How Rebreathers Kill People
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- Dominic Adams
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1 How Rebreathers Kill People Slide 1
2 Sources of Safety Data Failure Mode Effect and Criticality Analysis (FMECA) Incident Reports: Interview with survivors of incidents reported from dive clubs Coroner s Reports Fully Documented Fatalities Web sites maintaining partial rebreather fatality lists Forums advising of accidents, with follow up interviews where possible CCR Manufacturers reports HSE Reports IMCA Reports BSAC Dive Accident Reports DAN Accident Reports Slide 2
3 Diving Hazards and Rebreathers Slide 3 Diving is in itself a hazardous activity, with risk of fatality between 1 in 10,000 and 1 in 80,000 hours: around 1 in 9,000 diver years. The highest socially acceptable risk is considered to be the same for a woman in a developed country giving birth: a 1 in 9000 risk of a fatal outcome. Some rebreathers are more than 100 times more dangerous. The fatal accident rate on CCRs is as high as 1 in 17 units manufactured for particular rebreather models, and is around 1 in 55 on average. That is an extraordinarily high risk. Risks posed by diving are catalogued in The Physiology and Medicine of Diving, P. Bennett & D. Elliott (4 th Edition). CCR diving entails a much higher level of risk than Open Circuit diving, from DAN, HSE and BSAC reports. This implies there are additional hazards not listed by Bennett & Elliott. The increased risk of CCR diving is not explained by lack of training: CCR divers tend to be much more experienced and trained than the Open Circuit divers. In FMECA reviews of third party CCR designs, a strong correlation between design defects and the accident rate of any particular rebreather was observed: that is, between a low MTBCF and a high fatality rate. This report considers some of the reasons why that risk is so high and how it can be reduced.
4 FMECA Reports Requirement of EN14143 that manufacturers perform a FMECA No requirement within EN14143 to publish results Hence most manufacturers are keeping their report confidential, if it even exists EN14143:2003 requires compliance with EN 61508, which in turn requires 1 billion hour fault tolerance, but is not implemented by manufacturers (CE Marks are being put on equipment falsely). In 2013 manufacturers succeeded in removing Functional Safety compliance from the CE process: compliance with IEC EN was removed from EN 61508, against the advice of many safety specialists. Users and Government Safety Organisations are turning a blind eye to the death rate. Result is no pre-2011 rebreather can tolerate one worst-case failure Result is users have not the faintest idea of the safety of what they are diving Result is no-one can challenge wrong conclusions in a FMECA Result is there is no FMECA data on which to build better systems Recommendation: All manufacturers selling any piece of life critical equipment to the public should publish the full FMECA Report on their web site along with the EN calculation and safety case. Slide 4
5 Incident Reports Incidents 1 to 10 are from one dive club. Incidents 11 to 20 are from fatality or serious accident reports. 1. Computer decided to do a cal underwater, all on its own 2. Rebreather controller hanging 3. Displaying wrong PPO2 values when all sensors are working 4. Sudden massive flood, including CO2 hit and caustic cocktail 5. All O2 sensors failed 6. Mistakenly injecting O2 on descent instead of diluent 7. Loss of diluent on descent 8. O2 injector sticks on 9. Connector mismated: flood 10. Manifold O ring fails 11. CO2 retention due to increase in Work of Breathing caused by fitting faulty component 12. CO2 hits due to scrubber failure 13. Unit not switched on 14. PPO2 falls below that required to sustain life due to slow O2 sensors 15. O2 injection rate insufficient for ascent: this is an error in EN14143: PPO2 set point allowed to be lower than that required for safe ascent 17. Errors in O2 sensor calibration 18. Bugs in decompression software 19. CNS toxicity 20. Use of uncalibrated O2 Slide 5
6 Incident 1: Jump to Cal Location: Scapa Flow, May Dive Profile: Diving to 100ft, displays showed PPO2 at set point of 1.3. Incident Report: I heard O2 injector come on and stayed on all of its own accord. Looked at handset. It had jumped to performing a calibration and was injecting pure O2. Bailed out. No alarms. Cause: System checked by qualified electronics engineer. Slide 6 Unused memory locations were random codes when they should have been a jump to a recovery point. There was no Watchdog Timer installed. The Brown-Out Circuit was tested and design found to be completely ineffective. Power supply circuits were prone to brown out. Manufacturer advised, corrected shortcomings on new product, but did not recall any product. These faults were not disclosed to coroners investigating deaths, in circumstances where the Coroner may have concluded the CCR controller was the cause if disclosure was made. Recommendation: CE requirements need to be enforced: application of EN 14143:2003 and its requirement to meet EN 61508, would have prevented these deaths. Alas: The Industry response to this recommendation was to remove all Functional Safety (EN 61508) requirements from the European rebreather standards, and create an industry body (RESA) to justify the unjustifiable, and create slander sites targeting whistleblowers.
7 Incident 2: Hanging Computer Location: Scapa Flow, June Dive Profile: Diving to 110ft, displays showed PPO2 at set point of 1.3. Incident Report: It occurred to me that the O2 injector was not firing (it was silent for too long). Did a flush. Displays stayed the same. Did not respond to buttons. Concluded computer had hung. No alarms sounded. Tried switching off and back on. Computer insisted on calibrating sensors. On cal, computer injected pure O2 even though depth was 110ft. Bailed out. If I had not been listening for the O2 injector, I would be dead. Cause: System checked by qualified electronics engineer. Unused memory locations were random codes when they should have been a jump to a recovery point. There was no Watchdog Timer installed. The Brown-Out Circuit was tested and design found to be completely ineffective. Power supply circuits were prone to brown out. Manufacturer advised, corrected shortcomings on new product, but did not recall any product These faults were not disclosed to coroners investigating deaths, in circumstances where the Coroner may have concluded the CCR controller was the cause if disclosure was made. Recommendation: CE requirements need to be enforced: application of EN 14143:2003 and its requirement to meet EN 61508, would have prevented these deaths. Slide 7
8 Incident 3: PPO2 Falls Location: Leith Dock, October Dive Profile: Quayside Incident Report: When injector fires, display PPO2 drops due to current drain. Almost new batteries. System then keeps injector on for too long, so PPO2 level seesaws. Cause: Engineers from two companies each specialising in dive safety were present. Problem caused by lack of screening on O2 sensor cables and poor power supply circuit. Manufacturer advised, investigated but declined to fix problem. Recommendation: Publishing FMECA would have highlighted the problem. Slide 8
9 Incident 4: Sudden Flood Location: Lower Clyde, June Dive Profile: Deep Support Diver for an extremely deep dive Incident Report: Sudden massive flood and CO2 hit. Caustic cocktail inhaled, lots of it. Difficult getting back to surface and staying on surface due to loss of buoyancy because of flood. When CO2 hit, under influence of CO2 hit, caustic cocktail in mouth but hallucinated it was in nose. No warning headache. Became a critical situation. Averted by last second bail out. Due to CO2 did not think of dropping my weight belt. Forums and bulletin boards contain a number of similar reports. Cause: Caused by inadequate keying of hose: unit passes pressure tests with hose rotated and not in keyed position, if hose nut is tightened down. However, a bump on the hose causes it to fail with water pouring into the scrubber. The hose keying is a serious design fault. Manufacturer advised, disregarded problem. Charged for service of rebreather, writing Not dishwasher proof on inside of scrubber lid after user completely stripped it down and tried a dishwasher to remove caked on caustic chemicals. Early warning of a flood (gurgle) not covered in course. Recommendation: An FMECA should have highlighted the problem. This indicates that no adequate FMECA was carried out. The manufacturer has sinced changed their training procedure and manuals to highlight the effect of a flood. Slide 9
10 Incident 5: Multiple O2 Sensors Fail Location: Dunbar, August Dive Profile: To 160ft, Beside Bass Rock Incident Report: One O2 sensor failed during dive (lower than others). Running on 2 sensors. Then injector was injecting more often than I would expect given constant depth. Flush indicated PPO2 was different to what I expected, but not massively. I made an error in this due to narcosis. Concluded (incorrectly) that O2 injector was firing more often due to blockage in O2 line. Aborted dive remaining on closed circuit. During ascent suddenly injector firing problem cleared. Descending again caused injector problem to return. Remaining O2 sensors had both developed a ceiling fault at the same time. Based on depth and set-point at which injector was working normally (25ft, PPO2 of 1.2) I recognised this as a ceiling error on the other two cells. Cause: Unsafe O2 injection algorithm: PPO2 was far above the normal PPO2 that was displayed. How far above was unknown. It could be from 2.5 bar to 5 bar! Replacement of all cells at the same time is a bad practice. Voting logic is prone to follow cell failures. Recommendation: A fault tolerant PPO2 controller is mandated in Europe, but the law is not applied. Cells should not be replaced at the same time. CCRs should not use voting logic for O2 controllers to substitute for a properly designed sensor management subsystem. Slide 10
11 Incident 6: Injecting O2 Accidentally Location: Dunbar, September Dive Profile: To 130ft, Beside Bass Rock Incident Report: Was very tired that day as I had had a lot of hassle. Still thinking about it during start of dive. Thought alarm was from another diver who had something bleeping (boat load going down together). Before I saw the bottom, felt very bad and left eye was twitching then left eye closed out (like seeing a curtain come down half way and what was left was in negative colour). Saw handset with other eye which was normal. Rebreather was full of O2, instead of DIL. Bailed out and simultaneous did max rate ascent to 20ft. Ascent so fast it was off scale of dive computer, a Cochran, which locked out afterwards. Then from 20ft slow ascent to surface. Took about 10 minutes for eye to return to normal. Cause: User kept pressing O2 button instead of dil button on descent. Recommendation: Would have been avoided if Auto Shut-Off valve fitted. Question on why O2 manual button is needed. Requires clearer alarms, such as voice annunciation. Slide 11
12 Location: Dunbar, September Incident 7: Loss of Dil Dive Profile: To 60ft Incident Report: Dil injector came off during descent. Descent accelerated while trying to turn on bail out gas to bail out reg. Hit the bottom so hard it formed a mushroom cloud in the water. Fortunately only 60ft. Embarrassing minute. Had been concentrating on turning on bail out gas (switched off because I did not want freeflow on diving into the water), rather than filling the BCD which I should have done: when in a real squeeze, you get tunnel focus on breathing rather than depth. Cause: Dil connector not plugged in properly and requires only one action to disconnect. No ADV fitted by rebreather manufacturer. Recommendation: Suggested to manufacturer and to forums that an ADV be created. Many disagreed with need for ADV with connector that is not plug-in. Slide 12
13 Incident 9: Connector Unplugs Location: Scottish West Coast, May Dive Profile: To 90ft Incident Report: Flood. After an earlier flood event, I had changed the original BCD to OMS 110lb dual wing, so no problem with buoyancy, so was able to do instant bail out with no buoyancy problems. Cause: Connector at the back of the unit: connector seals before it has positive ident. This allows unit to pass all negative and pressure tests with connector not properly engaged. Recommendation: Where connectors are used in the breathing loop, they must not seal until locked. Slide 13
14 Incident 8: O2 Injector Stuck On. Location: Scapa Flow, April Dive Profile: To 110ft Incident Report: O2 alarms went off. Injector was firing continuously. Cause: Injector stuck on, after first stage changed without changing interstage pressure. Solenoid Injectors fail too easily. Solenoid not designed for life critical systems. Recommendation: Cheap solenoid injectors designed for machine automation should not be used for rebreathers as they are prone to rust and cannot tolerate the full range of intermediate pressures provided by dive first stage regulators in common use. The injector should be made from a rust free material, with reasonable oxygen compatibility, such as SS 6ML. Iron parts should be coated to prevent corrosion, e.g. with DLC. Whole question of whether solenoids are suitable at all for control of PPO2 in a rebreather. Slide 14
15 Incident 10: Manifold Ring Fails. Location: Swimming Pool, Edinburgh Dive Profile: To 12ft Incident Report: Lots of bubbles suddenly. Rotating around I could see it was from back of the unit. Manifold cap came loose. Just swam back on the surface. Rarely use the manifold. Removed it now permanently: it is completely unnecessary. Cause: Superfluous manifold, created additional failure points. Recommendation: FMECA had failed to remove all non-essential points of failure. Slide 15
16 Incident 11: WOB Failure Location: Bushman s Hole, South Africa Dive Profile: To 900ft Incident Report: See Report on Dave Shaw fatality on and analysis of fault on Cause: Fitting incorrect scrubber filter material. Recommendation: Fit a Respiratory Monitor, so when respiratory rate becomes too high, or tidal volume too low, warn the user to breathe more deeply and slowly. Same monitor could detect increase in WOB at outset. Deep Life have a WOB monitor using the same hardware components as scrubber monitor. This means that adding a WOB monitor does not cost a cent more in terms of hardware build. Could be useful to fit a fan as an emergency assisted WOB, and this can double up as a breathing-bag-drier during battery recharge. Slide 16
17 Incident 12: CO2 Hits Location: Numerous reports, including a fatality by group preparing for 2 nd dive on HMS Dasher. Dive Profile: Occurs usually during decompression Incident Reports: and Cause: Scrubber expires and no alarm. Manufacturer had not published adequate information to assess the suitability of the scrubber for deep dives. In fact, scrubber duration was a tiny fraction of that expected, because the manufacturer's duations were for a 40m profile not 40m flat or flat for other depths. Recommendations: 1. Fit a CO2 alarm 2. Fit an effective scrubber life monitor 3. Redesign the scrubber so it does not fail suddenly, but gradually, giving time for the alarm to sound and for the diver to take corrective action. Slide 17
18 Incident 13: Unit not turned on Location: Several deaths where the unit has been found to be switched off Dive Profile: Not applicable Incident Reports: List of fatalities maintained on Diver Mole web site Cause: User error and design omission Recommendations: 1. All eccrs should turn on automatically when PPO2 is less than When the unit is switched on automatically, it is essential the design is one where it cannot hang under any possible circumstance. Therefore the user should never need to switch it off underwater. Slide 18
19 Incident 14: PPO2 falls below that required to sustain life due to slow O2 sensors Location: Found using formal verification tools checking O.R. design, reported on a dive forum, then users of existing rebreathers reported near fatal accidents due to use of slow sensors. Dive Profile: Rapid ascent Incident Reports: On dive forums Cause: User error and design limitation Recommendations: 1. The sensors should be keyed so users cannot change the sensor type 2. The control software should check the rate of change of the sensors during cal and reject slow sensors. No existing CCR did this: it was possible to pass cal on all rebreathers that were checked, using sensors with 25 second response of the 11 possible O2 sensor failure modes result in a low PPO2 reading or a slow sensor reading. The sensor voting algorithm can track this. The sensor processing should test for slow O2 response. 4. Use of an Auto Shut Off Valve safeguards the user in the event of this fault Slide 19
20 Incident 15: O2 injection rate insufficient for ascent Location: Found using formal verification tools checking O.R. design, then cross checked with existing rebreathers and found to correlate with high fatality rate on particular units Dive Profile: Low PPO2 set point followed by rapid ascent. Incident Reports: On dive forums Cause: Design limitation Recommendations: 1. EN 14143:2003 needs a work around to comply with the standard while allowing the CCR to inject more than 6 litres per minute of O2 in emergency. One work around is to fit multiple injectors (as in the O.R. design). 2. Manufacturer must allow ascents up to 350ft/min (max possible with an inflated BCD), from the maximum depth and with the lowest PPO2 set point supported by the CCR. 3. Auto Shut Off Valve would have prevented the deaths caused by this fault. Slide 20
21 Incident 16: PPO2 set point allowed to be lower than that required for safe ascent Location: A distinct variant on Incident 15: Found again using formal verification tools checking O.R. design, then cross checked with existing rebreathers and found to correlate with high fatality rate on particular units Dive Profile: Low PPO2 set point followed by rapid ascent. Incident Reports: On dive forums Cause: Design error on particular rebreathers Recommendations: 1. The min PPO2 set point when shallow, must allow the diver to pop to the surface without the PPO2 falling below 0.21 Slide 21
22 Incident 18: Bugs in decompression software Location: Multiple locations Dive Profile: Deco dives Incident Reports: Analysis of statistically high incidence of DCI on rebreathers, followed by formal verification of dive software in the O.R. project which compared results with those from several sources. No direct link, but strong indicator of link Cause: Failure to follow mandated design procedures Recommendations: All decompression software should be formally verified to prove that the algorithm implemented is actually that intended. Decompression computations should not be corrupted or reset in the event of a full reset underwater (e.g. a battery disconnect and reconnect). The PPO2 used by the dive computer lowest PPO2 that the sensors are measuring, not the mean or the highest. Slide 22
23 Incident 17: Errors in O2 sensor calibration Location: Red Sea Dive Profile: Deco dive Incident Reports: Reported and discussed on RebreatherWorld. Note of much higher DCI incidence with CCRs than expected statistically. Cause: User error and design omission, allowed the user to calibrate the CCR as if it was 98% O2, when PPO2 level in the loop could have been as low as 48%. Result was Cat III DCI. Recommendations: 1. All O2 sensors should calibrate in air when the unit is open: users should not be asked to calibrate with a gas supply which may not in itself be calibrated, injecting an uncalibrated amount of gas into an uncalibrated loop volume (the procedure used by the manufacturer). Slide 23
24 Incident 19: CNS toxicity Location: Multiple Dive Profile: Long dives Incident Reports: 6 accidents involving of CNS convulsions. See and Cause: Incorrect use of CNS calculation. Original papers describing CNS calculation is based on a 4% reduction in vital capacity with 100% CNS loading (Oxygen Toxicity Calculations. E. Baker). NUI research paper indicating 1% of users having CNS toxicity effects at 75% CNS loading. Despite this, users believe they can tolerate 100% CNS loading as a basic plan: some report regular dive planning with 175% and 250% CNS loading. Recommendations: 1. Modified CNS algorithm, with margin to reduce statistical incidence of measurable CNS damage. Published on DL Web Site, and on RebreatherWorld, with formal model to enable implementation to be verified 2. CCR controller should track CNS and maintain within safe limit by adjusting PPO2 set point if necessary Slide 24
25 Incident 20: Low FO2 in O2 Cylinder Location: Singapore and UK Dive Profile: Not applicable Incident Reports: RebreatherWorld one incident reported through dive club Cause: User error and design omission allowed user to dive with 60% O2 in cylinder used as 100% O2. Almost a fatality in both cases. Recommendations: 1. Rebreather itself should check the O2 composition before every dive. It has calibrated O2 sensors (if the recommendation to force calibration in air is adopted), and can inject O2 and check the composition of the loop gas on the surface to give an injector cal. It is not difficult to compensate the injector cal for depth, such that no gas switch can introduce a low FO2 gas 2. Auto Shut Off Valve would have prevented the problem affecting the diver s safety 3. Voice annunciation of the resulting low PPO2 level would have prevented the problem affecting the diver s safety Slide 25
26 Other Reports No coordinated central body receiving information on rebreather deaths. Diver Mole is doing a good job for Inspiration, but list very incomplete, and sometimes puts down to user error what is equipment failure. For example, Ian Smith died almost certainly from Incident 2. The two divers resuscitated were hit by Incident 1. Too many reports simply cite User Error. Needs to be a change of attitude to: Nobody dies on a rebreather from user error, unless they take the mouthpiece out of their mouth and do not replace it with something. Diver Mole s List of Inspiration Fatalities is: Slide 26
27 Preventing the Deaths 1. Rebreathers currently are nowhere near the standard expected of other life critical systems. 2. Most manufacturers use staff with no Functional Safety training, to design life critical systems, including the electronics and software in rebreather control. 3. Open review and fitting better safety systems could have prevented all of the incidents reported here. 4. Technologies are available that would have prevented every one of the incidents cited here. 5. That means people are dying because equipment is designed badly, with inadequate safeguards. 6. Manufacturers are split: a few respond quickly to safety issues, others oppose safety initiatives. The worst units described here, that reset and hang, have never been recalled. 7. The four sports rebreather manufacturers with the worst safety records try to gag Safety Professionals by sponsoring trolling and slander web sites against them. Those same manufacturers campaign for standard organisations to drop Functional Safety requirements for rebreathers. 8. It is left to the diver to be aware. Slide 27
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