Commercial Dive Safety OrganizationEjEpT 0~ : !;. ,: p~“:,~~ Dedicated to a safe work place through education b-y;: ‘-:“‘~L/$$~~O”* % SF 24 pQ 2: 14 437 35 C/sCG--y& 3 78-L @ Yf Proposed additions to: The United States l Coast Guard Commercial Diving Regulations 46CFR Chapter 1. Sub Part A Submitted By the: Commercial Dive Safety Organization Phone4258833500 2795 152”” Ave N.E. Fax4258610525 Redmond, Washington 98052 e 24 HOllR HOT LINE 1 800 675 0740 DiveSafe@,msn.com Commercial Dive Safety Organization Dedicated to a safe work place through education Table of Contents 1. Introduction . Part 1 2. Proposed 46 CFR Chapter 1 Subpart A.. .Part 2 (Commercial Dive Safety Organization) 3. Working Document . Part 3 (Comparison, Current: USCG, ADC, and CDS0 with comments) 4. Canadian Commercial Diving Regulations..Part 4 (For reference only) 5. Australian Diving Regulations.. ..Part 5 (For reference only) Phone4258833500 2795 152”” Ave N.E. Fax 425 861 0525 Redmond, Washington 98052 24HOURHOTLlNE180067S0740 Di\~eSafc~msll.Cor77 Commercial Dive Safety Organization l Dedicated to a safe work place through education Part 1 Introduction Phone 425 883 3500 2795 152”” Ave N.E. Fax425861 OS25 Redmond, Washington 98052 a 24HOURHOTLlNE18006750740 DiveSafc(@sn.con~ Commercial Dive Safety Organization l Dedicated to a safe work place through education Docket Management Facility [USCG-1998-37861 U.S. Department of Transportation, Room PL-401 400 Seventh Street S.W. Washington, D.C. 20590-0001 September 23, 1998 Subject: Commercial Diving Operations; 46 CFR 197 Advanced notice of Proposed Rulemaking Gentlemen: The Commercial Dive Safety Organization is a group of concerned citizens, past and present commercial divers and dive safety consultants who with the assistance of other interested individuals has compiled the attached documentation. Included here is the direct response to the questions posed in the Federal Register on June 26, 1998. In addition we have included a suggested revision to the current regulations, Part 2 attached. A comparison of the current regulation to the Association of Diving Contractors Proposal and the Commercial Dive Safety Proposal along with comments pertaining to all three, Part 3. Parts 4 and Part 5 are included for reference only and included the current Canadian and Australian Commercial Diving Regulations respectively. 1. Bawl cm ymr review of/he AIX sdmissio~~ lo /he (.‘ousf Gmrd. Wkh revi.~ion.~ should the (~‘ou.ot Gmrd iizcl2de in its proposed rule, rzoi irzchrde ii? u propaw/ de, or revi.Fe uid incli& ii1 u propo,Ved rlrle:~ Why In reviewing the proposal presented please refer to Part 3 attached for the individual comment addressed in the ADC submission It is our contention that The ADC Consensus Standard should not be adopted and or considered as an “industry standard” in this rulemaking procedure. Although many of the areas addressed in the ADC proposal are valid and show attention to areas not currently addressed by the existing regulation the ADC does not represent the entirety of the industqr. Nor has the industry had sufficient input to suggest that the Consensus Standard is an “industty standard.” The province of rulemaking should remain where it currently resides. By referencing a document that could potentially be revised without public revieiv could jeopardize the integrity of the adopted regulation. The Association of Diiing Contractors does not now nor has it ever established a means of requiring their member companies to follow the guidelines established within their current Consensus Standard. In addition the ANSI Standard suggested for consideration as a minimum standard for diver training is in need of serious review. Phone 425 SS3 3500 2795 152”” Ave N.E. Fax 425 861 0525 Redmond, Washington 98052 7~ H~IIR ww 1.1~~ i ftnn r;7< n74n Commercial Dive Safety Organization Dedicated to a safe work place through education 3. 1,s AlX”,s co.sl e.ulittwfc 0fS300,000.00~fits impletmnfit~g t1~eirprotpo.w~ regululory c1~ut1ge.s reu.sor1uhle~~ ~ft1ot, pleuse cspluin why und, !fpos.sihle, provide yaw own cost eslitttule. The safety regulations proposed for inclusion within the ADC proposal and the proposal attached to this document would have no financial impact upon the Department of Transportation. There could potentially be additional costs incurred by those entities that have elected to work on the fringes of employee safety. The question here might better be asked. What is the reasonable cost of worker safety? 4. Id 7wl dqfhitioi2.s iii the esisting regtrlulion.s should he trpduled or deleted, PIeuse e.\l/7loitl. Are there other terms /huf fhe Coust Chmrd shrld &fine in the regdutims? Pleaw expluin. Please refer to Part 2, attached 5. Shdtf ~~wuttticully po.sifiotied ve.s.sel.s (vessels will1 uti itxlulled sys~etti tliul u~~totttuticull~~ ttiuit1luiii.s the po.sifion ofllie ve.s.sel wiflzin u .speciJied lolerutice by cot1ftdlitig ot7hourd lIirxsfct:s to coinifet* llie,fi,rce.s oJ’ti1c wind, wives utzd cirrtmf.v) NIX/ retttotel~l operulecr vehicles he uddressed in /lie regzrlutioti~s~~ !f so, wiiuI pur~icirlut~ i.ssiic.V .s1101ild liie C.?tu.st (;ztnrur’pt.o~p(~.se to reg:IiIuIc) Please refer to Part 2, attached 6. Si1odtl the C ‘oust Gziurd ptqmse regidufioi1.s coricernitig diving in cotilnttiitiu~ed rsutct:s~~ lfJle.s, IKW siioirld il he ucldrc.ssect? Please refer to Part 2, attached 7. Simirld Ihe ~‘ousl (;t,ciidp~c~po.s~ regi~luti0n.s concerning ot1e uOtio.spiiet~e ohservuliori hell.s, .wif.s 0s ,sithttiet:sihle.s~~ !fy.s, lime sizoi~~ld il he uddrexsed~ Please refer to Part 2. attached 8. Slmrltl th ~‘ocrxl ~hrrtlpt~~p0.w regiilulion.~ coticerwitig bell /mince (u diving procediire w~herehjl u divitig bell is used lo fruti.~porf divers under utttiospiieric psexswe lo u work site, uncl szrhseqirerilly fo fmri.sporl the divers buck to iiie .wt$ice iii u tlecott1pre.s.sioti .slcifi~.v) .? lfyes, Iim~ shoidd if he uddre,ssed~ Please refer to Part 2, attached 9. Shodd the C ‘ousf Girurd psopose regdulioiis concerniiig suf wutf ion diving it1 ttioi*c detuil” !fJle,s, 110~~ simdd if he uddresseu? Please refer to Part 2, attached IO. Siwdtl the C ‘oas~ Gtrurd propose regtdu~ions concestzing t,eqzriretttetzl.s, fi,t. buck-1cp eqrlipttient url tile dive sile.? [fye,s, lime siioirld il he uddressed~ Please refer to Part 2, attached Phone 425 8S3 3500 2795 152”” Ave N.E. Fax 425 861 0525 Redmond, Washington 98052 34 UnllR HOT 1 .INF 1 RM 674 07Afi Commercial Dive Safety Organization Dedicated to a safe work place through education II. Si~oi~ltl the Coust Gziurdpropo.se regiiluli0n.s concerning itiiiiiniznti lruitiing reqitit’e1ti(?iil.s.fi,r divers? Ifyes, lion siioidd if he uddre.~.~ed, Please refer to Part 2, attached. In addition to a minimum level of training the United Coast Guard must consider a program of diver certification. A program not controlled by an industry group but rather an independent licensing authority with a standard approved by the Department of Transportation. 12. If~ou fizitlk /he regdu~iotw .sizodd itdm’e tt~it~itmotz fruinit1g reqltirernent.s, pleuse uti.wer tlie~fdlo~~~itig yire.stiot7.s: u. Wiiut cow.se.s- or it~fiwttiulioti siioirld liie lwitiitig iticlirde~~ 15. Wliu/ siioiild he the ttiiiiimim nimiher of hours reqi~ire~/.fbr 1rciitiitig? c. Wiici~ ~~oiild he llie [email protected] c~e.stuhli.siiing minimutti lruiniq rcqiiivettietil.s:)~ d Slioidd ttwining 0r~utii~ulioti.s or pi*ovidet:s ttieef cerf ~ficulioti rer~itiremctil.s’~ If so, +~~iinl orgut~izulioti shoiild certifji the lruitiitig orgutiixUiotis or- providers.‘~ The United States Coast Guard should consider a multi-leveled program of staged commercial licensing. One blanket certification or standard of education could not be deemed appropriate due to the complexity and varied situations under which commercial divers must operate. An individual retrieving golf balls in twenty feet of fresh water in land does not require the same level of training as a saturation diver working at 1000 feet of sea water off the coast. In conjunction with the training there must also be a uniform competency exam and minimum hours of not only training but experience to qualify for each level of certification. This certification should not be in the control of the employer but rather an independent third party or agency approved by the Department of Transportation, deemed qualified to evaluate the abilities of the applicant. A diver entering the water today has no assurance that his tender, standby diver or even dive supervisor has the required training or knowledge to assist in time of need. Without a comprehensive system of training, certification and qualification tied to a standardized diving record as described in section 197.406 (d) attached, there can be no verifiable control in practice. As in the case of most safety issues the majority of injuries are a result of human error. The only effective manor to reduce that possibility of human error is through a system of proper training and competency review. 13. Slm fld diving .wpervi.sors he licetised by tile C’our.sf Giiurd fo eti.swe coitipliuiice wifh jxleral regrtlurlims~? PIeuse eaxplciii? liie reu.soti,fi)r yoiir choice utitl, iJjwiir un.swer is ‘>e.s” provide exumple.s, ijpoxsihle, 0f.Eilmlfioti.s iii which u licensed divitig .wpervi.sor woiild hive ittzpiwed u silztulioti. As in the case of the diver the dive supervisor not only should be licensed but also certified for the type of work being performed. A dive supervisor accustom to working in river conditions will not necessarily be capable of supervising a saturation dive. Conversely a supervisor accustom to sea conditions not necessarily attuned to the safety conditions at a hydroelectric station.