PSD Teams and OSHA, NFPA compliance

[RatHatDiver]

Does anyone know if OSHA and NFPA's "2 in 2 out" rule is applicable in any way to PSD operations? My department follows NFPA 1006 and 1670 for technician qualifications, but someone told me that I need to follow 2 in 2 out for diving operations and I can't find that anywhere. Anyone have any input on this?

 

[Thalassamania]

http://www.ravenrescue.com/ What are the NFPA 1670 and 1006 Standards?

NFPA Standards have become the de-facto global standards for those who respond to technical search and rescue incidents with the goal of ensuring effectiveness, providing a common framework for rescue training and operations, and limiting liability. The Standards cover technical rescue disciplines including rope rescue, surface water rescue, vehicle and machinery rescue

Nothing about diving?

 

[tc]

The most applicable sections from OSHA for SCUBA-

1910.424(c)(1)

A standby diver shall be available while a diver is in the water.

1910.424(c)(2)

A diver shall be line-tended from the surface, or accompanied by another diver in the water in continuous visual contact during the diving operations.

 

[Tx_Jeff]

I'm just going off of the top of my head right now, but NFPA 1500 states that any time personnel are in an IDLH (Immediately Dangerous to Life or Health) atmosphere, personnel must be at the ready to effect a rescue of personnel operating in the IDLH atmosphere. The exception to this is if an immediate rescue can be performed prevent the loss of life, then personnel exterior of the IDLH atmosphere would not be warranted.

When I get to work on Wednesday I can post the actual standard.

 

[Tx_Jeff]

I'm just going off of the top of my head right now, but NFPA 1500 states that any time personnel are in an IDLH (Immediately Dangerous to Life or Health) atmosphere, personnel must be at the ready to effect a rescue of personnel operating in the IDLH atmosphere. The exception to this is if an immediate rescue can be performed prevent the loss of life, then personnel exterior of the IDLH atmosphere would not be warranted.

When I get to work on Wednesday I can post the actual standard.

 

[Tacman55]

The most applicable sections from OSHA for SCUBA-

1910.424(c)(1)

A standby diver shall be available while a diver is in the water.

1910.424(c)(2)

A diver shall be line-tended from the surface, or accompanied by another diver in the water in continuous visual contact during the diving operations.

The above applies specifically to standards for commercial diving operations, from which Public Safety Diving operations are exempt.

Taken from the OSHA website:

"The commercial diving operations standard does not apply to diving operations under the following conditions:

29 CFR 1910.401(a)(2)(ii). Diving solely for search, rescue, or related public-safety purposes by or under the control of a government agency. "

 

[Thalassamania]

One of the other things that you need to check is your state OSHA, it often requires that public sector workers be protected by rules and regulations that are AT LEAST AS STRINGENT as those being applied to similar private sector workers by Fed OSHA, thus adding back in public sector workers that Fed OSHA let out.

 

[Firefyter]

I'm just going off of the top of my head right now, but NFPA 1500 states that any time personnel are in an IDLH (Immediately Dangerous to Life or Health) atmosphere, personnel must be at the ready to effect a rescue of personnel operating in the IDLH atmosphere. The exception to this is if an immediate rescue can be performed prevent the loss of life, then personnel exterior of the IDLH atmosphere would not be warranted.

Emphasis mine. This is the part of the standard that makes it applicable for any agency that adheres to NFPA standards.

 

[BladesRobinson]

What are the NFPA 1670 and 1006 Standards?

NFPA Standards have become the de-facto global standards for those who respond to technical search and rescue incidents with the goal of ensuring effectiveness, providing a common framework for rescue training and operations, and limiting liability. The Standards cover technical rescue disciplines including rope rescue, surface water rescue, vehicle and machinery rescue

Nothing about diving?

============================================

Both NFPA 1670 and 1006 address publc safety diving. Neither 1670 nor 1006 address the "two in, two out" issue since public safety dive operations use a "one in, one out" system and most teams have adopted and support the concept of a 90% diver as a "back up to the back up." That essentially makes for a "one in, two out" system which allows for quite a bit of safety. No one to my knowledge endorses having two public safety divers underwater (regularly working as a "buddy team" in zero vis) so the "two in" rule would not make any sense.

The OSHA standard does NOT apply to public safety diving. It is important to note though that there is much information contained within the OSHA standard that is beneficial for public safety divers to follow.

NIOSH works under OSHA and their firefighter fatality reports offer guidelines to prevent line of duty deaths. The most recent (published) PSD fatality report involves a PSD in Pennsylvania getting "recreational" training and details can be found at: Fire Fighter Fatality Investigation Report F2005-29 | CDC/NIOSH

The following is quoted from that report...



NIOSH investigators concluded that, to minimize the risk of similar occurrences, fire/rescue departments should:

• develop, implement, and enforce standard operating procedures (SOPs) or protocols regarding diver training
  
  
• ensure that each diver maintains continuous visual, verbal, or physical contact with his or her dive partner
  
  
• ensure that a backup diver and ninety-percent-ready diver are in position to render assistance
  
  
• ensure that positive communication is established among all divers and those personnel who remain on the surface.

I hope this helps. I believe the most important key to safe dive operations is good training and not making things more difficult than they need to be while assuring diver safety. If you have additional questions or concerns, please contact me off list, via e-mail at: brobinson @ diverescueintl "dot" com.

Blades Robinson, Director
Dive Rescue International
www.DiveRescueIntl.com

 

[DMarelli]

There is a common misconception that all public safety diving is exempted from CFR 29 1910 Subpart T. This is not true. The OSHA commercial diving standard covers any diving for hire not specifically exempted. This does not mean that every PSD operation is exempt from OSHA, only where life, limb, property, or environmental damage may occur if an immediate response is not made.

Rescues are an example where the PSD exemption is appropriate. Searches for evidence and bodies as well as extracting vehicles from the water fall under 29 CFR 1910, Subpart T. This includes your training evolutions. Ask the city of Indianapolis about that.

Also remember that if your dive teams do not follow the de facto national standard for training and operation (NFPA) or the task involved exceeds what a reasonable PSD team would do (examples would be heavy lifts, cutting, welding, explosive use etc.) you default into the OSHA commercial diving standard. If an accident were to happen OSHA will investigate so it's best to be prepared.