Ladydiver, I'm not sure this is the appropriate place for this thread, but it's the best place I can find. If you feel it should be moved into the Instructor's Forum, please do so, but please also give me access (I wasn't able to gain access, or even to address this with the administrator via the forum paths that I found).
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My purpose here is to point out that the OSHA exemption from the Commercial Diving regulations for scuba instructors appears not to apply to Technical Diving Instructors. I testified in the Oregon hearings on the commercial diving regulations in 1978, and the instructional agencies (I was a member of NAUI) wanted to ensure that scuba instructors were not included in the commercial diving regulations. One other group, the scientific diving community, also did not wish to be included. But the two organizations went about it differently, and so today the scientific divers (under AAUS) have a much broader exclusion to the commercial diving regulations than do scuba instructors. Here are the exclusions:
They also have the following definitions in the code:
The full Commercial Diving code can be viewed at:
http://www.cbs.state.or.us/external/osha/pdf/rules/division_2/div2_t.pdf
This is Oregon's version, but it is virtually identical to (with one exception, in the definitions) the federal code.
What does this mean? Well, to me it means that Tek diving instructors, and their schools, are not exempt from the OSHA Commercial Diving regulations. They are operating outside the specific exemption for diving instructors, and therefore need to comply with all the provisions in the code, including the provisions for qualifications for dive teams, a safe practices manual, and emergency procedures, including on-scene recompression capability in a recompression chamber for deep, decompression dives.
To my knowledge, this code has never been put into effect for Tek diving, and it probably won't either. But, what may happen is that an accident leads to an OSHA complaint, which then leads to an investigation, which will discover that the Tek diving instructors are outside the provisions of the OSHA scuba instructor's exemption, by the very nature of Tek diving.
What I'm trying to show here, before someone gets burned badly, is Tek diving instructiors/charters need to be Doing It Really Right (D.I.R.R., and yes, it is a play on the acronym). This includes making your profession legal before the regulatory agencies charged with overseeing workplace safety, Federal OSHA. It also includes making provisions for emergency procedures that can save lives, such as having an on-scene recompression chamber. If Tek divers are going to push the limits, they need an out other than to call the Coast Guard and await a helicopter for a rescue, which may well arrive too late.
SeaRat
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My purpose here is to point out that the OSHA exemption from the Commercial Diving regulations for scuba instructors appears not to apply to Technical Diving Instructors. I testified in the Oregon hearings on the commercial diving regulations in 1978, and the instructional agencies (I was a member of NAUI) wanted to ensure that scuba instructors were not included in the commercial diving regulations. One other group, the scientific diving community, also did not wish to be included. But the two organizations went about it differently, and so today the scientific divers (under AAUS) have a much broader exclusion to the commercial diving regulations than do scuba instructors. Here are the exclusions:
§1910.401 SCOPE AND APPLICATION.
(a) Scope.
(1) This subdivision (standard) applies to every place of employment within the waters of the United States, or within any State, the District of Columbia, the Com-monwealth of Puerto Rico, the Virgin Islands, American Samoa, Guam, the Trust Territory of the Pacific Islands, Wake Island, Johnston Island, the Canal Zone, or within the Outer Continental Shelf lands as defined in the Outer Continental Shelf Lands Act (67 Stat. 462, 43 U.S.C. 1331), where diving and related support operations are performed.
(2) This standard applies to diving and related support operations conducted in connection with all types of work and employments, including general industry, construction, ship repairing, shipbuilding, shipbreaking and longshoring. However,this standard does not apply to any diving operation:
(i) Performed solely for instructional purposes, using open-circuit, compressed-air SCUBA and conducted within the no-decompression limits;
(ii) Performed solely for search, rescue, or related public safety purposes by or under the control of a governmental agency; or
(iii) Governed by 45 CFR Part 46 (Protection of Human Subjects, U.S. Depart-ment of Health and Human Services) or equivalent rules or regulations estab-lished by another federal agency, which regulate research, development, or related purposes involving human subjects.
(iv) Defined as scientific diving and which is under the direction and control of a diving program containing at least the following elements:
(A) Diving safety manual which includes at a minimum: Procedures covering all diving operations specific to the program; procedures for emergency care, including recompression and evacuation; and criteria for
diver training and certification.
(B) Diving control (safety) board, with the majority of its members being active divers, which shall at a minimum have the authority to: Approve and monitor diving projects; review and revise the diving safety manual; assure compliance with the manual; certify the depths to which a diver has been trained; take disciplinary action for unsafe practices; and, assure adherence to the buddy system (a diver is accompanied by and is in continuous contact with another diver in the water) for SCUBA diving.
They also have the following definitions in the code:
No-decompression limits: The depth-time limits of the no-decompression limits and repetitive dive group designation table for no-decompression air dives, U.S. Navy Diving Manual or equivalent limits which the employer can demonstrate to be equally effective.
Scientific diving means diving performed solely as a necessary part of a scientific, research, or educational activity by employees whose sole purpose for diving is to perform scientific research tasks. Scientific diving does not include performing any tasks usually associated with commercial diving such as: Placing or removing heavy objects underwater; inspection of pipelines and similar objects; construction; demolition; cutting or welding; or the use of explosives.
SCUBA diving: A diving mode independent of surface supply in which the diver uses open circuit self-contained underwater breathing apparatus.
The full Commercial Diving code can be viewed at:
http://www.cbs.state.or.us/external/osha/pdf/rules/division_2/div2_t.pdf
This is Oregon's version, but it is virtually identical to (with one exception, in the definitions) the federal code.
What does this mean? Well, to me it means that Tek diving instructors, and their schools, are not exempt from the OSHA Commercial Diving regulations. They are operating outside the specific exemption for diving instructors, and therefore need to comply with all the provisions in the code, including the provisions for qualifications for dive teams, a safe practices manual, and emergency procedures, including on-scene recompression capability in a recompression chamber for deep, decompression dives.
To my knowledge, this code has never been put into effect for Tek diving, and it probably won't either. But, what may happen is that an accident leads to an OSHA complaint, which then leads to an investigation, which will discover that the Tek diving instructors are outside the provisions of the OSHA scuba instructor's exemption, by the very nature of Tek diving.
What I'm trying to show here, before someone gets burned badly, is Tek diving instructiors/charters need to be Doing It Really Right (D.I.R.R., and yes, it is a play on the acronym). This includes making your profession legal before the regulatory agencies charged with overseeing workplace safety, Federal OSHA. It also includes making provisions for emergency procedures that can save lives, such as having an on-scene recompression chamber. If Tek divers are going to push the limits, they need an out other than to call the Coast Guard and await a helicopter for a rescue, which may well arrive too late.
SeaRat