Recurring concern

Unreliable medical fitness controls for divers

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First reported 3 Mar 2014•Latest report 18 Nov 2025

Definition

What this concern includes

Includes failures in the dedicated process for assessing, disclosing, verifying and monitoring divers’ medical fitness before and during occupational, recreational or technical diving, including reliance on self-report, obtaining relevant medical information, checking current certificates and enforcing fitness requirements before courses or dives.

Not included

  • Excludes general diving hazards, including immersion pulmonary oedema awareness, decompression risks and water-rescue arrangements, where medical-fitness controls are not deficient.
  • Excludes diver training, instructor qualifications and experience where the asserted deficiency is not the verification or management of medical fitness.
  • Excludes firearms, driving and other non-diving licensing medical-assessment processes.
  • Excludes clinical treatment or emergency response after a diver’s medical fitness has been reliably assessed and the relevant dive has commenced.
Reports
4

Distinct published reports

Individual concerns
5

A report can raise multiple concerns

Date range
2014–2025

First to latest report issue date

Stated actions
8

Described in published responses

Reports over time

Reports over time

Reports about this concern issued each year.

* 2026 is projected from reports observed to 7 Sep 2026.

Most frequent recipients

Most frequent recipients

Reports about this concern sent to each recipient.

British Diving Safety Group1
British Sub-Aqua Club1
Health and Safety Executive1
N.D.A.C. Limited1
Professional Association of Diving Instructors (PADI)1
St Richard's Hospital1
Sub-Aqua Association1
University Hospitals Sussex NHS Foundation Trust1

Concerns and responses across reports

Only concerns grouped under this recurring concern are included. Select any concern, action or position to view the source wording.

  1. West Sussex, Brighton and Hove

    AI-generated summary

    Dominic Edward Arthur HURLEY · Prevention of Future Deaths report

    This summary was generated using AI from the published report. Please read the original report for the complete account.

    Report summary

    On 8 July 2024, Dominic Hurley became unwell during an offshore dive, made a rapid uncontrolled ascent, became unconscious, and later died in hospital. The principal concern was that he had not disclosed a previous serious diving incident and cardiac history when renewing his diving licence, with reliance on self-declaration questionnaires without further enquiry or access to previous medical history identified as a potential risk.

    Read the report on judiciary.uk

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Overreliance on self-declaration questionnaires without further enquiry or access to previous medical history

    Wider context from the report

    “In 2018 Mr Hurley suffered shortness of breath and pulmonary oedema during a dive in Malta. This led to him having a heart bypass on his return to the UK. There was significant family history of cardiac related issues. Time passed but in 2021 and 2023 Mr Hurley sort to renew his diving licence. Mr Hurley completed his self declaration questionnaire. At no stage did he declare the events in 2018 in relation to his dive and nor did he discuss this with the Dr assessing him. It is likely that he Dr been aware of the previous diving incident a different course of action may have taken. There is currently too much reliance placed on the self declaration questionnaire without any further enquiry or access to previous medical history. This leads to a false sense of reality and put the diver and others at potential risk of death on further dives. ”

    Source location

    Dominic Edward Arthur HURLEY · Prevention of Future Deaths report
    Page 1 · concerns

    Open source report

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Include immersion pulmonary oedema in the diving medical screening declaration.

    Verbatim wording from the response

    “The SAA use the medical screening system managed by the UKDMC (United Kingdom Diving Medical Committee) (https://www.ukdmc.org/). I have checked my medical form archive and note that “immersion induced pulmonary oedema” was introduced in the May 2020 version of the declaration at question 17. The current version, May 2024, of the form has this at question 16.”

    Source location

    Response from Sub Aqua Association Space Solutions Business Centre
    Page 1 · response
    Published 19 November 2025

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Remind members at renewal and through periodic newsletters to complete medical declarations accurately.

    Verbatim wording from the response

    “I believe that the SAA has advised its membership and revised their training programme in such a manner as to have already implemented the changes required to mitigate the risk of IPO when diving, in so far as any risk can be mitigated. However, the SAA will ensure that the membership is reminded of the importance of accurately completing medical by emphasising the fact at renewal and with periodic reminders in their newsletters.”

    Source location

    Response from Sub Aqua Association Space Solutions Business Centre
    Page 2 · response
    Published 19 November 2025

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Revised medical screening forms and existing training changes are considered sufficient to mitigate the risk of immersion pulmonary oedema in diving.

    Verbatim wording from the response

    “I believe that the revision to the current dive medical screening forms now meet the change you are now seeking to make.”

    Source location

    Response from Sub Aqua Association Space Solutions Business Centre
    Page 2 · response
    Published 19 November 2025

    Open published response
  2. Gloucestershire

    AI-generated summary

    Richard Paul Victor Sanders · Prevention of Future Deaths report

    This summary was generated using AI from the published report. Please read the original report for the complete account.

    Report summary

    Richard Sanders, an experienced diver aged 52, became unresponsive during a dive to 45 metres on 11 April 2019 and was pronounced deceased at the scene. The concerns included awareness of immersion pulmonary oedema risks, the need for fitness-to-dive medical certification, and methods for removing divers from the water.

    Read the report on judiciary.uk

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Failure to give sufficient consideration to a fitness-to-dive medical certificate as a prerequisite for diving participation

    Wider context from the report

    “2. Whether sufficient consideration has been given to the requirement for a “fitness to dive” medical certificate as a prerequisite to participation in diving activities. ”

    Source location

    Richard Paul Victor Sanders · Prevention of Future Deaths report
    Page 1 · concerns

    Open source report

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Consider new information affecting fitness-to-dive guidance at each committee meeting.

    Verbatim wording from the response

    “The UKDMC sets the medical requirements for diving for several national amateur diving organisations in the UK. Its members also advise the Health and Safety Executive on the medical requirements for commercial diving. The committee meets about 4 times per year and at every meeting it considers new information that might affect our guidance on fitness to dive.”

    Source location

    2022-0003-Response-from-St-Richards-Hospital_Published-1
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Require health declarations to identify IPO and other health factors influencing IPO risk before referral for medical advice or physical examination.

    Verbatim wording from the response

    “The UKDMC fitness assessment depends on a health declaration which determines whether a UKDMC Medical Referee (who will have received updates on IPO and its known risk factors) should be approached for advice or a physical examination. The health declaration asks specifically about IPO and also asks about other aspects of health which can influence risk of IPO. Routine annual physical examination has not been required for many years as it added no benefit to the assessment of those who did not declare any problems. Many divers have not declared problems, sometimes leading to fatality, but re-introduction of routine physical examination would not capture those who choose to dive independently and, due to lack of a specific test for susceptibility to IPO, would still miss individuals at risk.”

    Source location

    2022-0003-Response-from-St-Richards-Hospital_Published-1
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Update recreational diving medical questionnaires to include specific screening questions or references concerning immersion pulmonary oedema.

    Verbatim wording from the response

    “Given that physical health is an important factor when diving, the two medical assessment forms have been updated in the past 2-3 years to include sections specifically to screen for a person’s susceptibility to IPO.”

    Source location

    2022-0003-Response-from-British-Diving-Safety-Group_Published
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    The existing health declaration and referral process is considered sufficient; routine annual physical examinations add no benefit for those declaring no problems.

    Verbatim wording from the response

    “The UKDMC fitness assessment depends on a health declaration which determines whether a UKDMC Medical Referee (who will have received updates on IPO and its known risk factors) should be approached for advice or a physical examination. The health declaration asks specifically about IPO and also asks about other aspects of health which can influence risk of IPO. Routine annual physical examination has not been required for many years as it added no benefit to the assessment of those who did not declare any problems. Many divers have not declared problems, sometimes leading to fatality, but re-introduction of routine physical examination would not capture those who choose to dive independently and, due to lack of a specific test for susceptibility to IPO, would still miss individuals at risk.”

    Source location

    2022-0003-Response-from-St-Richards-Hospital_Published-1
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Reintroducing routine physical examinations would not identify independently diving people or those at risk because no specific test for IPO susceptibility exists.

    Verbatim wording from the response

    “Unlike flying, vocational driving or commercial diving, there is no legal requirement to have a medical examination for recreational diving. As a result, although some organisations insist that people diving with them satisfy the UKDMC requirements, people can dive independently without any medical examination.”

    Source location

    2022-0003-Response-from-St-Richards-Hospital_Published-1
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Reducing dishonest health declarations remains difficult because access to general practitioner records has proved unhelpful in some cases.

    Verbatim wording from the response

    “We do not condone dishonest declarations, not least because such behaviour endangers the diver’s buddy. We have considered ways that we can reduce dishonest declaration but even access to General Practitioner records has been unhelpful in some cases. This situation is not unique to diving. For instance, applicants make false medical declarations about eyesight, blackouts etc in order to retain a driving licence.”

    Source location

    2022-0003-Response-from-St-Richards-Hospital_Published-1
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    A medical certificate requirement based on IPO risk is considered justifiable only if an equivalent requirement applies to open-water swimming.

    Verbatim wording from the response

    “Finally, more cases of IPO occur during open water swimming than in divers each year because there are more open water swimmers than divers. As a result, we believe that a requirement for a medical certificate for diving based on the risk of IPO could only be reasonably justified if the same was required for open water swimming.”

    Source location

    2022-0003-Response-from-St-Richards-Hospital_Published-1
    Page 2 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Responsibility for current diving-operation safety arrangements lies with DTSL, the new operator, which should be contacted for further information.

    Verbatim wording from the response

    “Until 23 December 2021, the Diving Centre was operated by N.D.A.C. Limited (NDAC) at Dayhouse Quarry (also known as Tidenham Quarry). However, in connection with the sale of Dayhouse Quarry to a third party, NDAC’s rights to operate the Diving Centre at the quarry were terminated as from 23 December 2021.”

    Source location

    2022-0003-Response-from-National-Diving-Activity-Centre_Published-1
    Page 1 · response
    Published 10 January 2022

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Existing self-declaration questionnaires and referral arrangements are considered sufficient; a fitness-to-dive medical certificate is not required before participation.

    Verbatim wording from the response

    “Current arrangements: All the significant training agencies and the sports’ governing body, use one of two self-guided questionnaires to screen for medical conditions which require referral to a Diving Medical Referee for consultation and advice e.g. epileptics requiring medication or diabetics with recent hypoglycaemia are advised not to dive because of the risk of unexpected loss of consciousness which could be fatal underwater.”

    Source location

    2022-0003-Response-from-British-Diving-Safety-Group_Published
    Page 6 · response
    Published 10 January 2022

    Open published response
  3. Leicester City and South Leicestershire

    AI-generated summary

    Kevin Robert Miles · Prevention of Future Deaths report

    This summary was generated using AI from the published report. Please read the original report for the complete account.

    Report summary

    Kevin Robert Miles was undertaking a re-breather diving course at Stoney Cove on 25 September 2018 when he experienced difficulties underwater. He was brought to the surface, but resuscitation attempts failed and he was declared deceased at the scene; the cause of death was recorded as unascertained. The report raised concerns about the absence of a requirement to obtain divers’ GP records or otherwise verify medical advice when assessing fitness to dive, and about the risks to divers and potential rescuers or dive buddies.

    Read the report on judiciary.uk

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Reliance on divers’ self-reporting failing to ensure disclosure of salient health facts

    Wider context from the report

    “An Occupational Health Physician, who is also a UK Sport Diving Medical Referee and an HSE Approved Medical Examiner of Divers certified Mr Miles as fit to dive for two years on the 30 January 2018 based on the information given to her by Mr Miles himself in the medical questionnaire and on her physical examination of him. There is currently no requirement to obtain the diver’s General Practitioner records (which are often a ‘hub’ of various information regarding treatment by both hospital and/or private clinic) or otherwise personally enquire into treatment or advice given by any other medical practitioner. In my opinion this system is open for misreporting of health problems or, in fact, failing to report them at all. If there had been a requirement to obtain Mr Miles GP records it would have been quite clear that he had been advised that he should not dive again and presumably the certificate would not have been granted. My concerns are that not only may divers be risking their own lives by not disclosing salient health facts (that is at their own risk) but that they are also putting the lives of potential rescuers/dive buddies at risk as well. ”

    Source location

    Kevin Robert Miles · Prevention of Future Deaths report
    Page 1 · concerns

    Open source report

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Lack of requirement to obtain divers’ General Practitioner records or enquire into other practitioners’ treatment or advice

    Wider context from the report

    “An Occupational Health Physician, who is also a UK Sport Diving Medical Referee and an HSE Approved Medical Examiner of Divers certified Mr Miles as fit to dive for two years on the 30 January 2018 based on the information given to her by Mr Miles himself in the medical questionnaire and on her physical examination of him. There is currently no requirement to obtain the diver’s General Practitioner records (which are often a ‘hub’ of various information regarding treatment by both hospital and/or private clinic) or otherwise personally enquire into treatment or advice given by any other medical practitioner. In my opinion this system is open for misreporting of health problems or, in fact, failing to report them at all. If there had been a requirement to obtain Mr Miles GP records it would have been quite clear that he had been advised that he should not dive again and presumably the certificate would not have been granted. My concerns are that not only may divers be risking their own lives by not disclosing salient health facts (that is at their own risk) but that they are also putting the lives of potential rescuers/dive buddies at risk as well. ”

    Source location

    Kevin Robert Miles · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    The current self-certification system, including requests for further information and specialist advice, is considered sufficient; no change is needed.

    Verbatim wording from the response

    “At present, any diving referee [doctor with extra training in diving medicine] who is approached by a diver who declares a problem on the current self certification form, can ask them to provide further medical information prior to seeing them. The self certification process was brought in for sport divers in 1999 after a review of the previous system of regular medical examinations was shown to have a very low pick up of problems. The form is reviewed and altered if necessary every 2-3 years.”

    Source location

    Response from UKDMC
    Page 1 · response
    Published 26 May 2019

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Obtaining full, unadjusted medical records for all divers is impractical because general practitioners refuse non-NHS forms.

    Verbatim wording from the response

    “As a committee, we have had a lengthy discussion about the points raised by ████████. We were all agreed that in an ideal scenario all divers or potential divers should bring copies of a full and non adjusted medical record to all consultations. However we already have a situation where our hard pressed general practitioner colleagues are refusing to sign or even fill in any forms which are none NHS work.”

    Source location

    Response from UKDMC
    Page 1 · response
    Published 26 May 2019

    Open published response
  4. North and West Cumbria

    AI-generated summary

    Carl Andrew Morris · Prevention of Future Deaths report

    This summary was generated using AI from the published report. Please read the original report for the complete account.

    Report summary

    Carl Andrew Morris died from a heart attack with an already compromised heart while diving at Wastwater on 27 January 2013. The report identified concerns that his medical certificate was not up to date for the technical diving courses and that no check was made to ensure compliance with the requirement for a certificate. It also identified a wider concern that compliance with PADI rules for technical diving courses was not effectively policed.

    Read the report on judiciary.uk

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Lack of a system to verify divers’ medical-certificate compliance before Technical diving courses

    Wider context from the report

    “(1) Diving is both a method of work and a recreational sport. There is an inherent danger in diving, particularly when a dive requires decompression stops and the use of different gases. Because of the depth of the dives the risk of death or serious harm is significant. (2) The inherent danger in Technical diving is recognised by PADI in that there is a requirement for members undertaking Technical diving courses to have a medical certificate confirming their fitness to dive. (3) In Mr Morris’s case he must have been aware of the need for a medical certificate, but omitted or neglected to ensure that his certificates were up to date for each course. No check was made to ensure that he was compliant for the Tec 50 course. (4) Where recreational divers are undertaking Technical diving courses, particularly with Instructors who know them well, there is a danger that those requirements are overlooked, and there is no system for policing compliance. (5) As PADI have recognised the need to ensure that divers, before starting a course, are compliant with the PADI rules, there should be a method devised to police the adherence to those rules. ”

    Source location

    Carl Andrew Morris · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Require current physician approval for students undertaking technical diving courses.

    Verbatim wording from the response

    “2. The inherent danger of technical diving is recognised by PADI in that there is a requirement for members undertaking technical diving courses to have a medical certificate confirming their fitness to dive.”

    Source location

    2014-0092-Response-by-PADI-Europe
    Page 1 · response
    Published 3 March 2014

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Provide Tec Diver Training Records for instructors to document training steps and medical-statement sign-off.

    Verbatim wording from the response

    “The PADI Instructor in charge of the course is responsible for ensuring that all requirements are met.”

    Source location

    2014-0092-Response-by-PADI-Europe
    Page 2 · response
    Published 3 March 2014

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Operate a Quality Management Program that monitors and responds to concerns about training omissions and paperwork.

    Verbatim wording from the response

    “PADI has the diving industry’s most robust quality management and training systems. In addition to the proactive measures described above, PADI's Quality Management Program monitors and responds to all concerns regarding omissions from training and paperwork.”

    Source location

    2014-0092-Response-by-PADI-Europe
    Page 4 · response
    Published 3 March 2014

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Existing medical-certification requirements, forms and course standards are considered sufficient to ensure current medical approval for technical-diving courses.

    Verbatim wording from the response

    “PADI provides a Tec Diver Training Record. This form allows instructors to record each step of the training, including medical requirements. It is a specific section to record the Medical Statement (signed by student and physician), with a sign off line for the instructor to add their signature.”

    Source location

    2014-0092-Response-by-PADI-Europe
    Page 2 · response
    Published 3 March 2014

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Existing standards updates, training support, student acknowledgements and quality-management processes are considered sufficient to address omissions and safety concerns.

    Verbatim wording from the response

    “Membership Agreement PADI Membership Agreement requires all PADI members to have instructor guides for all courses they teach and to keep them updated.”

    Source location

    2014-0092-Response-by-PADI-Europe
    Page 3 · response
    Published 3 March 2014

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Instructors, rather than the organisation, are responsible for ensuring course requirements are met and maintaining familiarity with current standards and procedures.

    Verbatim wording from the response

    “The PADI Instructor in charge of the course is responsible for ensuring that all requirements are met.”

    Source location

    2014-0092-Response-by-PADI-Europe
    Page 2 · response
    Published 3 March 2014

    Open published response
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Data last updated 7 September 2026