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 http://www.osha.gov.

February 22, 1996

Mr. Rudy C. Watts
H. T. Marine Services
808 W. 8th Street Circle
Lynn Haven, FL 32444-1642

Dear Mr. Watts:

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 scuba diving when two (2) divers are in the water.

In establishing the required number of dive team members required for a particular situation, proper consideration must be given to §1910.421(d) - "Planning and assessment," §1910.421(e) - "Hazardous activities," and §1910.422(b)(3) which requires providing a means to assist an injured diver from the water (e.g., diver stage, small boat, stokes stretcher) or into a bell.

Commercial scuba air diving with two (2) divers in the water requires a minimum of four (4) dive team members as follows: designated person-in-charge (DPIC) [§1910.410(c)], a standby diver [§1910.424(c)(1)], and two (2) divers [§1910.424(c)(2)]. The two (2) divers must be in continuous visual contact of each other or connected by a buddy line. The two (2) divers do not require a tending line to the surface unless they are required to work against a current exceeding one (1) knot. When required or deemed necessary, one (1) tending line to the surface is sufficient when the two (2) divers are connected by a buddy line. With respect to deployment of the standby diver, it is required that the standby diver be line-tended from the surface. The standby diver can be the DPIC provided that he/she is a qualified diver, and that the fourth 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.

Should you require additional clarification please contact Mr. Steve Butler at (202) 219-8131 x154 or myself at (202) 219-8131 x151.

Joe Nolan

Division of Maritime
Compliance Assistance