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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 https://www.osha.gov.
March 29, 2000
The Honorable Joseph I. Lieberman
Office of U.S. Senator Joseph I. Lieberman
One State Street, 14th Floor
Hartford, CT 06103
Dear Senator Lieberman,
This is a follow up response to your December 8, 1999 letter on behalf of Mr. Raymond Palumbo regarding commercial diving. In his letter, Mr. Palumbo seeks clarification from the Occupational Safety and Health Administration (OSHA) regarding the acceptability of commercial diving schools, training to national consensus standards, and commercial diving licenses in meeting the requirements of 29 CFR Part 1910.410 Qualifications of dive team. Please excuse our delay in responding to this request.
OSHA considers an employer to be in compliance with 29 CFR Part 1910.410 requirements if documentation shows that the diver completed training to the appropriate level (e.g., surface-supplied air diver certificate, surface-supplied mixed gas diver certificate) at a commercial diving school within a particular state, military school, federal school (e.g., Army Corps of Engineers), or an Association of Commercial Diving Educators (ACDE) accredited school. An employer is also in compliance when documented evidence attests to the training level of employed divers under the national consensus standard published by the American National Standards Institute (ANSI) and the Association of Commercial Diving Educators (ACDE); ANSI/ACDE-01-1998 American National Standard for Divers - Commercial Diver Training - Minimum Standard. There are no commercial diver licensing programs in the United States, however, there is a commercial diver certification card which is issued through the Association of Diving Contractors International (ADC). OSHA considers an employer to be in compliance with 29 CFR Part 1910.410 diver training requirements for any employed diver with a valid "ADC Commercial Diver Certification Card" for the appropriate training level.
Thank you for your interest in occupational safety and health issues. Should you have any questions or require further assistance regarding this matter, please contact Mr. Stephen Butler from our Division of Maritime Compliance Assistance at (202) 693-2153.
Charles N. Jeffress