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New ADC Regulations, B.S.
Following is a letter that I posted on the Offshore Diver Web sight. Any Comments?
John,
Here is the notice that I received from the ADCI. I am just expressing my personal feelings about this, I don't want to get into a p*****g contest with anyone but I would like to hear some feedback, good or bad. I am 100% for safety but this has got to be one of the stupidest ideas that the ADC has come up with yet. Who did they consult with before they came up with this idea?
I think someone at the ADC has got himself a sewing machine and he is going to cut a fat hog making these things. Each one would have to be custom made and I imagine the cost would be anywhere between $500 to $1000.00. The contractor is not going to pay for it so that is another item that is going to have to be paid by the diver. No harness no worky.. This Informational announcement failed to list any emergency procedures so I just added a little addendum to it.
The following items of information are provided to bring your attention to recent industry developments, initiatives, or safety notices.
DETAILS
ADCI Informational Announcement 2012 - 1
The following reminder is being issued for all ADDICT General Members and Associate Member Schools:
Implementation of Certification and Equipment Requirements for the ADDICT Consensus Standards (6th edition)
For those Items that were annotated with a superscript "1", please note that the requirements will take effect on 8 February 2012.
We are drawing very close to the 12 month anniversary of the distribution date of the Consensus Standards (6th edition). Those items that were annotated with a superscript "2" will take effect 8 July 2012.
• 6.3.4 HARNESSES²
A working diver shall be equipped with a full body diving harness that:
a. Is designed to:
I. Provide a method to securely attach the umbilical to the diver.
II. Lift an unconscious or injured diver and his or her equipment from the water in an emergency.
III. Be utilized for underwater use.
b. Has an overall breaking strength of no less than 2,000 pounds.
c. Is equipped with a positive buckling device (i.e., designed to prevent strap pull-through and accidental release by the diver). It shall not be possible to release the harness by a single action.
d. Is equipped with at least one attachment point for the umbilical that is rated to at least the same breaking strength as the lifeline or strength member in the umbilical bundle. If the harness has multiple attachment points of different strengths, those suitable for umbilical attachments are to be clearly identified.
e. Is equipped with adjustable leg straps.
f. Is fitted with at least one lifting (recovery) ring, accessible when the diver is fully dressed, suitable for recovery of the diver from the water in an emergency using a hoisting device or other suitable means.
g. Is designed to maintain the diver in a heads-up position during recovery (using the lifting ring) from the water in an emergency.
h. Allows for easy disconnect of the main umbilical and weights, without removal of the main bail-out harness. This may be achieved by use of a separate/independent outer harness or jacket for the bailout system and diver’s weights, or similar systems.
i. Is to be visually inspected prior to use for any signs of deterioration or damage. Any harness whose material condition is in doubt shall not be used until a determination is made by the diving supervisor.
j. Is to be regularly maintained in accordance with the manufacturer’s recommendations.
k. Is certified by the manufacturer as detailed below.
Certification and Testing of Diving Harnesses
A new diving harness shall be certified by the manufacturer or supplier to confirm that:
a. Each securing point intended for attaching an umbilical or lifting a diver out of the water in an emergency shall withstand a tensile of at least 2,000 pounds for five minutes without sustaining damage that would render it inoperable or unsafe to use.
b. Each complete full-body harness, including adjustment systems, buckles, etc., shall withstand a tensile load of at least 2,000 pounds for five minutes, applied in the direction of lift, without sustaining damage that would render it inoperable or unsafe to use.
c. Each harness is clearly marked in a durable manner with the following minimum information:
• Manufacturer’s name and country of origin.
• Product model and number.
• Month and year of manufacture.
• Unique serial number for that harness.
• Breaking strength.
635 HARNESS EMERGENCY PROCEDURES.
A. This procedure to be used only if dedicated crane or operator are not available.
1. Back company pickup to bulkhead.
2. Take dedicated rope and hook down ladder and attach to divers harness.
3. Remove slack from dedicated rope.
4. Attach dedicated rope to Pickup bumper.
5. Put tender in truck.
6. Tell tender to go like hell.
B. This procedure is going to put the diver or what is left of him on the deck
1, This procedure should not render the harness, inoperable or unsafe to use because it has
a unique serial number and it can withstand a 1 ton test for 5 minutes.
After more the 40 years in the business it is good to know that things are getting better. Unless OSHA regulations have recently changed a crane operator cannot pick a man out of the water or anyplace else for that matter unless he has a certified and dedicated man basket. Maybe these regs. are going to change and we will get to have a dedicated crane and operator on each job. I am sure the client will be overjoyed about that.
I started in this business in 1969 and I have worked the East Coast, The Midwest, the Gulf, West Coast and Alaska and a number of other places and I can honestly say that I have never been on a job that has required the use of something like this. I like to attribute this to good dive safety and planning but it has probably just been blind dumb luck. I have never had to haul a diver out of the water but I am sure that some of you have. If I had to I would damn sure find a way to do it without an uncomfortable 1 ton harness. The ADC has brought many changes to the business, some good and some not so good but I think that this is the worst pile of crap they have tried to push on us so far. I would like to hear other comments, good or bad.
Views: 1300
Replies to This Discussion
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Permalink Reply by Lance S Padfield on
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My biggest problem w/ the ADC is the fact that they & some companies are trying to make the commercial divers pay for these ridiculous cards or be blocked from employment, that is illegal, i agree w/ the safety progressions they profess. Also the laziness the ADC BOD'S will not back up the facts when companies are still up to bad practices , they will not notify or kick them out of their membership because they are paying them. We also have divers at ADC companies that carry cards and have hats that are s***, yet they allow the diver to work w/ the failed or not inspected hat while exempting the diver that is up to date on everything but does not pay the "Non-profit org. ADC" for the 100$ card, union & non union both. Alot of other crap going on also. Our local 34 union says it is not a requirement to carry a ADC card for employment, dept. of labor & the atty. general says so also. Maybe these dive cos. need to be made aware of this, but you know how the divers are , they keep jumping thru more loops and the association keeps on doing it until they are corrected. I have commercial creds, etc.. The ADC has some good ideas and i agree w/ their interactiveness but they are not supposed to be charging us or cos. in lieu of them either. It seems to me they are trying to make as much money for the association as they can.We need to start doing something to correct this.
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JD,
I think around flow and intakes this might be an extra pre-caution. ADC lost me when they sold a lisc. to my boss with 0 B.T. I don't know how he aquired one, but he did. He also askes me questions like..."why don't we just blow down the decompression chamber w/ O2. There are 4 bottles of it right there?" That's what I think of the ADC.
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Permalink Reply by Jerry Babin on
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Here's a reminder from the conversation I had with the Coast Guard Commander last March. The ADCI is NOT, I repeat not the Governing body, by any congressional or senatorial edict. It is a self proclaimed title. The ADC does not write the standard, the USCG does, we the divers and supervisors who bleed in the field are the authority. Until every diver in this business wakes up and contacts the USCG directly and request to be put on their e-mail list ( which the ADCI has no access to) the d******s in TEXAS will continue to influence the education and continue to allow divers to stand alone in court rooms. anyone got any questions, please contact me directly at babingj@gmail.com mark it urgent in the title and detail your questions. Also see my page on linkedin. (http://www.linkedin.com/in/jerrygreywolfbabinstructdvr )
and if John Roat sends you an email or he posts something on this site read it and respond..... He knows his s*** and was out there when I was greener than the new paint on a 66 ford...
long before the ADC demi gods built the throne they now sit on. They also own the businesses that control the services in the GOM, and are redistributing Government doc**ents that are public property for profit, which is against Federal LAW!
THe Consences is nothing more than ACOE, USN, and USCG doc**ents doctored up with ADCI logos which is also illegal. If your boss is a member, your Xmas bonus was short because his dues are based on the ADC's physical review of their annual reciepts. Add this one up The Big 3 in the GOM control the ADC + compete with your bosses ( who are adc members ) = who do you think controls the flow of jobs in the GOM. Are any of you pissed off yet? Its time to change it Im working on one solution, is anyone interested in helping out? email me. Help is appreciated, or Ill do it alone but starting this year, Im starting.
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2 shay, is that what i said basically a year ago? Yes, & thank you for seeing it.
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Just a note, the ADCI has no LEGAL Authority to order any diver to purchase anything. The title "Governing Body" is assumed, not granted by the US Government or a majority vote of those it is supposed to serve.
Straight from the mouth of the USCG Officer in charge of writing the CFR/Regulations the ADCI claims were written by them.
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Speak w/ the Federal Atty General on whether the ADC can make workers buy cards.????, Also i am going to call Mike Brown and ask or request the names of the Fed OSHA figure heads that they , the ADC claim had this so called agreement they say gave them superceding rights to take money from the industry personnel. If we stay on this , i believe we will correct this theatre the ADC is acting out. It is a racquet.
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Permalink Reply by Dive Diva on
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First, a little history for the younger divers. THe ADC was formed in 1968, incorporated in 1970 in LA and is now based in Houston, TX. The reason the ADC was formed was because the contractors were worried about unionization efforts by the divers and having garnered the attention of the federal govenrment.were afraid the feds were going to step in and start regulating the industry. Which Congress did to a certain degree when they gave the USCG jurisdiction. ADC's founding was self serving to protect the diving contractors interests.
Federal law requires that the company provide all life safety equipment. The company can either provide it or rent it from the diver i.e. gear rental. I would suggest that beside the USCG, AG, and OHSA contact with the federal Labor Board
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OSHA Final Rules 72.64341-64430 (2007, November 15) spells it out. What this means:
* Employer must provide the protective equipment, including Personal Protective Equipt. (PPE).
* The employer cannot require the employee provide or pay for his or her own PPE. In other words, the employer must provide you with PPE, if you own your own PPE and the employer doesn't provide your PPE, the employer may reimburse you for the use of your PPE - i.e. gear rental pay. However if the employer provides an employee with PPE and you elect to use your own gear anyway, then the employer IS NOT required to pay you for it's use because the employer did have adequate PPE available for your use. You simply volunteered to use your own gear with the employer's permission.
* The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.
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Permalink Reply by Nick Daly on
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The funny thing about PPE costs is that the company I worked for that is not in the ADC bought me PPE and most ADC companies charge me for it on my first check. I found that pretty ironic.
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The other companies were O$HA compliant.
29 CFR Parts 1910 1915 1917 1918 & 1926
make it clear that the employer ie the dive contractor is required to provide and maintain all PPE needed for employee safety and at no cost to the employee. This includes items such as helmets, harnesses, etc.
I would send those companies that charged you for the items a letter requesting reimbursement for their error in charging you for the equiptment.if they don't refund your monies I would send copies to the Federal Labor Board, OSHA and the IRS.
Unfortunately, some ADC companies for whatever reasons don't adhere to labor laws. Some companies hire the divers not as employees but as sub contractors. Thus they don't have to pay workers comp insurance, provide PPE, not paying payroll taxes and if something goes wrong lay the blame elsewhere.
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With regard to the divers having to buy into the ADC ($100 card) as a condition of employment or other perks; could be construed as a First Amendment violation. Such efforts could be viewed as "Labor Extortion" by the courts.
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This is Why I have said that ALL divers need to stand together and form a union. Then we wouldnt have to worry about the ADC and their bs. I am in the carpenters union as a diver and love it.
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