sign in sign up
<<
Home , Commercial diving

COMMERCIAL DIVING OPERATIONS DURING SALVAGE AND RESPONSE OPERATIONS1

James E. Elliott Seventh Coast Guard District (mr) 909 SE First Avenue Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 Miami, Florida 33131

ABSTRACT: Oil spill response personnel encounter diving contractors meet the applicable OSHA and USCG commercial diving operations during salvage and pollution commercial . This provision is also a response operations. During an oil spill or hazardous substance requirement of companies awarded a Basic Ordering Agreement release, the National requires that response (BOA) for pollution response operations. To obtain a BOA, operations, including commercial diving operations, be commercial diving contractors "self-certify" that they perform conducted in accordance with the requirements, standards, and services in accordance with the required OSHA and USCG regulations of the Occupational Safety and Health regulations. Responders must still conduct a summary inspection Administration. Additionally, the Coast Guard requires that of the actual on-site diving operation to confirm that commercial commercial diving contractors meet their own commercial diving diving personnel, operations, and equipment meet the applicable regulations (46 CFR 197) during response operations. Incident regulations. commanders and safety officers should ensure that an inspection Incident commanders and safety officers should ensure that an of the on-site diving operation is conducted to confirm that inspection of the on-site diving operation is conducted to confirm commercial diving personnel, operations, and equipment meet the that commercial diving personnel, operations, and equipment applicable regulations. This technical paper provides guidance to meet the applicable regulations. This technical paper provides response personnel on the inspection of commercial diving guidance on the inspection of commercial diving operations operations during marine response operations and an overview during marine response operations and an overview of the of the equipment used to protect divers in contaminated waters. equipment and procedures used to protect divers in contaminated Additionally, this guidance provides to facilitate the waters. Additionally, this guidance provides checklists to inspection of commercial diving operations to protect the health facilitate the inspection of commercial diving operations to and safety of commercial divers. protect the health and safety of commercial divers.

Introduction Background

Oil spill response personnel will typically encounter Historically, the USCG focused its inspection of commercial commercial diving operations during the oversight of salvage and diving operations to those related to the offshore oil industry in pollution response operations. During an oil spill or hazardous the . Qualified offshore marine inspectors substance release, the National Contingency Plan (40 CFR 300) typically conduct these inspections. Recent commercial diving requires that response operations, including commercial diving operations associated with submerged oil recovery and salvage operations, be conducted in accordance with the requirements, operations, however, created the need for guidance to marine standards, and regulations of the Occupational Safety and Health response personnel on how to perform an inspection and Administration (OSHA). In general, the OSHA diving standards oversight of a commercial diving operation. (29 CFR 1910.401-441) apply to all commercial diving In 2002, the Seventh Coast Guard District in Miami, Florida, operations that take place in U.S. waters. Additionally, when published regional guidance on commercial diving operations that diving in contaminated waters, commercial divers must meet the included the following summary to facilitate the requirements of the Hazardous Waste Operations and Emergency inspection of commercial diving operations to protect the health Response (HAZWOPER) standards of 29 CFR 1910.120. and safety of commercial divers. The regulatory checklist has U.S. Coast Guard (USCG) policy also sets an expectation for proven effective in the Gulf of Mexico and throughout the their personnel to inspect commercial diving operations in Southeast U.S. Additionally, in 2002, the Coast Guard Atlantic accordance with their own diving regulations (46 CFR 197) when Area Commander recommended the policy for publication as operations occur from any deepwater port, offshore platform, or agency-wide guidance. The International Association of Diving vessel required to have a certificate of inspection. Contractors also published the commercial diving regulatory During a USCG directed and funded oil or hazardous material checklist in their industry trade publication. response, internal Coast Guard policy requires all commercial

153 154 2003 INTERNATIONAL OIL SPILL CONFERENCE

Commercial diving regulatory checklist however, additional requirements apply when conducting operations from vessels that require a Coast Guard certificate of Safety officers should review the following checklist with the inspection. The following checklist summarizes the regulatory or designated person-in-charge before requirements for each phase of the inspection and distinguishes commencing diving operations. This checklist is not a between OSHA and Coast Guard regulations. comprehensive regulatory inspection. It is intended to provide an If the commercial diving contractor wishes to deviate from the indicator of substantial non-compliance with the mandatory USCG requirements, the contractor must submit a variance health and safety requirements for commercial divers. request in writing to Coast Guard Headquarters via the local Additionally, it will provide supporting documentation to shut Marine Safety Office. A copy of all approved variances must be down a commercial diving operation for safety concerns. available at the dive location or aboard the dive support vessel In general, a commercial diving operation inspection consists before commencing diving operations. OSHA does not permit Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 of three phases: (1) Personnel, (2) Operations, and (3) Equipment. deviations from their diving standards. The OSHA and Coast Guard regulations are similar in scope;

I. Commercial Diving Personnel.

Requirement OSHA Regulation USCG Regulation Comments Dive team members must be qualified to 29 CFR 1910.410 (a) 46 CFR 197.404 There is not a "commercial diver certification card," conduct assigned tasks. 29 CFR 1910.120 46 CFR 197.410 similar to those required by the community. The Association of Diving Contractors offers a certification card or the company can provide proof of experience. Divers should provide proof of HAZWOPER training before commencing diving operations in contaminated water. | All dive team members must have 29 CFR 1910.410 1 CPR and first-aid certifications. For surface-supplied and scuba 29 CFR 1910.410(b) 46 CFR 197.432 The three-person dive team is an OSHA regulation and operations, a qualified three-person dive an accepted industry practice by the Association of team, consisting of a person-in-charge, Diving Contractors. The Coast Guard requires a three- dive tender, and line-tended diver, is member dive team for Coast Guard contracts (ref: required. ALDIST 228/99). The diving supervisor must not serve in a dual role as both supervisor and diver. A standby diver, when required, must be dressed out and ready to dive. | An experienced, designated person-in- 29 CFR 1910.410(c) 46 CFR 197.208 Under the OSHA regulations, the person-in-charge is charge is on-scene and supervising the 46 CFR 197.210 the qualified diving supervisor. When diving operations occur on an inspected vessel, under USCG operation. 46 CFR 197.402 regulations, the person-in-charge (the owner, agent, or 46 CFR 197.404 master of the vessel) and the diving supervisor are separate individuals, and both must be designated in writing.

II. Commercial Diving Operations.

Requirement OSHA Regulation USCG Regulation Comments A Safe Practices Manual or Operations 29 CFR 1910.410 46 CFR 197.420 OSHA regulations require a Safe Practices Manual Manual must be available on-site. that describes the diving activities, while USCG regulations require an that meets Note: During salvage operations, the requirements of the Safe Practices Manual. This is welding and burning equipment should the site-safety plan. In particular, response personnel not be used to open tanks without first should review emergency procedures, emergency assessing contents and explosion phone numbers, and the directions to the nearest associated with these types of operations. chamber and hospital. For contaminated water diving, a more specific safety plan that addresses the specific contaminant and protective equipment should be available. The divers must have a plan to obtain 29 CFR 1910.421(b) 46 CFR 197.420 If a decompression chamber is not on site, ensure that emergency assistance, specifically, a 46 CFR 197.314(b) the divers know the location and contact numbers of two way communications system. the nearest facility and hospital. Most importantly, the divers must have the capability to reach emergency services. SALVAGE, IT'S ROLE IN POLLUTION RESPONSE 155

II. Commercial Diving Operations, continued.

Requirement OSHA Regulation USCG Regulation Comments First-aid equipment, including a hand- 29 CFR 1910.421(c) 46 CFR 197.314 For dives deeper than 100-fsw (feet sea water) or dives held resuscitator, must be located on site. 29 CFR 1910.423 46 CFR 197.432 outside the no-decompression limits, an operating decompression chamber and supply of gas sufficient to treat for must be located on-site. The chamber must be within five minutes of the dive station. The more conservative OSHA limitation of 100-ft depth should be applied. The Diving Supervisor must conduct a 29 CFR 1910.421(f) 46 CFR 197.410 All members of the dive team must attend. Key pre-dive safety briefing and inspect personnel of the ship or facility should also attend. Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 equipment. A warning signal (dive flag) must be 29 CFR 1910.421(h) COLREGS, Rule 27 The warning signal must be a rigid replica of the displayed. international code "A" flag at least one meter in height. The person-in-charge and the diving 29 CFR 1910.440 46 CFR 197.480 The log should contain the date, time, and location of supervisor must maintain a . the start and completion of dive operations; underwater and surface conditions; name of diving supervisor; and general nature of the work performed.

III. Operations.2

Requirement OSHA Regulation USCG Regulation Comments Scuba diving must be conducted in 29 CFR 1910.424(b) 46 CFR 197.430 (a) OSHA regulations require an operating decompression depths less than 130 fsw, within the no- chamber on-site when diving greater than 100 fsw or decompression limits, and in currents outside the no-decompression limits. less than one knot. A standby diver is available while the 29 CFR 1910.424(c) 46 CFR 197.430(c) scuba diver is in the water. The scuba diver must be either line- 29 CFR 1910.424(c) 46 CFR 197.430 (d) tended or accompanied by another diver with continuous visual contact. If the scuba diver must work in a 29 CFR 1910.424(c) 46 CFR 197.430 (e) During salvage operations, divers may enter confined physically confining space, another diver spaces to position float bags and/or harnesses. must line-tend from the underwater point of entry. Scuba divers must carry a reserve 29 CFR 1910.424(c) Coast Guard regulations do not specifically require a supply. reserve breathing supply for scuba diving operations (less than 130 fsw of water).

IV. Surface-Supplied Air Diving.3

Requirement OSHA Regulation USCG Regulation Comments Surface-supplied air diving must be 29 CFR 1910.425(b) 46 CFR 197.432 Dives of 30-minutes or less may be conducted to conducted at a depth of 190 fsw or less. depths of 220 fsw. Each diver must be continuously tended. 29 CFR 1910.425(c) 46 CFR 197.432 (c) Divers must carry a reserve breathing gas 29 CFR 1910.425 46 CFR 197.432 (e) Note that Coast Guard regulations require a secondary supply at depths greater than 100 fsw or (c) (4) (iii) (reserve) breathing gas supply at depths greater than outside the no-decompression limits. 130 fsw or outside the no-decompression limits. However, the Coast Guard (decision March 5, 2001) and the ADC recommend that bailout bottles be used for all commercial diving operations, regardless of depth. An operating decompression chamber 29 CFR 1910.425(b) 46 CFR 197.432 (e)(2) Note that Coast Guard regulations require a must be on-site for any dive outside the decompression chamber on-site for dive operations no-decompression limits or deeper than greater than 130 fsw or outside the no-decompression 100 fsw. limits. The more conservative OSHA limitation of 100 fsw should be applied. 156 2003 INTERNATIONAL OIL SPILL CONFERENCE

V. Commercial

Requirement OSHA Regulation USCG Regulation Comments Air used to supply air to the 29 CFR 1910.430 (b) 46 CFR 197.310 diver must be equipped with a volume tank with a check valve on the inlet side, a gauge, a relief valve, and a drain 1 valve. Air intakes for air compressors must be >CFR 1910.420 (b» 46 CFR 197.310(b) located away from areas containing exhaust 1 fumes or other hazardous materials.

The output of the air systems 29 CFR 1910.420(b) 46 CFR 197.450 The diving supervisor must provide laboratory Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 must be tested for air purity every six months 46 CFR 197.340 results or maintenance records for air quality. and after every repair or modification. Compare the compressor identification number with that noted on the laboratory results or An analysis certificate stating the serial maintenance records. Compressed air used for number of the compressor and the results of breathing mixtures must be 20 to 22 percent the air test should be available at the dive by volume, have no objectionable odor, location. and have no more than 1000 ppm (particles per million) carbon dioxide, 20 ppm carbon monoxide, 5 mg/cubic meter of solid and liquid particulates including oil, and 25 ppm hydrocarbons. | Surface-supplied helmets and masks must 29 CFR 1910.430(h) 46 CFR 197.322 (a) have a non-return valve, an exhaust valve, | and a two-way voice communications system. Breathing gas supply hoses must have a 29 CFR 1910.430(c) 46 CFR 197.312 Ensure the breathing supply line has been pressure working pressure at least equal to the tested to 1.5 MAWP within the past year. working pressure of the total breathing Additionally, ensure all connectors are made of system, have a bursting pressure at least equal corrosion-resistant material and the umbilical is to four times the working pressure, and be marked in 10-foot increments from the diver to tested at least annually to 1.5 times their 100 fsw and is constructed of kink-resistant 1 working pressure. material. | A is required for every diver. 29 CFR 1910.430(g) 46 CFR 197.318 OSHA and USCG regulations require a depth gauge that can be read on the surface for surface- supplied divers. Additionally, OSHA requires a depth gauge that can be read by the scuba diver. | A diving ladder or stage must be provided to 29 CFR 1910.425 46 CFR 197.320 When using heavy gear in depths greater than 100 assist entry and exit. 46 CFR 197.432 fsw, an in-water stage must be provided. A must be used for divers with an 29 CFR 1910.425 46 CFR 197.432 This rule does not apply when heavy gear is worn in-water decompression time greater than 120 or diving is conducted in physically confining | minutes. spaces. | A diver's safety harness, with a positive 29 CFR 1910.420(j) 46 CFR 197.324 buckling device capable of distributing the pulling of the umbilical, is required for 1 surface-supplied divers. When are worn, the belt or assembly 29 CFR 1910.430 (j) 1 should be equipped with a quick release. Decompression chambers, or "pressure 29 CFR 1910.430(f) 46 CFR 197.328 Records must show that the chamber has been vessels for human occupancy (PVHO)," must 46 CFR 197.462 examined for mechanical damage or deterioration be properly equipped and maintained. on an annual basis. Additionally, the pressure 1. PVHO must be stamped ASME PVHO-1 vessel and associated piping must be pressure tested every three years. 1 or have documentation of CG approval. 2. PVHO piping must have a shut-off valve Note: The full inspection of a PVHO is beyond within 1-foot of every pressure boundary the scope of this guidance. Contact a qualified penetration. inspector experienced in commercial diving operations to schedule a complete inspection. 3. The PVHO must have a (a) pressure relief device, (b) two-way communications between compartments and to the outside, (c) a pressure gauge in each compartment, (d) view ports, (e) enough illumination to allow occupants to read gauges, (f) a means of extinguishing an interior fire, and (g) a means of overriding interior breathing and pressure- supply controls. SALVAGE, IT'S ROLE IN POLLUTION RESPONSE 157

Contaminated water diving Conclusion

When diving operations are conducted in contaminated water Commercial divers often play a critical role in the success of or in an area where there is a substantial threat of discharge of oil pollution response and salvage operations. Following the T/B or hazardous materials, commercial divers must also comply with Morris J. Berman submerged oil recovery, the Coast Guard noted the OSHA training and operational standards for Hazardous that commercial divers are "necessary in areas inaccessible or Waste Operations and Emergency Response (HAZWOPER).4 inappropriate for because of environmental concerns" Divers should provide proof of HAZWOPER training, and (Bums, 1995; Ross, 1994). Additionally, divers can operate in evidence that they have completed the annual refresher training, low to zero visibility unlike a remotely operated vehicle that is before commencing diving operations. limited by visibility and prone to entanglement (Travers, 1986). Diving in contaminated water requires equipment that protects In 1995, Salvor John Witte, Don Jon Marine, observed after divers from pollutants. As a rule, if the pollutant is unknown, removing oil from the 50-year-old wreck of the T/B CLEVECO in Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 diving operations should not be permitted. With the exception of Lake Erie, "As wrecks throughout the world begin to decay and the requirement to comply with the HAZWOPER standards, to release their cargoes of pollutants into our sensitive environment, date, the U.S. Coast Guard, OSHA, and the International there will need to be professionals [divers] ready to respond in a Maritime Organization have not published regulations that timely and effective manner" (Davin and Witte, 1997). Recent mandate specific equipment or training for diving in submerged oil recovery operations, such as the SS Jacob contaminated water. However, the National Research Council Luckenbach oil recovery operations off the U.S. West Coast at a (NRC), U.S. Environmental Protection Agency (EPA), and the depth of 175 feet (Enge, 2002) and the responses to the degrading National Oceanic and Atmospheric Administration (NOAA) have WWII era ships in the waters of Micronesia, are examples of our published guidance and protocols. Additionally, the Association continued need for commercial divers in response operations. of Diving Contractors (ADC) has drafted industry standards for It is the responsibility of the FOSC to ensure that properly contaminated water diving that are now under review by the trained and equipped commercial divers safely conduct members of the association. underwater salvage and pollution response operations. The The NRC s report on spills of nonfloating oils recommends guidance provided in this report can supplement the safety operational limitations for diving in contaminated waters to officers' efforts to ensure diving operations are conducted in depths of 20 meters, a minimum visibility of 0.5 to 1.0 meter, and accordance with existing standards and best practices to achieve low water currents (NRC, 1999). However, existing OSHA and the goal of protecting the health and safety of the divers. USCG regulations allow commercial divers to work in depths in excess of 60 meters, zero visibility, and heavy currents. Additionally, the ADC, EPA, and NOAA do not restrict Acknowledgements commercial diving operations to depths that are more stringent than the depth requirements noted in the regulatory checklist, nor The following Coast Guard officers and Association of Diving do they mandate visibility and current-speed standards. Contractor representatives provided comments on the commercial A review of historical submerged oil recovery case studies diving operation regulatory checklist: Captain William Fels, shows that commercial divers have safely and successfully Captain Glenn Anderson, Lieutenant Commander Michael Hunt, completed operations in conditions that exceed the NRC s Lieutenant Commander Robert Kirk, Lieutenant Commander proposed operational limitations. For example, during the T/B Paul Dittman, Lieutenant Josh Peters, Mr. Tom Eason (Eason Apex 3512 oil recovery from the bottom of the lower Mississippi Diving and Marine Construction, Inc.), Mr. Terry Hetrick in 1995, divers worked in depths that exceeded 20 meters, "zero (Marine Engineering Systems Company, Inc.), and Dr. Ross visibility and a strong downriver current" (Weems, et al, 1997). Saxon (Association of Diving Contractors). Divers encountered similar conditions during the winter of 1995 submerged coal tar recovery in the Detroit River (Heiland, et al, 1997). Biography It should be noted that, according to the EPA, equipment problems in contaminated water are caused primarily by Lieutenant Commander Jim Elliott is Chief of Marine petroleum products (Traver, 1986). Divers exposed to petroleum Response Operations at the Seventh Coast Guard District in constituents often experience equipment failure and deterioration. Miami, Florida. During his previous tour of duty in Morgan City, For example, Purser and Kunz provide a case study where a diver Louisiana, he led numerous commercial diving operation was exposed to elevated levels of benzene: "The benzene inspections and casualty investigations as chief of the United weakened the rubber straps on his helmet and his neck, face and States' largest and busiest Outer Continental Shelf inspection head were well exposed to the benzene mixture for a few zone. Mr. Elliott holds a bachelor of science in environmental seconds." The diver was later hospitalized due to his brief management and a masters in environmental policy. exposure (Purser and Kunz, 1985). To prevent these types of accidents, safety officers should supplement their site-specific safety plan and on-site safety audits with the following safety checklist for contaminated water diving. The recommended actions were gleaned from existing OSHA standards and various federal agency and industry recommendations. 158 2003 INTERNATIONAL OIL SPILL CONFERENCE

Contaminated Water Checklist

Action Sources Comments Conduct a Hazard Evaluation: ADC, NOAA, Diving operations should not be permitted until ! a. If contaminant is unknown, conducta sampling study before diving. EPA, OSHA the pollutant has been characterized and a b. Dc?ermine degree and extent of contamination. hazard evaluation is complete. c. Determine duration of potential exposure to the contaminant. Standard scuba gear does not provide adequate d. Determine environmental exposure due to geographic location protection in contaminated water environments. (thermal conditions, depth, current speed, and weather forecast). e. Establish three zones of contamination based on sampling study: Diving operations should cease if there is any i. Support or Cold Zone suspected breach in the watertight integrity of ii. Contamination Reduction Zone (CRZ) the surface-supplied diving system. Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 1 iii. Exclusion or Hot Zone Place commercial divers and topside personnel that could be potentially OSHA, NOAA, Ensure both divers and support personnel are on exposed on an approved Medical Monitoring Program. EPA a medical monitoring program that includes a baseline examination and annual physical examinations. 1 Assign a site safety officer and prepare a site-specific safety plan. OSHA, EPA 1 Choose and test commercial diving equipment that will prevent contact with NOAA, EPA, Scuba diving gear and band-masks are not contaminated water: ADC, OSHA recommended. NOAA recommends using the a. Every piece of diving equipment, including umbilical and connectors, "suit-under > t" concept or the traditional must be compatible with the contaminants. surface-suppi \r*ot diving system with b. Diving system materials must be of matching durability. encapsulated div*. 0 „au. The ADC and EPA c. Conduct a diving system leak test before diving. recommend a helmeted surface-su r'«': ~<\ diver d. Consider using a positive pressure diving system to limit exposure. with a return-line exhaust system ana a mating e. Review diving equipment durability, material rate, and with attached boots and gloves. potential break-through time. Equipment used in contaminated water must be Note: Personal protective equipment is only as strong as its weakest point. maintained, repaired, and replaced more Evaluate, inspect, and test seam construction, potential breach frequently than equipment used in unpolluted points, and exhaust valves or through-suit penetrations. Though there are no environments. specific regulatory standards for the construction of contaminated water diving equipment, manufacturers use the National Fire Protection Association (NFPA) Air compressors must be located in a clean Standard for Vapor Protective Suits for Hazardous Chemical Emergencies and atmosphere or divers should use bottled air the American Society for Testing and Materials (ASTM) Standard Guide for compressed in a clean atmosphere. Chemicals to Evaluate Protective Clothing Materials to develop test formats (TreUeborg Viking, 2001). Ensure that divers and topside personnel are trained to conduct contaminated ADC, OSHA, Training should be based on the duties and water diving. Specifically, diving personnel should have the following training EPA function to be performed by each member of or experience: the contaminated water , surface a. Decontamination Procedures. support personnel, and decontamination teams. b. Dry Suit Diving (Donning/Doffing and Emergency Procedures). c. Leak Testing Procedures. d. Maintenance, repair, and proper use of contaminated water diving systems. e. Sampling Procedures. f. Emergency Procedures. g. HAZWOPER Training (plus annual refresher). Backup team or standby divers must be equipped and trained to the same EPA, OSHA, In Diving in High- Environments, Barsky standard as the entry team. ADC notes, "The backup or standby diver must have equipment that equals or exceeds that of the diver in the water. If the diving mode is surface- supplied, the standby diver's hose must be at least 50 feet longer than that of the diver in the water" (Barsky, 1993). A decontamination system must be set up and manned by trained responders. OSHA, ADC, The majority of hazardous materials response a. Procedures must be in place to remove the specific contaminant from NOAA, EPA injuries are caused by improper the surface of the diver, diving system, equipment, the environment, decontamination procedures (Oleniczak, 2002). and property. b. There should be a system in place to measure the effectiveness of the decontamination procedures. A disposal plan for contaminated equipment and decontamination wastes must OSHA, EPA Wastes should be contained and properly be reviewed and approved by the Incident Commander. disposed in accordance with federal, state, and local regulations. Maintain comprehensive records: NOAA, OSHA, a. Medical surveillance records. ADC, USCG b. A detailed description of exposures to hazardous substances. c. Complaints following exposures to hazardous substances. d. Training records. e. A complete log of response actions. f. Equipment maintenance records. SALVAGE, IT'S ROLE IN POLLUTION RESPONSE 159

References March 4, 1996 with the Loss of Life: Action by the Commandant. March 5, 2001. 1. Association of Diving Contractors. Consensus Standards 21. U.S. Coast Guard. ALDIST 228/99 Commercial Diver for Commercial Diving Operations, Fourth Edition, 1992; Contracting by Coast Guard Units. 1999. Change 1, 1994. 22. U.S. Coast Guard. Commercial Diving Regulations (46 2. Barsky, S. M. Diving in High-Risk Environments; 2nd CFR 197 Subpart B). Edition. Dive Rescue International, Inc. 1993. 23. U.S. Coast Guard. National Contingency Plan (40 CFR 3. Barsky, S. M. "Diving Accidents: Truth or 300). Consequences." Underwater Magazine, Summer 1999. 24. U.S. Coast Guard. International and Inland Navigation 4. Barsky, S., et al. Association of Diving Contractors Rules. COMDTINST M16672.2D. Contaminated Water Diving by Commercial Divers, First 25. U.S. Coast Guard. Marine Safety Manual Volume II, Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021 Draft. February 2002. Chapters 8.C.5.e; 16.E; and 24.G. 5. Burns, G. H., Recovery of Submerged Oil at San Juan 26. U.S. Department of Labor, Letter from the Occupational Puerto Rico 1994. Proceedings of the 1995 International Safety and Health Administration to the Honorable Joseph Oil Spill Conference. I. Lieberman, dated March 29, 2000. 6. Davin, J. J. and Witte, J. A. CLEVECO Underwater Oil 27. U.S. Department of Labor, Letter from the Occupational Recovery: Removing a 50-Year-Old Threat. Proceedings Safety and Health Administration to the Association of of the 1997 International Oil Spill Conference. Diving Contractors, Inc., dated October 29, 1998. 7. Enge, Marilee. "Oil leak effort stalls: Weather, undersea 28. U.S. Department of Labor, Letter from the Occupational corrosion hinder work at onetime mystery spill." Mercury Safety and Health Administration to the Association of News, July 11, 2002. Diving Contractors, Inc., regarding air quality analysis, 8. Heiland, R. et al. Underwater Recovery of Submerged Oil dated August 25, 1994. During a Cold Weather Response. Proceedings of the 29. U.S. National Oceanic and Atmospheric Administration 1997 International Oil Spill Conference. (NOAA). NOAA Diving Manual: Diving for Science and 9. International Diving Schools Association. International Technology. October 1991. Certification Standards and Procedures, 30. Weems, L.H., et al. Recovery of LAPIO from the Bottom Revision 1. September 2001. of the Lower Mississippi River. Proceedings of the 1997 10. International Maritime Organization. Code of Safety for International Oil Spill Conference. Diving Systems. Printed and published by the International Maritime Organization, London. 1985. 11. National Research Council. Spills of Nonfloating Oils: 1 Disclaimer: The views expressed herein are those of the author Risk and Response, National Academy Press, and are not to be construed as official or reflecting the views of Washington, D.C., 1999. the Commandant, the U.S. Coast Guard, or the Department of 12. Occupational Safety and Health Administration. Transportation. Commercial Diving Regulations (29 CFR 1910 Subpart 2 Scuba diving is not appropriate where there is a risk of oil or T). toxic chemical ingestion. The NOAA Diving Manual states 13. Occupational Safety and Health Administration. "Standard scuba gear offers inadequate protection to divers Hazardous Waste Operations and Emergency Response operating in contaminated water environments" (NOAA, 1991). (29 CFR 1910.120). Barsky et al note that diving equipment designed to eliminate any 14. Occupational Safety and Health Administration. Training exposure to the water "should be considered when diving in Manne Oil Spill Response Workers Under OSHA's waters containing biological contamination, petroleum fuel or Hazardous Waste Operations and Emergency Response lubricating oils, and industrial chemicals known to cause long Standards. OSHA 3172, 2001. term health risks or death" (Barsky et al, 2002). 15. Oleniczak, A. Dupont Protective Apparel. Interview by 3 Commercial divers may also use mixed-gas systems to conduct author on July 22, 2002. salvage and pollution response operations. Additionally, divers 16. Purser, P.E. and Kunz, H.S., Prologue to Diving in may conduct operations. These operations are Polluted Waters. Searle Consortium, Ltd., Proceedings of highly technical and require the use of diving bells and IEEE/MTS Oceans' 85 Conference. 1985. decompression chambers with a sufficient supply of the 17. Ross, R. G., Federal On-Scene Coordinator's Report for appropriate mixed breathing gas on-site for decompression and the Tank Barge Morns J. Berman Spill, San Juan, Puerto emergency treatment. Oversight of mixed-gas diving operations Rico, January 7, 1994; Submerged Oil Recovery and saturation diving operations is beyond the scope of this Operations. U.S. Coast Guard Marine Safety Office San guidance. The regulations covering these operations include 46 Juan. 1994. CFR 197.434 and 29 CFR 1910.426. Responders should contact a 18. Traver, R. P. Interim Protocol for Diving Operations in qualified offshore inspector experienced in commercial diving Contaminated Water. Hazardous Waste Engineering operations inspections for additional guidance. Research Laboratory, Office of Research and 4 In 2001, OSHA published training guidance for marine oil spill Development, U.S. Environmental Protection Agency. response workers: "Training Marine Oil Spill Response Workers August 1986. Under OSHA's Hazardous Waste and Emergency Response 19. Trelleborg Viking, Inc. Diving in Contaminated Waters. Standard," (OSHA 3172). Portsmouth, New Hampshire, 2001. 20. U.S. Coast Guard. Commandant's Action on the Formal Investigation into the Circumstances Surrounding the Commercial Diving Accident Onboard the Mobile Offshore Drilling Unit Cliff's Drilling Rig No. 12 on Downloaded from http://meridian.allenpress.com/iosc/article-pdf/2003/1/153/2350529/2169-3358-2003-1-153.pdf by guest on 30 September 2021