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Is a Service Log Really Worth Keeping?
by Dr. Thomas Powell:
OSHA fined a team $7,000 for their regulators being out of service
The public safety diving community is one that sits on the fringes of both the realms of traditional scuba diving and public safety service. The men and women who choose to become public safety divers work in harsh conditions, take on unique training, and operate within various standards and regulations. They dive outside of the traditional “fun” environments, and they often dedicate themselves to diving with a team.
Various organizations that operate on local, state, and even federal levels, establish rules and regulations that may be applicable to a group taking on public safety diving operations. These regulations may involve equipment service, decontamination protocols, operational standards, team structure, and even the types of operations that a team may perform. The oversight organizations may include OSHA, the NFPA, state or local emergency management offices, and even state departments of labor. The actions of the team, and state laws concerning employee/employer relations, often govern who can oversee and provide direction to teams.
In January of 2013, a team in Washington was fined $172,900 for violations of Department of Labor regulations following a site inspection. The regulations cited were part of the Washington Administrative Code put forth and enforced by the state’s department of labor. Essentially, the inspection was performed as a safety and health inspection of a work place for the safety of employees. The violations deemed serious by the inspector were also forwarded to OSHA for further investigation.
Once the citation was assessed, the team was required to correct all noted violations and provide a written statement of correction. If these actions were not taken, further financial penalties would be passed on to the team. Similarly, an appeal or payment period of only 15 days was provided to the team. A total of 16 penalties were assessed. Of these, two were deemed willful violations, eight were deemed serious violations, and six were deemed general violations.
Historical record of maintenance
The first serious violation reported by the Department of Labor inspector involved equipment maintenance and a historical record of maintenance. According to the Washington Department of Labor, any equipment used by an employee to provide direct life support must be subjected to a planned maintenance and preventive maintenance program. The Department of Labor also cited the Association of Diving Contractors International (ADCI) in regard to the need for a maintenance program. Essentially, commercial standards were used to establish a standard for public safety dive teams in the state of Washington.
The same citation issued also showed that the dive team was not following manufacturer standards for equipment service, the team service technician was not rated as a current manufacturer-certified technician, cylinder hydrostatic testing was not within date, and at least one cylinder had not been visually inspected following industry standard. In each of these notations, ADCI commercial standards were again referenced as the endorsement for violation recognition.
During this inspection, the inspector went to great lengths to examine the team’s equipment. He noted that improper seats were used in regulators, intermediate pressures were not to manufacturer standard, and second stage cracking pressures were lower than manufacturer standard. The inspector also disassembled and analyzed buoyancy compensator dump valves, checked every hose used by the team, and noted any equipment modifications that were not put into place by the equipment manufacturer. Though various problems were discovered by the inspector, many of the things he noted can be found in team vehicles all over the United States. For these violations, the team was fined $7000. This was only a small portion of the total team fine. What a reader must note is that in this case, the inspector had the ability to break down equipment and recognize subject matter that violated industry and manufacturer suggested standards. This was an inspection that went much farther than typical governmental oversight.
Preventive maintenance program
In this case, the state inspector suggested that a formal preventive maintenance program be developed by the team that follows manufacturer and industry standards. This recommendation suggests that maintenance records should be established and stored by any team wishing to take on public safety diving operations. Teams should also recognize and follow manufacturer-suggested standards to ensure compliance during service periods. Finally, state and federal service requirements for life support equipment must also be observed. In this case, buoyancy compensators were required to have a three to six month service period which is beyond manufacturer standards.
Establishing a history of care for life support equipment is critical. In this case we see a team fined for working outside industry standards in various spheres. The problem is that public safety divers already work in harsh conditions and they must rely on the equipment they use. Knowing what is in good condition and what items need to be serviced can provide peace of mind for team divers. Similarly, proper records and a plan for equipment use that follows service protocols can prevent a similar instance where fines from a governing body destroy a team through financial expenditure. Lastly, teams must take care to recognize what state and federal standards they must follow. In this case, commercial standards were used by the state of Washington to perform inspections. Essentially, though an OSHA exemption for public safety diving may have been recognized for certain actions with regard to this team, the state department of labor chose to follow commercial standards because Washington follows an internal state plan for occupational health and safety. Do not be the team that gets in trouble or hurts team members just because the team did not know what rules to follow.
Thomas Powell – Owner/Instructor Trainer – Air Hogs Scuba, Garner, NC