Tek Instructors, D.I.R.R. and the OSHA Exemption

[John C. Ratliff]

I've worked closely with OSHA on a number of occasions professionally, and Pipedope's thoughts are not quite right. OSHA upholds its standards; they are there to be used and for firms to conform to. They have very limited resources, and so inspect only those firms in industries that are targeted by their previous losses. This is the same on both the State and Federal level. But just because the inspections are not there, don't get the idea that the standards are not to be applied. The standards remain for firms to comply with. There will not usually be an inspection, unless there is a complaint, a fatal accident, or the inspector is in the area and happens to observe an unsafe situation. If the latter happens, they do stop, conduct an inspection, and issue citations.

SeaRat

 

[pipedope]

More to the point.

You are far more likely to get hammered by your insurance company than by OSHA.

I used to repair large metal working machinery. I installed and repaired the controls and safety systems. Anyone want to guess how often we had to deal with OSHA? How about how many companies upgraded safety equipment due to OSHA? Now guess how many upgraded the equipment at the insistence of thier Workmans Comp carrier?

The ratio was at least 9 to 1 and probably much closer to 99 to 1.

Big companies were not scared of OSHA and little companies were rarely bothered by them.

Everybody listens to the insurance company because without workmans comp you are out of business.

It is funny how there are lots of companies out there who have no problem paying to buy and maintain or rent a half a million dollar excavator but they will not pay what it costs to do a proper diving operation. Happens every day.

If OSHA was enforcing their standards, they would have shutdown every golf ball recovery and boat bottom cleaning operation out there. NONE of them are diving anything even close to the requirements of the regs.

 

[MikeFerrara]

More to the point.

You are far more likely to get hammered by your insurance company than by OSHA.

I used to repair large metal working machinery. I installed and repaired the controls and safety systems. Anyone want to guess how often we had to deal with OSHA? How about how many companies upgraded safety equipment due to OSHA? Now guess how many upgraded the equipment at the insistence of thier Workmans Comp carrier?

The ratio was at least 9 to 1 and probably much closer to 99 to 1.

Big companies were not scared of OSHA and little companies were rarely bothered by them.

Everybody listens to the insurance company because without workmans comp you are out of business.

It is funny how there are lots of companies out there who have no problem paying to buy and maintain or rent a half a million dollar excavator but they will not pay what it costs to do a proper diving operation. Happens every day.

If OSHA was enforcing their standards, they would have shutdown every golf ball recovery and boat bottom cleaning operation out there. NONE of them are diving anything even close to the requirements of the regs.

Well I understand that osha's purpose is to protect employees from cheap employers but in technical divinh I don't think any one needs to be protected. If the osha standards for diving and gas mixing were applied there isn't any one who could afford to dive.

They need to extend the exemptions for recreational instruction to include mixed gas and staged decompression dives beyon 130 ft.

 

[John C. Ratliff]

rmediver2002 has some very good information, and I’d recommend everyone really look over what he has posted.

Pipedope, here is what you said that I was replying to:

“Our saving grace is that we are under the radar and so don't get held to the standards.
Small companies are not subject to the random inspections and only employee complaints (or accidents) will get OSHA involved.”

It was the phrase “we are under the radar and so don’t get held to the standards...” Being under the radar simply means that, with limited staff, OSHA probably will never inspect your place of employment on a routine inspection. It does not mean that you are not held to these standards. You will be responsible for these standards when “the #$@% hits the fan,” someone dies and OSHA becomes involved. You were also correct in stating that the worker’s comp insurance carrier will probably have a greater effect than OSHA. But, that still doesn’t mean you are not accountable to the standards. It means that you will ignore the standards until something happens.

My question, and the whole reason for bringing up Doing It Really Right (D.I.R.R.) is why don’t we insist on these standards for Tek diving? Let me give you some examples. I grew up learning scuba diving without instruction. I took my first course in 1963, through LA County.

Prior to that, my instruction was from reading what books I had available. The only one of note, that I must have read three or four times between 1959 and 1963 was J.Y. Cousteau’s The Silent World. One of the first things he did, when he set up the Undersea Research Group, was to procure his first vessel, the L’Esquillade. This was a small craft, and they needed something larger. “After L’Esquillade we took over the VP 8, a seventy-two-foot twin-screw launch, which Tailliez transformed into a diving tender, with a compressed-air supply, diving platform, and decompression chamber...” Please note that one of the first things Cousteau did was to install a decompression (recompression) chamber on his first active boat. Calypso also had one very early in their diving experience.

The DIR concept of diving does not address what we call in the safety profession “engineering controls.” They concentrate on personal protective equipment (PPE) configurations and training (an “administrative control” under safety profession definitions).

My thoughts, and the reason I’ve proposed D.I.R.R., is that we should be concentrating on engineering controls. What would these be? If you have read about the Tek diving fatalities on the Andrea Doria, or in Bernie Chowdhury book “The Last Dive,” you would see that the charters do not usually have the following:

--A recompression chamber on board, or close by (engineering control).
--A decent diving platform that would allow an inert diver to be easily recovered (engineering control).
--A standby rescue dive team trained in CPR and diving emergencies (administrative control).
--A Dive Team Tracking Procedure and an Emergency procedures books, with the emergency procedures regularly practiced.
--Communications between divers and the surface, and diver-to-diver communications.
--The use of Full-face Mask for Tek diving, in conjunction with the above-mentioned communications equipment.

These six measures would, in my opinion, have a very desirable impact on Tek diving safety. Not having a recompression chamber immediately available give the divers no backup in case the worst happens. And as we know from a description of “The Last Dive” something as small as a split in a backup scuba mouthpiece can cause missed decompression in even experienced dive teams. Without a recompression chamber immediately available, the diver is at the mercy of the situation.

I’m sure I will hear a lot of resistance based upon cost, and availability of technology for the “sport” diver. Be aware that Tek diving is not “Sport Diving” under commonly understood definitions of this by the diving community. These should be available now, as a part of the industry. That they are not, is a failure of our diving community to provide the minimum necessary safety equipment for Tek diving safety. Let me finish with this quote from Bev Morgan, in a talk he gave at the Human Performance and SCUBA Diving seminar held at Scripps Institution of Oceanography at La Jolla, California April 10-11, 1970:

“Assuming the reader is knowledgeable in SCUBA equipment that is currently available, I offer only the following comment: There has not been a major improvement in design in 10 years.

“The future of diving equipment will be controlled by the originality of the designer, the consumer, demand, and the consumer’s willingness to pay for improvements.

“My design work has been concentrated on the first five items listed under “Diver Equipment” above. The following is my opinion on what to expect in the next five years.

“1. RESPIRATION: Better regulators for open circuit SCUBA divers will be available. Inhalation resistance will be less than one inch of water pressure. Exhalation resistance may be improved, but only slightly if at all. Water spraying on inhalation, a common occurrence in today’s regulators, will be eliminated.
“Better semi and closed circuit breathing apparatus will be available for special applications such as deep diving. Inhalation and exhalation efforts will be eliminated. The apparatus will supply intake and exhaust breathing gasses at over and under pressures. If the diver passes out, the apparatus will automatically take over the breathing cycle and signal for assistance.

“2. BUOYANCY CONTROL: Although an important factor in diving, this is tied closely with the exposure suit and has not presented a serious problem in the past. A radical departure from current methods of insulation will eliminate the necessity of wearing weights for neutralizing suit buoyancy.

“3. SIGHT: Face masks for divers will change in the next five years. Although methods of extending the diver’s field of vision exist even today, these will not be accepted. This will be due to the resulting change in depth perception and vision disorientations that accompany any changes in the flat lens system now in use. Rather, the mask will be called upon to do functions in addition to providing vision. A workable, convenient system of providing a space for voice communication and providing a mounting platform for electronics packages will change the appearance of today’s masks.
“Some deep divers will be equipped with a complete helmet which will provide a superior convenience over today’s masks, yet provide dry atmosphere for the ears to improve communications.

“4. WARMTH: Divers will be well underway to a new material in suits. Foam neoprene will be replaced with a non-gas filled material what will not change buoyancy and will be far less buoyant. Entrapment of body heat will be improved and methods of adding heat will be available. Current wet suits made of foamed neoprene will still be around but the knowledgeable diver will be shifting to a new material.

“5. VOICE COMMUNICATIONS: The largest change in diving will be availability of a system of voice communications within the price range of the average sport diver. Well over 50 percent of all sports divers will be talking to each other underwater within five years.”
(Yttri, Cy, Director of Publications, HUMAN PERFORMANCE AND SCUBA DIVING, Proceedings of the Symposium on Underwater Physiology, Scripps Institution of Oceanography, La Jolla, California, April 10-11, 1970, The Athletic Institute, 1970, Library of Congress Catalog Card Number 77-142264, 1970, pages 19-20.)

Well, not much of what Bev Morgan said in 1970 has happened. My question to the rest of you is, why not? My tentative answer is that we have not demanded it, and have settled on older equipment, reconfigured per DIR, as an answer. It is an inadequate answer for Tek divers, in my opinion.

SeaRat

 

[MikeFerrara]

Well I have FFM with commumications and it's for sale cheap. Interested? IMO, the application for FFM in tech diving is extremely limited due the the other restrictrions on configuration. The real need is for a fool proof way to change gasses and share gas FAST. In most cases the need to share gas is temporary but in order to keep control it must be handed off fast. A full face mask without surface supplied and controled gas just complicates the things that need to be simple.

There wouldn't be anything wrong with a recompression and a trained technician on hand. Hey do you think we could have one of those hauled into the Missouri hills? LOL

I certainly pray that we don't end up with the commercial diving experts trying to tell us how to manage deep cave and wreck dives. Even at that, i guess they can tell us what they want but if they try to force it they'll be in for a fight.

Now if my boss told me that I had to do this stuff I might refuse to dive without a recompression chamber.

John if you're really intereasted in improving dive safety, focus on recreational diving. I've seen three or four recreational divers injured just this past season. Recreational divers with their poor training and screwed up equipment configurations are like lambs to the slaughter.

Also, I think it's a mistake to view what goes on in the books mentioned above as representative of technical diving in general. Many of those events were in the early days of technical diving and/or misguided acts by misguided individuals. Burny leaned heavy on the FFM as a saving grace but I don't at all agree. Trimix for deep dives, solid team diving procedures and a healthy dose of common sense would have cured about all the problems illustrated in those books. Those books were for the entertainment of a mostly non-diving public and is not suitable for a safety analysis of current technical diving.

There are reasons (some stated above) that we choose not to use FFM's in technical diving. OSHA needs to stick to ptotecting employees from employers and commercial divers need to stick to diving that has a financial justification for that kind of operation.

 

[John C. Ratliff]

I've had trouble posting since the software changes, and so this reply has been delayed.

Mike, I agree with much of what you've said, especially about recreational divers. But Tek divers need to be aware that they are being watched by recreational divers, and that many wish to emulate Tek divers. Therefore, I do address what I see as safety issues for Tek divers, as well as recreational divers.

Regarding the FFM, there are many varieties. Some are good, some not so good. I've used two that I liked quite a lot, one of which is no longer available (a USD FFM that allowed me to hook it to my double-hose regulators). The Divator mask (now named something else) is also pretty good. Some of the newer ones seem to have pretty restricted vision. That doesn't mean that all FFMs are bad, only that we need to shop a bit more. The new one by Scubapro seems to address the issues you bring up concerning switching gases mid-dive too.

But nothing you've said addresses the central question, which is why Bev Morgan's vision of diving expressed in 1970 has not happened. Communications, warmth, etc. seem to have gone away, and what we are left with is DIR. Doing It Right is not innovative; it simply reconfigures current equipment configurations. My question remains, what happened to Bev Morgan's vision expressed in my previous posting?

SeaRat

 

[MikeFerrara]

But nothing you've said addresses the central question, which is why Bev Morgan's vision of diving expressed in 1970 has not happened. Communications, warmth, etc. seem to have gone away, and what we are left with is DIR. Doing It Right is not innovative; it simply reconfigures current equipment configurations. My question remains, what happened to Bev Morgan's vision expressed in my previous posting?

SeaRat

I'll take a stab at it.[/QUOTE]


“1. RESPIRATION: Better regulators for open circuit SCUBA divers will be available. Inhalation resistance will be less than one inch of water pressure. Exhalation resistance may be improved, but only slightly if at all. Water spraying on inhalation, a common occurrence in today’s regulators, will be eliminated.
“Better semi and closed circuit breathing apparatus will be available for special applications such as deep diving. Inhalation and exhalation efforts will be eliminated. The apparatus will supply intake and exhaust breathing gasses at over and under pressures. If the diver passes out, the apparatus will automatically take over the breathing cycle and signal for assistance. [/QUOTE]

As far as open circuit, my regs breath great at 275 ft woth trimix and I don't get any water spray so there just doesn't seem to be a problem.

Rebreathers are comming into their own but they don't breath for you. If you pass out it's likely because of a problem with the gas and it wouldn't help.

“2. BUOYANCY CONTROL: Although an important factor in diving, this is tied closely with the exposure suit and has not presented a serious problem in the past. A radical departure from current methods of insulation will eliminate the necessity of wearing weights for neutralizing suit buoyancy.

This is the last thing we need. With the heavy tanks we use and the number of them we carry, we actually need a buoyant suit to offset some of that weight. Many if not most technical divers do not need to add weight. The usual problem isn't being too light it's being too heavy.

A dry suit provides the constant buoyancy that we need as apposed to a wet suit that looses buoyancy with depth.

“3. SIGHT: Face masks for divers will change in the next five years. Although methods of extending the diver’s field of vision exist even today, these will not be accepted. This will be due to the resulting change in depth perception and vision disorientations that accompany any changes in the flat lens system now in use. Rather, the mask will be called upon to do functions in addition to providing vision. A workable, convenient system of providing a space for voice communication and providing a mounting platform for electronics packages will change the appearance of today’s masks.
“Some deep divers will be equipped with a complete helmet which will provide a superior convenience over today’s masks, yet provide dry atmosphere for the ears to improve communications.

Aside from the issues associated with many gas switches during the dive and these sound like fun toys that solve a problem that we don't have.

Most non-hard wired commumications are ultrasonic which requires line of sight so they won't get us diver to surface communication while penetrating wrecks or caves.

Brian Peace has developed a unit that uses radio that does provide diver to surface communications even from deep in a cave. Wes Skiles uses it in his films and I have watched a version of the system used to map a cave system from the surface. Wes Skiles also uses a FFM for this but notice that in these shows he isn't doing a bunch of gas switches. Most of us don't procedurally trust the switch blocks and quick disconects available.

Getting the wrong gas at the wrong time has been a leading killer of technical divers. Fool profe gas switches are what's need more than the communications offered by a FFM. We have good gas switch procedures.

“4. WARMTH: Divers will be well underway to a new material in suits. Foam neoprene will be replaced with a non-gas filled material what will not change buoyancy and will be far less buoyant. Entrapment of body heat will be improved and methods of adding heat will be available. Current wet suits made of foamed neoprene will still be around but the knowledgeable diver will be shifting to a new material.

Forget wet suits. They suck. Most technical diving is done in a dry suit and there are heaters available. There are both commercial and mome made versions. That's how the OCDA can spend 7 hours in Roubidoux. I don't have one because I don't need it. I just don't do 7 hour dives.

“5. VOICE COMMUNICATIONS: The largest change in diving will be availability of a system of voice communications within the price range of the average sport diver. Well over 50 percent of all sports divers will be talking to each other underwater within five years.”

Voice communication is available. Recreational divers shy away from the cost. As I explained above a FFM complicates gas switches which is a far bigger problem than no being able to talk.

Perhaps some here don't realize the number of gas switches that can be needed on some dives. As far as diver to surface comms go, what is some one on the surface going to do for you when you're an hour into a cave? Any problem that we have needs to be solved fast and those at the surface are of no help. That's why it's only used for making TV shows where when Wes Skiles wants his voice on TV.

Well, not much of what Bev Morgan said in 1970 has happened. My question to the rest of you is, why not? My tentative answer is that we have not demanded it, and have settled on older equipment, reconfigured per DIR, as an answer. It is an inadequate answer for Tek divers, in my opinion.

Define inadequate.

Leaving DIR out of it, what we have works and when it doesn't we change something. Technical diving does take advantage of new inovations when they are useful.

As I see it the problem with the predictions above is a lack of understanding of technical diving and the real provlems that go with it like the suggestion that we need a suit that isn't buoyant. It's just not what we need. The repeated reference to voice communications. Again not what we need. Yet there was no mention of improving the reliability of gas switches. I guess there weren't many gas switches going on in 1970 but that just goes to show that these predictions were from some one who didn't understand the technical diving that we're doing today.

Most of the really useful inovations come from the divers themselves since they know what they need.

 

[BigJetDriver]

QUOTE FROM MIKE FERRARA----Getting the wrong gas at the wrong time has been a leading killer of technical divers. Fool proof gas switches are what's needed more than the communications offered by a FFM.---Forget wet suits. They suck. Most technical diving is done in a dry suit and there are heaters available.---Voice communication is available. Recreational divers shy away from the cost. As I explained above a FFM complicates gas switches which is a far bigger problem than not being able to talk.

Perhaps some here don't realize the number of gas switches that can be needed on some dives.---Any problem that we have needs to be solved fast and those at the surface are of no help. That's why it's only used for making TV shows where when Wes Skiles wants his voice on TV.

Most of the really useful inovations come from the divers themselves since they know what they need.[/QUOTE]

----------------------------------------------------------

Hello to all and Happy New Year!

Actually, I took the liberty of separating out some of Mike's more pertinent (at least in my view) comments.

As he says in the last line, the divers themselves will decide what they need and what they do not.

For myself, I decided that I wanted to cut down on weight and needless gas switching, so I obtained a really good CCR. Since it gives me the absolute "best mix" at all times based upon my position in the water column, it alleviates problems with gas switching, and reduces deco obligations.

Since I want comm with the surface for various reasons, I went with the Widolf DR-600, a commercial standard FFM. In line with Mike's comments, AFTER you solve the immediate problem, you may well find there are situations where comm with the surface can save time and effort. I can think of one high-profile incident recently where it could well have saved a life.

As protection against Mr. Murphy and his minions, I installed a commercial quality RB/OC switch-block built by Divematics USA. It is easy to use, and stone reliable.

Since I, like Mike, don't appreciate freezing my cojones off, I purchased the DUI CF-200X and had it fitted with the electric underwear. Now, that's comfort, baby! (P.S.---The "P" valve is a real god-send!)

As it turns out, we do have many of the improvements that Bev (one of our pioneers) had on his wish list!

BJD :anakinpod

 

[MikeFerrara]

BJD,

What are you using the switch block for? OC bail out?

For for those of us without rebreathers I can't see using a switch bloch with as many as 4 gasses and a bunch of switches including stages. We would also have to through quick disconnects into the mix because in a cave we don't carry everything with us. Even if we did I can't see having all those tanks straped on and all of them plugged into switch blocks. All it would take is for one hose or switch to get in the wrong position and we'd end up breathing pure O2 at two or three hundred feet.

I can see rebreathers getting really popular though especially with the cost of helium. That will change lots of things.

 

[BigJetDriver]

Mike,

Yes, the block is used for a quick bail-out to OC. To any kind of normal depth, it is plumbed direct to one bail-out bottle. Below 250 fsw, it is plumbed to an actual gas manifold allowing the user to select a safe bottom gas, or a gas to surface with (just a left-right switch). Yes, selection of the correct gas is a critical point, as in any deep gas switch. The only time it would be used, of course, is in the bail-out mode.

You are quite right about the price of helium. As it goes up and up, it will take less and less bottom time to reach the "break-even" point needed to make the CCR cost-effective!

Cheers! BJD :anakinpod