Article References:

1. 29 CFR, Part 1910.401 - 1940.441
2. 46 CFR, Part 197, 197.200 - 197.488
3. Flag State/National Regulations
4. ADC Consensus Standards for Commercial Diving Regulations

Whether commercial diving and underwater operations are conducted under specific regulations such as those of the United States (references a and b) or, under regulations (c) promulgated by a Flag State (nation), there can be no doubt that these operations must be conducted in a manner that promotes the highest standards of safety. Reference (d) addresses these concerns and presents the consensus of not a US industry, but rather one of a global nature.

The ADC International Consensus Standards for Commercial Diving and Underwater Operations is founded on the basis that there must be certain minimum standards that, if followed, will create an environment of safety. These standards reflect the fact that in no instance is it considered appropriate that there be less than a three-man diving team, that all team members must be formally trained and experienced, and that recreationally-trained divers do not meet the formal training requirements necessary to assure safety. These facts are backed by numerous letters, interpretative documents, and statements made by certifying bodies within government and the recreational diving community.

The Consensus Standards also recognize the fact that, in some instances, perfectly competent commercial diving personnel may have received the bulk of their training on-the-job rather than through a formal training mechanism. This is especially true in areas of the world where commercial diving training schools are not available.

Diving personnel, wherever trained and in whatever manner, should be evaluated for competence based on an employer recognizing and attesting to their capabilities in conducting commercial diving and underwater operations. ADC International does not consider that third-party testing, evaluation, or auditing can prove the professional competence of an individual to conduct underwater operations. However, the certification of commercial diver personnel must meet certain standards such as those contained in the Consensus Standards, a mechanism that stresses the importance of formal training to an established curriculum, if available.

Sometimes More, But Never Less Than Three
As in any approach to safety, the regulations, instructions, codes, or practices around the world may differ somewhat. However, the basic premise of the ADC Consensus Standards is that, if developed by industry, recognized by government, properly and consistently applied, and enforced, such standards will produce significant safety benefits. These standards are developed so that, where additional safeguards are considered appropriate, there should be no hesitation in applying same. However, in no case should the minimum standards represented by the Consensus Standards be reduced or overlooked.

Users of commercial diving services should be aware that substantial risk exposure is present through the use of improperly trained or inexperienced personnel, or when inadequate manning of a dive team is permitted. That risk exposure relates not only to the increased possibility of an in-water incident, but also to substantial fines that may be levied by national authorities. Significant damage to the reputation of a user of such services not concerned about safety should also be understood.

Users of commercial diving services should also be aware that, notwithstanding the fact that a minimum dive team must comprise three persons, for many underwater operations a team of three persons will not be adequate for proper performance of the intended operations. Such instances arise when, for example, any form of confined space or penetration diving is intended, underwater obstructions are present, surrounding construction activities are present, or the use of underwater "hose" supplied tools are necessary. In each of these instances the composition of the dive team must be increased to assure appropriate safety.

The number of persons with which to increase the dive team composition can only be determined by a thorough job planning and assessment analysis, conducted with all parties to the operation present. This action, variously entitled a Job Hazard Analysis or Job Safety Analysis, is a requirement of references (a), (b), (d), and - where the ADC Consensus Standards have been formally adopted by another Flag State - reference (c).