Interesting discussion. Knowing the requirements of the AAUS scientific diver status, I've never been confused by the difference between what AAUS certified divers do and what others divers doing scientific research or monitoring (and that includes myself since although I am a marine ecologist PhD and dive largely to further my research and educational efforts, I am not AAUS certified). When the Catalina Conservancy Divers group became affiliated with the USC Marine Science Center here on Catalina, their divers were required to certify under AAUS.
There is not such thing as AAUS Certification, there are only institutional rules. In this case the Catalina Conservancy Divers were brought under the auspices of the USC Marine Science Center, an organization that has, for a long time, maintained rules and regulations that were in compliance with the guidelines of the AAUS.
I would think that the distinction between the AAUS certified divers and other divers doing scientific or conservation work while diving should be an easy one to make (even for a governmental agency). If the divers involved are AAUS certified, then they fall under that aegis... if not, any incidents become statistics attributed to the general population of divers but NOT those who are AAUS certified.
It is an easy distinction to make, however, a hard one to maintain within the legal system. The example of the Catalina Conservancy Divers is a good example. If the Catalina Conservancy Divers were to have had an accident prior to their establishment of an AAUS relationship the ensuing lawsuit would attempt to use the AAUS standards to point out how the Catalina Conservancy Divers were not operating up to the standard of practice of the community. It is singularly dangerous for any institution or organization to permit their personnel, volunteer or otherwise, to operate outside of the AAUS framework until such time as they are able to clearly establish that they have a standard of practice that is equally or more protective.
Thal...
Your statistical citation is a red herring and explains nothing, much less prove "a very real likelihood". You are comparing a small population of "professional" research divers to the global population of all recreational divers everywhere. The differing variances alone would likely exclude comparison of the two populations. What is the incident rate for recreational divers with similar training and experience? More precisely, what is the incident rate for volunteers in research diving for scientific organizations not regulated by AAUS protocols versus volunteer divers in AAUS programs? Can you demonstrate a potential harm to AAUS organizations through a statistically significant difference in incident rates between AAUS controlled volunteers and volunteers under other scientific programs? If not, you entire argument is scatology.
I am simply making precisely the same comparison that OSHA made in deciding that the research diving community could continue to operate under it's existing consensual standard. Whether that is statistically valid, or good science, or not, is not particularly relevant ... this is politics not science. The fact remains that there are different standards for science divers and for recreational divers and that they have, by a set of OSHA promulgated definitions, been severed into two separate and distinct populations by those definitions. If you feel as strongly about this issue, as you seem to, I suggest that you work to get the OSHA exemption changed. I spent ten years of my life working to get the best result that would could, if you can do better, knock yourself out.
I would point out several items, however:
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... OSHA fines are small and a willingness to turn on a dime and change in order to comply with OSHA usually takes care of OSHA. This is not a question of OSHA rules and OSHA sanctions, this is a question of the use of OSHA rules to define, in the minds of judges and jury members, what the proper procedures for minimizing risks are.
- I am not comparing to the global population of all recreational divers everywhere. I are only concerned with the comparison of American research divers (which includes foreign research divers in US waters to recreational divers in US waters.
- I am not partitioning either American research divers nor recreational divers into subgroups, that is not my problem. If you have a need to do so, please do so, but it is irrelevant to this discussion unless you can make the case that some such sub-group (such as your "volunteers in research diving for scientific organizations not regulated by AAUS protocols," or perhaps "SSI certified, left handed, brown haired, blue eyed volunteers") is protected by an equally effective or superior set of safety standards. If you are permitted to pare the recreational diving community down to a precious few, then, of course, you can come up with any predetermined level of risk, but that is not real nor rational. The fact is that in over thirty years of involvement in the administration of scientific diving programs I never had an applicant for research diver status, who was formally trained according to what are now AAUS standards, who was not acceptable to me; however, during that same period of time I only had a single diver who credentials were solely recreational in nature, that I could bring aboard without remedial work.
The OSHA exemption the research divers have is analogous to OSHA's VPP in industrial applications. A facility may be exempted from the normal enforcement scrutiny by enlisting in the VPP, then demonstrating an increased safety performance level, and then maintaining the program. It's not a new and wondermous concept that only exists in the underwater realm; industrial facilities all over the US enjoy a similar benefit. OSHA does not apply an accident at facility X to all the other facilities that are similar to X. They're pretty smart folks and can tell a bad apple from a good one. They would use the direct comparison I requested above rather than misleading anecdotal information.
VPP's are fine, but somewhat different, and in any case irrelevant here because, as I pointed out above, the only real importance of the OSHA regulations is that it creates a standard of the community: either AAUS rules or OSHA rules, there is no alternative. If you can create one, more power to you. But until you do, you're just pissin' into the wind.
That said, I think you are missing my point. Your overt paranoia about your specific exemption immediately led me to believe that by volunteering I might somehow negatively impact scientific divers, which would harm the research organizations we would be looking to support. I am certain other people got the same impression. This perception that volunteers would irreparably harm the research diving community defeats the whole purpose of the OP seeking opportunities for volunteerism in diving. It's the proverbial wet blanket, and is a disservice to both volunteers and prospective organizations that would benefit from the services of qualified volunteers.
It is hardly paranoia, and I'm hardly missing the point. I understand your point, which is not germane, as I have pointed out repeatedly. That is an easy accusation for you to make, since you have no skin in the game. It doesn't really effect you. You think that I should stand idly by whilst you can any risks that you want with my community's future and if it does go bad, well ... it doesn't even cost you a "oops, sorry 'bout that." Well ... sorry 'bout that, 'aint gonna happen.
Until you bring about the changes that you desire in the OSHA regulations, or establish an accepted VPP, you're just out spending someone else's money ... and that's not right.