USCG Advisory_12-01 reference Diving Operations

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Capt Gary

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Scuba Instructor
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Location
Tavernier, Florida Keys
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New Marine Safety Advisory from USCG. Recommendations for Recreational Diving Operations Occurring from Commercial Passenger Vessels.

Good Diving,
 

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  • USCGAdvisory_12-01.pdf
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That's better than I expected. We'll have to revise some logkeeping procedures, but we have all of the briefings covered. I had a little headsup last inspection.
 
Most good ops already do all this, but the tone of this seems to put more responsibility on the Master to have written procedures on just about everything.

Has there been an increase in dive accidents? This seems to be the reason for this advisory.

The thing is, though, the captains don't do the actual diving, the divers do, and while rec. diving isn't 'regulated', this seems an indirect way to do it by leaning on licensed captains who have keep the Coast Guard (who licenses them) happy.
 
I think it's more a matter of fatality "clusters". Kinda like we had with DCS in the Flower Gardens in the late 90's. We looked at the root cause and I determined that divers were doing too many dives on air, so we made nitrox available, then we gave it away. There aren't more fatalities, in fact, DAN says we are safer than we have ever been, but we've had 4 or 5 fatalities this year in the Northeast, a couple in North Carolina, a couple in WPB, and a couple in the keys. As you know, clusters of anything tend to make regulators sit up and take notice. Especially if we haven't had any fatalities over a few years. It also seems that the CG is trying to implement some sort of "zero tolerance" system for passenger injuries. The local OCMI in Key West wants all dive vessels to carry a FRB (his words, not mine). If you know anything about FRB's, they only belong on IMO vessels, and most FRB's would be bigger than most keys 6-packs. It's kinda like the new survival craft rule. They are making regulations for problems that don't exist.

At least this is a guidance document and not a regulation. My only beef with is is that in the event of a lawsuit, the plaintiffs lawyer will use this guidance document against a master as well as the vessel owner and beat them over the head with it.

"So, Captain Wasson, why didn't you log potty training as a part of the pre-boarding briefing?"

"Well sir, I don't consider potty training to be essential safety training for divers"

"Well, Captain Wasson, the Coast Guard does, as they spell out in USCG Advisory 12-01"

Sir, I don't believe that the Coast Guard intended to have me........."

It puts the Master in a bad place. It is well written, however.
 
The problem for us is that advisory documents like this tend to become regulations.

If they really looked at the dive accidents from charter boats I would bet that in the majority of incidents nothing that the boat operator did or did not do was related to the cause. We can brief the divers and tell them what they should be doing, but sure can't control them once they jump off the boat. I cannot recall a single incident in NC when the dive boat operator caused the event other than taking them out there to go diving.

I have almost all of their list covered in my pre-departure briefing, which is a printed laminated document and used as a checklist every trip. Now it looks like when my turn comes for the boarding and inspection that they have been doing off NC I had better have a binder full of documented procedures showing that I don't forget how to run my boat. Did they even get anyone from the charter industry to help them with this or did it just pop from the either like the life raft BS?
 
The Passenger Vessel Association is giving the CG holy hell over the life raft issue. I would expect to see the regs change before 1/15. I also have a laminated list for pre-board, for departure safety, and for dive briefings. I will consider that good enough. The problem will fall when it is or isn't logged. As an inspected vessel, I'm required to keep all kinds of logs, but I've never seen it done on a day boat.
 
Maintenance logs and daily dive logs are kept but I do not keep a log of the daily operations and hope that I don't have too.
After reading the doc again I am just going to put a copy of the existing breifing materials in my Safety and Accident manual that I keep on board and call it done for now. I would bet that my local CG guys have not even heard about this. Last dive accident event (deco hit) that they dealt with me about I had to provide them the proper CG form to report it on as the only one they had was the one you use for collisions and spills. It sure made the follow up with them go faster.
 
"It is well written, however"

except for the typo - hazzards
 
Nanny mentality, their efforts to prevent ANYONE from being injured will have us all living in a padded cell and will not even come close to accomplishing that goal. This is the first step towards new regulations and the associated fines. I was using old, sturdy life rings on a saftey line and God forbid they wern't stamped USCG approved. I had one that was approved ready to be deployed in any direction on board but those extra rings were a no-no! I ended up stenciling the rings "NOT A SAFETY DEVICE" and using them anyway as they worked better that a round boat bumper or float.
 

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