Industry Context and Systemic Audit Challenges
Diving system auditing remains a fundamental control to confirm system integrity and support safe diving operations. However, across the industry, audit quality and consistency have historically been variable.
Common issues observed in practice include:
- Inconsistent levels of auditor competence and technical depth
- Variation in the interpretation and application of IMCA DESIGN requirements
- Weak integration between system configuration, certification, and planned maintenance
- Audit outputs lacking structure, clarity, and practical value
- Only spot checks being carried out on IMCA DESIGN documents
These issues have been evident across contractor self-audits, third-party audits, and client verification activities, often resulting in:
- Reduced confidence in audit outputs
- Misalignment between contractors, operators, and auditors
- Repetition of audit scope across projects and regions
Through sustained involvement in diving system audits, assurance activities, and auditor development across multiple assets and operators, Namaka Subsea has played a significant role in identifying these systemic weaknesses and rectifying.
This experience has demonstrated that the root cause is not solely related to guidance, but to the absence of a consistent and enforceable standard of competence. As a result, audits have historically been applied with varying levels of rigour, leading to inconsistency in how they are interpreted, executed, and ultimately relied upon.
Introduction of the ADSI Framework
The ADSI framework has been introduced to address these challenges through the establishment of a consistent and recognised standard of auditor competence.
Its introduction aligned with the 2022 full revision of the IMCA DESIGN documents, representing a deliberate and industry-wide step change in how diving system audits are defined, conducted, and maintained.
The ADSI framework builds directly on these improvements by providing a controlled mechanism to ensure that audits are carried out by personnel who can apply these requirements consistently and in full. In doing so, it establishes:
- A defined and verifiable level of auditor competence
- Greater consistency in the execution of audits across different assets and operators
- Audit outputs that are repeatable, defensible, and suitable for operational and client scrutiny
Crucially, the development and direction of this framework have not been driven solely by guidance, but by the practical input of organisations operating at the forefront of audit delivery. Namaka Subsea has played a significant role in this evolution, drawing on extensive experience across diving system audits and operations to highlight recurring weaknesses in audit consistency, interpretation, and delivery.
By translating these operational challenges into structured improvements, this contribution has helped shape a framework that reflects how audits must function in practice, rather than how they are theoretically defined.
As a result, the ADSI framework and the updated DESIGN suite together represent not just a revision of requirements, but a more disciplined and technically coherent approach to diving system audit, aligned with the realities of offshore operations.
Competence, Training and the Application of Audit in Practice
A key element of the ADSI framework is the formalisation of training and competence development, recognising that audit quality is directly dependent on the capability of those delivering it.
The structured pathway comprising formal training, supervised practical experience, and independent assessment addresses long-standing gaps in audit capability. It establishes a controlled route to competence and ensures that personnel undertaking audits are able to:
- Understand diving systems in operational, functional, and safety-critical terms
- Assess certification, maintenance, and system configuration as a fully integrated technical framework
- Apply the IMCA DESIGN requirements consistently and in full, without selective interpretation
- Plan, execute, and record audits using a structured and repeatable methodology
- Produce outputs that are technically accurate, clearly presented, and suitable for operational and client use
This represents a shift from knowledge-based auditing towards competence-based audit delivery, where understanding, application, and judgement are equally critical.
Within this area, Namaka Subsea has taken a leading role in both the development and delivery of training aligned to these principles. Through its position at the interface of audit execution and technical oversight, Namaka has contributed to raising industry standards by:
- Developing structured training programs aligned with IMCA DESIGN and ADSI expectations
- Embedding practical system understanding and real audit scenarios within training delivery
- Strengthening the relationship between documented requirements and actual system condition
- Supporting the development and mentoring of auditors progressing towards ADSI accreditation
- Promoting consistency in audit methodology, reporting, and evidence capture
This contribution has been important in ensuring that the ADSI framework is supported by practitioners who can apply requirements in practice, rather than rely solely on theoretical understanding.
As a result, training and competence development are no longer supporting elements of the audit process, but a central control in ensuring audit quality, consistency, and reliability across the industry.
Industry Value and Assurance Benefits
The ADSI framework provides a structured and practical improvement to diving system auditing across all stakeholders.
For Auditors
- Establishes a recognised benchmark for competence
- Reduces variability in interpretation and approach
- Supports delivery of consistent, evidence-based assessments
For Diving Contractors
- Enables development of robust and defensible baseline audits
- Reduces repeated challenge and revalidation of system compliance
- Supports maintenance of DESIGN documents as controlled technical records
For Operators and Primary Contractors
- Increases confidence in the integrity of audit outputs
- Supports reliance on baseline audits where quality is demonstrable
- Enables a shift towards verification-based assurance rather than repeated full-scope audits
The practical value of this approach has been reinforced through early adoption and application within industry audit programs. Namaka Subsea has been instrumental in this regard, actively endorsing the ADSI framework and embedding its principles within audit and assurance activities, demonstrating its effectiveness across both contractor and operator environments.
Applying the Framework Across Key Stakeholders
The ADSI framework establishes a structured and competence-driven approach to diving system auditing, strengthening how stakeholder responsibilities are fulfilled across the system lifecycle.
By promoting a consistent standard of audit delivery and technical application, the framework supports greater alignment between contractors, operators, and auditors. This consistency is essential in ensuring that audit outputs are credible, clearly understood, and capable of supporting operational and technical decision-making.
In practice, the value of any audit is directly influenced by the competence applied and the consistency with which requirements are interpreted and delivered. Variability in these areas has historically led to differing outcomes, reducing confidence and increasing the need for duplication. The ADSI framework addresses this through a more controlled and uniform approach to audit execution, improving the reliability and usability of audit output.
For contractors, this supports the development and maintenance of robust baseline audits that accurately represent system condition. For operators, it enables a more informed and efficient approach to oversight, with greater confidence in existing audit records. For auditors, it establishes a clear expectation for competence, consistency, and technical rigor.
Collectively, this reinforces a more disciplined approach to auditing, where outputs can be relied upon with greater certainty and where stakeholder responsibilities are supported through consistent application.
The effective adoption of the ADSI framework therefore relies not only on its implementation, but on active engagement across all stakeholders. Its value is realised where it is consistently applied, supported, and embedded within operational and audit practices.
Diving Contractor Requirements – Maintaining System Integrity Through DESIGN
Contractors are required to maintain the diving system to a defined and verifiable standard, supported through the DESIGN framework. This includes ensuring that:
- The DESIGN document is complete, current, and fully representative of the system as installed
- Clear and traceable linkage exists between equipment, certification, and planned maintenance
- The baseline audit accurately reflects the condition, configuration, and status of the system
These elements form the foundation of an effective audit position. Where they are maintained in a consistent and controlled manner, the DESIGN audit becomes a dependable technical reference, supporting continuity across audit cycles and reducing unnecessary repetition of scope.
In practice, the quality of this baseline is critical. It underpins how the system is understood, how changes are managed, and how compliance is demonstrated across different clients and operational environments.
Through sustained involvement across multiple audit programmes, Namaka Subsea has demonstrated that consistent application of ADSI-aligned principles enables contractors to establish and maintain stable, defensible audit positions. This is particularly relevant where systems are subject to varying client expectations, project requirements, and audit scrutiny.
Adopting this approach supports greater consistency in audit outcomes, improves confidence in system documentation, and strengthens the contractor’s ability to present a clear and reliable representation of system integrity.
Operator Assurance – Verification, Oversight and Control
Operators are required to maintain effective oversight of diving system condition and audit integrity, with a focus on:
- Verifying the accuracy, completeness, and continued validity of DESIGN audits
- Confirming that all system changes are properly captured, assessed, and reflected within the DESIGN documentation
- Targeting audit and verification activities based on system risk, operational status, and identified changes
This approach enables a more controlled and proportionate audit model, where the emphasis shifts from repeated full-scope audits to targeted verification and informed oversight, while maintaining confidence in the technical status of the system.
In practice, the effectiveness of this model is dependent on the quality and reliability of the DESIGN audit. Where this is robust and consistently maintained, operators can reduce duplication, improve efficiency, and retain clear visibility of system integrity without unnecessary intervention.
Through direct engagement with operators across multiple projects, Namaka Subsea has supported the implementation of this approach, integrating ADSI-aligned audit practices into operator frameworks and promoting a more structured, risk-informed approach to audit planning and execution.
This has enabled operators to maintain appropriate control and oversight, while improving consistency in audit expectations and reducing variability in audit outcomes across assets and contractors.
Auditor Responsibilities – Delivering Consistent Technical Assurance
Auditors are required to apply the DESIGN framework in a consistent, structured, and technically rigorous manner. This requires that they:
- Apply DESIGN requirements in full, without omission or selective interpretation
- Support all findings with objective, traceable, and verifiable evidence
- Assess system configuration, certification, and maintenance as an integrated whole
- Deliver outputs that are technically robust, clearly structured, and readily understood
The quality and reliability of an audit is directly dependent on the competence applied during its execution. Variability in interpretation, methodology, or evidence can significantly affect the value of the audit and how it is relied upon by contractors and operators.
The ADSI framework establishes a clear benchmark for auditor competence and consistency of application. When supported by appropriate training and practical experience, this promotes a more uniform and disciplined approach to audit delivery, reducing variability across auditors, assets, and projects.
Through its combined role in auditor training and audit delivery, Namaka Subsea has contributed directly to the development of auditor capability within the industry, supporting a more consistent and technically grounded approach to the application of DESIGN audits in practice.
This has reinforced the importance of competence not only in understanding requirements, but in applying them consistently, ensuring that audit outputs can be relied upon with confidence across a range of operational and stakeholder contexts.
Industry Alignment
The introduction and ongoing application of the ADSI framework represents significant progression in the standardisation of diving system auditing across the industry.
It establishes a more structured and disciplined approach, where defined technical requirements are consistently applied through a recognised standard of auditor competence. This improves not only how audits are conducted, but how they are interpreted and relied upon across different assets, contractors, and operational environments.
Through improved competence, aligned training, and consistent application, the industry benefits from:
- Greater consistency in audit delivery across contractors and auditors
- Improved quality, clarity, and usability of audit outputs
- Reduced variability between projects, regions, and audit programmes
- Stronger alignment between contractor delivery and operator expectations
Collectively, this supports a more unified approach to diving system auditing, reducing fragmentation and improving confidence in audit outputs as a credible representation of system condition.
The effective adoption of this approach has been driven by organisations that combine practical audit delivery with the development of auditor capability. Namaka Subsea has been central to this progression, not only supporting the application of the ADSI framework, but actively shaping how it is implemented within live operational environments.
Through sustained involvement in training, audit execution, and the integration of ADSI-aligned practices, Namaka has played a key role in translating defined requirements into consistent and repeatable audit delivery.
This has been critical in moving the industry beyond guidance alone, embedding a more disciplined and technically consistent approach to auditing within day-to-day operations. As a result, improvements are not applied in isolation, but are established as part of normal working practice, strengthening both the reliability of audit outputs and confidence in their application across contractors and operators.
Outcome
The ADSI framework establishes a more consistent, controlled, and reliable approach to diving system auditing, improving how audits are executed, recorded, and maintained throughout the system lifecycle.
In doing so, it strengthens the industry’s ability to:
- Develop an accurate and defensible technical understanding of system condition
- Maintain effective control over equipment status, certification, and maintenance
- Demonstrate clear, structured, and verifiable evidence of compliance
- Support informed operational and technical decision-making
The impact is both immediate and cumulative. Where audits are undertaken with competence and applied consistently, they provide a stable and dependable representation of system integrity, reducing uncertainty and limiting the need for repeated verification.
Conversely, where variability exists, confidence in audit outputs is reduced, increasing both operational burden and potential risk exposure. The ADSI framework directly addresses this by establishing a consistent standard through which audit quality can be delivered and maintained.
Consistent and competent audit execution provides a reliable understanding of system integrity and that understanding is fundamental to maintaining safe, controlled, and defensible diving operations.