COMMERCIAL DIVING OPERATIONS.pdf
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This document is an appendix detailing commercial diving regulatory requirements from the Coast Guard (COMDTINST M3150.1D), providing comprehensive guidelines for commercial diving operations across personnel, equipment, and safety standards. The appendix systematically outlines regulatory requirements from both OSHA and USCG perspectives, covering critical areas such as dive team qualifications, personnel requirements, operational protocols, equipment specifications, and safety procedures for different diving types including SCUBA, surface-supplied, and saturation diving. Key regulatory details include depth limitations (e.g., surface-supplied diving limited to 190 feet sea water), mandatory equipment standards (such as compressor air purity testing, breathing gas supply specifications), personnel certifications, safety equipment requirements, and specific protocols for different diving scenarios.
The document provides granular guidance on essential elements like minimum dive team composition (three personnel for SCUBA, four for surface-supplied diving), mandatory safety equipment (decompression chambers, communication systems, first-aid equipment), equipment testing protocols, and specific regulatory citations from 29 CFR and 46 CFR. Critical safety requirements include having a designated person-in-charge, maintaining dive logs, ensuring two-way communications, providing emergency assistance plans, displaying warning signals, and meeting specific equipment standards like non-return valves on helmets, pressure-tested breathing hoses, and properly maintained decompression chambers. The appendix serves as a comprehensive reference for ensuring compliance with federal diving safety regulations.
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COMDTINST M3150.1D
A-1
APPENDIX A. COMMERCIAL DIVING REGULATORY REQUIREMENTS
The member charged with oversight to diving operations should review the following requirements with the diving supervisor or designated person-in-charge before commencing diving operations. This table is not a comprehensive regulatory inspection document. It is intended to provide an indicator of substantial compliance with the mandatory health and safety requirements for commercial divers.
COMMERCIAL DIVING PERSONNEL
Requirement OSHA Regulation USCG Regulation Comments
Dive team members must be qualified to conduct assigned tasks.
29 CFR 1910.410 (a)
29 CFR 1910.120
46 CFR 197.404
46 CFR 197.410
There is not a “commercial diver certification card,” similar to those required by the recreational diving community. The Association of Diving Contractors International offers a certification card or the company can provide proof of experience. Divers should provide proof of hazardous waste operations and emergency response (HAZWOPER) training before commencing diving operations in contaminated water.
All dive team members must have current cardiopulmonary resuscitation (CPR) and first-aid certifications.
29 CFR 1910.410
For SCUBA diving operations, a minimum of three personnel are required: the person-in-charge, a standby diver, and the diver.
For Surface Supplied Diving operations, a minimum of 4 personnel are required: the person-in-charge, a standby diver, the diver, and a diver-tender.
29 CFR 1910.410 (b)
29 CFR 1910.424
29 CFR 1910.425
29 CFR 1910.426
46 CFR 197.430
46 CFR 197.432
46 CFR 197.434
A minimum of three personnel for SCUBA and four personnel for Surface Supplied Diving is required by OSHA regulations and is an accepted industry practice by the Association of Diving Contractors International. The Coast Guard requires a minimum three-member dive team for Coast Guard contracts (ALDIST 228, 1999). The diving supervisor must not serve in a dual role as both supervisor and diver. The standby diver must be dressed out and ready to dive.
An experienced, designated person-in-charge is on-scene and supervising the operation.
29 CFR 1910.410 (c)
46 CFR 197.208
46 CFR 197.210
46 CFR 197.402
46 CFR 197.404
Under the OSHA regulations, the person-in-charge is the qualified diving supervisor. When diving operations occur on an inspected vessel, under USCG regulations, the person-in-charge (the owner, agent, or master of the vessel) and the diving supervisor are separate individuals, and both must be designated in writing.
COMMERCIAL DIVING OPERATIONS
Requirement OSHA Regulation USCG Regulation Comments
A Safe Practices Manual or Operations Manual must be available on-site.
Prior to welding or burning on closed compartments, structures or pipes, which contain a flammable vapor or in which a flammable vapor may be generated by the work, they shall be vented, flooded, or purged with a mixture of gases which will not support combustion.
29 CFR 1910.420
29 CFR 1910.421(b)
29 CFR 1910.422
(g)(5)
46 CFR 197.420
OSHA regulations require a Safe Practices Manual that describes the diving activities, while USCG regulations require an Operations Manual that meets the requirements of the Safe Practices Manual. This is the site-safety plan. In particular, personnel should review emergency procedures, emergency phone numbers, and the directions to the nearest decompression chamber and hospital.
For contaminated water diving, a more specific safety plan that addresses the specific contaminant and protective equipment should be available.
Appendix A to COMDTINST M3150.1D
A-2
COMMERCIAL DIVING OPERATIONS
Requirement OSHA Regulation USCG Regulation Comments
The divers must have a plan to obtain emergency assistance, specifically, a two-way communications system.
29 CFR 1910.421(b)
46 CFR 197.420
46 CFR 197.314 (b)
If a decompression chamber is not required on site, ensure that the divers know the location and contact numbers of the nearest facility and hospital. Most importantly, the divers must have the capability to reach emergency services.
First-aid equipment, including a hand-held resuscitator, must be located on site.
29 CFR 1910.421(c)
29 CFR 1910.423
46 CFR 197.314
46 CFR 197.432
For dives deeper than 100-fsw (feet sea water) or dives outside the no-decompression limits, an operating decompression chamber and supply of breathing gas sufficient to treat for decompression sickness must be located on-site. The chamber must be within five (5) minutes of the dive station. The more conservative OSHA limitation of 100-ft depth should be applied.
The Diving Supervisor must conduct a pre-dive safety briefing and inspect equipment.
29 CFR 1910.421(f) & (g)
46 CFR 197.410
All members of the dive team must attend.
Key personnel of the ship or facility should also attend.
A warning signal (dive flag) must be displayed. 29 CFR 1910.421(h) COLREGS, Rule 27
The warning signal must be a rigid replica of the international code “A” flag at least one
(1) meter in height.
The person-in-charge and the diving supervisor must maintain a dive log.
29 CFR 1910.440 46 CFR 197.480
The log should contain the date, time, and location of the start and completion of dive operations; underwater and surface conditions; name of diving supervisor; and general nature of the work performed.
SCUBA DIVING OPERATIONS
Requirement OSHA Regulation USCG Regulation Comments
Scuba diving must be conducted in depths less than 130 fsw, within the no-decompression limits, and in currents less than one (1) knot.
29 CFR 1910.424 (b) 46 CFR 197.430 (a)
OSHA regulations require an operating decompression chamber on-site when diving greater than 100 fsw or outside the no-decompression limits.
Scuba diving is not appropriate where there is a risk of oil or toxic chemical ingestion.
The NOAA Diving Manual states “Standard scuba gear offers inadequate protection to divers operating in contaminated water environments” (NOAA, 1991).
A standby diver is available while the scuba diver is in the water.
29 CFR 1910.424 (c) 46 CFR 197.430 (c)
The scuba diver must be either line-tended or accompanied by another diver with continuous visual contact.
29 CFR 1910.424 (c) 46 CFR 197.430 (d)
If the scuba diver must work in a physically confining space, another diver must line-tend the diver from the underwater point of entry.
29 CFR 1910.424 (c) 46 CFR 197.430 (e)
During salvage operations and underwater oil recovery operations, divers must often penetrate the hull to conduct damage assessments, connect equipment, and recover floating oil.
Scuba divers must carry a reserve breathing gas supply.
29 CFR 1910.424 (c)
A-3
SURFACE-SUPPLIED DIVING
Requirement OSHA Regulation USCG Regulation Comments
Surface-supplied air diving must be conducted at a depth of 190 fsw or less.
29 CFR 1910.425 (b) 46 CFR 197.432 Dives of 30 minutes or less may be conducted to depths of 220 fsw.
Mixed-gas must be used as a breathing mixture for dives deeper than 220 fsw.
29 CFR 1910.426 46 CFR 197.434
A separate dive team member must tend each diver in the water.
An open bell is required for dives deeper than 220 fsw or when the dive involves in-water decompression times greater than 120 minutes.
29 CFR 1910.426 (b) 46 CFE 197.434 (c)
A closed bell is required for dives greater than 300 fsw.
29 CFR 1910.426 (b) 46 CFR 197.434 (d)
The regulations permit an exception to this rule when diving is conducted in a physically confining space.
When closed bell operations are conducted, a diver must be available in the closed bell to assist the diver in the water.
Each diver must be continuously tended. 29 CFR 1910.425 (c) 46 CFR 197.432 (c) Divers must carry a reserve breathing gas supply at depths greater than 100 fsw or outside the no-decompression limits.
29 CFR 1910.425
(c) (4) (iii)
46 CFR 197.432 (e)
Note: Coast Guard regulations require a secondary (reserve) breathing gas supply at depths greater than 130 fsw or outside the no-decompression limits. However, the Coast Guard (decision March 5, 2001) and the ADCI recommend that bailout bottles be used for all commercial diving operations, regardless of depth.
An operating decompression chamber must be on-site for any dive outside the no-decompression limits, mixed-gas diving, or for dives deeper than 100 fsw.
29 CFR 1910.425 (b)
29 CFR 1910.426
46 CFR 197.432 (e) (2)
Note: Coast Guard regulations require a decompression chamber on-site for dive operations greater than 130 fsw or outside the no-decompression limits. The more conservative OSHA limitation of 100 fsw should be applied.
When saturation diving is conducted (1) a standby diver must be available when the closed bell leaves the dive location until the divers are in saturation, and (2) a member of the dive team must be able to assist in the recovery of the closed bell or its occupants.
20 CFR 1910.426 46 CFR 197.434 (g)
COMMERCIAL DIVING EQUIPMENT
Requirement OSHA Regulation USCG Regulation Comments
Air compressors used to supply air to the diver must be equipped with a volume tank with a check valve on the inlet side, a pressure gauge, a relief valve, and a drain valve.
29 CFR 1910.430 (b) 46 CFR 197.310
Air intakes for air compressors must be located away from areas containing exhaust fumes or other hazardous materials.
29 CFR 1910.430 (b)(2) 46 CFR 197.310 (b)
A-4
COMMERCIAL DIVING EQUIPMENT
Requirement OSHA Regulation USCG Regulation Comments
The output of the air compressor systems must be tested for air purity every six (6) months and after every repair or modification.
29 CFR 1910.430 (b)(4)
46 CFR 197.450
46 CFR 197.340
The diving supervisor must provide laboratory results or maintenance records for air quality. Compare the compressor identification number with that noted on the laboratory results or maintenance records.
Compressed air used for breathing mixtures must be 20 to 22 percent oxygen by volume, have no objectionable odor, and have no more than 1000 ppm (particles per million) carbon dioxide, 20 ppm carbon monoxide, 5 mg/cubic meter of solid and liquid particulates including oil, and 25 ppm hydrocarbons.
Surface-supplied helmets and masks must have a non-return valve, an exhaust valve, and a two-way voice communications system.
29 CFR 1910.430 (h) 46 CFR 197.322 (a)
Breathing gas supply hoses must have a working pressure at least equal to the working pressure of the total breathing system, have a bursting pressure at least equal to four times the working pressure, and be tested at least annually to one and one-half (1.5) times their working pressure.
29 CFR 1910.430 (c) 46 CFR 197.312
Ensure the breathing supply line has been pressure tested to one and one-half (1.5) times the Maximum Allowable Working Pressure within the past year. Additionally, ensure all connectors are made of corrosion-resistant material and the umbilical is marked in 10-foot increments from the diver to 100 fsw and is constructed of kink-resistant material.
A depth gauge is required for every diver.
29 CFR 1910.430 (g) 46 CFR 197.318
OSHA and USCG regulations require a depth gauge that can be read on the surface for surface-supplied divers. Additionally, OSHA requires a depth gauge that can be read by the SCUBA diver.
A diving ladder or stage must be provided to assist entry and exit.
29 CFR 1910.425
46 CFR 197.320
46 CFR 197.432
When using heavy gear in depths greater than 100 fsw, an in-water stage must be provided.
A diver’s safety harness, with a positive buckling device capable of distributing the pulling force of the umbilical, is required for surface-supplied divers.
29 CFR 1910.420 (j) 46 CFR 197.324
When weights are worn, the belt or assembly should be equipped with a quick release.
29 CFR 1910.430 (j)
Decompression chambers, or “pressure vessels for human occupancy (PVHO),” must be properly equipped and maintained.
1. PVHO must be stamped ASME PVHO-1 or have documentation of CG approval.
2. PVHO piping must have a shut-off valve within 1-foot of every pressure boundary penetration.
3. The PVHO must have (a) a pressure relief device, (b) two-way communications between compartments and to the outside,
(c) a pressure gauge in each compartment,
(d) view ports, (e) enough illumination to allow occupants to read gauges, (f) a means of extinguishing an interior fire, and (g) a means of overriding interior breathing and pressure-supply controls.
29 CFR 1910.430 (f)
46 CFR 197.328
46 CFR 197.462
Records must show that the chamber has been examined for mechanical damage or deterioration on an annual basis.
Additionally, the pressure vessel and associated piping must be pressure tested every three (3) years.
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