Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

FEB 1 1991

The Honorable Al Swift Member,
United States House of Representatives
308 Federal Building
Bellingham, Washington 98225

Dear Congressman Swift:

Thank you for your letter of December 3, 1990 concerning a request for assistance from Mr. Thomas E. Hemphill. Mr. Hemphill desires a review and approval of his course outline for Commercial Scuba Diver Training and Certification. We previously responded directly to Mr. Hemphill on November 26, 1990 in response to his letter of November 16, 1990. A copy of the response is enclosed.

The Occupational Safety and Health Administration (OSHA) does not approve or certify any specific products or programs. We are sure you can understand the myriad of problems such endorsements or certifications would create.

We have reviewed the materials and course outline supplied by Mr. Hemphill and it is our opinion that the topics and requirements, as stated, address the basics required by the Commercial Diving Standards at 29 CFR 1910, Subpart T.

If we may be of further assistance, please contact us.


Gerard F. Scannell
Assistant Secretary


cc: Washington, D.C. Office

CMCA:Bode:auh:01-04-91 [Bode:\Hemphill] cc:Reidy/Nolan/Bode/OCIS/CEO/SOL/Region x R.A./Chron

Control #E23483
Due Date 12/31/90


Congress of the United States
House of Representatives
Washington, DC 20515
(202) 225-2605
December 3, 1990

Department of Labor
Office of Congressional Liaison
200 Constitution Ave N.W.
Washington, D.C. 20210

Dear Sir or Madam:

I am writing to ask your consideration of the attached letter which requests official (government) acknowledgement that NACSD training and certification fulfills OSHA requirements.

This request by Thomas Hemphill follows an opportunity to direct a training program in Hong Kong. Any assistance you may provide in making this a possibility will be appreciated. Your response may be directed to my Bellingham District Office.

Thank you.


Al Swift Member of Congress

AS:sww enclosure


November 26, 1990

Congressman Al Swift
104 W. Magnolia - Room 308
Bellingham, WA 98225

Dear Mr. Swift:

I am writing to you with the hope that you may be able to assist me. I have been a professional diving educator in Washington State for more than 20 years. I specialize in training and certifying scuba diving instructors.

I have an opportunity to direct a training program in Hong Kong. The representatives in Hong Kong have requested that I send them an official document from our government that would indicate that our training and certification program meets U.S. Government standards. It's difficult to acquire this type of documentation because there are no agencies that I am aware of that offer such a certificate.

I am a certified Instructor Trainer by the National Association of Underwater Instructors, which is a world-wide training and certification agency founded in 1959. I'm the president of the National Association of Commercial Scuba Divers which is also a training a certification agency that we founded in 1983. These organizations are recognized throughout the industry as professional educational associations. I'm an educational consultant and instructors trainer.

OSHA has established standards for commercial diving operations in the U.S. I have contacted Mr. Tony Brown who works for OSHA in Washington D.C to try to acquire a letter stating that NACSD training and certification fulfills the OSHA requirements.

I have explained to the Hong Kong representatives, in letters and on the phone, that our government does not certify training associations and programs. They still insist that I provide them with these documents.

I would sure appreciate your assistance in this matter.

Thank You,

Thomas E. Hemphill