PFD report

Kevin Lapwood · Prevention of Future Deaths report

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Issued 30 Apr 2026•Berkshire

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

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Concerns
5

Raised in this report

Recipients
2

Named on the report

Responses found
2

Of 2 recipients

Stated actions
17

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

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Report evidence summary

Concerns raised5

  1. Lack of requirement for HSE medical doctors to confirm advice about immersion pulmonary oedema risks
    Part of recurring concern: Failure to reliably recognise and control immersion pulmonary oedema risks in diving
  2. Insufficient awareness of immersion pulmonary oedema risks for divers with high blood pressure
    Part of recurring concern: Failure to reliably recognise and control immersion pulmonary oedema risks in diving
  3. Insufficient guidance on the duties of shore support or surface cover
    Part of recurring concern: Unsafe diving operations
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.14

  1. Action

    Review Dive Marshal guidance to incorporate explicit eyes-on-the-water requirements.

    Stated by British Diving Safety GroupStated plannedThe respondent said that this action was planned when they made their response on 25 June 2026.
  2. Action

    Revise resources to strengthen instructors’ awareness and enforcement of Diving at Work Regulations medical requirements.

    Stated by British Diving Safety GroupStated in progressThe respondent said that this action was in progress when they made their response on 25 June 2026.
  3. Action

    Rewrite shore-cover guidance defining the roles and responsibilities of shore support.

    Stated by British Diving Safety GroupStated in progressThe respondent said that this action was in progress when they made their response on 25 June 2026.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.4

  1. Position

    The relationship between the deceased and the commercial diving project falls outside the organisation’s expertise to advise on.

    Stated by British Diving Safety GroupOutside remitThe respondent said that this matter was outside its role or authority.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of requirement for HSE medical doctors to confirm advice about immersion pulmonary oedema risks

Wider context from the report

“3. I am concerned that there is currently no requirement for doctors conducting HSE medicals to confirm that they have advised patients who fail the HSE medical, for reasons similar to those in Kevin’s case, of the risks of IPO. ”

Is this part of a recurring concern?

Yes — Failure to reliably recognise and control immersion pulmonary oedema risks in diving.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient awareness of immersion pulmonary oedema risks for divers with high blood pressure

Wider context from the report

“2. I am concerned about the level of training and awareness around the risks of immersion pulmonary oedema(“IPO”) for divers with high blood pressure. Whilst the more common risks of hypertension will be better understood (such as heart attack and stroke), awareness of IPO appears to be less well understood. ”

Is this part of a recurring concern?

Yes — Failure to reliably recognise and control immersion pulmonary oedema risks in diving.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient guidance on the duties of shore support or surface cover

Wider context from the report

“3. I am concerned about whether there is sufficient guidance regarding what the role of shore support /surface cover entails. Specifically, should that include having eyes on the water? ”

Is this part of a recurring concern?

Yes — Unsafe diving operations.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient training and awareness of medical requirements for volunteer divers

Wider context from the report

“1. I am concerned about the level of training and awareness nationally – specifically of the medical requirements for volunteers involved in projects like Kevin was. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Ambiguity in legislation and guidance about applicability to volunteer divers

Wider context from the report

“1. Clarity of the approved code of practice (‘ACOP’) entitled “Recreational diving projects – Diving at Work Regulations 1997”, published in 2014, in the following respects: a. The title of the document – does this document adequately reflect that it also covers volunteers? Is there a risk that, on reading the initial heading of the document, it may be felt that it is not relevant to volunteers working in the capacity that Kevin did? b. Would the reference to “associated guidance” on the title page be better with the use of a hyperlink to guidance such as the volunteer diver guidance note? c. The definition of “diver” in the ACOP is “a person at work who dives”. The definition of “at work” is (in summary) an employee or a self-employed person. Although the guidance does go on to deal separately with those in a diving role as part of a project, there is some potential ambiguity here. For instance, it may be possible to look at the guidance on Regulation 12 which states that no “diver” shall dive in a diving project unless he has an HSE medical. If “diver” is defined as being somebody at work, then there is a risk that the regulations could be interpreted in the way it appears they were here – ie only applying to somebody who is paid. A careful reading of the guidance should make the position clearer, but I believe there is a remaining risk of misinterpretation without very careful analysis of this document. 2. All the titles of the relevant legislation and guidance refer to diving “at work”. It is easily foreseeable that someone looking at this may assume that it is not relevant for volunteers used as part of a diving project. I appreciate that naming legislation is not within the gift of the HSE, but it may be something that could be communicated in relation to future legislation, and taken into account in HSE guidance – particularly the titles of any future guidance. ”

Is this part of a recurring concern?

Yes — Unsafe diving operations.

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

Review Dive Marshal guidance to incorporate explicit eyes-on-the-water requirements.

Verbatim wording from the response

“The SAA utilizes a Dive Marshal system to monitor divers but acknowledges their current guidance does not explicitly state the phrase "having eyes on the water." They have committed to reviewing their standards to address the Coroner's specific concern.”

Source location

Response from British Diving Safety Group
Page 5 · response
Published 25 June 2026

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

Revise resources to strengthen instructors’ awareness and enforcement of Diving at Work Regulations medical requirements.

Verbatim wording from the response

“Considering the Coroner's report, PADI is actively revising its resources to heavily stress and enforce awareness of these specific DWR medical requirements. | Requires all Divemasters and Instructors to be examined and declared fit to dive by a physician prior to qualifying. SAA | Warns members that any element of reward/payment triggers DWR and voids SAA insurance. Acknowledges that commercial volunteer projects are too complex for their expertise, advising contractors to seek formal legal advice. | Utilizes the UKDMC self-cert recreational screening system (requiring medical declarations for conditions like immersion-induced pulmonary oedema).”

Source location

Response from British Diving Safety Group
Page 2 · response
Published 25 June 2026

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

Rewrite shore-cover guidance defining the roles and responsibilities of shore support.

Verbatim wording from the response

“Agency | Role Definition & Guidance Structure | Current Action / Status IANTD UK | Utilizes a historical code of conduct for instructors to bridge the gap between training standards and UK law. Demands a strict localized risk assessment for every operation. | Mandates that the surface brief must include explicit "eyes on the water" protocols, kit management, emergency plans, and verbal IPO awareness briefings. ScotSAC | Mandates appropriate shore cover for all training activities, grounding the surface team's responsibilities directly in the dive's risk assessment. | The exact text detailing the specific roles and responsibilities of Shore Cover is currently undergoing a comprehensive rewrite. SAA | Uses a Dive Marshal framework, assigning this individual complete responsibility for the dive team and the monitoring of divers for the day.”

Source location

Response from British Diving Safety Group
Page 5 · response
Published 25 June 2026

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

Form a working group to define recommended qualifications and good practices for shore cover.

Verbatim wording from the response

“As BDSG we will put together a working group to define a set of recommendations of qualifications and good practices for all shore cover”

Source location

Response from British Diving Safety Group
Page 7 · response
Published 25 June 2026

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

Publish a further immersion pulmonary oedema article and deliver a dedicated recorded webinar for professional members.

Verbatim wording from the response

“SAA | Incorporates the identification and treatment of IPO into initial and second-level diver training, as well as specialized Oxygen Administration and Emergency Diver First Aid courses. | Regularly features IPO awareness pieces in newsletters sent directly to all members. PADI | Requires professionals to read provided articles regarding IPO. | Published multiple specific articles for professional members; planning another publication later this year alongside a dedicated July 2026 webinar to be archived as a permanent resource. SSI | Has added IPO/IPE information to its Science of Diving program (a prerequisite for professional membership) and its XR (Extended Range) programs. | Covering IPO in the upcoming rewrites of Open Water and Diver Stress and Rescue course materials.”

Source location

Response from British Diving Safety Group
Page 4 · response
Published 25 June 2026

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

Review Dive Management guidance to address the concern that shore support should maintain eyes on the water.

Verbatim wording from the response

“Report #3: Agency Response BSAC Role Definition & Guidance Structure Uses 'BSAC Safe Diving Practices' code of conduct which includes having an appropriate dynamic risk assessment and a suitable Dive Management. Dive Management is integral to the BSAC Diver Training Programme training expanded on with each diver grade.”

Source location

Response from British Diving Safety Group
Page 14 · response
Published 25 June 2026

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

Integrate immersion pulmonary oedema guidance into the remaining Advanced Diver training programme as it is revised.

Verbatim wording from the response

“• Producing guidance for both Divers and Instructors on the risks, awareness, prevention and resolution of IPO.”

Source location

Response from British Diving Safety Group
Page 12 · response
Published 25 June 2026

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

Implement a UK-specific addendum training SSI professional trainers on UK Diving at Work Regulations and Approved Code of Practice requirements.

Verbatim wording from the response

“Organization | Volunteer Protocols & Project Awareness | Medical Screening & Enforcement Standards IANTD | No separate standards exist for project volunteers. Duty of care and qualification requirements are left entirely to the subjective inclinations of individual project organizers. | Dependent on localized project risk assessments and task loading. All professional members must upload HSE medicals annually. SSI | Advises UK commercial facilities that all team members should have HSE medicals, as it is highly unlikely a commercial business can legally escape the DWR. | All professionals must upload a doctor-signed medical clearance annually. SSI is implementing a UK-specific addendum to explicitly train instructors on UK DWR laws and ACOPs. PADI | Provides summaries of HSE rules upon instructor qualification.”

Source location

Response from British Diving Safety Group
Page 2 · response
Published 25 June 2026

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

Continue promoting immersion pulmonary oedema risks through incident reports, publications, online channels, conferences, guidance, training, seminars and collaboration with water-safety organisations.

Verbatim wording from the response

“Since that time BSAC has increasingly promoted greater awareness of the condition through all possible avenues including but not limited to:”

Source location

Response from British Diving Safety Group
Page 12 · response
Published 25 June 2026

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

Produce and publish volunteer diver guidance clarifying medical fitness requirements for volunteers essential to diving projects.

Verbatim wording from the response

“To address this HSE has taken several steps:-”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 25 June 2026

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 approved medical examiners of the importance of explaining diving implications of medical conditions, particularly when divers are found unfit for work.

Verbatim wording from the response

“Through our ongoing engagement with the AMEDs we will remind them of the importance of explaining the implications of medical conditions for diving, particularly where a person is found unfit to dive at work.”

Source location

Response from Health and Safety Executive
Page 3 · response
Published 25 June 2026

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

Work with PADI to promote guidance helping recreational diving members comply with the Diving at Work Regulations.

Verbatim wording from the response

“2. HSE have worked with the Professional Association of Diving Instructors (PADI) as the largest provider of recreational diver training in GB, where the instructor or other divers are likely to be at work. Since 2004 PADI have published on their own website guidance on how its members should ensure compliance with DWR. This guidance contains near identical wording to the HSE volunteer diver guidance above. http://apsto.org.uk/wp-content/uploads/2023/01/2022-Diving-at-Work-Regulations-advice-from-PADI-2022.pdf”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 25 June 2026

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

Use industry liaison and annual recreational diving trade-show attendance to educate the diving community about medical fitness requirements.

Verbatim wording from the response

“3. Through industry liaison with the British Diving Safety Group and annual attendance at recreational diving trade shows, HSE diving specialist inspectors have sought to educate the recreational diving community on the importance of medical fitness to dive and in particular the requirement for any person whose involvement in a diving project is core to the minimum legally required diving team, to be properly assessed as medically fit by holding a valid certificate of medical fitness to dive.”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 25 June 2026

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

Review and update volunteer diving guidance to provide clear, unambiguous information, taking account of the coroner’s concerns.

Verbatim wording from the response

“HSE is currently in the process of reviewing and updating its guidance including the volunteer diving guidance document. HSE is committed to ensuring that it provides clear, unambiguous guidance and will be cognisant of the matters you have raised when the ACoP is next reviewed.”

Source location

Response from Health and Safety Executive
Page 3 · response
Published 25 June 2026

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 relationship between the deceased and the commercial diving project falls outside the organisation’s expertise to advise on.

Verbatim wording from the response

“The relationship between the deceased and the commercial diving project he had volunteered to assist is not the type of event that the SAA have the expertise to advise on. Based on HSE guidance for “Using volunteers in diving at work projects” this is a complex area, and their advice is that the diving contractor should consider seek legal advice.”

Source location

Response from British Diving Safety Group
Page 10 · response
Published 25 June 2026

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 diving contractor should seek legal advice about applying volunteer safety requirements to the commercial diving project.

Verbatim wording from the response

“The relationship between the deceased and the commercial diving project he had volunteered to assist is not the type of event that the SAA have the expertise to advise on. Based on HSE guidance for “Using volunteers in diving at work projects” this is a complex area, and their advice is that the diving contractor should consider seek legal advice.”

Source location

Response from British Diving Safety Group
Page 10 · response
Published 25 June 2026

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

Specific medical guidance for divers with high blood pressure should be provided by appropriately qualified medical professionals.

Verbatim wording from the response

“ScotSAC IPO education materials are included in our core diver training which provides an overview on the condition, symptoms and treatment from an emergency perspective. Specific medical guidance/information for any members with high blood pressure would only be provided by someone with the relevant medical qualification. All diving ScotSAC members require an annual medical certificate – the validity of this is based on the information declared by members.”

Source location

Response from British Diving Safety Group
Page 14 · response
Published 25 June 2026

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 recreational diving ACoP applies only to diving projects under DWR, not purely leisure dives by members of the public.

Verbatim wording from the response

“With regards to the “Recreational diving projects – Diving at Work Regulations 1997” approved code of practice (ACoP), the title of the document reflects that it is applicable only to diving projects which come under DWR, and not to dives conducted purely for leisure purposes by members of public.”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 25 June 2026

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.3

  1. 1

    Continue compiling an incident pack to help preserve diving equipment, witness and other evidence for investigations of serious accidents.

    Stated by British Diving Safety GroupStated in progressThe respondent said that this action was in progress when they made their response on 25 June 2026.
  2. 2

    Amend messaging to advise divers experiencing immersion pulmonary oedema symptoms not to re-enter the water until obtaining medical advice.

    Stated by British Diving Safety GroupStated in progressThe respondent said that this action was in progress when they made their response on 25 June 2026.
  3. 3

    Continue monitoring and reviewing diving incidents to identify further cases involving immersion pulmonary oedema.

    Stated by British Diving Safety GroupStated in progressThe respondent said that this action was in progress when they made their response on 25 June 2026.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.1

  1. 1

    Existing medical assessment questionnaires are considered sufficient; a fitness-to-dive medical certificate is not required before participating in diving activities.

    Stated by British Diving Safety GroupExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.

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

Continue compiling an incident pack to help preserve diving equipment, witness and other evidence for investigations of serious accidents.

Verbatim wording from the response

“BDSG – Preservation of Evidence: The BDSG has created, and is continuing to compile a pack for use at an incident to help preserve evidence:”

Source location

Response from British Diving Safety Group
Page 21 · response
Published 25 June 2026

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

Amend messaging to advise divers experiencing immersion pulmonary oedema symptoms not to re-enter the water until obtaining medical advice.

Verbatim wording from the response

“3. We have also seen more evidence of divers continuing to dive after an episode of IPO and so we are amending our messaging to include: Current guidance recommends that anyone experiencing symptoms of IPO during any of these activities should avoid re-entering the water until medical advice has been obtained. It is now well understood that even mild symptoms significantly increase the likelihood of recurrence upon subsequent immersion. A likely instance of such a recurrence can be seen in the BSAC incident report (24/111)”

Source location

Response from British Diving Safety Group
Page 13 · response
Published 25 June 2026

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

Continue monitoring and reviewing diving incidents to identify further cases involving immersion pulmonary oedema.

Verbatim wording from the response

“• Continuing to monitor and review diving incidents to identify evidence of further instances of IPO”

Source location

Response from British Diving Safety Group
Page 12 · response
Published 25 June 2026

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 assessment questionnaires are considered sufficient; a fitness-to-dive medical certificate is not required before participating in diving activities.

Verbatim wording from the response

“Summary: The awareness of IPO in the UK is significant greater in the UK compared to the rest of the world. This, in part, is due to considerable efforts made by BDSG and its members in promoting the risk. The BDSG members would very much welcome the assistance of the Coroner’s Service and others (as outlined above) to help show the true extent/scale of the problem so that divers not only fully appreciate the risks associated with IPO but take the risks seriously. As outlined above, there is no screening test that can definitively determine whether an individual will suffer from IPO, but there are a number of known factors which increase the likelihood of an individual being subject to IPO. Completing either the UHMS or UKDMC medical declaration form prior to any training/diving taking place helps in identifying the known risk factors.”

Source location

Response from British Diving Safety Group
Page 25 · response
Published 25 June 2026

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026