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Divers Association

Personal Recommendations Posted to Coast Guard #1

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About This File

All individual comments I post to the Coast Guard on 46 CFR Parts 8 and 197 will be posted here as well. As I make more comments I will add them to this post. Below are three specific questions the Coast Guard ask for comment on. I believe that question 3 is the most important so I responded to that one first SEE ATTACHED.

Each of you can comment on any part of part of what has been suggested for regulation. Both positive and negative comments are important.

VII. Requests for Specific Comments

We would like more information about the SCUBA dive teams, whether all dive teams should include medical technicians, and whether or not we should consider alternative approaches to our proposed regulations. The following questions relate to these three issues. In response to these questions we ask for public comments with supporting data and references if possible.

SCUBA dive teams. Our first issue is the minimum size of a SCUBA dive team. Our NPRM proposes setting the minimum at four members, the same as required by the Army Corps of Engineers, but one more than OSHA's minimum.

QUESTION 1: The Coast Guard proposes a SCUBA dive team consisting of four members,

based on the assumption that prudent commercial diving operators use SCUBA only when

conditions are favorable to the diver and risk is minimal: that is, underwater visibility is greater

than 3 feet, currents are less than 1 knot, and dive depth is no more than 100 fsw with no

decompression. Is that assumption valid? Should a SCUBA dive team consist of more or fewer

than four members? Why? What costs would be incurred and what benefits would be gained by

setting the minimum higher or lower than four members? Medical technicians.

The second issue involves certified diving medical technicians (DMTs). Commercial diving exposes divers to unique risks and physical challenges, such as barotrauma, that may require specialized and readily available medical care.

QUESTION 2: Should a DMT always be available, either as part of the dive team or at the dive

site during a dive? Why or why not? What costs would be incurred and what benefits would be

gained by requiring this level of availability?

Alternative approaches. Our third issue involves alternative

QUESTION 3: Under one alternative to our proposals, the Coast Guard would not directly

over see TPO audits of commercial diving operations and would allow TPOs to self-certify that

their audits comply with Coast Guard standards. However, we would indirectly oversee audits

by investigating reported marine casualties and associated civil penalty proceedings. Under a

second alternative, neither the Coast Guard nor a TPO would conduct inspections or audits of

commercial diving operations. The only compliance oversight would come through casualty

investigations and civil penalty proceedings. The Coast Guard requests input on what merits and drawbacks may be associated with these two alternative approaches

To make your comments go here: http://www.regulations.gov/#!home Enter in the search engine:

Docket No. USCG-1998-3786