OSHA amendment to commercial

[Genesis]

Mike, I understand your point, but here's the general set of problems as I see it:

1. Any compressor used for an FO2 over 21% must be an oilless compressor. This is a problem - nearly all current commercial compressors in shops are oil-lubricated! There is no history of problems with them (assuming we're talking commercial units with air testing history) either.

2. PP blending into individual tanks is banned (if its an employee's tank.) That's nice. So now every shop must have a dedicated Nitrox bank?

3. How do you mix deco gasses? You can't PP blend into an employee tank, so how do you make 50/50? You can't "blend" into a tank, so cutting a mix (say, putting 40% into your Nitrox bank and then cutting it with air) appears to be banned TOO!

4. Continuous hydrocarbon testing is required. Even with an oilless compressor. Exactly how do hydrocarbons get in the gas output of an oilless compressor again?

The implications of this stuff look pretty ugly for the shop owners that happen to have instructors - which is like all of them! The economic impact alone of forcing shops into the VX series of Rix compressors - which this appears to do - are pretty nasty.

I'm more and more happy I bought my own fillstation.

 

[rmediver2002]

They are worried about build up over time within the equipment. The concern is for fire / explosion:

This goes much further in depth in the NOAA manual but the grade "E" requirement of less than 5 mg / m3 of oil mist was deemed not adequate and a requirement of less than .1 mg (the lowest portion detectable) was settled on.

ref. NOAA dive manual pg. 15-17 and 15-18

Jeff

 

[rmediver2002]

Genesis -- this is specifically for employees engaged in recreational SCUBA instruction or guideing, employees decompressing as a condition of work are not exempted from the commercial diving regulations and will not be with this amendment. The same hold true for mixes other than nitrox or with less than 21% oxygen...

There is nothing saying it can not be done on one's own (not as a condition of employment)

Jeff

 

[MikeFerrara]

I they enforce these regs every dive shop in the world will be out of business or they will have to rely on not having employees dive nitrox.

BTW, Genesis 50/50 wouldn't be a concer because they are limiting you to 40% or less. They also state you can't go beyond the NDL. Even if they clean this stuff up no shop could have an employee teach a technical class. Oh and if you notice trimix is a taboo. LOL. I wonder if any of the 5th-D instructors teaching triox are employees.

I read it to say that you could use oiled compressors but there was an additional list of requirements.

Hey but look at it this way, untill now it was illegal to have an employee dive nitrox without a chamber on site.

Either they are up to something dirty or they just didn't do any research into how things are done.

I could see it now Nitrox $500/tank

 

[Genesis]

I understand that.... which was why my amazement when I first saw it, to the point that I wondered if there was something odd about the Dixie Diver situation that made them "different" than the regular shops.

The idea that NOBODY can teach technical diving (for money) without a chamber on-site is, well, laughable in the context of what's been done up until now! So much for GUE eh?

CF blending is basically out of the question without an oilless compressor and even most RIX units (the SA series won't do), since NO compressor manufacturer I am aware of (NOT the repackagers such as the DNAx folks - the MANUFACTURERS such as Bauer, Coltri, Alkin, etc) will approve their oiled compressors for ANY mix that has more than 21% FO2 at the inlet. If there is an exception to this I'd love to see it - statements by some rep don't count - what is written by the manufacturer and certified as "ok" is what counts here.

This looks bad - real bad.....

 

[raybo]

MikeFerrara once bubbled...
Either they are up to something dirty or they just didn't do any research into how things are done.

My guess would be the latter. Somewhere, sometime in an inspection of an "accident" some over zealoous ureaucrat trying to scramble up the ladder took up the cuase in the name of a "safe working environment" without any comprehensive understanding of the real world situation.

In the constuction industry, a lot of what we have to abide by is the result of some idiot leaving his brain at home when he left to go to work in the morning, (or maybe with the forethought and malicious intent to defraud the insurance system) and the rest of the industry has to pay for it forever.

Not that everything that OSHA requires is not appropriate, it just seems to be inconsistent with reality in a lot of cases.

 

[rmediver2002]

It would not be a difficult stretch to meet the requirements of the science diving exemption for conducting and training of technical divers...

Technical diving is clearly outside what has come to be refered to as recreational diving...

I don't think anyone will be out of business...

Jeff

 

[raybo]

Genesis once bubbled...

CF blending is basically out of the question without an oilless compressor and even most RIX units (the SA series won't do), since NO compressor manufacturer I am aware of (NOT the repackagers such as the DNAx folks - the MANUFACTURERS such as Bauer, Coltri, Alkin, etc) will approve their oiled compressors for ANY mix that has more than 21% FO2 at the inlet. If there is an exception to this I'd love to see it - statements by some rep don't count - what is written by the manufacturer and certified as "ok" is what counts here.

So what are medical gas suppliers using? Commons sense (I know~ a foreign concept to OSHA!) would dictate that if a system/method is adequate for the medical industry, ought to be acceptable to the general public.

And it's odd that it would be OK for a customer to use the process, but not an employee.

Anybody know what the Navy process entails, and what their position on this is?

 

[rmediver2002]

Heli-ox and Nitrox are blended into banks using pure source gas.

The transfer is conducted using a manifold with O2 clean haskels.

Jeff

 

[Genesis]

are typically using RIX O2-rated compressors or Haskels to pull from the Dewers full of LOX and compress into individual cylinders.

They are available, but they're EXPENSIVE, and most of the compressors have a maximum pressure of either 2600 or 3000 psi, since "HP" oxygen tanks are typically 2015 or 2260 psi (most with the "+" or "*", giving them the 10% overfill) Haskels don't have that problem (they are typically rated for higher pressures) but they're both expensive and require a lot of drive air.

The problem is that most bank storage tanks at a dive shop are rated for 4500 PSI, so you need a compressor that can hit that number all day long in order to run up your bank, and even "straight fill" folks using no bank need to hit 3500 PSI if they expect to be able to fill HP steel cylinders.

It seems to me that the "solution" for this problem down the road appears to be for the shop to go for a Haskel-based system (as opposed to a traditional compressor) with a high volume "drive air" compressor (shop air - but in large volume.)

That's expensive (maybe VERY expensive on a volume delivered basis) but avoids any contact with potential hydrocarbons in the O2 and air sides.

The only other alternative I can see is the RIX VX series if you need high-volume operation.