July 6, 1992
MEMORANDUM FOR: JAMES W. LAKE
FROM: PATRICIA K. CLARK, Director
Directorate of Compliance Programs
SUBJECT: Review of Draft Regional Interpretation, OSHA Commercial
This is an interim response to your subject memorandum which was received in
this office on June 12, 1992.
The basic issue that has to be resolved with respect to your memorandum is
whether a diver-worn "dive computer" provides an acceptable means of
establishing a dive profile (depth/time relationships) and maintaining diving
records. Unless evidence is available to support a conclusion that a dive
computer is as safe or safer than the U.S. Navy Standard Diving Tables, such
devices will not be considered to be in compliance with 29 CFR 1910.422(e)
and .423(d). In a phone conversation between Mr. Joel Dovenbarger of the
Diver's Alert Network (DAN) and Mr. Steve Butler of OCMCA, Mr. Dovenbarger
advised us that all dive computers allow for increased diver exposure levels.
Therefore, dive computers are inherently less safe than the U.S. Navy
Standard Diving Tables. This does not mean that such devices are unsafe, but
they are not as safe as the standard diving tables so they cannot be
considered as providing equivalent protection without further investigation.
We have requested available information and studies on dive computers from
DAN and the U.S. Navy in order to evaluate this matter properly. Upon
completion of our evaluation we will advise you further.