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I'd never be responsible for putting a diver in contaminated water with just an AGA. I'll have to check, but if memory serves, NOAA rules do apply (at least technically).
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Having now read OSHA Standards-CFR 29, section 1910 as it pertains to "commercial diving" and in particular, surfaced supplied air and SCUBA, it is clear that the spirit (if not the letter) of these OSHA regs are intended for hard hat diving operations and not for mom-and-pop dive services performing hull cleaning of pleasure craft in marinas.Those federal sections (actually state adopted equivelants) apply to fstbttms as well. Too bad he doesn't know it yet.
I'm amazed that EPA's team does that, that violates NOAA rules for contaminated water diving ... even positive pressure AGA's don't cut it ... you need a Superlight mated to the suit with doubled exhaust wiskers.
What are the criteria for contaminated water? It sounds like most of you consider harbors to fall into this category. I can't speak for any place but California, and San Francisco Bay in particular, but I certainly do not consider these bodies to be "contaminated". Are they pristine? No. But niether are they impaired to the point where Haz Mat gear need be used.I have never used the Cressi mask as shown in the attached photo, but I agree that since it looks like a modified gas mask (kind of like the Mantis) I would not use it in icky water.
That's why God and the IRS invented the Independant Contractor.As far as acute issues ... if one of your employees as much as came down with a cold, you're hanging out in the breeze on a workman's comp claim, and under some circumstances you could be facing the unlimited liability of the Jone's Act.