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.