintenance systems to integrated, purpose-built digital platforms, including Namaka NAMS. This evolution has introduced clear benefits in accessibility, traceability, and efficiency; however, it has also highlighted a growing gap between system capability and how it is applied in practice.

Modern PMS solutions provide the ability to centralise asset data, automate maintenance scheduling, and generate audit-ready outputs. While this represents a step change in capability, the underlying compliance expectations defined by IMCA D018 and DESIGN remain unchanged. The format has evolved, but the evidential standard remains the same.

A consistent theme observed across audits is the assumption that task completion within a PMS equates to compliance. This is not the case.

For baseline and annual audits, the requirement remains that auditors verify the content, accuracy, and completeness of certification and maintenance records, not simply their completion status. Where PMS work orders or renewal entries replace traditional certificates, they are expected to meet the same level of technical detail, traceability, and evidential quality as their paper-based predecessors.

PMS as the New Certification Standard

Digital PMS platforms now function as the primary mechanism for recording certification and maintenance activities, with work order entries effectively serving as the certification record.

In practice, this requires:

• Each renewal or maintenance entry to provide a complete and technically robust record of the activity performed.
• Clear documentation of:

1. What was tested, inspected, or maintained?
2. How the activity was performed (method, conditions, equipment used)
3. The acceptance criteria applied.
4. The results obtained, including confirmation of compliance.

• The capture of relevant technical parameters (e.g., pressures, tolerances, environmental conditions) where applicable
• The inclusion of competent person or witness details where required.
• The attachment and clear reference of third-party certification and supporting documentation.

Many platforms, including Namaka asset management system (NAMS), can generate standalone certificates per asset however, these are typically direct extractions of the underlying system record.

As such, the value of any generated certificate is wholly dependent on the quality and completeness of the source data. The format may resemble traditional certification, but it does not independently validate compliance.

Verification Beyond Completion

A key area of misunderstanding within the industry is the reliance on PMS status indicators (e.g., “complete, “closed, or “in date”) as evidence of compliance.

Audit practice continues to require direct verification of recorded data:

• Auditors assess the quality, technical accuracy, and completeness of work order and renewal entries.
• Verification is undertaken against IMCA D018 and DESIGN requirements, not system-generated status.
• A completed task lacking sufficient detail, supporting evidence, or traceability may still be deemed non-compliant.

The audit process should still reflect the same historic methodology:

• Reviewing the Certificate (now the PMS entry or extracted output)
• Confirming it meets required standards.
• Verifying alignment with the asset, system, and supporting documentation

System status, report outputs, or auto-generated certificates, regardless of platform do not demonstrate compliance in themselves. Assurance is derived from the integrity, depth, and traceability of the recorded information.

Emerging Industry Challenges

Despite the advanced capabilities offered by modern platforms, a number of recurring issues are being identified across audits:

• Vague or non-technical work order entries that do not reflect the activity performed.
• Failure to record key test data, acceptance criteria, or conditions.
• Missing or unreferenced supporting documentation and third-party certification
• Poor asset structuring or grouping, limiting traceability and audit navigation.
• Misallocation of assets within incorrect system categories

The effectiveness of digital PMS platforms is fundamentally dependent on the quality, accuracy, and completeness of the information entered. System outputs, reports, and generated certification are a direct reflection of the data captured at task level. Where this information lacks detail, structure, or alignment with audit requirements, the reliability and evidential value of the system are inherently reduced. Audit assurance is therefore not derived from system functionality, but from the integrity and discipline applied to the information within it.

The Benefits of Digital Systems

When applied effectively, structured PMS platforms provide a significant improvement in control, transparency, and audit readiness.

Effective implementation typically includes:

• Work order entries that are detailed, technical, and aligned with certification requirements
• Consistent attachment and reference of supporting documentation
• Logical asset structuring aligned with DESIGN audit workflows.
• Maintenance routines defined in line with risk and system criticality.
• Use of system functionality (e.g. reporting tools and dashboards) to support pre-audit verification
• Routine internal validation and self-audit of data quality
• Clear traceability from assets through to maintenance, certification, and supporting evidence.

When these principles are applied, digital systems enable a more efficient, transparent, and defensible audit process than traditional paper-based methods.

The Bottom Line

The transition to digital PMS represents a change in format, not a reduction in standard.

Where work orders within systems such as Namaka’s NAMS replace traditional certificates, they should meet the same evidential threshold expected under IMCA D018 and DESIGN.

Audit outcomes are determined not by system completion, formatting, or generated outputs, but by the accuracy, depth, and traceability of the information recorded.

Key Takeaways

DESIGN audits exist to provide assurance that diving systems are configured, maintained, and operated in a manner that protects the safety of divers. At their core, they are a critical control measure within the broader system of engineering and operational assurance that underpins safe diving operations.

The process is not simply about documentation or system completion. It is about demonstrating, through verifiable evidence, that all equipment, systems, and supporting controls are in place, functioning as intended, and subject to appropriate inspection, testing, and maintenance.

Several key principles define effective audit outcomes:

• A DESIGN audit is a complete technical assessment, requiring full coverage of the system and all applicable requirements.
• Diver safety is dependent on system integrity, which can only be confirmed where equipment, certification, and maintenance are fully aligned and traceable.
• The DESIGN document serves as a live technical reference, reflecting the true condition and configuration of the system at any given time.
• Traceability is critical, ensuring that all safety-critical equipment can be linked directly to valid certification, inspection, and maintenance records.

The transition to digital Planned Maintenance Systems, such as NAMS, has enhanced how this information is managed, but it has not reduced the level of assurance required:

• Completion is not assurance, audit outcomes are based on the quality, accuracy, and completeness of the underlying evidence.
• Work orders and renewal entries now function as certification records and must demonstrate the same technical standard as traditional certificates.
• System outputs, reports, and generated certificates only have value where the data behind them is complete, accurate, and properly structured.

Across the industry, the most consistent and reliable audit performance is achieved where:

• Systems are maintained in a state of continuous readiness, rather than prepared at the point of audit.
• Information is accurate, complete, and immediately accessible.
• Clear linkage exists between equipment, certification, maintenance, and documentation.
• A high level of data discipline and technical oversight is applied to all records.

A successful DESIGN audit provides confidence that the diving system is fit for purposes, correctly maintained, and capable of supporting safe operations under all expected conditions.

The standard of the audit is therefore defined not by the presence of systems or documentation, but by the ability to clearly demonstrate that the integrity of the system is understood, controlled, and maintained in a way that always protects the diver.