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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

October 29, 1996

Mr. Ross Saxon, Executive Director
Association of Diving Contractors, Inc.
2611 FM 1960 West, Suite F-204
Houston, Texas 77068

Dear Mr. Saxon:

This is in response to your request for an interpretation of OSHA's Commercial Diving standards (29 CFR Part 1910, Subpart T), regarding the minimum number of dive team members required to support air dives using scuba equipment and surface-supplied diving equipment. In establishing the required number of dive team members required for a particular situation, proper consideration must be given to §1910.421(d) - "Planning assessment", §1910.421(e) - "Hazardous activities", and §1910.422(b)(3) which requires providing a means to assist an injured diver from the water or into a bell.

Commercial scuba air diving requires a minimum of three (3) dive team members as follows: designated person-in-charge (DPIC) sometimes referred to as the diving supervisor [§1910.410(c)], a standby diver [§1910.424(c)(1)], and a line-tended diver [§1910.424(c)(2)]. The standby diver can be the DPIC provided that he/she is a qualified diver, and that the third dive team member is trained and capable of performing all necessary functions of the DPIC while the DPIC is in the water as the standby diver. The standby diver can also be the tender provided that he/she is a qualified diver; in this case, the DPIC would assume tending duties when the standby diver is in the water.

Commercial surface-supplied air diving requires a minimum of three (3) dive team members as follows: DPIC sometimes referred to as the diving supervisor [§1910.410(c)], and a diver who "shall be continuously tended (by a tender) while in the water" [§1910.425(c)(1)]. For surface-supplied air diving which is 100 feet or less and does not involve scheduled decompression, a standby diver is not a specified requirement for all dives. Also, based upon the requirements of §1910.421(d), "Planning and assessment", the hazard analysis/assessment of the dive may dictate the use of a standby diver even though not specifically required (e.g., underwater debris, suctions, no free access to the surface, possibility of diver entanglement, bottom conditions unknown).

Should you require additional clarification please contact Mr. Steve Butler at (202) 219-8131 x154 or myself at (202) 219-7234 x141.


Larry Liberatore
Director, Maritime Safety Standards