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Commercial Diving Operations During Salvage and Pollution Response Operations1

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Commercial Diving Operations During Salvage and Pollution Response Operations1 COMMERCIAL DIVING OPERATIONS DURING SALVAGE AND POLLUTION 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 diving regulations. 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 Contingency Plan 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 checklists 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 Gulf of Mexico. 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 checklist 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 diving supervisor 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 recreational diving 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 current 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 Operations Manual 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 risks phone numbers, and the directions to the nearest associated with these types of operations. decompression 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.
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