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

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

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issues commercial diver certification cards in accordance with the ADCI Consensus Standards<br />

for Commercial Diving and Underwater Operations (Section 3.0, 6 th Edition (2011)). <strong>OSHA</strong><br />

considers an employer to be in compliance with the 29 CFR 1910.410 diver-training<br />

requirements when the employed divers have a valid ADCI commercial diver certification card<br />

indicating the appropriate training level.<br />

Question #5: Do the Consensus Standards for Commercial Diving and Underwater<br />

Operations published by the Association of Diving Contractors International (ADCI)<br />

comply with <strong>OSHA</strong> and U.S. Coast Guard requirements for commercial diving operations<br />

For diving operations that are not covered by <strong>OSHA</strong> or U.S. Coast Guard regulations, such<br />

as maintenance and repair of pressure vessels for human occupancy (PVHO) or handling<br />

systems for diving bells, what does <strong>OSHA</strong> recognize as the best industry practice<br />

Answer: <strong>OSHA</strong> recognizes the ADCI Consensus Standards for Commercial Diving and<br />

Underwater Operations as meeting the general requirements of 29 CFR 1910.420 for a safe<br />

practices manual. The contents of this document meet or exceed the requirements of 29 CFR<br />

Part 1910, Subpart T. For diving-related operational, maintenance, and testing matters that are<br />

not addressed by <strong>OSHA</strong> standards, <strong>OSHA</strong> recognizes ADCI standards as the best established<br />

industry practice.<br />

<strong>OSHA</strong>’s recognition of the ADCI standards is consistent with the position taken by the U.S.<br />

Coast Guard. In a letter from the U.S. Coast Guard, Chief, Office of Compliance, to the ADCI<br />

dated February 9, 2<strong>00</strong>5, the U.S. Coast Guard stated, “Of significance, ADCI’s Consensus<br />

Standards for Commercial Diving and Underwater Operations fully meet and exceed the Coast<br />

Guard’s regulatory requirements for commercial diving operations found in 46 CFR 197. Now<br />

in its Fifth Edition, the ADCI Consensus Standards are considered commercial diving industry<br />

best practices and are recognized and used by the United States Coast Guard as our<br />

comprehensive guidance document.”<br />

NOTE: The ADCI Consensus Standards for Commercial Diving and Underwater Operations is<br />

now in its 6th Edition (2011).<br />

Question #6: How is a determination made of a safe or minimum operating pressure for<br />

commercial diving surface-supplied equipment<br />

Answer: The minimum safe operating pressure for any surface-supplied diving system is<br />

dependent upon three principal factors: (1) the depth of the dive; (2) pressure loss through the<br />

diving air-supply hose; and (3) the pressure requirements for the diving helmet or mask. Equally<br />

important is the flow (volume) of air supplied to the diver. Employers must comply with the<br />

manufacturers’ recommended operating pressures and flow requirements for diving helmets and<br />

masks, and all diving systems must be analyzed by a competent person to ensure that the systems<br />

will support the diving operations adequately.<br />

As required by 29 CFR 1910.430(h)(2), a surface-supplied air helmet or mask must have a<br />

minimum ventilation rate capability of 4.5 acfm at the depth of the dive, or the capability of<br />

maintaining the diver’s inspired carbon-dioxide partial pressure below 0.<strong>02</strong> ATA when the diver<br />

is producing carbon dioxide at a rate of 1.6 standard liters per minute. Diving system flow<br />

requirements must be analyzed as follows: (1) the flow volume of breathing gas needed by the<br />

A-3

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