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DIRECTIVE NUMBER: CPL 02-00-151 EFFECTIVE DATE ... - OSHA

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APPENDIX A: Commercial Diving Operations Questions and Answers<br />

This appendix consolidates <strong>OSHA</strong> interpretations related to commercial diving operations that<br />

have been issued and remain valid as of the date of this instruction. Previously issued<br />

interpretations were reviewed to determine their current validity and accuracy. Interpretations<br />

for which standard references have changed were updated to reflect the current standard<br />

reference.<br />

<strong>OSHA</strong> requirements are set by statute, standards, and regulations. The Agency’s interpretations<br />

explain these requirements and how they apply to particular circumstances, but they cannot<br />

create additional employer obligations. These responses constitute <strong>OSHA</strong>’s interpretations of<br />

the requirements discussed. Note that our enforcement guidance may be affected by changes to<br />

<strong>OSHA</strong> rules. Also, from time to time we update our guidance in response to new information.<br />

To keep apprised of such developments, you can consult <strong>OSHA</strong>’s website at:<br />

http://www.osha.gov.<br />

Question #1: Are diving operations involving the underwater inspection of bridges and other<br />

submerged structures considered to be “scientific diving” under 29 CFR 1910.401(a)(2)(iv),<br />

and if this diving is “scientific diving,” what standards apply to these divers<br />

Answer: The underwater inspection of bridges and other structures by divers is governed by<br />

<strong>OSHA</strong> regulations for commercial diving, 29 CFR Part 1910, Subpart T – Commercial Diving<br />

Operations. The exemption from <strong>OSHA</strong>’s commercial diving standard for scientific diving<br />

would not be applicable to underwater inspections of bridges or other submerged structures.<br />

Question #2: What are the minimum number of dive-team members required to support<br />

air dives using SCUBA equipment and surface-supplied diving equipment, with one diver<br />

in the water<br />

Answer: In establishing the number of dive-team members required for a dive, proper<br />

consideration must be given to 29 CFR 1910.421(d) Planning and assessment, 29 CFR<br />

1910.421(e) Hazardous activities, and 29 CFR 1910.422(b)(3). This latter provision requires<br />

employers to provide a means to assist an injured diver from the water (such as an inwater stage,<br />

small boat, or stokes basket) or into a diving bell, that may necessitate additional dive-team<br />

members.<br />

Commercial SCUBA air diving with one diver in the water requires a minimum of three diveteam<br />

members: a designated person-in-charge (DPIC) (see 29 CFR 1910.410(c)), a standby<br />

diver (see 29 CFR 1910.424(c)(1)), and a line-tended diver (see 29 CFR 1910.424(c)(2)). A<br />

tender who is a qualified diver can be the standby diver; for a three-person dive-team, the DPIC<br />

would assume tending duties when the standby diver (tender) is in the water. A DPIC also can<br />

be the standby diver, provided that: (1) he/she is a qualified diver, and (2) another dive-team<br />

member at the dive location is trained and capable of performing necessary DPIC-functions<br />

while the DPIC is in the water as the standby diver.<br />

Commercial surface-supplied air diving with one diver in the water requires a minimum of three<br />

dive-team members: a DPIC (see 29 CFR 1910.410(c)), and a diver “who shall be continuously<br />

A-1

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