Tethering Policy?
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Without going into a debate, can you clarify the OSHA statement about the standards?
Nemoh, I didn't say you brought it up, but you said that OSHA standards were required for Public Safety Diving. I wasn't singling you out, just responding.
Jared, in a previous post, I alluded to the can of worms being opened. The reason is that elements within the Public Safety Diving world, notably Mark Phillips with PSDA were concerned about the verbiage excluding PSD operations from OSHA requirements. Opinions were split and the topic discussed exhaustively in the PSDiver forum with informed people (agencies too, but we won't go there) arguing for both sides of the argument. Also, depending on the state you are functioning in, you may actually have a state OSHA plan that will SUPERCEDE the federal one.
the following is an article from ERDI and puts a good scope on the concerns and issues: OSHA Standards and PSD Teams: Are We Really Exempt? | SDI | TDI | ERDI. It takes the position that PSD divers ARE required to meet OSHA standards (at least in part). Notice that the date is in 2011.
http://www.si.edu/dive/pdfs/Butler.pdf is a paper from the US Department of Labor (OSHA Division). I do not have a date for this paper , but on page 2, paragraph 2, it is pretty explicit (and I believe the clarification is in direct response to the discussion on PSdiver and other forums). I've included that paragraph below, but you will want to refer to the document itself for references.
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Jared, in a previous post, I alluded to the can of worms being opened. The reason is that elements within the Public Safety Diving world, notably Mark Phillips with PSDA were concerned about the verbiage excluding PSD operations from OSHA requirements. Opinions were split and the topic discussed exhaustively in the PSDiver forum with informed people (agencies too, but we won't go there) arguing for both sides of the argument. Also, depending on the state you are functioning in, you may actually have a state OSHA plan that will SUPERCEDE the federal one.
the following is an article from ERDI and puts a good scope on the concerns and issues: OSHA Standards and PSD Teams: Are We Really Exempt? | SDI | TDI | ERDI. It takes the position that PSD divers ARE required to meet OSHA standards (at least in part). Notice that the date is in 2011.
http://www.si.edu/dive/pdfs/Butler.pdf is a paper from the US Department of Labor (OSHA Division). I do not have a date for this paper , but on page 2, paragraph 2, it is pretty explicit (and I believe the clarification is in direct response to the discussion on PSdiver and other forums). I've included that paragraph below, but you will want to refer to the document itself for references.
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2. “Search, rescue, and related public safety diving by or under the control of a governmentalagency.”
[/FONT][/FONT]OSHA received a number of comments from persons engaged in diving incidental to police andpublic safety functions, and the Agency concluded that an exclusion was appropriate for suchapplications. The "by or under the control of a governmental agency" language is intended to make theexclusion applicable to all divers whose purpose is to provide search, rescue, or public safety divingservices under the direction and control of a governmental agency (
[FONT=TimesNewRoman,Italic][FONT=TimesNewRoman,Italic]e.g., [/FONT][/FONT]local, state, federal government)regardless of whether or not such divers are, strictly speaking, government employees. Divingcontractors who occasionally perform such services privately on an emergency basis, and who are notunder the control of a governmental agency engaging their services, do not come under this exclusion.Such divers may, however, be covered by the provision concerning application of the standard in anemergency [29 CFR §1910.401(b)]. In excluding these search and rescue operations, OSHA determinedthat safety and health regulation of the police and related functions are best carried out by the individualStates or their political subdivisions. It is pointed out that this exclusion does not apply when work other
than search, rescue and related public safety diving is performed ([FONT=TimesNewRoman,Italic][FONT=TimesNewRoman,Italic]e.g., [/FONT][/FONT]police divers repairing a pier).
Thank you for the clearification.
I think it would be advantageous to agree with your boss but hard and fast scribed in stone rules are not effective. And by agree I mean that you look at ALL dives as "tethered" or "safety line" and only rule them out based on operational need. A circular search cannot be done with a diver tethered to the surface, however the searching diver would be attached his diver at the anchor point. But even then if either would be tethered to the surface you would be looking at a task overload for the divers and surface personal. From my experience there would not be too many occurrences that would warrant you NOT being on a line, but they do exist and to be stuck to policy would make it difficult to operate. It is difficult to discuss this without actually "discussing" it as I don't know what your manpower, politics and or policy guidelines you currently have in place.
Im not a public safety diver but have a lot of time on the end of a hose. I dont understand why anyone would dive Scuba with a rope tied to them. You may as well have an umbilical with essentially unlimited gas supplies and hard-wire communications. Add a pneumo hose if you are diving deeper than 30'.
An umbilical is stiffer and less-prone to entanglement. You can drop the size of the tank on your back, which becomes a bailout, and topside can help you navigate in black water. You can also dive solo with the other diver on the surface as a standby ready splash.
I can see a few advantages to Scuba in your business in limited circumstances, but they all go away once you tie a rope to yourself.
An umbilical is stiffer and less-prone to entanglement. You can drop the size of the tank on your back, which becomes a bailout, and topside can help you navigate in black water. You can also dive solo with the other diver on the surface as a standby ready splash.
I can see a few advantages to Scuba in your business in limited circumstances, but they all go away once you tie a rope to yourself.
In remote areas like woods or isolated rivers, you cannot get a trailer and dive rescue vehicles to the location at which the incident occurred. So in that case scuba with comm lines and backup divers are the only way to do a rescue/ recovery without topside support. Our surface supplied air relies on huge banks and a machine with a control box which is also connected to our video/ lights cable .
salth2owannabe
Contributor
Each geographical area has it's own unique requirements, each have it's own challenges to rescue/recovery. Speaking from our particular needs, our dives tend to be of very short duration, a couple of 5 min search patterns in strong current no/low vis and out, alternating with a safety diver at the surface. Not a real advantage to surface air in those situations (at least that I can see). We are often tethered but not usually direct to a harness, hand to a loop in the safety rope is pretty standard. The rope is used as a means to do a search pattern with direction/communication being directed from a tender at the surface. We often have to deal with large rocks/logs on the river bottoms which you often have to use your rope hand to maneuver around. If the rope was hard attached it would constantly hang up. I have also dove in current so strong that I was essentially a human fishing plug. A hard line to the back or chest would not have worked at all, except to fold you up like a pretzel.
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