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the ‘S’ word : Standards

'A New Life in the Sea' by Michael Lombardi

Re-hashing an oldie with some fresh perspective – Standards.

We all hate to love them, and love to hate them; ‘standards’ are the cookie cutter codes of practice that everyone follows in some form or fashion – be it standards by which we educate, standards by which we are obligated to meet for occupational health and safety, or even standards of care offered by a medical professional.

Not to be confused with actual laws, standards are generally a community consensus of practices or beliefs that set the precedent for codes of conduct. In cases where the precedent is pursued as law, then often times it becomes just that, and in the US can be part of our Code of Federal Regulations.

In diving lore, scientific diving in particular, standards are often a hotly debated topic, and with good reason. Almost 40 years ago the community set a precedent that diving in support of research or scientific tasks was exempt from the United States’ Occupational Safety & Health Administration (OSHA) Code of Federal Regulations that pertain to commercial diving, or diving for ‘work’. While that may sound like a lifetime ago, in the legal world that is recent history, and in the diving world, well, we’re still wearing diapers as far as I’m concerned.

Why the fight?

Commercial diving, by convention, arguably includes more demanding modes of diving that are potentially subject to greater risk than the dives typically made by diving scientists. Scientists therefore argued that they should not be required to meet the various heavy requirements on the diving operation, nor should their employer/institutions be subject to the workplace regulations imposed on commercial diving. With that comes high insurance premiums for both liability and worker’s compensation insurances, and an exponentially more complex system of management.

By contrast, the scientists said, “let’s make this easy”. They set a precedent for safety, argued the case to the federal government, and so it was set into law that ‘scientific diving’ was no longer ‘commercial diving’. The federal regulation clearly stipulates the criteria by which a scientific diving program is defined, and central to that is the make-up and function of its Diving Control Board. By design, the Diving Control Board, or DCB, is in place and charged with absolute and autonomous authority over the programs operations. This governance through peer-review is consistent with the democratic principles of the scientific community that this structure serves, and is a highly useful tool in navigating underwater science.

To meet the federal exemptiont, a set of ‘standards’ were put in place, largely stemming from early work at Scripps Institute for Oceanography. These standards defined the minimum scope of training, proficiency, and operational practices that a scientific diver must meet in order to claim that he/she is meeting the exemption for scientific diving. Today, the American Academy of Underwater Sciences (AAUS) is the organization that brings this community together to self police and regulate these standards of practice, and work cooperatively to afford continued benefits for the scientific diving community.

The beauty of the entire system, as I have viewed it, is that the science of diving itself is left with an open slate, where scientific divers may embrace what’s new and forward looking in order to give their science a leading and competitive edge. This does not mean rules and regulations can be arbitrarily created or broken, rather the system provides for reviewing new standards, even at the level of the self-regulating institution, for sake of making meaningful gains in the science of diving and diving for science. Expert level review falls on the responsibility of the Diving Control Board, thus a committee based peer review provides the approach to expand upon the minimum standards accepted by the institution.

All of this comes back to the founding principles of the AAUS, which are those that the community must forever uphold as its minimum standards; those which are set as law to take advantage of the exemption to OSHA 29 CFR 1910 Subpart T. Without that, diving for science is dead (in the US at least), and the sciences that benefit come to rest in a watery grave. If the commercial diving community had its way, all underwater work would be hired out to diving professionals, arguing that the average scientist isn’t fit for the task. By contrast, the scientists say that the average commercial diver doesn’t have the aptitude to conduct underwater science.

Interestingly, just as these two sectors disbanded several decades ago, the very nature of more advanced diving technology being used for complex scientific projects has created a gray area where I expect new standards to begin to evolve by necessity. It’s a very exciting time.

Like all systems, there are ups and downs, good and bad, and politics and personalities; but, when standards are needed, there they are, and having taken on some tremendously difficult program development assignments recently, I am more thankful than ever that the scientific diving community consensus is in place, and is there to lean on.

Standards are a matter of pride and principle, of law and are laudable, provide strength in incrementally moving forward, and are there for all of our protection.

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