Dive Regulations & Policies

1. Dive Regulations & Policies Presented by the NOAA Diving Center Seattle, Washington

2. Regulatory Authority History of NOAA regulations Applicability of regulations and exceptions NOAA Diving Program (NDP) organizational structure NDP advisory boards Eligibility and maintenance of certification NDP diver classifications Certifications Reciprocity Logging dives Reportable diving incidents Safety rules highlights OSHA Diving Regulations OSHA Scientific Exemption Compliance NOAA Scientific and Working Diving Manuals NAO 209-123 Global View

3. Introduction • Need & Value: Regulations bring order to events and help ensure safety. You need to know and adhere to various regulations during dive operations. You need to become familiar with NOAA and OSHA regulations that affect how you dive. • Effect: You will conform to all applicable regulations because you understand their purposes and the benefits of compliance.

4. Regulatory Authority • NOAA divers must adhere to two sets of regulations and policies specifically related to diving: • NOAA Diving Regulations (NAO 209-123) and OMAO Policies and, • 29 CFR 1910, Subpart T (OSHA Commercial Diving Regulations) • Additionally, NOAA scientific dives must comply with the standards outlined in the NOAA Scientific Diving Standards and Safety Manual.

5. NOAA DIVING REGULATIONS And Policies

6. Short History • In February 1972, the first set of NOAA diving regulations was implemented • Subsequent revisions • August 12, 1974 • November 30, 1983 • March 29, 1991 • May 2, 2003 • In November 2009, OMAO Policy 0301 established the 0300 series (these policies supersede portions of the NAO)

7. Scope & Exceptions • Who must comply and when? • All NOAA employees engaged in official diving duties using compressed gas as the breathing medium • Non-NOAA personnel using NOAA diving equipment and/or diving from NOAA-owned vessels, unless otherwise authorized by the NOAA Diving Program • Exceptions • Emergency conditions may warrant actions contrary to the dictates of this Order. Emergency conditions consist of situations where death, serious physical harm, total loss of property, or major environmental damage is likely, but only to the extent that the action is immediately necessary to prevent or minimize harm.

8. NOAA has divers in the following Line Offices: OMAO, NOS, NMFS, OAR, and NWS Each LO has a senior representative, appointed by their Assistant Administrator, that serves on the NOAA Diving Safety Board NOAA Diving Program (NDP) leadership hierarchy (in order of rank) Manager, NDP Line & Staff Office Diving Officers Unit Diving Supervisors Divemasters Lead Divers Divers Organizational Structure

9. Advisory Boards • NOAA Diving Control and Safety Board • The “Board of Directors” for the NDP • Made up of Program Manager, LODOs, FDO and DSO • Meet annually to review and set policies • NOAA Diving Medical Review Board • Consists of five, world-class hyperbaric physicians (non-NOAA) and chaired by the NOAA Diving Center (NDC) Diving Medical Officer • Review all diving incident reports and recommend medical policies to the chairperson

10. Certification Requirements • Who’s eligible to become NOAA certified to dive? • NOAA employees (GS, CAPS, WG, WM, and NOAA Corps) and contractors • Non-NOAA personnel when statutory authority allows volunteers • NOAA diving qualification requirements • Pass a NOAA diving physical examination • Pass a NOAA swim test • Pass written test(s) • Complete checkout dive • Current CPR, First Aid and Oxygen Administration

11. Diver Classifications • NOAA diver classifications • Observer Diver • Volunteer Diver • Scientific Diver • Working Diver • Advanced Working Diver • Master Diver • Scientific divers are limited to tasks associated with observation and data collection • Working divers are not limited by the tasks to be performed

12. Issuance of certifications • NOAA certifications/authorizations to dive shall be issued by the NOAA Diving Program Manager • NOAA personnel, including contractors, shall be issued NOAA diver identification cards and letters of authorization to dive • Non-NOAA personnel are issued letters of authorization to dive

13. Requirements for maintaining dive certification: Maintain dive proficiency 2 dives per month recommended 1 dive every 6-weeks required Maintain a current diving physical Every 5 years to age 50 Every 2 years to age 60 Annually after 60 Maintain current CPR, First Aid, and Oxygen Administration Maintenance of certification Note: Remember a dive physical is not cleared until it has been approved by the NDC Diving Medical Officer

14. Recertification requirements • > 6 weeks and < 6 months without performing a dive • Must complete a requalification program consisting of a checkout dive and other requirements as determined by the UDS • > 6 months and < 1 year without performing a dive • Must complete a requalification program determined by the LODO/FDO • > 1 year without performing a dive • Must complete a NDP-authorized refresher course

15. Suspension & Revocation of Cert • Cause for suspension and revocation of dive certification: • Failure to maintain minimum diving proficiency • Failure to pass a NOAA diving physical • Evidence of inexplicable medical condition (e.g., unexplained unconsciousness) • An injury requiring recompression therapy or hospitalization • Failure to properly use or maintain NOAA-issued dive equipment • Any other potentially serious incidents

16. Logging of Dives • NOAA divers are required to log all official dives and are encouraged to log all non-duty dives • Dives must be logged using the web-based system accessible from the NDC website (www.ndc.noaa.gov) • Paper copies may be submitted to the NDC when access to the internet is unavailable • Non-duty dives can be used to maintain NDP diving proficiency requirements (count as proficiency dives)

17. Use of SEP Dive Gear • NOAA divers are permitted to use Standardized Equipment Program dive gear for non-duty dives • NOAA Diver Agreement for Off-Duty Use • Liability Waiver • Off-Duty Proficiency Skills Checklist • At minimum, NOAA divers must use the following SEP equipment on all duty dives: • Regulator set, depth and pressure gauges • Reserve Air Supply System • Buoyancy compensator* *Note: Use of personal BC’s will be considered on a case-by-case basis

18. Reciprocity • NOAA has reciprocity with over 100 non-NOAA institutions, organizations, and agencies • Reciprocity allows NOAA divers to dive with these pre-approved institutions and vice-versa • NOAA divers needing to dive with a reciprocity organization must contact the NDC to request a “Letter of Reciprocity” to be sent to the receiving organization’s Diving Safety Officer • NOAA contractors are also eligible to dive under a reciprocity agreement, however, they may be required to provide the receiving organization with “Verification of Coverage” for liability purposes

19. Reportable Injuries • All work-related injuries, whether the direct, or indirect result of diving, must be reported in compliance with DOC and NOAA policies • Examples of reportable diving injuries include: • Fatalities • Injuries requiring recompression therapy • Injuries, whether work-related or not, requiring hospitalization or that otherwise may affect an individual’s fitness to dive • Any injury requiring more than basic first-aid, or hospitalization of any kind must be reported to the UDS/NDC!

20. Other Reportable Incidents • Occasionally incidents occur that do not result in a reportable injury, but that nevertheless may warrant awareness by NDP officials • Examples include: • Equipment malfunction or failure (e.g., ScubaPro regulator) • “Near miss” or “close call” incidents that could have resulted in a fatality or serious injury • Evidence of poor judgment by a NOAA diver

21. NDP Safety Rules • No solo diving • A “Designated Person-In-Charge” and “standby diver” must be topside for all “working dives” • A “support person” must be topside for all “scientific dives,” and a “standby diver” must be topside for all “science dives” and prepared to render assistance unless otherwise authorized by the Unit Diving Supervisor • Diving depths are limited to 130 feet unless approved by the NOAA Diving Control & Safety Board (NDCSB) and diving is limited to the USN no-decompression limits unless approved by the NDCSB • Over-bottom dives require direct reference with surface

22. NDP Safety Rules con’t. • Dives beyond a comfortable swimming distance from shore, in current and/or arduous egress require a support boat and operator/tender • A means must be available to safely remove an injured diver from the water • Form 64-3 “Dive Safe Ship Operations Checklist” is to be used during ship-related dive activities • The location, means of accessibility, and contact information for the nearest operational recompression chamber must be obtained before diving

23. NDP Safety Rules con’t. • All divers must be trained and current in CPR, first aid, and oxygen administration • Oxygen resuscitator for non-breathing victim must be on-site • Use of dive equipment other than open-circuit scuba and/or breathing mixtures other than air or nitrox, requires approval of the NDCSB • Air compressors must be tested for air quality every 6 months • Regulators will be inspected and overhauled annually

24. NDP Safety Rules con’t. • Scuba cylinders inspected annually and hydrostatically tested every five (5) years (Stickers available from NDC) • Minimum diver-worn equipment required includes floatation device, depth gauge, pressure gauge, dive timer, and alternate air source • Equipment used with breathing gases containing >40% oxygen must be cleaned and maintained for oxygen service • NOAA certified divers shall undergo yearly refresher training in oxygen administration, recognition & treatment of diving accidents and injuries, and decompression tables, and conduct in-water rescue exercises (on NDC website and MOCDOC’s)

25. NDP Safety Rules con’t. • Two-way communications capable of contacting emergency assistance from the dive site • The NOAA Reserve Air Supply System (RASS) must be worn on all OSHA “working” dives and on selected NOAA “scientific” dives. • A formal written dive plan must be completed and submitted to the appropriate Unit Diving Supervisor, or his designee, for review, approval and signature prior to each separate dive operation.

26. NDP Safety Rules con’t. • A copy of the Dive Accident Management Plan must be submitted to the appropriate Unit Diving Supervisor, or his designee, for review and approval prior to each separate dive operation. • A formal written pre- and post-dive checklist must be completed by the on-site Divemaster or Lead Diver prior to each diving day. • A formal pre- and post-dive briefing must be completed prior to and at the completion of each dive by the Divemaster or Lead Diver.

27. NDP Safety Rules con’t. • All divers must surface from dives with a minimum of 500 psi in their scuba cylinders. Failure to do so will result in temporary suspension. • All NOAA divers must demonstrate basic dive proficiency by completing a checkout dive and in-water rescue skills, including the retrieval of an unconscious diver from the water to a vessel or shore, twice a year.

28. OSHA DIVING REGULATIONS

29. Background & overiew • In 1978, Occupational Safety & Health Administration (OSHA) implemented regulations governing commercial diving operations • Applies to all NOAA employees performing dives on official work time • Specific requirements covering all aspects of diving (e.g. equipment, air requirements, safety and operational procedures) • Extremely limiting for scuba operations

30. Scuba diving highlights • Max depth 130 fsw, dives >100 fsw, outside no-deco limits, or using mixed-gas (e.g. nitrox) require a chamber on-site • Requires a standby diver plus topside supervisor for all dives • 1 diver requires 1 standby diver + 1 supervisor = 3 total • 2 divers require 1 standby diver + 1 supervisor = 4 total • Requires a diver-carried, independent gas supply for emergency breathing • Breathing media limited to compressed air • Requires diver(s) be line-tended in current >1 knot

31. Exemptions • In 1984, OSHA granted exemption to their diving regulations for certain limited activities - 29 CFR 1910 • Instructional purposes (e.g. NAUI, PADI, SSI, YMCA) for open-circuit, no-decompression air diving only • Search, rescue, and public safety by a government agency • Research, development, or related purposes on human subjects • Scientific diving under the control of a diving program

32. Scientific exemption • Requirements • A Diving Safety Manual covering operational & emergency procedures, and diver training and certification criteria • A Diving Control Board with the majority of its members being active divers • Limitations • The tasks of a scientific diver are those of an observer and data gatherer • Does not include tasks traditionally associated with commercial diving

33. Scope of scientific Exemption • OSHA Scientific Exemption does not regulate: • Maximum depth of a scientific dive • Type of equipment worn on a scientific dive (e.g. open-circuit, closed-circuit, surface-supplied) • Breathing gas medium used on a scientific dive (e.g. air, nitrox, heliox, trimix) • NOAA Diving Program meets the requirements for the scientific diving exemption since it has: • NOAA Scientific Diving Standards & Safety Manual, and • Diving Control & Safety Board

34. Exemption requirements • In order to qualify for the scientific exemption, certain criterion must be met. • The following list of questions is presented to help NOAA divers and their supervisors determine whether underwater tasks constitute a scientific dive. • A negative answer to any one of these questions would potentially disqualify the task from being conducted under the exemption.

35. Exemption requirements con’t. • Can the tasks be accomplished using simple hand tools (e.g., small hammers, pliers, chisels, wrenches, cameras, measuring tapes, nets, collection jars) weighing <25 pounds underwater? • Do the tasks require the expertise of a scientist or scientist-in-training? • Can the tasks be accomplished with minimal physical exertion?

36. Exemption requirements con’t. • Can the tasks be accomplished in short duration (e.g., <1-hour) per dive? • Do the tasks involve observation of natural phenomena or responses of natural systems and/or gathering of data for scientific analysis? • If the tasks require moving or lifting objects, do the objects weigh <100 pounds underwater? • Will the tasks result in the advancement of science?

37. Non-exempt tasks • NOAA divers may be required to perform both scientific and commercial diving tasks • Typical non-scientific tasks include: • Ship husbandry • Placing & removing heavy objects • Underwater cutting • Use of power tools or hand tools • Heavy salvage • Construction

38. Compliance • When performing commercial diving tasks, the OSHA Diving Regulations must be followed • Remember, when using scuba equipment for non-scientific diving tasks: • Breathing gas limited to compressed air • Must have a reserve breathing supply • Cannot dive >100 fsw or outside no-decompression limits • Must have two people topside-- standby diver and Divemaster • Standby divers must be accompanied by another diver or line tended • Must line tend diver(s) in currents greater than 1 knot

39. Compliance con’t. • Failure to comply with OSHA commercial diving regulations exposes federal programs to written citations and non-federal programs to monetary fines • It is the responsibility of every NOAA diver to know and comply with the NOAA and OSHA diving regulations

40. NOAA Scientific & working diving standards and safety manuals

41. Scientific Manual • The NOAA Scientific Diving Standards and Safety Manual was adopted on 15 August 2008 • The manual, which was based on the AAUS Standards and meets the requirements for the scientific exemption outlined in 29CFR1910.401(a)(2)(iv)

42. Scientific Manual cont’. • The manual is to be used when performing tasks that fall under the OSHA scientific exemption, and not working tasks • The manual needs some minor revisions to correct typographical errors and update some policies that have changed since the manual was released • The manual has been updated and should be ready for dissemination by mid-June 2010

43. Working Manual • TheNOAA Working Diving Standards and Safety Manual, due for implementation in mid-June 2010, is to be used when performing working tasks, not science-exempt tasks • The manual incorporates regulations and policies from 29 CFR Subpart T and NAO 209-123

44. NOAA administrative order 209-123

45. NAO 209-123 • NOAA Administrative Order 209-123 (aka, the NOAA Diving Regulations) is still in effect, however, some of the sections have been superseded by the NOAA Scientific Diving Standards and Safety Manual & OMAO Policies • Once the NOAA Working Diving Standards and Safety Manual is approved, and the NOAA Scientific Diving Standards and Safety Manual is revised, the NAO will be revised to point to these documents for details

46. Key Points - 1 • NOAA divers must adhere to both the NOAA and OSHA diving regulations • All NOAA employees and non-NOAA employees using NOAA dive gear or diving from NOAA owned vessels are subject to the NOAA diving regulations • The NOAA Diving Control and Safety Board establishes policies and standards for the NDP • The NOAA Diving Medical Review Board makes recommendations concerning medical standards and policies

47. Key Points - 2 • NOAA diver classifications include Observer, Scientific, Working, Advanced Working, and Master diver • The primary difference between scientific diver and working diver is the tasks that they are authorized to perform • Maintenance of diving certification requires regular performance of dives, physical exams, and CPR, First Aid, and oxygen administration training • Failure to meet dive proficiency requirements results in temporary suspension pending completion of a recertification program

48. Key Points - 3 • Certifications may be temporarily suspended or revoked for non-compliance with applicable regulations, standards and policies • Divers must log official duty dives • NOAA divers may use SEP dive equipment for non-duty dives (forms required) • NOAA federal employees are eligible for dive pay • All diving incidents are required to be reported • NDP has reciprocity with many other diving programs

49. Key Points - 4 • Any injury requiring more than basic first-aid, or hospitalization of any kind must be reported to the UDS/NDC • Some NOAA divers perform work that falls outside the OSHA scientific exemption, and therefore must comply with the OSHA commercial diving regulations • OSHA commercial diving regulations require equipment and topside support beyond that required by the NDP • The NOAA Scientific Diving Standards & Safety Manual prescribes standards for scientific dives.