Info on Recommendations for New Coast Guard Diving CFR's

For those of you that are interested this web site will let you read what is being recommended and by who.

 

http://www.regulations.gov/search/Regs/home.html#docketDetail?R=USCG-1998-3786

 

You will note that the ADCI still wants no one responcible but the Dive Sup..

 

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I took it upon myself to call the coast guard investigations office in morgan city today. i spoke with a woman who seemed knowledgable of 'some' aspects of diving issues in the GOM. She couldn't give me any intense details about cases, but she did answer some questions, like whether the cg had finished the investigation or not. if not, then she said she would gladly report it to the headquarters office that there are 'dangling chad' investigations from far too long ago that need addressed. She told me that anyone is allowed to submit a freedom of information request for investigation information, once the case is closed, the big cheeses will forward you a copy of the investigation. She will make herself available to anyone who wants to chat it up with a coastie.

Also, she said there was 1 fatal dive accident last year in her zone. No reports in the area of dive injuries, near misses, etc. So, i take that to mean that even our brethren are not 'manning up' and making the call or filing the injury reports to the local coast guard office. Any type of diver injury counts - she quoted me some regulation sights like scripture or something. I'm not selling her short, despite the quality of coast guard stuff i have seen.

For those of you who say you've 'taken it in the wallet' over time, then, WHY NOT DOC**ENT/REPORT the unsafe practices your being asked to submit to? If you are already up $hit creek, don't thro out your oars.

Project manager, huh? Some (most) aren't even on boat. So, if this schmo tells me to do something unsafe, I just take it and collect pay hoping nothing happens. And keep on working. i understand i gotta feed the family, but, if i kill someone or get killed from unsafe stupidity bcuz project man said so, who's feeding 'em then? As a dive community, there's got to be a better answer. I want to push uphill, dirty hands and all, but, what do i push uphill? As a collective group of smart, experienced and often educated professionals (divers) - we don't even know what we want the coast guard or osha to know or provide as regulation. Whens the last time you gave a full, complete, naked truth statement to an investigator when you know your buddy screwed the pooch, or your friend allow this accident to happen? It's the fear of the mighty 'black-balled category' that keeps divers from telling the real story to the people who could possibly make a difference (regulators), admission of fault and all.

As for fur-flying / please don't judge me as rude or whatever. I am just looking for enlightenment on the ties that bind and I don't have time for p****-footing around what I really want to ask savvy folks/divers.
All;

There is one issue here for me; It has nothing to do with pay or coming together as a group. It has everything to do with having a Clear Safe Standard to work to and Basic enforcement by the governing body.

I have been p*****g them off for years and still feed my family, so I want everyone to think carefully how you go about what you feel like you can do. So far everything I have done is let the ADCI know if they don't do it right I will do what I can. So far they have changed several of their “We are ready to present to the Board Dates”. Well it is my sincere hope that when they do everything is acceptable and we can all give them an at-a-boy. If not just be ready… There are some good people trying to do it right.
There needs to be an accountability of the contractors, a diver certification program and a supervisors licensing program. Unfortunately it looks like the date to comment has come and gone unless they are considering the comments submitted back in 1998. The request is basically the same today as it was back then, the only modifications are the names of the Coast Guard personnel and the reference to the Cliffs 12 report.
Guess I should be reading the federal Docket more often
Peter;

Most of that is from the last time the CFRs were changed. There’re is one from me and a couple others on the last page. This will not heat up until the ADCI submits their suggestions, The ADCI has put that off several times.

Watch the ADCI web page, they are suppose to submit there suggestions to their board then we are suppose to have 90 days to make suggestions. Then when the ADCI board pa**** their Standards they will submit them to the Coast Guard.

I will assure you it is time to pay close attention!
Carl,
Thanks for the link to the PRM. I see that all the old submissions made 12 years ago have also been incorporated including the ADC and mine. Unfortunately my submittal is listed under Commercial Dive Safety Organization which no longer exists. Phone have long since been disconnected and the address someone else's with the exception of the email address Divesafe@msn.com
I appreciate that we should keep an eye on the ADC and their proposed revisions but I think we all know what their Consensus will be. Make the supervisors responsible, protect the contractors.
If this revision to the antiquated CFR is to be revised it needs to be done correctly there needs to be:
A proper definition of a diving supervisor including a staged licensing system
A proper definition of a diver including mandatory log books
The removal of any reference to the supervisor "is responsible"
Minimum crew sizes
requirements for backup systems
If there is a difference to be made the DIVERS must also present a uniform front and demand a public hearing before the proposed rule making becomes the law for the next thirty years.
For those that may not have read the United State Coast Guard Commandants recommendations for revisions to the CFR I include them here
Attachments:
Perhaps I am missing something here? In 1998 the United States Coast Guard proposed revisions to the archaic 46CFR as they pertain to commercial diving. There was a comment period during which many of us participated. Now 12 years later it appears there is an attempt to follow through and continue the process. My question here is why has the ADC not posted their Standard so that it may be reviewed?
How is it that IMCA refers to a submission by the National Off Shore Safety Advisory Committee but that report is also not posted.
during the request in 1996 seventy nine of us responded, now there are only eight. Perhaps the only people involved are those chosen to participate by NOSAC and the ADC.
The time has come to demand a public hearing. Participate or live with archaic regulations for another 30 years
Pete Pilkington divesafe@msn.com
The ADCI has postponed putting out their Standards a couple times. They say they’re not done. I believe the ADCI, IMCA and the Oil and Gas Producers are holding meetings and trying to have a joint agreement to present to the Coast Guard.
Perhaps the time has come for a group of concerned divers to get together and create their own "Consensus" standard of what should be included in the new CFR. Lets raise the bar, bring divers into the 21st century. Participate in the creation of the new 46 CFR. We should demand a public hearing, we need to participate or the regulations will be filled with the same looph***s the current regulations contain.

Last week the President of the United States was speaking about the mine disaster in West Va.
"A failure first and foremost of management, a failure of oversight and a failure of laws so riddled with looph***s that companies repeatedly can violate safety regulations without penalty."

As horrific as the mine disaster was let's remember that far more men die at the end of a hose each year then in our nations mines. And if you think the federal regulations as they are written do not contain looph***s you need to read them again.

Yesterday I started working at getting the divers heard before the regulations are set in stone, anyone care to step up and go to Washington?
I have been an activist my entire life and will fight. William Wallace style and in the spirit of my distant relative, Sam Houston. I assume everyone knows the story behind the anti-union movement towards divers? It's in the book, "A History of Oilfield Diving"/

Another book I suggest everyone reads is "A People's History of the United States"
Let me answer your question as best I can. First I am not a commercial diver. Until fourteen years ago the only thing I knew about commercial diving was what my son told me regarding his day to day work and experiences. Then by necessity I figuratively jumped in attempting to understand the regulations, understand the culture. without legal assistance, initially, took on the USCG, fought through the layers of "carp" culminating in a formal investigation four years later.
"Who knows someone who knows someone who knows how to deal with the layers of crap in Washington? Who knows the rules of lobbying and how to effectively make a presents?"
Put together a group not afraid to make a difference and try it. Need help let me know.
Lets move forward on these issues guys.

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