ADCI & OSHA Recommendation 3 Man Dive Team.

Here is my post to the Rule Makers:

I am Commenting on the ADCI Comment Tracking Number: 1jz-8iyk-54h3

 

ADCI Recommendation APPLICABILITY §197.200

 

“As further stated below, we recommend that the proposed manning levels in the NPRM be confined only to the OCS so as not to conflict with existing OSHA manning levels in the inland environment."

"Currently, legitimate diving contractors already have trouble at times competing for this work while following current OSHA manning requirement this instance, we recommend that, outside of the OCS, OSHA’s requirements and manning levels for commercial diving operations should apply when working inland or off of towboats in shallow depths(in areas recognized as inland waters), as is currently done."

 

 

Under No Circumstances should this be allowed

 

Reasoning: It would Expose a greater number of divers to the # 3 man Minimum OSHA/ADCI Dive Team. OSHA does not even require a death report be made for 5 days after the death. I believe you should take into Consideration the current 2280 signers on our Petition Target at: Department of Labor, OSHA and the Coast Guard. This petition is still active and will remain so until the

Petition:

No. 1 regards the OSHA and Coast Guard investigation and reporting:

We the undersigned, require that the Coast Guard and OSHA, as regulatory bodies for the commercial diving industry, be charged with the investigation and reporting of all incidents occurring on any commercial diving operation in a timely manner.

No. 2 removes the 3 man team.

We the undersigned, require that a minimum five man team manning level be a requirement of law, and must consist of:
• One certificated diving supervisor
• One certificated diver
• One certificated standby diver
• Two qualified diving tenders
We also require that for mixed gas diving operations, an additional dedicated surface gas rack operator be mandatory.

No. 3 regards Dive Supervisor (certificate) Licensing:

We the undersigned, require the Coast Guard and OSHA set up a Licensing system for Dive Supervisors. It should have legal standing under law. This license should be revocable and the licensees subject to law for gross negligence. At this time a SCUBA Certification has more standing under U.S. Law than an ADCI or IMCA Supervisor Card.

PETITION HERE

 

Only The ADCI, supports and promotes the OSHA 3 man minimum dive team. Every other Diving related trade Organization or Commercial Diving Safety Group supports a 5 man minimum Dive Team. This Includes The Divers Association Int., IMCA, DCBC, ADAS, IOGP and The GOM Dive Safety Working Group.

 

John Carl Roat
JCRoat-Subject Matter Expert Services, LLC
Mobil:337-281-4415
E-mail class29r@cox.net
Dive Safe! It is profitable and hurts less