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We Have an Ally in the CFR process that many have been un aware of.
Divers, in regard to all the hot headed wonder about the up comming CFR submittal. We do not agree on alot of the information contaied in the consences.
This is well known but what we have all been un aware of, (Most of us) is that we have a direct line of input to the Coast Guard office responsible for writing the CFR's.
For those who have been wasting time praying tat you would be heard by the ADC by answering the review questions on the Underwater Web site - stop wasting tme.
We know for a fact that our input, is usually ignored.
I had th privlage of speaking wth the Coast Guard team Commander who writes them.
There is a period where new directives are "OPEN FOR COMMENT" .
Here's pretty much how it works.;
1.The Coast Guard looks to the industry for input and comments on the new regulations.
a. the ADC is going to submit this package we hve been reviewing.
2. THe Coast Gurad will review and select the things in it that compliment or increase the safety level of a process write a ddraft and open it for comment.
a.the ADCwill not inform you of this
b. the OPEN FOR COMMENT period is open to ALL stakeholders in the industry - ESPECIALLY THOSE AFFECTED BY THE REGULAATIONS (MEANING US!!!!!)
c. the regulation modification is based on input from EVERYONE,
3. THE USCG analyses (sorry my spelling sucks my eyes are worn out) the comments (like a tally), and modifies the regulation according to the opinions and concerns of th stake holders.
a. ie adc 1 comment vs. the divers men and women effected by the regulations. the higher tally usually sugests a need to investigate and ask more questions or increase the level of rule to insure thsafety of the "Public" (US).
LAter today I will have information that will involve all of you, your comments are to GOvernment officials, and not subject to review by theADC or any other self proclaimed "GOVERNING BODY".
I will be on later with more information
GOD BLESS
An open door can only yield reward if you open and enter....
Views: 149
Replies to This Discussion
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Permalink Reply by Jerry Babin on
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Ok crew, here's the information I promised.
The Lead Developer for writing the new regs and changes ( recommeded, required, requested) is Mr. Patric Mannion e-mail patric.j.mannion@uscg.mil direct line contact 202-372-1439.
The Gentelman in Charge is Commander Patrick W. Clark e-mail patrick.w.clark@uscg.mil direct line contact 202-372-1410.
Ladies and Gentlemen it has taken me alot of effort to find these people and establish a line of communication. these gentelmen are looking out for the interest of the industry, but first the safety of the public and those who are affected by the rules written.
1. these me are ally's not the enemy I would ask that you show them the respect due them, and direct legitemate, serious, respectful inquiries concerns, and questions to them. They will give you answers, if you ask questions.
2. Please do not abuse this information and usit to whine about pay, insurance or anything NOT related to safe operations.
3. Listen and act accordingly to the information you recieve. It Will make a difference in this industry. Your opinion is important, (as long as its related to the regs). Read the regs before you open your mouth, and know what you are talking about to maintain your credibility. It will pay off in te end.
4. Pass this information on to any diver you encounter. Rookie or Vet. Especially the rookies. The ADC doesnt teach the regs (OSHA< USCG< ANSI) in schools for a reason. If you think you are following the book, it is not the Red Book you should be reading, it's the USCG Book you should be living by. Everything in the red one is in the Coast Guard Manual. Thats where most of the info comes from.
Fair WInds Brothers and sisters Use this information wisely and respectfully. I got the door opened, all you guys have to do is go straight to the source and ask questions and make recommendations to the men actually writing them. Heres the most important place to cast your vote. Do not let anyone speak for you ( especially if you have problems with the sermon they preach) speak for your self to some one who wants to listen.
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Permalink Reply by Joseph on
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Jerry,
EXCELLENT INFORMATION!
I crossed posted this on offshorediver.com see URL:
http://members.boardhost.com/offshorediver/msg/1287594581.html
NOW EVERYONE READING THIS WHO WOULD LIKE TO SEE CHANGE IN THE CFR SHOULD WRITE TO:
"Mr. Patric Mannion e-mail patric.j.mannion@uscg.mil direct line contact 202-372-1439.
The Gentleman in Charge is Commander Patrick W. Clark e-mail patrick.w.clark@uscg.mil direct line contact 202-372-1410"
AND REQUEST FOR THE CHANGE YOU WOULD LIKE TO SEE.
IF YOU DO NOT GET INVOLVED AND REQUEST CHANGE YOU HAVE NO ONE TO BLAME BUT YOUR SELF!
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Permalink Reply by John Carl Roat on
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Keep up the good work guys I believe the Coast Guard is tired of being used as a patsy’s and is in fact listening!!
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I had the privilage of two hours of open communication. No, they cannot and will not discuss the upcomming regs, bt what they will listen to, is complaints, safety issues and suggested solotions to these problems. THe ADC DOES NOT write the regs, if you want to keep it that way, send emails and call. Get on the email list and get involved during the Real Reg Review period. THe USCG will email you with details.
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Permalink Reply by Roc Taylor on
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Thank you gentlemen for getting this information. I ask this, I see that a Dive crew of 5 is being requested. Would a Dive crew of 6 not be safer?
1 Supervisor
1 Designated Rack Operator
1 Diver
1 Tender for working diver
1 Stand By Diver, fully dressed
1 Tender for Stand By Diver
Just my opinion.
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Hell I would be happy if they would call for a Rack Op on gas dives they don't. Minimum 5 man team for surface gas.
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WHen the Coast Gurad gets our comments,complaints and recommendations the draft will be edited by them ( no one else) to include what is considered an honest safe standard. The edited draft is then reviewed and compiled by the Reg Committe (USCG no Civilians), and enacted. The GUys at the Reg office can explain it better they will speak to you, and they will answer emails ( we pay their salaries, and the rules they write must protect our best interest over and above business dollars.
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Send an email, every comment we make ( explain the reason) against the ADC's cfr submittal and their Red Book, counts like a vote. ADC gets one vote if they ant a 3 man team, and we specify why we need a 5 man team for all operations, that counts as a vote ( If all o us disagree, guess how many men will be on deck when the USCG pa**** or writes their reg.! We win but we need to stop wasting time commenting on the ADC's suggestions they dont want us emailing the people we have a legal right to communicate openly with. The USCG Draft will be comming out soon, If you want big brother controling your life keep commenting on the ADC site. If you guys want your opinion to count start sending suggestions straight to the coast guard. HEads up all emails sent will guarantee you notification on the OPEN COMMENT period so you can be heard when it really counts by the people we pay to protect us.
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Send the email and get on the Reg Comittees mailing list.
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Roc,
Write up what You would like and send copies to the appropriate people.
Not trying to be a wise ass, everyone MUST write in what they would like.
The more people write, the better it is for the "personal working in the field!"
NEVER FORGET!
ADC/ADCI IS NOT YOUR FRIEND!
"ADC was formed by a group of five diving companies who were operating in the Gulf and decided to fight unionization. Their goal was to establish standards so that the government would not start imposing regulations on the diving companies."
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Its time for the Government to get involved. Every diver on the beach should have been paid for lost time and opportunities. We dive Navy tables, and education is established by ANSI (another government group - not ADC) why no unions, because other groups who do not use divers could not overcharge the OGI (Oil & Gas Industry ) for junk in boxes that never gets used. This is the dark sideof ASSOCIATIONS. If Our tax dollars pay for NEDU research and NEDU diver education and NAvy Salvage DIver training then why is the education format currently used so weak in hands on and so much in books that arent used in the field? I and every oldtimer here has taught tenders at one time or another that education was free, though I wh*** heartedly support schools, the format has to change, and the word Diver needs to be removed from the Cert card. Tenders ar Tenders not divers. SO why are rookies diving over experienced divers?
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