Epa Diving Safety Manual 2016
Epa Diving Safety Manual 2016
Washington, D.C.
April 15, 2016
Acknowledgments
The Safety and Sustainability Division (S&S) acknowledges the cooperative participation
of members of EPA’s Diving Safety Board over the years, including those members
listed below.
Jed Campbell
Gary Collins Brandi Todd
Tara Houda TChris MochonCollura
Steven J. Donohue Eric P. Nelson
Eric Newman Mel Parsons
Dave Gibson Rob Pedersen
Alan Humphrey Kennard Potts
William Luthans Sean Sheldrake
Disclaimer
The contents of this manual reflect the views of EPA’s Diving Safety Board in
presenting the standards of their operations.
1.1 Purpose
This policy section prescribes the administration and safety rules for the EPA
Underwater/Diving Safety Program. Federal law requires that individual underwater
activities (diving) conducted in performance of any employment condition must conform
with Occupational Safety and Health Administration (OSHA) regulations 29 CFR Part
1910 — OSH Standards; Subpart T — Commercial Diving Operations. EPA has opted,
as the basis for its policy, to conduct its diving operation in accordance with the scientific
diving exemption as codified in that document.
This directive sets forth EPA’s policy for minimizing its worker’s occupational hazards
to the underwater environment. Divers must be aware of the additional specific
underwater-related hazards such as drowning, near-drowning and the hyperbaric
illnesses, which include nitrogen narcosis, decompression sickness (DCS), arterial gas
embolism (AGE), oxygen toxicity and other ancillary health and safety issues.
The program’s objectives include compliance with applicable federal, state, and local
governmental laws, regulations, guidelines, and executive orders; incorporation of
appropriate elements of nationally recognized consensus standards; and effective use of
the wide range of both internal and external resources and expertise available to EPA.
Standard operating procedures (SOPs), maintained under this program establish the
general approaches and work practices that are implemented at the operations level to
achieve the various requirements of the program in laboratory, field, and other settings.
The program and its associated SOPs incorporate nationally accepted and consistent
means and methods for planning and conducting underwater and diving activities to
minimize the potential hazards associated with these activities. To efficiently
manage the EPA Diving Safety Program, the Diving Safety Board (DSB) will create,
revise, and delete SOPs using this document, the program’s Diving Safety Manual.
The manual is considered separable from the S&S Policy and Program document
and is outside of the revision process for that document. SOPs will be reviewed at
the DSB annual meeting, as necessary, and S&S will be informed of the board’s
action in the annual report of the meeting. A partial lists of the current SOPs are
contained in Appendix K.
1.2 Background
The EPA Underwater/Diving Safety Program and its associated SOPs address various
aspects of Agency workers’ protection from job-related hazards such as might typically
be found at land-based EPA work sites as well as those specific to the underwater
environment (such as immersion in chemically and/or biologically contaminated waters)
and hyperbaric induced illnesses (such as DCS or AGE) in accordance with the Diving
Safety Manual. A Memorandum of Agreement (MOA) (see Appendix N) provides for
management of the program by the Office of Administration (OA) and daily
administration by the Chairperson of the DSB. The MOA affirms the authority of S&S
for overall program administration and formalizes the relationship between the DSB and
S&S, whereby S&S has program policy authority and the DSB provides program
technical assistance and support, but retains some independence to ensure that
administrative or technical demands do not unduly influence or require field personnel to
perform operations with unreasonable risk.
1.3 Policy
As with any employer, it is the Agency’s responsibility to limit its workers’ exposure of
occupational hazards with reasonable risk. This document focuses attention to the risk
of injury or to health in diving and other underwater hazards to fall within the limits
prescribed by underwater diving certifying entities for no-decompression diving. It is
the policy of the Agency to maintain adequate protection for its employees, property and
those for whom it has a responsibility, and to limit occupational exposure to diving-
related injuries and other underwater hazards.
1.4 Scope
The scope of this manual applies to all EPA employees engaged in underwater activities
using compressed gas as the breathing medium in the self-contained or surface-supplied
mode and shall be administered following the guidance of EPA’s basic policies. This
document is the policy by which EPA employees* conduct diving operations. The term
“employees” includes full-time, part-time, temporary, and permanent EPA employees;
enrollees in EPA’s Senior Environmental Employment (SEE) Program. In addition, this
manual applies to contractors and other organizations conducting diving operations at
EPA-controlled sites or conducting dives under EPA supervision do so in accordance
with EPA policy.
1.4.1 Federal Regulations. The directives set forth here are not intended to apply to
other federal, state or local governmental agencies or contractor personnel.
However, the employees or agents of such agencies, when performing duties at
EPA facilities or at EPA-controlled sites working as members of an EPA dive
unit, are required to comply with:
Contractors, grantees and organizations with which EPA has agreements other
than by reciprocating must comply with applicable federal, state and local laws
and regulations pertaining to underwater diving unless otherwise covered under
this manual. Among other requirements are those mandated in the sections
below. Two principal federal agencies regulate and govern diving operations:
OSHA and the U.S. Coast Guard, as indicated below:
29 CFR Part 1910 exempts scientific diving under the following conditions:
practices; and, assure adherence to the buddy system (a diver is accompanied by and is
in continuous contact with another diver in the water) for scuba diving. ...
2.1.1 Policies/Procedures
a. The EPA DSB shall be composed of the UDOs from each diving unit and
the DSB Chairman as voting members, and a representative from S&S as
an ex-officio member.
2.1.2 Responsibilities
The DSB shall make recommendations and be responsible for:
2.2.1 Policies/Procedures
a. The DSB Chairperson shall be the principal contact within EPA for diving
operational policy and safety procedures.
b. The DSB Chairperson shall be a diver with a wide range of experience and
be:
c. The DSB Chairperson will be elected by simple majority from among the
DSB members to nominally serve a term of five years.
2.2.2 Responsibilities
The DSB Chairperson shall make recommendations to allocate sufficient
resources to provide technical assistance and support to S&S, regions, laboratories
and other operating units to ensure implementation, management and maintenance
of program policies, standards, protocols, priorities and evaluation activities in
accordance with the MOA between S&S and the DSB and the statutes,
regulations and guidelines identified below. The DSB Chairperson, nominated
from the DSB membership and confirmed by S&S, shall be responsible for:
b. Conducting an annual review with the EPA DSB of all EPA diving
operations during the preceding calendar year and submitting an annual
report at the end of the calendar year to S&S and a quarterly report, as
may be requested by S&S for Division reporting purposes.
2.3.1 Policies/Procedures
a. The DSB shall elect an EPA Technical Director who will be the principal
contact with the DSB Chairperson for safety, equipment and technical
matters.
2.3.2 Responsibilities
The Technical Director shall be responsible to the DSB Chairperson for:
c. Working with the DSB Chairperson in reviewing all EPA diving accidents
or potentially dangerous incidents and issuing reports on preventive
measures to ensure safe diving.
2.4.1 Policies/Procedures
a. The DSB shallelect an EPA Training Director from its membership who
will be the principal contact with the DSB Chairperson for training,
certification and diver qualification. In addition, the Training Director
will be an additional resource on issues of safety, equipment, and technical
diving matters.
c. The DSB Training Director will be elected by simple majority from the
DSB membership to serve an indefinite term.
2.4.2 Responsibilities
The Training Director shall be responsible to the Chairperson of the DSB for:
b. Managing these courses with the advice and assistance of the EPA DSB
by discussing possible private (contract) sources of trainers and by
delegating various training course responsibilities to the EPA UDOs
whom are able to participate in the course.
2.5.1 Policies/Procedures
a. The DSB shall elect a Special Operations Director from its membership,
who will be the principal contact with the DSB Chairperson related to
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b. The Special Operations Director and DSB Chairperson shall be the lead
contacts within the EPA Dive Program for major homeland security or
hazardous materials incidents, national disaster response, and coordination
of EPA Dive Unit response actions during significant national events.
2.5.2 Responsibilities
The Special Operations Director shall be responsible to the DSB Chairperson for:
2.6.1 Policies/Procedures
2.6.2 Responsibilities
The UDOs shall compose EPA’s DSB, representing the regional, Headquarters
offices, and laboratories, and shall be responsible within the unit for:
q. Ensuring the maintenance of equipment files at the unit and the ship/work
party levels to include type, brand name, serial number and repairs
completed on compressors, tanks, regulators, depth gauges, pressure
gauges and decompression meters and/or dive computers.
t. Ensuring that all divers demonstrate their ability to meet basic physical
fitness standards by successfully completing the swim test requirements of
the EPA Diver Training Program. This test should be conducted at least
every two years, and at any time the UDO deems necessary (e.g.,
following a long hiatus of not diving).
u. Ensure that all divers use breathing gas meeting standards found in
Appendix A.
2.7.1 Policies/Procedures
An Alternate UDO will be designated at the discretion of the UDO by internal
memorandum to the Office Director (or equivalent level), the DSB Chairperson,
and the UDO’s appropriate supervisor, to temporarily assume the duties of the
UDO in his/her absence. The primary responsibility is to provide coverage for
administrative responsibilities in the UDO’s absence.
2.7.2 Responsibilities
(see UDO Responsibilities above)
2.8 Divemaster
2.8.1 Policies/Procedures
2.8.2 Responsibilities
Designated Divemasters are responsible for:
c. If requested by the UDO, overseeing the proper handling and use and
timely replacement of critical diving equipment.
e. Being aware of their divers and other workers who are diving profiles that
approach the no-decompression limits (or oxygen toxicity limits for Nitrox
or mixed-gas profiles) and monitoring those individuals for neurological
or toxic effects.
i. All diving operations are conducted safely in accordance with prescribed EPA
diving safety rules and regulations.
ii. All divers are certified, properly trained and physically fit to perform the
required diving and that the prescribed files are maintained if responsibility has
been delegated by the UDO.
iii. All equipment is in a safe operating condition and that the required
maintenance records are maintained as directed by the UDO.
iv. Emergency procedures are understood by all personnel before diving.
v. An accurate log of all diving activities is maintained (e.g., times in/out of
water, tank pressures) as required in Section 3.0, Dive Program Elements,
Subsection 3.1.7, “Diving Plans, Reports and Logs.”
vi. All divers are monitored after each dive for symptoms of decompression
illness (e.g., DCS or AGE).
vii. Reporting immediately all diving-related accidents/incidents within their unit
in conformance with Section 3.0, Dive Program Elements, Subsection 3.1.8,
“Reporting, Investigating and Reviewing Diving Accidents.”
On hazardous waste sites, OSCs or RPMs are ultimately responsible for the health and
safety of all site workers. In diving operations, the designated EPA Diving Safety
Supervisor, as the Divemaster, is immediately responsible for the health and safety of
divers under his/her control. The EPA Divemaster should make recommendations to the
OSC and/or RPM for commercial diving subcontractors. Because of the shared
responsibilities, both parties shall ensure implementation of this program and all related
guidance and directives at reporting units, establishments or workplaces.
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2.9.1 Designation
A Diving Safety Supervisor will be approved by the EPA DSB with written
concurrence of the regional or laboratory office in which the candidate is located.
2.9.2 Qualifications
The Diving Safety Supervisor shall:
d. Have at least three years of experience with the EPA Diving Program.
2.9.3 Responsibilities
The Diving Safety Supervisor shall be responsible for:
a. Ensuring that all diving operations are conducted in compliance with the
EPA Diving Safety Policy.
2.10.1 Policies/Procedures
a. Individual divers shall be certified by the EPA DSB Training Director and
the DSB Chairperson in accordance with the provisions of Section 4.0,
Diver Training and Certification, Subsection 4.4, “EPA Diver
Certification.”
2.10.2 Responsibilities
The individual divers (including the Dive Tender, as the specific dive plan
requires) are responsible for:
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b. If at any specific time the diver feels that he/she is not in good physical or
mental condition for diving.
c. If, by diving, the diver would violate the dictates of training or applicable
regulations. The conditions and reasons for refusing to dive may be
required to be documented. If requested, the incident will be reviewed by
the UDO, and appropriate action may be taken. Any action resulting from
this review may be appealed to the EPA DSB.
2.11.1 Policies/Procedures
A Dive Tender, designated by the Divemaster or UDO, shall accompany all EPA-
sanctioned dive operations. Except for low-risk dive operations, the Dive Tender
shall be a fully qualified Scientific Diver having knowledge and experience with
the dive operation. For low-risk dives, the Dive Tender may be a non-diver, but
must be currently certified in CPR and first aid and be familiar with dive
operations.
2.11.2 Responsibilities
The Dive Tender is responsible for:
c. Recording each diver’s tank pressure before and after each dive, their
bottom time, and maximum water depth.
d. Alerting divers, when necessary, on the status of their bottom time via the
Diver Recall Unit.
e. Advising other vessels of the diving operation and warning off boat traffic
that might pose a hazard to the divers.
f. Assisting the divers in exiting the water and doffing their equipment.
2.12.1 Policies/Procedures
a. The S&S Operations Branch Chief will be responsible for appointing the
Diving Medical Specialist (DMS). Nominations may be considered from
both the DSB and S&S. Upon the advice of the EPA DSB Chairperson,
the EPA DMS must perform or fulfill the following roles:
b. The EPA DMS will receive overall policy guidance, except for medical
policy, from S&S, and shall make recommendations to the EPA DSB or to
its Chairperson, as appropriate.
2.12.2 Responsibilities
An EPA DMS, appointed by (and/or under contract to) S&S, shall be responsible
for:
2.13.1 Policies/Procedures
2.13.2 Responsibilities
The S&S Representative shall make recommendations and be responsible for:
d. Support staffing.
In the case of long-term programs other than standard scuba not covered
elsewhere in these regulations, an EPA DSB review shall be conducted annually
or when major personnel or diving system changes occur.
A Dive Tender shall always be present to assist divers in and out of the water.
Depending on conditions, and at the Divemaster’s discretion, a fully suited,
equipment-ready standby diver might also be required.
Recordkeeping
a. The original project’s dive plans, Dive Tender’s logs, and dive reports will
be maintained by the UDO. Dive Plans should be prepared by the
Divemaster for the project and signed by the UDO, and if required, by a
higher local authority. Dive reports will be signed by the project
Divemaster and sent to the UDO for signature. The reports should be
submitted to the UDO within five working days after completion of the
dive project authorized by the dive plan.
b. Dive logs for each dive unit will be maintained by the UDO. The divers
will provide the UDO with their dive log summaries on an annual basis.
The annual reports of the diving activities of each unit will be provided to
the Chairperson and the DSB. Topics to be addressed in the unit reports
are listed in Appendix I, EPA Dive Program Report. The DSB
Chairperson will ensure that an overall report of all dive unit operations is
forwarded to S&S annually.
i. UDO
ii. Regional, Office, or Laboratory Director
iii. DSB Chairperson
iv. Director of S&S
3.2.5 High Altitude Diving (> 1,000 ft.) (Refer to the most current edition of the NOAA
Diving Manual or AAUS standards for guidance.)
3.2.6 Low-Visibility Diving (Refer to the most current edition of the NOAA Diving
Manual or AAUS standards for guidance.)
3.2.7 Blue Water (Over-Bottom) Diving (Refer to the most current edition of the
NOAA Diving Manual or AAUS standards for guidance.)
3.2.8 Swift Water (Strong Current) Diving (Refer to the most current edition of the
NOAA Diving Manual or AAUS standards for guidance.)
3.2.9 Underwater Communications Systems (Refer to the most current edition of the
NOAA Diving Manual or AAUS standards for guidance.)
3.2.10 Underwater Pinger/Locator (Refer to the most current edition of the NOAA
Diving Manual or AAUS standards for guidance.)
3.2.11 Diver Propulsion Vehicles (DPVs) (Refer to the most current edition of the
NOAA Diving Manual or AAUS standards for guidance.)
3.3.1 Rules
The EPA Diving Safety Rules shall be adhered to on all diving operations (see
Appendix A).
S&S will be responsible for conducting periodic audits of the various diving
unit programs. All audits will be conducted following procedures outlined in
the audit checklist in Appendix J.
3.4 Recordkeeping
d. The choice of treatment location and regime is beyond the typical training
of EPA field personnel. Emergency evacuation personnel should be
instructed to communicate with the Divers Alert Network (DAN) at 919-
684-9111. Non-emergency diving-related inquiries should be made to
DAN at 919-684-2948.
3.6.2 Communications
The Divemaster will ensure that there is at least one means of emergency
communication with shore support, such very high frequency (VHF) radio or
cellular telephone. In the event of an emergency on site, such as diver injury,
sudden adverse weather, or chemical release that might have an impact outside of
the immediate area, the Divemaster or his/her alternate is responsible for
immediately communicating the emergency to the nearest emergency response
unit and the EPA unit from which the operation is based.
3.6.4 Transportation
In the event of injury at a remote dive site, communication will be established
with the closest available emergency response unit (e.g., Coast Guard, local
authority via 911, VHF radio, or satellite telephone communication). The ranking
dive team member will be responsible for determining the best course of action as
to stabilize the diver’s condition and await transportation (e.g., for Coast Guard
evacuation) or to make best speed toward shore for treatment. For any diving-
related injury (e.g., DCS, AGE), providing 100% oxygen is critical to successful
treatment and recovery.
3.7 Reciprocity
To facilitate joint diving operations between EPA and colleges and universities,
private institutions, grantees, states or counties, or any other agencies or entities, the
UDO may institute a reciprocity agreement that has been approved by the DSB
Chairperson and meets the following criteria:
e. A reciprocity agreement.
3.7.2 Any reciprocity agreement shall apply only to divers in the employ of or studying
under the sponsoring institution specified in the agreement; additional agreements
will be required for divers not directly covered by the sponsoring institution. No
third-party agreements are allowed, per Subsection 3.7.6 below. The visiting
diver must have written permission from his/her Diving Safety Officer (or UDO).
In addition, the visiting diver must be covered by a comprehensive accident
insurance plan by his/her sponsoring institution.
3.7.3 For a non-EPA diving program to be considered comparable to the EPA Diving
Program, it must, at a minimum, conform to the OSHA Commercial Diving
Standard (29 CFR 1910, Subpart T) or the terms of the Scientific Exemption for
that standard. The EPA UDO or his/her designee shall ensure compliance with
the terms of the reciprocity agreement; however, some records, such as medical
records, may remain in the possession of the sponsoring institution. Compliance
with the terms of this reciprocity agreement, as well as the actual diving
operations, are subject to on-site inspection by members of the EPA DSB at any
time. UDOs may request written verification from the reciprocating organization
as to the date of the last medical examination and request that the individually
named diver is cleared and rated for the given diving activities.
3.7.4 The reciprocity agreement may be renewed annually with the consent of all
parties to the agreement, or it may be terminated or modified by the DSB
Chairperson or the DSB at any time.
3.7.6 Reciprocity agreements from EPA may not cover third parties to the co-signing
organizations. Dive projects that involve three or more organizations may require
that each organization interested in participating in an EPA-sponsored project
enter into a reciprocity agreement with EPA.
3.7.7 Any EPA regional office or laboratory that does not have an established dive unit
and that may have need for occasional diving services, is required to conduct
those operations in adherence to the policies and procedures set forth under the
EPA Underwater Diving Safety Management Program and this Diving Safety
Manual. Such units are urged to seek the services of other EPA units that have
this capability. Contracted diving service organizations must show proof of
operating under OSHA and Coast Guard regulations and have in place their own
“Diving Safety Program,” even if EPA may have oversight. The OSC or RPM
should request assistance from an EPA UDO to review the contractor’s operating
procedures and safety plans to ensure compliance.
3.8 Exceptions
a. The observing diver does not participate in work being performed and is
accompanied by a fully certified EPA diver who is not performing work.
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Persons who fall within the scope of this policy must provide to the EPA UDO
prior to participating in a dive:
d. Ensure that the observing diver is informed of the EPA Diving Safety
Rules and that those rules are complied with during the dive. (Note: The
observer shall sign a statement indicating his/her understanding of the
EPA Diving Safety Rules, and this shall be countersigned by the
facility/installation directore. Maintain a file on each observer diver. The
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file shall include but not be limited to a dive log, a copy of the
certification, the physical examination, and a signed/countersigned
statement of EPA Diving Safety Rules understanding.
EPA personnel with or without previous training may apply through proper channels to
the appropriate Unit Director to be considered for EPA diver training and certification
when the need exists. Diver training may be provided by the EPA Diver Training
Center in Gulf Breeze, Florida, or by the NOAA Diving Program.
4.2.1 As part of the application process to the EPA Training Center, each applicant for
initial training, as well as those for certification based on past training, must
complete the following preliminary actions that may apply:
g. For certification based on prior training and experience (see Section 4.6),
the applicant shall submit verification of prior training and experience
through the UDO to the EPA Training Director and DSB Chairperson for
approval. The candidate must also pass the standard EPA scuba written
examination.
4.2.2 Applicants for diver training with the NOAA Diving Program must fulfill the
requirements in the Application for Training and Physical Examination
sections of the NOAA Diving Program Administrative and Safety Rules (as
currently provided).
assigned duties.
4.3.3 UDOs will make the necessary arrangements to ensure that diver medical
examinations occur in a timely manner. UDOs will provide divers/candidates
with the official EPA Diving Medical Examination Form (gray shaded area for
completion by candidate) and the NOAA Medical Examination Forms (SF-88 and
SF-93) if required for submission to NOAA.
4.3.4 UDOs will ensure that candidates and divers report to the closest EPA-contracted
medical provider for completion of the examination. The diver/candidate has the
responsibility to complete the medical history portion of the evaluation form.
Any questions or statements that are unclear to the candidate should be identified
to the examining physician for clarification.
4.3.5 UDOs will ensure that the completed examination and all of the associated
diagnostic studies are forwarded to the DMS for review and determination of
diver qualification. The completed examination form, with attached diagnostic
tests, should be forwarded to:
4.3.7 UDOs will obtain qualification statements for each of their candidates and divers
from the DMS. The DMS shall also forward a copy of the qualification statement
to the DSB Chairperson. Should a quick response be required, a special request
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4.3.8 When the examination absolutely cannot be conducted by the EPA medical
contractor, the private provider should complete the EPA Diving Medical
Examination Form and forward it, as detailed above, to the DMS. The private
provider is responsible for identifying and describing any abnormal, historical, or
physical findings. As the private provider/personal physician may not necessarily
be professionally qualified or experienced in diving medicine, the DMS alone will
be responsible for determining diving duty medical qualification from the
available data.
4.3.10 Applicants or current divers with medical conditions that represent a relative
disqualification may be recommended for temporary suspension from diving-
related duties until a final determination can be made. Some extenuating
circumstances, however, may be accommodated. The formal recommendation of
the DMS will be considered, but the DSB Chairperson will make the final
decision. The following options are available:
b. In some cases, at the recommendation of the DMS and the approval of the
DSB Chairperson, a waiver board may be convened to consider the
medical data and offer guidance to the DSB Chairperson.
EPA conducts periodic diver training courses at the EPA Dive Training Center in Gulf
Breeze, Florida. A more detailed description of course contents is in the most current
version of the EPA Diver Training Curriculum.
a. Swim 250 yards, using any stroke (e.g., the crawl, sidestroke, and/or
backstroke) or swim a distance of one-quarter mile (440 yards) on the
surface in full scuba gear.
d. Transport another person 25 yards on the surface of the water without the
use of swim aids and/or transport another diver in full scuba gear 50 yards.
e. Surface dive to a depth of 10 feet using mask, snorkel and fins to recover a
4-pound weight and clear the snorkel upon returning to the surface.
4.4.5 Certification
Upon completion of basic scuba training requirements, satisfactory written and
medical examinations, and EPA field diver evaluations appropriate to the
situation, the EPA Training Director shall make a final review of all certification
requests. EPA employees shall then be considered for certification in one of the
following categories.
b. Authorization to Depths Over 130 FSW: Normally, EPA dives shall not
exceed 130 FSW. Proposals and dive plans for depths greater than 130
FSW will require written approval from the DSB Chairperson. A diver
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may be authorized to depths of 150 and 190 FSW after the completion of
four training dives near each depth. Dives shall be planned and executed
under the close supervision of a diver certified to this depth and the plans
approved by the DSB Chairperson. The diver must also demonstrate
knowledge of the special problems associated with deep diving (e.g.,
decompression diving, mixed gases), and unique safety requirements and
equipment (e.g., redundant air supply) required for the specified depths.
c. Progression to Next Depth Level: A diver under the auspices of EPA may
exceed his/her depth certification only if accompanied by a diver certified
to a greater depth. Under these circumstances, the diver may exceed
his/her depth limit by one step.
4.5 Issuance
4.5.1 An EPA Diver Certification shall be issued by the EPA Training Director based
upon the recommendations of the training team (e.g., Training Director, UDOs,
Instructors and Divemasters), following final review of each applicant’s submitted
documents. The EPA Training Director shall issue a Letter of Certification (see
Appendix F) to the diver and to the diving program file established for the diver.
(Note: This file is subject to requirements of the Privacy Act of 1974.)
4.5.2 EPA recognizes and accepts diver certifications issued by the Director, NOAA
Diving Program, for candidates who successfully complete the NOAA Diver
Certification process.
UDOs may evaluate the credentials of a dive candidate with prior non-EPA dive
training and experience for application into the EPA Diving Program. After the
candidate successfully passes the medical examination for diving and the written
EPA scuba examination, the UDO will determine if the applicant sufficiently
meets EPA’s criteria as a Trainee or Scientific Diver. If the candidate does not
meet either of these criteria, he/she will be required to take EPA’s Diver Training
Program as directed by the EPA Training Director. If the candidate meets the
Trainee or Scientific Diver criteria, the UDO shall:
4.7 Requalification
An EPA diver qualification may be suspended for cause by the UDO or DSB
Chairperson. Violation of any policy in this Diving Safety Manual or
demonstration of poor judgment may be considered cause. The diver shall be
informed in writing of the reasons for suspension and will be given the
opportunity to appeal the suspension in writing to the EPA Diving Safety Board.
Violations of regulations in this Diving Safety Manual include, but are not limited
to:
a. Not maintaining one or all of the EPA field safety and health requirements
including physical fitness, CPR, AED, first aid, Oxygen Administration and
medical monitoring.
c. Violating any requirements in this Diving Safety Manual that could endanger
themselves or others.
Dives conducted in excess of 100 ft. require that divers have commensurate
training and or experience working at the proposed depth. If no prior experience
exists, the diver is to complete a checkout dive to the planned water depth or
greater within six weeks of the scheduled working dive. Depending upon
conditions, and at the recommendation of the divemaster or UDO, an alternate or
redundant air source may be required. See Depth Limitations, Tab IV, D.6, for
addition individual recommendations.
6. Diving Logs. All EPA divers are required to maintain an EPA dive log. The
information logged must include the dive location, purpose or function, maximum
water depth, and bottom time. In addition, the dive tender shall also record (on
the Dive Tender's Log) any other information that is needed by the Divemaster or
the UDO. The dive tender must also record the diver's surface interval time for
repetitive dives. The diver must log his/her bottom (subsurface) time and surface
interval time in the case of repetitive dives. A dive is completed when a diver
leaves the water after completing an activity or, after surfacing for more than ten
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, April 15, 2016)
Appendix A-2
minutes, before re-submerging to perform a different activity.
a. Bottom Time is the total elapsed time rounded up to whole minutes from
when a diver leaves the surface to begin his/her descent until the time the
diver begins a direct ascent to the surface. A "dive" is that time and
activity spent beneath the surface of the water by a person equipped with
diving gear.
b. Safety Stop. When possible, divers should include a safety stop (i.e., time
spent to help dissolved nitrogen evolve from tissues) at 15 FSW for 3
minutes to reduce the chance of decompression illnesses. Safety stop time
is not typically added to bottom time, as tissues are in the process of
releasing nitrogen.
c. Surface Interval is the time that the divers have spent on the surface
following a dive, beginning as soon as the divers surface and ending as
soon as they begin their next descent. For surface intervals less than ten
(10) minutes, add the total bottom time of the previous dive to that of the
repetitive dive and choose the decompression schedule for the bottom time
and the deepest water depth achieved for the sequence.
7. Decompression Dives. Routine working dives shall not exceed the U.S. Navy no-
decompression limits. Diving activities that exceed the limits of no-
decompression will be permitted only under the following conditions.
a. Proposal. A detailed dive plan has been reviewed by the UDO and the
DSB Chairman.
b. Competence. The project leader must demonstrate to the UDO or his/her
designee, that the Divemaster and all members of the diving team have a
thorough knowledge of decompression and repetitive dive principles.
c. Dive Team. The team must be composed of no fewer than five people:
two divers in the water, a standby diver, a dive tender, and a Divemaster.
d. Equipment. Each participating diver must wear a watch or bottom timer
and a depth gauge and have on hand a decompression schedule for the
maximum proposed depth of dive or dive computer.
e. Hyperbaric Chamber. Must be on site attended by trained personnel.
11. Over-Bottom Dives. Dives in water where a diver could sense a loss of
orientation or descend below safe diving depths are to be considered over-bottom
dives. No over-bottom dives shall be made unless some direct contact with the
surface is maintained, such as net web, a marked line suspended from a surface
float, or depth gauges for all participants, which permit the divers to determine
when ascent or descent occurs. Additional procedures can be found in the current
edition of the NOAA Diving Manual.
12. Boat Tending. During dives beyond swimming distance from shore or those in
areas of strong currents, a small boat with a qualified operator will tend the divers
(see item 20.j regarding use of "diver down" flag).
13. Ship Activities. When appropriate during ship-related diving activities, the "Dive
Safe Ship Operations Checklist" (i.e.., NOAA Form 64-3) will be used and
completed.
15. Emergency Procedures. The UDOs, or their designee, with the approval of the
EPA DSB will prescribe emergency procedures to be used in handling diving-
related accidents in the operational area, and all divers shall be familiar with these
procedures.
16. Diving Accident Management Training. All divers shall have diving accident
management training and must maintain certifications (refer to 2.10.2.i), , and
shall complete appropriate refresher training to maintain skills. A first-aid kit is
required to be available for all dive operations (SM-05).
ii. SCUBA Valves. Valve types are matched to the cylinder rating
and regulator type. Typical valve types are the
* K-valve
* DIN valve used in the newer high pressure cylinders
iii. SCUBA Regulators and Full Face Mask Systems. Most major
manufacturer open-circuit (exhaled air exhausted to environment versus
being recirculated) regulator systems with demand second stages are
appropriate for use in EPA divingSpecial considerations may be necessary
for contaminated water diving.
e. Variable Volume Dry Suits (VVDS). VVDS will be used only after
satisfactory completion of a minimum of three (3) hours of training in the
use of these suits [two (2) hours of which must have been in open water]
from qualified persons designated by the EPA DSB Training Director, or
equivalent prior experience verified by a qualified EPA UDO or designee.
g. Depth Gauge. A depth gauge shall be carried by each diver on all dives.
j. Diving Flag. An appropriate diving flag shall be shown at all times while
actively diving, according to U.S. Coast Guard regulations.
m. Line Cutter/Dive Knife. Each diver shall carry at least one line cutter
(e.g., dive knife, scissors, or other cutting tool) for use in release of line
entrapment.
21. Equipment Maintenance. All diving gear and accessory equipment shall be
maintained in a safe operating condition. Manufacturers' recommended servicing
policy shall be followed. Equipment in questionable condition shall be tested,
repaired, overhauled, or discarded. Such equipment shall be kept separate from
operational equipment and clearly identified. A record of the inspection and repair
will be filed with the UDO.
22. SCUBA Cylinder Inspection and Testing. All SCUBA cylinders must be visually
inspected annually by a qualified SCUBA tank inspector, who will attach a dated
visual inspection sticker to the cylinder. Cylinders will be hydrostatically tested
at least every five (5) years. The dates of the last hydrostatic test must be stamped
on the cylinder.
23. Air. SCUBA cylinders shall be charged only with air or an oxygen-enriched air
mixture certified as meeting established air standards. Standards for diver's
breathing air are discussed in the following sources:
* Compress Gas Association Grade E (minimum standard)
* American Academy of Underwater Sciences “Oxygen-Compatible” Air
(for use in oxygen-clean cylinders)
* U.S. Navy Diving Manual (Revision 6, 15 April 2008) Section 4-3.1,
Diver's Breathing Gas Purity Standards, Diver’s Breathing Air,
specifically the U.S. Military Diver's Breathing Air Standards from Table
4-2, Diver's Compressed Air Breathing Requirements if from Commercial
Source (FED SPEC BB-A-1034 Grade A Source I (pressurized container)
or Source II (compressor) air:
• Oxygen: 20-22% by volume,
• Carbon Dioxide: maximum 500 ppm (by volume),
• Carbon Monoxide: maximum 10 ppm (by volume),
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, April 15, 2016)
Appendix A-8
• Total Hydrocarbons (as methane): maximum 25 ppm (by volume),
• Particulates and oil mist: maximum 5 mg/m3,
• Odor and taste: not objectionable.
• Separated Water: none
• Total water: maximum 20 mg/m3, and
• Halogenated Compounds: maximum 0.2 ppm (by volume)
* Occupational Safety and Health Administration Standard for Commercial
Diving Operations (29 CFR 1910, Subpart T)
* American National Standards Institute, Z86.1 standard.
24. Minimum Air Supply. Divers must surface with a minimum of 500 psig in the
tank as a safety factor for reaching the shore or boat and to prevent inclusion of
water in the cylinder.
U.S. Navy No
Decompression Dive
Tables (15 April 2008)
Air and Nitrox
&
Appendix B-1
US EPA NO-DECOMPRESSION DIVE TABLES - AIR*
DEPTH Z O N M L K J I H G F E D C B A DEPTH
K K K K K K K K K K K K K K K K K K
10 427 246 159 101 58 10
NO LIMIT
15 450 298 218 164 122 89 61 37 15
NO LIMIT
20 462 331 257 206 166 134 106 83 62 44 27 20
NO LIMIT
25 470 354 286 237 198 167 141 118 98 79 63 48 34 21 25
125 241 309 358 397 428 454 477 497 516 532 547 561 574
30 372 308 261 224 194 168 146 126 108 92 77 63 51 39 28 18 30
63 110 147 177 203 225 245 263 279 294 308 320 332 343 353
35 245 216 191 169 149 132 116 101 88 75 64 53 43 33 24 15 35
16 41 63 83 100 116 131 144 157 168 179 189 199 208 217
40 188 169 152 136 122 109 97 85 74 64 55 45 37 29 21 13 40
11 27 41 54 66 78 89 99 108 118 126 134 142 150
45 154 140 127 115 104 93 83 73 64 56 48 40 32 25 18 12 45
10 21 32 42 52 61 69 77 85 93 100 107 113
50 131 120 109 99 90 81 73 65 57 49 42 35 29 23 17 11 50
11 19 27 35 43 50 57 63 69 75 81
55 114 105 96 88 80 72 65 58 51 44 38 32 26 20 15 10 55
9 16 23 30 36 42 48 54 59 64
60 101 93 86 79 72 65 58 52 46 40 35 29 24 19 14 9 60
8 14 20 25 31 36 41 46 51
70 83 77 71 65 59 54 49 44 39 34 29 25 20 16 12 8 70
9 14 19 23 28 32 36 40
80 70 65 60 55 51 46 42 38 33 29 25 22 18 14 10 7 80
6 10 14 17 21 25 29 32
90 61 57 52 48 44 41 37 33 29 26 22 19 16 12 9 6 90
4 8 11 14 18 21 24
100 54 50 47 43 40 36 33 30 26 23 20 17 14 11 8 5 100
5 8 11 14 17 20
110 48 45 42 39 36 33 30 27 24 21 18 16 13 10 8 5 110
4 7 10 12 15
120 44 41 38 35 32 30 27 24 22 19 17 14 12 9 7 5 120
3 6 8 10
130 40 37 35 32 30 27 25 22 20 18 15 13 11 9 6 4 130
1 4 6
140 37 34 32 30 27 25 23 21 19 16 14 12 10 8 6 4 140
4 6
*Based on USN Tables, Rev. 6, April, 2008
US EPA NITROX I (32% O2) DIVE TABLES *
%O2 DEPTH @ 1.6 DEPTH @ 1.5 DEPTH @ 1.4 DEPTH @ 1.3 DEPTH @ 1.2 DEPTH @ 1.1 DEPTH @ 1.0
21 218 203 187 171 156 140 124
22 207 192 177 162 147 132 117
23 197 182 168 154 139 125 110
24 187 173 160 146 132 118 105
25 178 165 152 139 125 112 99
26 170 157 145 132 119 107 94
27 163 150 138 126 114 101 89
28 156 144 132 120 108 97 85
29 149 138 126 115 104 92 81
30 143 132 121 110 99 88 77
31 137 127 116 105 95 84 73
32 132 122 111 101 91 80 70
33 127 117 107 97 87 77 67
34 122 113 103 93 83 74 64
35 118 108 99 90 80 71 61
36 114 105 95 86 77 68 59
37 110 101 92 83 74 65 56
38 106 97 89 80 71 63 54
39 102 94 85 77 69 60 52
40 99 91 83 74 66 58 50
*MOD=(PPO/Decimal % O2*33)-33
AIR DECOMPRESSION TABLE (All Stops at 20 Feet)*
Bottom Time Bottom Time Bottom Time Bottom Time Bottom Time Bottom Time Bottom Time Bottom Time
Depth
Stop Time Stop Time Stop Time Stop Time Stop Time Stop Time Stop Time Stop Time
30 371 380 420 480 540
0 5 22 42 71
35 232 240 270 300 330 360
0 4 28 53 71 88
40 163 170 180 190 200 210 220 230
0 6 14 21 27 39 52 64
45 125 130 140 150 160 170 180 190
0 2 14 25 34 41 59 75
50 92 95 100 110 120 130 140 150
0 2 4 8 21 34 45 56
55 74 75 80 90 100 110 120 130
0 1 4 10 17 34 48 59
60 60 65 70 80 90 100 110 120
0 2 7 14 23 42 57 75
70 48 50 55 60 70 80 90 100
0 2 9 14 24 44 64 88
80 39 40 45 50 55 60 70 80
0 1 10 17 24 30 54 77
90 30 35 40 45 50 55 60 70
0 4 14 23 31 39 56 83
100 25 30 35 40 45 50 55 60
0 3 15 26 36 47 65 81
110 20 25 30 35 40 45 50
0 3 14 27 39 50 71
120 15 20 25 30 35 40 45
0 2 8 24 38 51 72
130 10 15 20 25 30 35
0 1 4 17 34 49
140 10 15 20 25 30
0 2 7 26 44
US Navy Manual, Rev. 6, April, 2008
Required Surface Interval Before Ascent to Altitude After Diving
Increase in Altitude
Repetitive
Group 1000 2000 3000 4000 5000 6000 7000 8000 9000
10000
Designator
A 0:00 0:00 0:00 0:00 0:00 0:00 0:00 0:00 0:00 0:00
B 0:00 0:00 0:00 0:00 0:00 0:00 0:00 0:00 0:00 2:11
C 0:00 0:00 0:00 0:00 0:00 0:00 0:00 0:00 3:06 8:26
D 0:00 0:00 0:00 0:00 0:00 0:00 0:09 3:28 7:33 12:52
E 0:00 0:00 0:00 0:00 0:00 0:51 3:35 6:54 10:59 16:18
F 0:00 0:00 0:00 0:00 1:12 3:40 6:23 9:43 13:47 19:07
G 0:00 0:00 0:00 1:23 3:34 6:02 8:46 12:05 16:10 21:29
H 0:00 0:00 1:31 3:26 5:37 8:05 10:49 14:09 18:13 23:33
I 0:00 1:32 3:20 5:15 7:26 9:54 12:38 15:58 20:02 24:00
J 1:32 3:09 4:57 6:52 9:04 11:32 14:16 17:35 21:39 24:00
K 3:00 4:37 6:25 8:20 10:32 13:00 15:44 19:03 23:07 24:00
L 4:21 5:57 7:46 9:41 11:52 14:20 17:04 20:23 24:00 24:00
M 5:35 7:11 9:00 10:55 13:06 15:34 18:18 21:37 24:00 24:00
N 6:43 8:20 10:08 12:03 14:14 16:42 19:26 22:46 24:00 24:00
O 7:47 9:24 11:12 13:07 15:18 17:46 20:30 23:49 24:00 24:00
Z 8:17 9:54 11:42 13:37 15:49 18:17 21:01 24:00 24:00 24:00
NOTE 1 When using Table, use the highest repetitive group designator obtained in the previous 24-hour
period.
NOTE 2 Table may only be used when the maximum altitude achieved is 10,000 feet or less. For ascents
above 10,000 feet, consult NAVSEA OOC for guidance.
NOTE 3 The cabin pressure in commercial aircraft is maintained at a constant value regardless of the actual
altitude of the flight. Though cabin pressure varies somewhat with aircraft type the nominal value
is 8,000 feet. For commercial flights, use a final altitude of 8000 feet to compute the required surface
interval before flying.
NOTE 4 No surface interval is required before taking a commercial flight if the dive site is at 8000 feet or
higher. In this case, flying results in an increase in atmospheric pressure rather than a decrease.
APPENDIX C
EXAMPLE EPA MEDICAL EVALUATION FORM
SS# (last four digits only): Date of Birth: Gender: Male Female
My position may require the use of a respirator Light Moderate Heavy Strenuous
Please check your smoking status and complete that section:
Never Smoked (if selected, DO complete questions below) Extent of usage:
Current Smoker (PERFORM SPIROMETRY IF THIS CHOICE INDICATED) On a daily basis
Number of cigarettes per day ________ Occasionally - but more than once a week
Number of cigars per day ________ What type of respirator do/will you use? Rarely - or for emergency situations only
Number of pipe bowls per day ________ Cartridge Air supply SCBA
Total years you have smoked ________ Length of time of anticipated effort in hours:____________________
Former Smoker How often do you use a respirator?
Number of cigarettes per day ________ Daily Weekly Monthly < two times a year Special work considerations (i.e., extra cold water, polluted water, deep diving, etc.):
Number of cigars per day ________ ______________________________________________________________
Number of pipe bowls per day ________ Effort while using respirator? DIVING HISTORY
Total years you smoked ________ Light Moderate Heavy How many dives (wet) do you perform per year (on average)? ________
Chronic exposure to environmental tobacco smoke
Alcohol/Drug Use Hazards present during use? How many chamber dives per year? __________
What is your average alcohol consumption in a week? High altitude Temperature extremes Confined spaces
__________ drinks How deep do you dive, on average?__________
(1 drink = 12 oz. beer, 1 glass wine, or 1.5 oz liquor) Have you ever had or do you now have any of the following? Do you perform moderate or heavy physical labor at depth?
Please check all that apply and use the space below to comment on positive responses.
Never Rarely Sometimes Usually Always
How often do you drink alcohol? Yes No
Weekdays Weekends Both Persistent cough
Heart trouble History of:
Shortness of breath Decompression sickness___________________________
Do you use recreational drugs? History of fainting or seizures Arterial gas embolism______________________________
Currently Previously Never Fear of tight or enclosed spaces Ear barotrauma____________________________________
ANIMAL HANDLER QUESTIONS Sensation of smothering Pulmonary barotrauma______________________________
List type of occupational animal exposure: Heat exhaustion or heat stroke Marine envenomation_______________________________
Contact lenses or eyeglasses
Non-human primates and their tissue/fluid Other conditions that might interfere with respirator use or
Disease from exposure to cold, heat____________________
Pregnant mammals (non-rodents) result in limited work activity
Have you ever been restricted in your diving duties due to a medical condition?
Venomous animals (including snakes) Client comments regarding positive responses to respirator clearance questions: Yes No If yes, explain:
_____________________________________________________________
Wild-caught mammals and birds ________________________________________________________________
Have you ever required hyperbaric oxygen therapy?
Bats Yes No If yes, explain:
Birds ANIMAL HANDLER OCCUPATIONAL CONCERNS:
_____________________________________________________________
Standard lab animals (usual EPA exposure = mice, rats, Is animal husbandry an essential part of your duties (i.e. provide
rabbits, dogs, cats, pigs, etc.) food/water, clean cages, groom animals, etc.)
Other species ________________________________________ What % of your day are you in direct contact with animals or their blood, MENTAL HEALTH Yes No
tissues, fluids? ____
Current psychological/psychiatric condition
Animal handler medical history concerns: Does your work require you to use infectious agents in animals? ____ Depression
Known allergies or suspected allergies to animals Since your last exam have you experienced any of the following in History of psychosis
Chronic health problems such as diabetes relation to your animal exposure duties: Poor adaptation to stress
o Sneezing and runny nose
Serious renal or liver disease o Skin eruptions including hives Anxiety or phobia disorder
Valvular heart disease o
o
Cough
Chest tightness
Panic attacks, hyperventilation
Immune system deficiencies or other limitations to your ability to o Wheezing Uncontrollable rage
fight off disease o Shortness of breath Claustrophobia
Current therapy with high dose steroids, radiation therapy or cancer DERMATOLOGY Yes No Diagnosed personality disorder or neuroses
therapies Sun sensitivity
History of problems with your spleen or absence of spleen Allergic dermatitis to rubber ENDOCRINE Yes No
Pregnant or planning to get pregnant? History of chronic dermatitis Diabetes (requiring insulin)
Exposure to animals outside the workplace. If yes, please describe: Active skin disease Diabetes (not requiring insulin)
______________________________________________________________ Moles that change in size or color Childhood onset diabetes
Thyroid disease
OBSTETRIC Yes No IMMUNOLOGY/ALLERGY Yes No Obesity
Are you currently pregnant? Allergies Unexplained weight loss or gain
Which one(s) (including antibiotics)? _____________________________________
NEUROLOGICAL
Yes No Normal Abnormal Comments/findings:
Any neurological disease Cranial nerves
Seizures Cerebellum
Spinal cord injury Motor/sensory
Numbness or tingling Deep tendon reflexes
Head/spine surgery Mental status exam
History of head trauma with persistent deficits
Chronic recurring headaches (migraine)
Brain tumor
Loss of memory
Insomnia (difficulty sleeping)
GASTROINTESTINAL
Yes No Normal Abnormal Comments/findings:
Esophageal diverticula Auscultation
Severe reflux Palpation
Hiatal hernia Organo-megaly
Gas bloat syndrome Tenderness
Gastric outlet obstruction Inguinal hernia
Ileostomy obstruction
Diverticulitis
Hernias
Fistulae
Colostomy
Hepatitis
Active ulcer disease
Irritable bowel syndrome
Rectal bleeding
Vomiting blood
GENITOURINARY
Yes No Normal Abnormal Comments/findings:
Blood in urine Urogenital exam
Difficult or painful urination
Infertility (difficulty having children)
If yes, type:
foam
pre-mold/plugs ear muffs __________________________________________________________________________________________
Yes No
Have you had prior military service? __________________________________________________________________________________________
Have you had prior ear surgery?
Have you had an eardrum rupture? HEARING (Nurse to complete)
Have you had recurrent ear infections?
Do you wear a hearing aid? Audiogram: Baseline Annual Termination (Attach current and baseline audiogram)
_________________________________________________
Review/compare with baseline: Change No change
________________________________________________________________________________________
_________________________________________________________________________________________
How long have you been doing this type of work?____ years
Have you ever been off work more than a day because of work-related illness or injury? Yes No
If this is your first EPA medical surveillance exam, list any previous jobs with associated hazards, starting with the one before your current position:
Functional Activities (current position): Heavy lifting/carrying (40 lbs or more) Walking
a motor ____hrs/day
vehicle
Biological agents Solvents Hot temperatures Heavy metals Asbestos Dust Pesticides
Fumes, smoke, gases Radiation Excessive noise Confined space entry Sewage Cold temperatures
Additional factors/comments: ____________________________________________________________________________________________________________
2.
3.
4.
5.
6.
*Exposure Levels: Include both frequency of exposure (number of days) and duration of exposure (hours per day)
Diet Is workplace monitoring data or other exposure data for this employee or this
Low-calorie position available for review? ________________________________________________________
Low-fat Yes No
Low-salt ________________________________________________________
If yes, what type of data are available? _____________________________
Cholesterol ________________________________________________________
Avoid sun exposure/sun screen How were data made available? To the RMO: Based on my examination, it is my opinion that the employee
Electronic database is: (check each)
Alcohol use Hard copy report
Employee self-report capable of participating in all job functions.
Cancer screening
Please explain what changes, if any, were made in the examination due to cleared for unrestricted respirator use.
Immunizations review of these data:
________________________________________________________ cleared for use of all other suitable protective equipment (chemically
Hearing protection resistant clothing, face shield, glasses, gloves, earmuffs/plugs).
Vision referral Based on your knowledge of the physical demands of the position and/or the IF indicated: A prescription for antibiotics was was NOT written
potential exposure to occupational hazards, please answer the following: and signed by the examining physician and given to the employee/Safety
Other personal protective equipment Does the Employee need to continue in a medical surveillance program? Manager.
Job stressors Yes IF indicated: Employee has has NOT been cleared for the
No Voluntary Exercise Program
Referral(s) Cannot determine based on information available
Other Please explain if box not checked:
Others:____________________________________________ ________________________________________________________
____________________________________________ ________________________________________________________
Note: Please do not provide any official statement (oral or written)
concerning the examinee’s fitness or capability to perform the duties of
any occupation. The Reviewing Medical Officer (RMO) will provide
written opinions to the agency.
I have had the examination findings explained to me and received a copy of the examination if requested. I understand the medical recommendations.
Non-EPA Diver
&
Appendix D-1
Name:
EPA
LIABILITY RELEASE A ND EXPRESS ASSU MPTION OF R ISK
Address:
This is a release of your rights to sue. This release may be used against you in a court of law if you sue any release party or person.
Please re ad care fully, fill in all blanks and initial each paragraph before signing.
(PRINT AGENCY) as provided by assigned certification number (PRINT Certification Num ber)
, hereby affirm that I have been advised and thoroughly informed of the inherent hazards of skin and scuba diving.
Further, I understand that diving with compressed air involves inherent risks, including but not limited to: decompression sickness, embolis m, or other hyperbaric injuries
which may occur that require treatment in a recompression chamber. I further understand that the diving activities which the U.S. Environmental Protection Agency engages in from
time to time, m ay be co nduc ted at a s ite that is re mote , either b y time o r distan ce or bo th, from a recom press ion cha mbe r, and n oneth eless a gree to proce ed with the divin g activity in
spite of the possible absence of a recompression chamber in proximity to the site.
I understand and agree that the U.S. Environmental Protection Agency (US EPA) and its employees, nor any duly appointed staff or crew member of the U.S. Environmental
Protection Agency or property owner of the site dived, (hereinafter referred to as "Released Party"), may be held liable or responsible in any way for any injury, death, or other
dam ages to me or my fa mily, he irs, or ass igns tha t may o ccur a s a resu lt of my p articipa tion in this diving a ctivity or as a result o f any cau se inclu ding th e neg ligenc e of any p arty,
including th e Relea sed Pa rty, whether ac tive or pass ive.
In consideration of being allowed to participate in this diving activity, I agree to dive within the dive guidelines defined by the "US Environmental Protection Agency
Statem ent of U nders tandin g". I here by pers onally as sum e all risk s in con nectio n with s aid activ ity, for any ha rm, inju ry, or dam age th at ma y befall m e while I am en gage d in this
activity, including all risks connected therewith, whether foreseen or unforeseen. I understand this Liability Release and Assumption of Risk (Release) hereby encompasses and
applies to all diving activities in which I choose to participate as part of the US EPA diving activities. These may include, but are not limited to activitie s which may be considered
spec ialty diving activities such a s: navig ation, n ight, de ep, altitu de, bo at, drift, dry s uit, wrec k or oth er ove rhead enviro nme nt, und erwate r natura list, and u nderw ater ph otogra phy.
I further save and hold harmless any and all Released Parties from any claim or law suit by me, my family, estate, heirs, or assigns, arising out of my association with, and
particip ation in th is U.S . Enviro nme ntal Pro tection Agen cy diving activity.
I also un dersta nd tha t skin d iving an d scub a diving are ph ysically stre nuou s activitie s and th at I will be e xerting m yself dur ing suc h activity, a nd tha t if I am inju red as a result
of a heart attack, panic hyperventilation, etc., that I expressly assume the risk of said injuries and that I will not hold the above listed Released Parties responsib le for the same.
I also unde rstand tha t diving from a boat po ses add itional hazard s such a s slippery bo at decks and sho relines and move ment c aused b y wave ac tion could c ause m e to
loose my footing, fall and/or be injured, especially while carrying or wearing SCUBA equipment. In consideration of being all owed to participate in this diving activity, I hereby
perso nally ass ume all risks in conn ection with ge tting to an d from said ac tivity, for an y harm , injury, or da mag e that m ay befa ll me w hile I am enga ged in s uch ac tivity, includ ing all
risks connected with travelling to and from the dive site, whether foreseen or unseen.
I further state that I am of lawful age and legally competent to sign the liability and release, or that I have acquired the writ ten consent of my parent or guardian as provided
b e lo w .
I hereby state and agree that this Release will be effective and valid for all specialized div ing activities as defined above for a period of one year from the initial date on
which I execute this Release.
I understan d that the term s herein a re contrac tual and a re not a m ere recital, an d that I have s igned this d ocum ent of m y own free a ct.
I u n de rsta n d th a t divi ng w ith oxygen enr iched air involves cer tain inh er ent r i s k s of ox ygen toxi c i ty and/or i m pr oper m i x tur es of br eathi ng gas. I agr ee to a s s u me a l l ri s k s
associa ted with bre athing oxyg en enrich ed air und er hyperba ric condition s and ag ree to pers onally determ ine the oxyg en conte nt of my bre athing ga s and pla n the dive a ccording ly to
include a maximum depth and time.
I T IS T H E I N T E N TI O N O F (P R I N T N A M E ) B Y T H I S I N S T R U M E N T T O E X E M P T A N D R E LE A S E T H E U . S . E N V I R O N M E N T A L
P R O T E C T I O N A G E N C Y A N D A N Y P R O P E R T Y O W N E R I MM E D I A T E LY A S S O C I A TE D W I T H A C C E S S IN G T H E D I V IN G A C T I V IT Y , A N Y D U L Y A P P O IN T E D S T A F F O R C R E W
M E M B E R , A N D A L L R E L A T E D EN T I T IE S A S D E F IN E D A B O V E FR O M A L L L I AB I LI T Y A N D R E S P O N S IB I LI T Y W H A T S O E V E R F O R P E RS O N A L IN J U R Y , P R O P E R T Y DA M A G E
O R W R O N G F U L D E A T H H O W E V E R C A U S E D , IN C L U D I N G , B U T N O T L IM I T E D T O , T H E N E G L IG E N C E O F T H E R E L E A S E D P A R T I E S , W H E T H E R P A S S I V E O R A C T IV E .
I H A V E F U L L Y I N FO R M E D M Y S EL F O F TH E C O N T E N T S OF T H IS L IA B I LI T Y R E L E A S E AN D E X P R E SS A S S U M P T IO N O F R IS K B Y R E A D IN G I T BE F O R E I S I G N ED I T O N
B E H A L F O F M YS E L F A N D M Y H E IR S . I F U R T H E R U N D E R S T A N D A N D A G R E E T H A T T H I S RE L E A S E IS E F F E C T IV E A N D V A L ID F O R A P E R IO D O F O N E Y E A R F R O M TH E
DAT E ON WH ICH I EXE CUT E TH IS REL EAS E.
Appendix D-2
Page 1 of 6
(Confidential information)
This is a statement in which you are informed of some potential risks To scuba dive safely, you must not be extremely overweight or out
involved in scuba diving and of the conduct required of you during any of condition. Diving can be strenuous under certain conditions. Your
supervised scuba diving activity. Your signature on this statement is respiratory and circulatory systems must be in good health. All body
required for you toparticipate in the scuba diving activity sponsoredby air spaces must be normal and healthy. A person with heart trouble,
the U.S. Environmental Protection Agency, a U. S. federal a current cold or congestion, epilepsy, asthma, a severe medical
government agency. The diving activity is operated under the problem, or who is under the influence of alcohol or drugs should not
Safety, Health, and Environmental Management Division in supervisor before participation in this activity. You are also advised to
Washington, D.C. thoroughly understand the important safety rules regarding breathing
Read and discuss this statement prior to signing it. You must and equalization while scuba diving. Improper use of scuba equipment
complete this Medical Statement, which includes the medical-history can result in serious injury. You must be thoroughly instructed in its
section, to participate in any EPA scuba diving activity. If you are a use under the direct supervision of a qualified individual to use it
minor, you must have this Statement signed by a parent or legal safely.
guardian.
Diving is an exciting and demanding activity. When performed If you have any additional questions regarding this Medical
correctly, applying correct techniques, it is very safe. When Statement or the Medical History section, review them with the diving
established safety procedures are not followed, however, there are supervisor before signing.
dangers.
MEDICAL HISTORY
To the Participant:
The purpose of this medical questionnaire is to find out if you should be examined by your doctor before participating in the Agency ss scuba diving activity.
A positive response to a question does not necessarily disqualify you from diving in the activity. A positive response means that there is a preexisting
condition that may affect your safety while diving and you must seek the advice of your physician.
Please answer the following questions on your past or present medical history with a YES or NO. If you are not sure, answer YES. If any of these items
apply to you, we must request that you consult with a physician prior to participating in scuba diving with the EPA. The diving supervisor will supply you with
a Medical Statement and Guidelines for Recreational Scuba Diver's Physical Examination to take to your physician.
Could yo u be preg nant or are you attem pting to bec ome p regnan t? History of diving accidents or decompression sickness?
Do you regularly take prescription or non-prescription medications? History of recurrent back problems?
(with the excep tion of bir th cont rol)
Are you over 45 years of age and have one or more of the following?
Have yo u ever ha d or do yo u curre ntly have... Inability to perform mode rate exercis e (walk o ne mile within 10 m inutes)?
Asthma, or wheezing with breathing, or wheezing with exercise? History of high blood pressure or take medicine to control blood pressure?
Histor y of chest surgery? History of ear disease hearing loss or problems with balance?
Claustrrophobia o r agorap hobia (fear of c losed or open sp aces)? Histor y of problems equalizing (popping ) ears w ith airplane or mountain travel?
Epilepsy seizures, convulsions or take medications to prevent them? History of any type of hernia?
Recurring migraine headaches or take medications to prevent them? Histor y of ulcers or ulcer surgery?
History of blackouts or fainting (full/partial loss of consc iousnes s)? Histor y of colostomy?
Do you frequently suffer from m otion sick ness (seasick, carsick, etc.)? History of drug or alcohol abuse?
The Information I have provided about my medical history Is accurate to the best of my knowledge.
Signature Date
DIVER
Please print legibly.
Mailing Address
City State/Province
Telex FAX ( )
Physician Clinic/Hospital
Address Phone ( )
Address Phone ( )
Were you ever required to have a physical for diving? ¡ Yes ¡ No If so, when?
PHYSICIAN
This person is an applicant for training or is presently certified to engage in scuba (self contained underwater breathing
apparatus) diving. Your opinion of the applicant's medical fitness for scuba diving is requested. Please review Guidelines for
Recreational Scuba Diver's Physical Examination.
Physician's Impression
Remarks
, M.D. Da te
Physician s Signature
Physician Clinic/Hospital
Address
Phone ( )
Appendix D-4
Page 3 of 6
Recreational scuba (self contained underwater breathing apparatus) diving has an excellent safety record. To maintain this status it is important to screen
divers for physical deficiencies that could place them in peril in the underwater environment.
The Recreational Scuba Diver's Physical Examination contains elements of medical history, review of systems and physical examination. It is designed
to detect conditions that put a diver at increased risk for decompression sickness, pulmonary overinflation syndrome with subsequent cerebral gas
embolization and loss of consciousness that could lead to drowning. Additionally,the diver must be able towithstand some degree of cold stress, cope with
the optical effects of water and have a reserve of physical and mental abilities to deal with possible emergencies.
The history, review of systems and physical examination should include, as a minimum, the points listed below. The list of contraindications, relative and
absolute, is not all inclusive. It contains the most commonly encountered medical problems only The brief introductions should serve to alert the physician
to the nature of medical problems that put the diver at risk, and (lead him) to consider the individual patient's state of health.
Diagnostic studies and specialty consultations should be obtained as indicated to satisfy the physician as to the diver's status. A list of references is
included to aid in clarifying issues that arise. Physicians at the Divers Alert Network (DAN) are available for consultation by phone (919) 684-2948 during
normal business hours. For emergency calls, 24 hours, 7 days a week, call (919) 684-8111.
Some conditions are absolute contraindications to scuba diving. Conditions that are absolute contraindications place the diver at increased risk for injury
or death. Others are relative contraindications to scuba that may be resolved with time and proper medical intervention. Ultimately the physician should
decide with the individual, based on his knowledge of the patient's medicalstatus, whether the individual is physically qualified to participate in scubadiving.
Remember at all times that scuba is a recreational sport, and it should be fun, not a source of morbidity or mortality.
CARDIOVASCULAR SYSTEMS
Relative Contraindications: The diagnoses listed below potentially render the diver unable to meet the exertions] performance
requirements likely to be encountered in recreational diving. The diagnoses listed may lead the diver to experience cardiac ischemia and
its consequences. Formalized stress testing is encouraged if there is anydoubt regarding physical performance capability. The suggested
minimum criteria for stress testing in such cases is 13 METS. Failure to meet the exercise criteria is disqualifying. Conditioning and
retesting may make later qualification possible.
* History of CABG or PCTA for CAD
* History of myocardial infarction
* Hypertension
* History of dysrythmias requiring medication for suppression
* Valvular regurgitation
* Asymptomatic mitral valve prolapse
* Pacemakers - The pathologic process that necessitated pacing should be addressed regarding the fitness to dive. Finally in those
instances where the problem necessitating pacing does not preclude diving, will the diver be able to meet the performance criteria?
Note: Pacemakers must be certified by the manufacturer as able to withstand the pressure changes involved in recreational diving (to
depths of 130 feet of sea water).
Absolute Contraindications: Venous gas emboli produced during decompression may cross Intracardiac shunts and enter the cerebral
circulation with potentially catastrophic results. Asymmetric septal hypertrophy and valvular stenosis may lead to the sudden onset
of unconsciousness during exercise.
* Congestive heart failure
PULMONARY
Any process or lesion that impedes air flow from the lung places the diver at risk for pulmonary overinflation with alveolar rupture and the
possibility of cerebral air embolization. Asthma (reactive airway disease), COPD cystic or cavitating lung diseases all may lead to air
trapping. Spirometery, provocative tests such as methacholine challenge and other studies to detect air trapping should be carried out
to establish to the examining physician's satisfaction that the diver is not at risk. A pneumothorax that occurs or recurs while diving is
catastrophic. As the diver ascends, air trapped in the cavity expands rapidly producing a tension pneumothorax.
Relative Contraindications:
* History of prior asthma or reactive airway disease (RAD)*
* History of exercise/cold induced bronchospasm (EIB)*
* History of solid, cystic or cavitating lesion*
* Pneumothorax secondary to: thoracic surg ery,* trauma or pl eural penetra tion,* previous overinflation injury*
* Restrictive Disease**
(*Air Trapping mus t be excluded) (**Exer cise Testing ne cessary)
Absolute Contraindications:
* Active RAD (asthma), EIB, COPD or history of the same with abnormal PFT's or positive challenge
* Restrictive diseases with exercise impairment
* History of spontaneous pneumothorax
Appendix D-5
Page 4 of 6
NEUR OLO GICAL
Neurologic abnormalities that affect a divers ability to perform exercise should be assessed individually based on the degree of compromise
involved.
Relative Contraindications:
* Migraine headaches whose symptoms or severity impair motor or cognitive function
* History of head injury with sequelae other than seizure
* Herniated nucleus pulposus
* Peripheral neuropathy
* Trigeminal neuralgia
* History of spinal cord or brain injury without residual neurologic deficit
* History of cerebral gas embolism without residual pulmonary air trapping has been excluded
* Cerebral palsy in the absence of seizure activity
Absolute Contrain dications: Abnormalities where the level of consciousness is subject to impairment put the diver at increased risk of
drowning. Divers with spinal cord or brain abnormalities where perfusion is impaired are at increased risk
of spinal cord or cerebral decompression sickness.
"* History of seizures other than childhood febrile seizures
"* Intracranial tumor or aneurysm
"* History of TIA or CVA
"* History of spinal cord injury, disease or surgery with residual sequelae
* History of Type II (serious and/or central nervous system) decompression sickness with permanent neurologic deficits
Equalization of pressure must take place during ascent and descent between ambient water pressure and the external auditory canal,
middle ear and paranasal sinuses. Failure of this to occur results at least in pain and in the worst case rupture of the occluded space with
disabling and possible lethal consequences.
The inner ear is fluid filled and therefore noncompressible. The flexible interfaces between the middle and inner ear, the round and oval
windows, are however subject to pressure changes. Previously ruptured but healed round or oval window membranes are at increased
risk of rupture due to failure to equalize pressure or due to marked over-pressurization during vigorous or explosive Valsalva maneuvers.
The larynx and pharynx must be free of an obstruction to airflow. The laryngeal and epiglotic structure must function normally to prevent
aspiration.
Mandibular and maxillary function must be capable of allowing the patient to hold ascuba mouth piece. Individuals who have had mid-face
fractures may be prone to barotrauma and rupture of the air filled cavities involved.
Relative Contraindications:
* Recurrent otitis externa
* Significant obstruction of external auditory canal
* History of significant cold injury to pinna
"* Eustachian tube dysfunction
"* Recurrent otitis media or sinusitis
"* History of TM perforation
* History of tympanoplasty
* History of mastoidectomy
* Significant conductive or sensorineural hearing impairment
* Facial nerve paralysis not associated with barotrauma
"* Full prosthedontic devices
"* History of mid-face fracture
"* Unhealed oral surgery sites
* History of head and/or neck therapeutic radiation
* History of temporomandibular joint dysfunction
Absolute Contraindications:
"* Monomeric TM
* Open TM perforation
"* lube myringotomy
"* History of stapedectomy
"* History of ossicular chain surgery
"* History of inner ear surgery
"* History of round window rupture
"* Facial nerve paralysis secondary to barotrauma
* Inner ear disease other than presbycusis
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3)
Appendix D-6
Page 5 of 6
"* Uncorrected upper airway obstruction
* Laryngectomy or status post partial laryngectomy
* Trachestostomy
"* Uncorrected laryngocele
"* History of vestibular decompression sickness
Relative Contraindications. As with other organ systems and disease states, a process that debilitates the diver chronically may impair
exercise performance. Additionally diving activity may take place in areas remote from medical care. The possibility of acute recurrences
of disability or lethal symptoms must be considered.
"* Peptic ulcer disease
* Inflammatory bowel disease
* Malabsorption states
** Functional bowel disorders
"* Post gastrectomy dumping syndrome
"* Paraesophageal or hiatal hernia
Absolute Contrain dications: Altered anatomical relationships secondary to surgery or malformations that lead to gas trapping maycause
serious problems. Gas trapped in a hollow viscous expands as th e diver surfaces and can lead to rupture or in the case of the upper GI
tract, emesis. Emesis underwater may lead to drowning.
* High grade gastric outlet obstruction
* Chronic or recurrent small bowel obstruction
"* Entrocutaneous fistulae that do not drain freely
* Esophageal diverticula
* Severe gastroesophageal reflux
"* Achalasia
* Unrepaired hernias of the abdominal wall potentially containing bowel
RelativeContraindications: With the exception of diabetes mellitus, states of altered hormonal or metabolic function should be assessed
according to their impact on the individual's ability to tolerate the moderate exercise requirement and environmental stress of sport diving.
Generally divers with altered hormonal status should be in as near an optimal physiologic state as is possible. It should be noted that
obesity predisposes the individual to decompression sickness and is an indicator of poor overall physical fitness.
"* Hormonal excess or deficiency
* Obesity
* Renal Insufficiency
Absolute Contraindications: The potentially rapid change in level of consciousness associated with hypoglycemia in diabetics on Insulin
therapy or oral anti-hypoglycemia medications can result in drowning. Diving is therefore contraindicated.
PREGNANCY
Venous gas emboli formed during decompression may result in fetal malformations. Diving Is absolutely contraindicated during any
stage of pregn anc y.
Abnormalities resulting in altered rheological properties may increase the risk of decompression sickness.
Relative Contraindications: Absolute Contraindications:
"* Sickle cell trait "* Sickle cell disease
"* Acute anemia "* Polycythemia
"* Leukemia
Appendix D-7
Page 6 of 6
ORT HOP EDIC
Relative impairment of mobility particularly in the small boat environment or ashore with equipment weighing up to 40 pounds must be
assessed. The impact of exercise ability is also an important consideration.
Relative Contraindications:
* Chronic back pain
* Amputation
* Scoliosis - must also assess Impact on pulmonary function
* Aseptic necrosis - possible risk of progression related to adequacy of decompression
BEHAVIORAL HEALTH
Behavioral: The diver's mental capacity and emotional makeup are important to safe diving. The student diver must have sufficient
learning abilities to grasp information presented to him by his instructors, be able to safety plan and execute his own dives and react to
changes about him in the underwater environment. The student's motivation to learn scubaand his ability to deal with potentially dangerous
situations is also crucial to safe diving.
Relative Contraindications:
* Developmental delay
* History of drug or alcohol abuse
* History of previous psychotic episodes
Absolute Contraindications:
* Inappropriate motivation to dive - solely to please spouse or partner, to prove oneself In the face of personal fears
* Claustrophobia and agoraphobia
* Active psychosis or while receiving psychotropic medications
* History of panic disorder
* Drug or alcohol abuse
BIBLIOGRAPHY
1. Physician's Guide to Diving Medicine. Shil ling et al, Plenum Pub. 1982
2. Diving and Subaquatic Medicine, 2nd Ed., Edmonds, Lowry, Pennfeather, Diving Med Centre, 1978
3. Fitness to Dive 34th UHMS Workshop, Vorosmarti (ed.), Chaired by Linaweaver, UHMS Pub No#70, 1987
4. Medical Examination of Sport Scuba Divers, 2nd Ed., Davis, Medical Seminars Inc., 1986
5. Hyperbaric and Undersea Medicine, Davis, Medical Seminars Inc. 1981
ENDORSERS
Keith Van Meter, M.D., F.A.C.E.P. Paul G . Linawea ver, M.D ., F.A.C.P
Assistant Clinical Professor of Surgery San ta Ba rbar a Me dica l Clinic
Tulane University School of Medicine Undersea Medical Specialist
Durham, NC Baltimore, MD
Milwauk ee, W I
Appendix D-8
APPENDIX F
LETTERS OF CERTIFICATION
SAMPLE
DIVER TRAINEE
AUTHORIZATION: You are authorized to use open-circuit, self-contained underwater breathing apparatus incident to
the performance of your official duties, and subject to the prescribed EPA policy and regulations governing the use of
such equipment, as provided in the EPA Diving Safety Manual.
RESTRICTIONS: When diving in unfamiliar conditions, you must be under the supervision of a diver
trained and experienced in those conditions.
SPECIAL QUALIFICATIONS: This diver has successfully completed Diving Accident Management.
REMARKS : This diver has completed all requisite classroom work; however, due to a temporary change
in physical status, this candidate did not participate in the required field exercises, as a Scientific Diver, the
candidate must demonstrate competence in these field exercises at the EPA Diver Training Facility in Gulf
Breeze, Florida.
May, 1981
___________________________
James M. Patrick
Training Director EPA
Diving Safety Board
___________________________
Don Lawhorn
Chairman EPA
Diving Safety Board
SAMPLE
SCIENTIFIC DIVER
AUTHORIZATION: You are authorized to use o pen-circuit, self- contained underwater breathing apparatus incident
to the performance of your official duties, and subject to the prescribed EPA policy and regulations governing the use
of such equipment, as provided in the EPA Diving Safety Manual.
RESTRICTIONS: W hen diving in unfamiliar conditions, you must be under the supervision of a diver trained
and experienced in those, conditions.
SPECIAL QUALIFICATIONS: This diver has successfully completed diving Accident Management and Dry-
suit Training.
REMARKS: The above individual was examined and found technically qualified and psychologically adapted for
diving.
_______________________________
Bruce Reynolds
Chairman
Diving Safety Board
SAMPLE
DIVE MASTER
AUTHORIZATION: You are authorized, to use open-circuit, self- contained underwater breathing apparatus incident
to the performance of your official duties, and subject to the prescribed EPA policy and regulations governing the use
of such equipment, as provided in the EPA Diving Safety Manual.
RESTRICTIONS: When diving in unfamiliar conditions, you must be under the supervision of a diver
trained and experienced in those conditions.
SPECIAL QUALIFICATIONS: This diver h as successfully completed Diving Accident Management and Scientific
Diver, Dry-Suit and Dive-Master Training. He is certified to use a Dry-Suit in operational diving and supervise EPA
divers.
REMARKS: The above individual was examined and found technically qualified and psychologically adapted for
diving.
_______________________
Bruce Reynolds
Chairman
Diving Safety Board
Between
and
The EPA Diving Program recognizes the Florida Department of Environmental Protection (FLDEP), Florida Marine
Research Institute (FMRI) authorization to dive as equivalent to EPA Authorization. Under this agreement, FLDEP
divers who meet FMRI Standards for Scientific Diving (Nov 15, 1991) Section 4.33 are allowed to participate in EPA-
sponsored diving projects and operations. Each diver will be required to present a current letter of authorization, signed
by the FMRI Diving Officer. This agreement can only be applied to personnel directly employed by or working under
the control of the State of Florida unless agreed upon by both diving programs.
Maintenance of this agreement is contingent upon strict compliance with all EPA diving regulations and standards,
when diving on EPA projects, as set forth in the EPA Diving Safety Policy. This policy specifically includes the
following: diver certification, annual medical examinations of the divers using the Standard Forms SF-88 and SF-93
and the NOAA medical criteria, annual CPR and first a id certification for diver s, periodic inspection and testing of
certain pieces of diving equipment, the preparation and approval of a dive plan before each dive, the logging of the
details of each dive, the. maintenance of diver proficiency and the provision for diver requalification should proficiency
lapse, the presence of a qualified divemaster at each dive site. The only exception to standard EPA procedures will be
that all certification and medical information will be retained by FMRI.
The EPA Unit Diving Officer for (Athens, Georgia), Donald Lawhorn, will be the point of contact. Please contact him
at (706) 5555--55-55 if there are any questions regarding diver certification, physicals, operational protocols, or
technical procedures. Compliance with the terms of this agreement as well as actual diving activities are subject to on-
site action by the EPA Diving Safety Board. This agreement may be terminated or modified by the DSB at any time.
This agreement may be renewed annually by mutual consent of both diving programs.
Don Lawhorn October 16, 1994 Chairman, EPA Diving Safety Board
EMERGENCY ASSISTANCE 911 – DAN 919 684 9111 - COAST GUARD CH-16
HOSPITAL:
________________________________________________________________________________
CHAMBER LOCATION:
_______________________________________________________________________________
************** OXYGEN WILL BE ON SITE **************
2. Review emergency equipment (e.g., AED, first aid, 3. Have diver’s drinking water available
oxygen kits, radio check with lab)
4. Record bottom times, tank pressures, and water
3. Review dive profile (e.g., times, depths, repetitive depths on Tender's Log
calculations)
5. Record problems, malfunctions, hazards encountered
4. Review communications (e.g., hand signals, diver on Tender's Log
recall)
6. Follow appropriate decontamination procedures as
5. Review project objective(s)
appropriate
6. Review potential hazards (physical & pollutant) 7. Clean up and stow all equipment; wash AGA masks
with soap and warm water.
7. Review decontamination procedures for contaminated
water diving
N/A
Name:
Unit Dive Officer:
Check one of the following: US EPA Employee (FTE) Contractor
Dates of Proposed Dive Operations:
APPLICANT’S E-MAIL ADDRESS AND TELEPHONE NUMBER
Email address:
Telephone:
US EPA DIVERS MUST BE CURRENTLY AUTHORIZED FOR APPROVAL OF LOR
Organization:
Email:
Address:
Phone:
NOTE - LOR’s with the listed Reciprocity Partner are valid for the remainder of the Calendar year,
unless the diver’s physical or training certifications expire. LOR Requests must be submitted at
least 4 weeks prior to start of dive operations or processing may be delayed.
TANK
PRESSURE TOTAL MAX
DIVER TENDER IN ............................ BOTTOM DEPTH
TIME TIME FEET
................................. feet.................
Office Address
Address/Phone
Dive Profile
TP: TP: TP: TP: TP: TP: TP: TP:
T: T: T: T: T: T: T: T:
Diver:
: : :
SI SI SI
BT: BT: BT: BT:
D: D: D: D:
Locations:
Comments
Notes: TP = Tank Pressure, T = Clock Time, BT = Bottom Time, D = Maximum Depth, and SI = Surface Interval
Time Oxygen Administration Started Ended
Send the patient’s dive computer with them to hospital/hyperbaric chamber for downloading of accident data
APPENDIX I
Diving [Input Unit; e.g., Region or Laboratory] Time Period: [Input Start
Unit: Date]
[Input UDO Name] [Input End
Date]
[List Alternate UDO Names]
A. DIVING ACTIVITIES
1. Describe each type of diving operation; include pollutant exposure (use separate
sheet, if necessary).
2. Locations of diving operations (list each state and type of water body).
3. Dive Statistics:
C. DIVE TRAINING
1. Describe the type of training conducted/received, and list the name, office, and
level of certification for each trainee. (Use separate sheet if necessary)
2. List any training needed.
D. DIVE EQUIPMENT
[List diving personnel names, current ages, sex, and certification levels.]
1. Time expenditures.
ACTIVITY (Describe) TIME
Review of Documents
(Identify, e.g., dive plans)
Other
* Each day of diving is an exposure day per diver (e.g., three divers diving on a given
day would equal 3 exposure days).
The Diving Safety Plan and Dive Plan can be two separate documents or they may be
combined. The dive plan is specific to the proposed dive operation, and the safety plan
can be either a generic plan developed by the dive unit or simply a copy of the Diving
Safety Policy, the U.S. Navy Decompression Tables, and area specific emergency
information. The elements of each plan are combined in the following checklist.
A. EMERGENCY INFORMATION
7. Are the Divers Alert Network (DAN) telephone numbers, (919) 684-2948 or
(919) 684-9111, for medical advice and locations of recompression chambers
listed?
YES NO N/A; Comments:
8. Is a copy of the EPA's Diving Safety Manual readily available at the dive site to
address unanticipated events or procedural issues?
YES NO N/A; Comments:
5. Were other environmental conditions identified and discussed in the dive plan?
a. tidal heights YES NO N/A; Comments:
6. Were the divers, boat operators, and support personnel identified in the plan?
YES NO N/A; Comments:
7. Has the dive plan been approved by the Unit Diving Officer?
YES NO N/A; Comments:
The project leader and divemaster for the dive should gather all project personnel
together just before diving operations are to start and review the following topics.
3. Were any safety protocols for the dive reviewed (e.g., a safety stop buoy line
descent/ascent, low air supply procedures/alternate air source use)?
YES NO N/A; Comments:
8. Was there a review of any specialized equipment for the dive (e.g., pinger, pinger
locator, current meters, ROVs, dive sleds, oxygen meters for Nitrox )?
YES NO N/A; Comments:
9. Were the dive team roles identified (i.e., divemaster, alternate divemaster, tender,
and if needed, standby diver)?
YES NO N/A; Comments:
10. Did the divers check all of their dive equipment prior to each dive?
YES NO N/A; Comments:
11. Were the tank pressures checked and recorded before each diver entered the water
and subsequent dive start times by the divemaster or tender?
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, April 15, 2016)
Appendix J-5
EPA Dive Safety Audit Checklist
12. Was the personal emergency information available for each diver (e.g., medical
history, family notification) and stored in a manner to ensure the privacy of the
information?
YES NO N/A; Comments:
During the dive it is important to observe the position of the support vessel(s), operation
of the equipment, and the topside diving personnel.
1. Was the tender monitoring the divers and not performing another function that
could interfere with tending responsibilities?
YES NO N/A; Comments:
3. Were the appropriate dive flags displayed on the vessel tending the divers?
a. red/white "diver down" flag on inland/coastal waters?
YES NO N/A; Comments:
b. r/w flag and blue/white code alpha flag in waters with international vessel
traffic?
YES NO N/A; Comments:
4. Was the size of the dive flags appropriate for the diving operation?
YES NO N/A; Comments:
7. Were the emergency first aid, AED (An Automatic External Defibrillator (AED) must be
onsite, and oxygen kits on the dive platform?
YES NO N/A; Comments:
Monitoring post-dive diving operations is important to ensure that divers are taking the
necessary precautions to avoid injury, protect themselves from environmental conditions,
and maintain their equipment.
1. Did the divemaster and/or tender monitor each diver exiting the water for signs
and symptoms of "bubble trouble?"
YES NO N/A; Comments:
4. Were the water depths, bottom time, and tank pressures of each diver recorded
after each dive?
YES NO N/A; Comments:
5. Was a dive report prepared that included appropriate information specific to the
diving operation (e.g., water depths and bottom times for the dives, tank
pressures, achievement of objectives, hazards encountered, malfunctions and lost
equipment)?
YES NO N/A; Comments:
7. Did the divers properly clean and store their equipment when they were not
diving or after they had completed the diving operations?
YES NO N/A; Comments:
An evaluation of the training, background, and capabilities of each diver involved in the
diving operation is of primary importance.
1. Were all divers current with diving physical examinations (within one or two
years depending on whether the dive unit conducts contaminated water dives, or has been
so advised by a physician.)?
YES NO N/A; Comments:
5. Were all divers certified for their respective levels of responsibility (i.e., as
Scientific Divers or Divemasters)?
YES NO N/A; Comments:
6. Were all divers using the air compressor, trained in its operation, if one was at the
dive site?
YES NO N/A; Comments:
7. Is there record of a rescue drill within the past 12 months (i.e., rescue of an
incapacitated diver from the water to the diving platform) been performed? (Note:
Rescue could involve use of a backboard or stokes litter, harness and tackle
system, or winch system for a high dive platform, or a hand lift of the patient and
backboard for a low dive platform.)
YES NO N/A; Comments:
8. Had all divers maintained their proficiency (i.e., dived within the last three
months)?
YES NO N/A; Comments:
9. Were all divers experienced with the working conditions that were expected
during the project?
YES NO N/A; Comments:
10. If the answer to nos. 8 or 9, above, is negative, what provisions and preparations
has the divemaster undertaken to prepare the diver for the new situation?
Comments:
Diving equipment must be maintained according to the requirements in the Diving Safety
Policy, the manufacturer’s specifications, whichever are the most conservative.
A. SCUBA EQUIPMENT
1. Were all SCUBA cylinders tested within the 5-year hydrostatic test date?
YES NO N/A; Comments:
2. Had all SCUBA cylinders been visually inspected within the past 12 months?
YES NO N/A; Comments:
3. For EPA-owned or leased compressors, was an air quality test result form
obtained within the past 6 months? (Air quality must meet the standard, as cited in
Appendix A, #23.)
YES NO N/A; Comments:
4. If the compressor was not in use for more than six month, was it labeled with
“TAGOUT” or had the air quality been tested before dive operations resumed?
YES NO N/A; Comments:
6. Had all of the diver's gauges (e.g., pressure, depth, compass, bottom timers, and
watches) been critically examined and calibrated or replaced according to the
manufacturer’s recommended service interval?
YES NO N/A; Comments:
7. Had all valves and hoses been critically examined and replaced or overhauled as
needed?
YES NO N/A; Comments:
10. Were all buoyancy compensators in good condition and maintained in accordance
with manufacturers specifications?
YES NO N/A; Comments:
11. Were all buoyancy compensators capable of being inflated by two methods (one
other than oral)?
YES NO N/A; Comments:
12. Had the diver communication equipment been checked prior to use?
YES NO N/A; Comments:
13. Was a dive ladder available for the divers to enter the dive platform? (Some boats
are low to the water or have swim step and do not require a dive ladder.)
YES NO N/A; Comments:
15. Were all full-face masks free of corrosion and in good operating condition?
YES NO N/A; Comments:
17. Were the manufacturer’s repair and maintenance manuals available for the
specialized dive equipment (e.g., the communication equipment, and full-face
masks)?
YES NO N/A; Comments:
18. Was the dive equipment, in general, free of corrosion and in good working
condition?
YES NO N/A; Comments:
19. Were adequate spare parts and repair materials available at the dive site?
YES NO N/A; Comments:
20. Is out of service dive equipment (e.g. regulators) clearly tagged out?
1. Was the emergency oxygen kit capable of servicing two divers with demand
second stage regulators at the same time?
YES NO N/A; Comments:
2. Did the emergency oxygen kit have an oxygen cylinder that was size "E" (626
liters) or larger?
YES NO N/A; Comments:
3. Had the regulator on the oxygen cylinder been maintained according to the
manufacturer’s specifications?
YES NO N/A; Comments:
4. Did the oxygen kit contain a cylinder wrench (or wheel) for opening and closing
the tank valve?
YES NO N/A; Comments:
5. Were the hoses, valves, and regulators in the oxygen kit in good condition and
clean, particularly of oil and grease?
YES NO N/A; Comments:
9. Was there an adequately supplied first aid kit (appropriate for the project)
available for the divers, the contents stored properly, and appropriate for the
users?
YES NO N/A; Comments:
11. Was there a backboard for emergency use on board the survey vessel or in the
dive staging area?
YES NO N/A; Comments:
Generic Dive Plans and Reports Dive Tender's Log Semi-annual Report of Unit Dive Training
and Operations Dive Safe Ship Ops - Check List First Aid Kit EPA Field Emerging Form
A. NITROX Reference:
Reference A: Nitrox Manual; Complete Guide to Nitrox Diving -- by: Dick Rutkowski © 1994;
Hyperbarics International; 490 Caribbean Drive; Key Largo, FL 33037
AAUS Recommendations and Guidelines for Scientific Nitrox Diving and Nitrox
Diver Certification, September 1991
Reference C: Oxygen toxicity Management in the Field, Alert Diver, DAN periodical May/June
2008, pp 13-14. DAN Recommendation for a maximum oxygen partial pressure of 1.4
ATA for open-circuit scuba using nitrogen-oxygen breathing gas mixtures.
EPA (United States Environmental Protection Agency). 2010. Sheldrake, Pedersen, Humphrey
et. al. EPA three part polluted water diving module presentations, AAUS 2010
PART A
Minimum EPA standards for the use of oxygen enriched air for EPA sanctioned diving operations
are listed below.
1. A dive plan designating a divemaster, trained and certified in the use of oxygen enriched air,
must be approved by the Unit Diving Officer (UDO).
2. All EPA and EPA-sanctioned divers who use oxygen enriched air shall be trained and certified
by a nationally recognized organization approved by the UDO.
All EPA and EPA-sanctioned divers who are NITROX certified should complete at least one
NITROX dive per year to maintain proficiency. Divers or dive units must re-qualify for
NITROX diving if they have not maintained NITROX proficiency but anticipate having to
utilize NITROX on an upcoming dive project. The dive unit UDO or his/her designee
overseeing the dive operation shall establish requalification procedures for NITROX use. At a
minimum, divers shall be able to independently determine percent oxygen content of their dive
cylinder, determine maximum operating depth, demonstrate an understanding of the limitations
of NITROX and be able to set, read and understand NITROX settings and repetitive dive
planning on their dive computer and/or appropriate tables.
3. Personnel blending or filling high-pressure storage or SCUBA cylinders and operating high-
pressure gas transfer equipment with oxygen enriched air shall be trained and certified to
perform these operations by a nationally recognized organization approved by the UDO. Gas
blending must occur prior to filling SCUBA cylinders or contact with breathing equipment
(e.g., an open-circuit regulator). Pre-mixed oxygen enriched air or Nitrox may be purchased
from a licensed, commercial supplier that provides breathing quality gas in accordance with
nationally recognized consensus standards.
4. All gas blending and transfer equipment and storage cylinders shall be cleaned and maintained
for oxygen service in accordance with nationally recognized consensus standards. This is
required only for equipment that may be exposed to oxygen concentrations equal to or greater
than 40%.
5. All high-pressure SCUBA cylinders containing oxygen enriched air shall belabeled;.
7. When diving with oxygen-enriched air, divers shall use a computer set at the percentage of
oxygen in the mix or diving and decompression tables calculated for the specific gas mixture used
(e.g. Nitrox I, II, or Equivalent Air Depth Tables).
8. Oxygen enriched air up to 40% oxygen can be used for EPA dive operations.
The EPA Diving Safety Board would like to thank the Divers Alert Network (DAN) and
in particular Matías Nochetto, M.D., Director, Medical Programs, and Ricky L. Langley,
M.D., M.P.H, FACP, FACOEM, of the North Carolina Department of Health and Human
Services for their valuable input to this document.
1. PURPOSE............................................................................................................................... 1
2. BACKGROUND .................................................................................................................... 2
3. BIOHAZARDS OF AQUATIC ENVIRONMENTS .......................................................... 3
3.1 Infectious Microorganisms .............................................................................................. 3
3.1.1 Viruses .............................................................................................................. 6
3.1.2 Bacteria ........................................................................................................... 10
3.1.3 Fungi ............................................................................................................... 16
3.1.4 Algae ............................................................................................................... 16
3.1.5 Parasites .......................................................................................................... 18
3.2 Dermatoses ..................................................................................................................... 19
3.2.1 Cymothoidism ................................................................................................. 19
3.2.2 Schistosome Dermatitis .................................................................................. 20
3.2.3 Seabather’s Eruption ....................................................................................... 20
3.2.4 Seaweed Dermatitis ........................................................................................ 20
3.2.5 Cutaneous Larva Migrans ............................................................................... 20
3.2.6 Other Allergic Reactions................................................................................. 21
3.3 Intoxications ................................................................................................................... 21
3.4 Envenomations ............................................................................................................... 22
3.4.1 Venomous Invertebrates ................................................................................. 22
3.4.2 Venomous Vertebrates .................................................................................... 24
3.5 Dangerous Non-Venomous Aquatic Animals ............................................................... 25
4. CONTROLLING AND PREVENTING EXPOSURE ..................................................... 27
4.1 General Considerations .................................................................................................. 27
4.1.1 Diving After Rainfall/Runoff .......................................................................... 28
4.1.2 Dermal Protection ........................................................................................... 28
4.1.3 Respiratory Protection .................................................................................... 28
4.1.4 Good Work Habits .......................................................................................... 29
5. MEDICAL MONITORING PROGRAM ......................................................................... 30
5.1 Medical Surveillance ..................................................................................................... 30
5.2 Prophylactic Vaccination ............................................................................................... 31
5.3 Post-Exposure Evaluation .............................................................................................. 31
6. EMPLOYEE AWARENESS .............................................................................................. 32
6.1 General Considerations and Training ............................................................................ 32
6.2 Biological Safety............................................................................................................ 32
7. REFERENCES .................................................................................................................... 34
8. GLOSSARY/DEFINITIONS.............................................................................................. 35
1. PURPOSE
The purpose of this document is to help safeguard divers, boat operators and other personnel
involved in aquatic operations from biohazards they may encounter in the environment.
Information on potential workplace biohazards is provided to help protect employees while
performing duties like collecting water, sediment, and sludge samples; acquiring marine and
freshwater specimens; and conducting various diving procedures. This document focuses on
those biohazards that may be unique to, or pose a higher risk for, participants in the EPA’s
Diving Program.
Since EPA scientific diving projects may involve diving and boating in water with biological or
chemical contaminants, the EPA Scientific Diver Training curriculum includes use of variable-
volume dry suits, full-face masks, compatible dive equipment and procedures for contaminated
water diving, first aid for marine wounds, and proper diver decontamination methods. However,
all trained EPA divers and support personnel must continually update their awareness of possible
biohazards in the marine environment.
“Biohazards of Diving Operations and Aquatic Environments” sets forth measures for
minimizing workers’ occupational exposure to biohazards in underwater and diving operations.
The hazards involved in dive operations are the same ones EPA workers may encounter in land-
based operations, but may also include hazards unique to the aquatic environment. (The scope of
this document does not include biohazards that divers or field personnel may face on the surface
from mosquito and other terrestrial disease-causing organisms.) As with any field operation,
aquatic and dive operations involve aspects of physical activity that can result in injury leading
to infection. Handling diving and aquatic equipment and supplies commonly involves the
potential for lacerations or abrasions that can become infected by microorganisms.
First responder activities for injured divers, or the sharing of diving equipment, can also
introduce risk of exposure to bloodborne pathogens. However small the risk, employers should
provide training on universal precautions, work practice controls, personal protective equipment
and other provisions of the Occupational Safety and Health Administration (OSHA)
“Bloodborne Pathogens” standard, available at Title 29 of the Code of Federal Regulations, part
1910.1030.
Further potential for infection exists from the aquatic environment, both fresh and saltwater, such
as exposure to biohazards from waterborne microorganisms, microbial toxins, plants and animals
that may be encountered in diving operations. This document also provides some information on
first aid for injuries and treatment related to biohazards.
All diving operations are conducted in biologically contaminated water, the degree of hazard
being a function of the type and number of potentially infective or venomous organisms and
aquatic life present. Seawater and inland waters are essentially mixtures of many different
microorganisms, some that inhabit the aquatic environment and others that originate from human
and animal excreta and shedding.
The majority of microorganisms found as aquatic inhabitants are harmless to humans – normal
commensals of animals, birds and mammals. But there are dangerous and life-threatening life
forms in all the waters of the world. Certain species of viruses, bacteria, fungi, algae and
parasites are recognized as human pathogens and opportunistic microorganisms; the major
sources of these disease-producing organisms are human and animal excreta, especially from
infected hosts. Besides these normal inhabitants of marine and fresh waters, contamination of
water from various sources poses an increased hazard to exposed persons. The discharge of raw
sewage into oceans, lakes and rivers is the primary source of exposure to potentially infectious
and toxigenic microorganisms for both humans and animals, including consumable species such
as shellfish. These sources of contamination include human and animal waste, industrial wastes,
agricultural wastes, and other forms of pollution such as fertilizer runoff from farms. Many
species of animal viruses, bacteria, fungi, algae and parasites are found in sewage effluents that
may be discharged into rivers, oceans and lakes.
The appearance of water per se may be misleading for workers (seemingly pristine, crystal-clear
water can be grossly contaminated with microorganisms, containing upwards of a million per
milliliter). However, brackish, foul-smelling water is significantly more likely to have extensive
microbial contamination – unless the pollution is due to toxic chemicals, which may also be
detrimental to microbial life and pose a risk to the diver. Taking protective measures is prudent
when entering water known to have been influenced, or potentially influenced, by effluents from
sewage disposal.
The injuries often experienced during aquatic operations, including abrasions, lacerations and
punctures, are readily contaminated with microorganisms, potentially leading to infection. In
addition, exposure of mucous membranes of the eyes (i.e., conjunctival exposure), nose (i.e.,
rhinal exposure), and mouth; exposure of the ear canal; exposure to genitalia, and the swallowing
and aspiration of contaminated water can lead to serious infections and intoxications.
Typically, every EPA scientific diver is issued a complete set of personal diving equipment,
which often includes a full-face mask, dry suit with dry hood, and dry gloves, to minimize
potential exposure to biological and chemical contaminants. However, equipment – such as
diving helmets – is sometimes shared during diving operations. Shared equipment can become
contaminated with blood and other body fluids. Consequently, the possibility of transmission of
human diseases from one diver to another exists, especially for diseases such as hepatitis B,
hepatitis C, tuberculosis, herpes virus and human immunodeficiency virus (HIV), among others.
This document describes appropriate precautions and other measures to eliminate or reduce the
potential for disease transmission when using shared diving equipment.
Information and training should be provided to employees on the presence of aquatic biohazards.
This training must include information on the cause of potential infectious diseases and
envenomation (poisonings), the clinical onset and symptoms of specific diseases, measures for
prevention and control of exposure, and accepted treatment modalities (methods of therapy).
Specific information on the proper cleaning and disinfection of diving equipment is mandatory.
The healthcare provider will give medical assistance to injured and ill workers, keep injury and
infection records for employees, immunize employees as indicated and keep vaccination records,
provide periodic serologic testing to establish immune status and infectivity, conduct skin testing
to monitor exposures to certain infectious agents (e.g., tuberculosis), and conduct periodic
physical examinations on employees.
The employer maintains the full responsibility for ensuring that all employees whose duties
require exposure to aquatic environments have the best protection possible against exposure to
both pathogens and other hazards associated with polluted waters.
It is important that the person involved with diving or sample/specimen collection and
processing be cognizant of the potential hazards involved in these operations in the waters they
are working in, and that they always perform their tasks as safely as possible to reduce or
eliminate injury or illness.
Human exposures to waterborne pathogenic and opportunistic microorganisms most often result
in illnesses such as gastroenteritis (i.e., inflammation of the stomach and intestines), respiratory
disease, wound infections, otitis externa (infection of the external ear canal), conjunctivitis (i.e.,
infection of the conjunctiva of the eyes) and sinusitis. However, more serious consequences and
life-threatening complications can occur. In addition, during diving operations workers may be
exposed to the blood or body fluids of coworkers as a result of sharing equipment, thereby
facilitating the transmission of disease agents. Exposure of workers in the aquatic environment
most often occurs through contact (i.e., skin, eyes and ears), penetrating injuries and respiration,
especially during aspiration of contaminated water. Some of the more important viruses,
bacteria, fungi, algae and parasites associated with waterborne disease or diving operations are
briefly discussed in this document.
An evaluation by a health care provider is recommended when symptoms of disease or injury are
evident or if the diver is concerned he/she may have been exposed to a potentially harmful agent.
3.1.1 Viruses
Many viruses can be found in marine and inland waters, especially those polluted with sewage.
Most viruses are found in human and animal wastes that can contaminate aquatic environments.
Currently there are more than 200 human enteric viruses that may be found in wastewater.
Enteric viruses, also known as enteroviruses, are those viruses that originate from the intestinal
tract. They are found at concentrations of 1 million virus particles per gram of feces. According
to Melnick et al. (1978), sewage levels of about 7,000 virus particles per liter are common in the
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United States, with levels in parts of the world reaching more than 500,000 virus particles per
liter of sewage. Viruses contaminating the oceans, seas, lakes and other bodies of water through
the dumping or release of sewage possess a variable survival in these aquatic environments – that
is, viruses are obligate intracellular parasites and cannot replicate without specific animal host
cells. Survival of free viruses in seawater is a function of both the specific virus and the
environmental conditions. Studies have indicated that survival is enhanced significantly by lower
water temperature and the presence of sediments. Enteroviruses such as the polioviruses and
coxsackieviruses have been shown to survive from 1 to 3 months in seawater, depending on the
season (summer or winter, respectively). The bacteria found in seawater also affect the survival
of viruses by releasing antiviral metabolites that rapidly inactivate viruses. In sewage treatment
plants, chlorination is moderately effective in viral inactivation.
The knowledge that viruses can survive for many weeks upon release to marine or fresh waters is
important for the understanding and application of exposure and infection control practices.
Moreover, besides the viruses associated with shedding and the release of sewage that contribute
to the pollution of aquatic systems, there are viruses that inhabit aquatic life as either indigenous
commensals (intestinal symbionts) or pathogens that can infect humans or contaminate seafood.
The major virus families recognized as sewage-associated waterborne organisms that pose a risk
to humans are the following:
• Adenoviridae: adenoviruses
• Astroviridae: astrovirus
• Caliciviridae: norovirus, Sapporovirus
• Hepeviridae: hepatitis E
• Picornaviradae: Aichivirus, coxsackievirus, poliovirus, echovirus, hepatitis A
• Reoviridae: rotavirus A, B and C
Viruses that are transmissible through blood and other body fluids could pose a risk to divers
sharing equipment that becomes contaminated with these fluids. Among these are:
• Hepatitis B (HBV)
• Hepatitis C (HCV)
• Human immunodeficiency virus (HIV)
• Cytomegalovirus (CMV)
• Epstein-Barr virus (EBV)
• Hemorrhagic fever viruses
• Varicella zoster virus (chickenpox or shingles)
• Influenza and common cold viruses
• Exanthematous viral infections
3.1.1.1 Adenoviruses
Adenoviruses are primarily associated with infections of the conjunctiva, respiratory system and
intestinal tract. There are more than 40 serotypes of human adenoviruses. Adenoviral infections
are primarily transmitted through the fecal-oral route and by contact, with fecal shedding
continuing for months or years after initial infection. Ocular infections have been associated with
exposure to fecal-contaminated water, resulting in sporadic or epidemic outbreaks of pharyngo-
conjunctival fever (PCF). Disease onset is abrupt, with sore throat, fever and conjunctivitis;
accompanying headache, malaise, nausea and diarrhea are common. In adults, the disease is
milder than among children, and primarily involves the eyes. Complete recovery occurs in
several weeks.
3.1.1.2 Enteroviruses
Enteroviruses include viruses responsible for gastroenteritis and for human poliomyelitis, which
is transmitted through the fecal-oral route. Enteric viruses can cause a variety of illnesses
including gastroenteritis and more rarely encephalitis, meningitis, conjunctivitis, myocarditis and
respiratory illnesses.
One of the more serious illnesses is polio. During the gastrointestinal phase of infection, copious
quantities of poliovirus are shed in the feces; this phase may last for months. With proper sewage
management, the poliovirus is inactivated; where sewage management is minimal or absent, the
poliovirus remains viable in the environmental setting for months. Transmission takes place
through consumption of contaminated water or food, or exposure to virus-contaminated vectors
(e.g., flies). Most infections remain asymptomatic, with approximately one paralytic case for
every 100-150 infections. Highly effective live and inactivated vaccine preparations against
poliomyelitis are available. In less developed regions of the world, poliomyelitis remains a
serious public health problem.
For the majority of enteroviruses, there are no vaccines available and treatment is primarily
symptomatic.
3.1.1.3 Hepatitis A
Hepatitis A is usually spread through the fecal-oral route, i.e., through sewage-contaminated
water and food (including seafood), and by contact. The virus can survive in both salt and fresh
water. Clinical symptoms include fatigue, fever, nausea, malaise and jaundice. The disease is
self-limiting, with a fatality rate of less than 0.1 percent. No chronicity (i.e., association with
cirrhosis or carcinoma of the liver) or carrier state develops, as can occur with hepatitis B and C
infections. A vaccine for hepatitis A is available. Prophylaxis with immune globulin should be
considered for travel to endemic areas if travel occurs within less than 1 week of vaccination.
3.1.1.5 Hepatitis C
Hepatitis C is usually spread through contact with contaminated blood or by sexual transmission.
Clinical disease is often mild and asymptomatic and characterized by waxing and waning
elevation in liver enzyme levels. Anorexia, fatigue, nausea, abdominal pain and jaundice may
occur. About 80 percent of cases may develop a chronic hepatitis. Serious sequelae may include
fatty liver, liver cancer and cirrhosis; infected persons have an increased risk of lymphoma,
glomerulonephritis and autoimmune thyroid problems. Risks for divers and other aquatic
workers include exposure to contaminated diving equipment. Although there is currently no
vaccine to prevent hepatitis C, medications are available and highly effective to treat the
infection.
3.1.1.6 Hepatitis E
Hepatitis E is usually transmitted through the fecal-oral route through sewage-contaminated
water and food, including shellfish. There is some evidence that hepatitis E may also be a
zoonotic infection. Anorexia, fatigue, nausea, abdominal pain and jaundice may occur. The
disease is usually mild, and no chronic state is recognized except in immunocompromised
persons. However, it may be serious in pregnant females with up to 20 percent mortality.
Treatment is primarily symptomatic, although the antiviral agent ribavarin has shown some
effectiveness in clearing the infection. There is no commercially available vaccine yet but trials
are underway. Immunoglobulin has not proven effective.
Skin and soft tissue infections resulting from injuries in the aquatic (fresh and salt water)
environment are not uncommon. Many species of “common bacteria” such as E. coli, Klebsiella
pneumoniae, Proteus sp., Psuedomonas aeruginosa, Staphylococcus sp. and Streptococcus sp.
can cause skin and soft tissue infection after an injury resulting in pyodermas, impetigo and
erysipelas. However, some more unusual bacteria can cause severe or prolonged skin and soft
tissue infections. These are presented in Table 2 below.
Table 2. Marine Bacteria Causing Human Skin and Soft Tissue Infections
Aeromonas hydrophila
Chromobacterium violaceum
Comamonas sp.
Edwardsiella tarda
Erysipelothrix rhusiopathie
Mycobacterium abscessus
Aeromonas hydrophila
Chromobacterium violaceum
Comamonas sp.
Edwardsiella tarda
Erysipelothrix rhusiopathie
Mycobacterium abscessus
Mycobacterium fortuitum
Mycobacterium marinum
Shewanella sp.
Streptococcus iniae
Vibrio alginolyticus
Vibrio cincinnatiensis
Vibrio damsela
Vibrio metchnikovii
Vibrio vulnificus
Adapted from Diaz 2014 and Diaz and Lopez 2015
In addition to the bacteria found in the aquatic environment, there are other potentially infectious
organisms that could be associated with the sharing of diving equipment due to contact with the
sputum of an ill person. Among these bacteria are the causative agents of tuberculosis
(Mycobacterium tuberculosis, which is readily liberated in the expelled air of clinically ill
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individuals) and Pseudomonas aeruginosa (an opportunistic bacterium associated with otitis
externa and other potentially serious infections).
The following subsections briefly discuss the more important bacterial pathogens associated with
aquatic environments and operations, including Aeromonas, Campylobacter, Erysipelothrix,
Mycobacterium, Pseudomonas, Vibrio, Salmonella, Leptospira, Legionella and fecal coliform
bacteria.
3.1.2.1 Aeromonas
Aeromonas species are gram-negative rod-shaped bacteria found as natural inhabitants of
freshwater, where they are responsible for infection among cold-blooded animals (e.g., frogs,
snakes, alligators). They can survive in both fresh and salt water, and have been isolated from
many harbor waters. The motile species – i.e., A. hydrophila, A. caviae and A. sobria – are
associated with human diseases such as soft tissue infections and gastroenteritis by either
penetrating trauma or ingestion, aspiration may result in respiratory infection and septicemia
(blood poisoning). Puncture wounds contaminated with Aeromonas can develop cellulitis within
8 hours, with erythema (reddening), edema (swelling) and a purulent discharge (pus). Localized
pain is considerable; fever, chills and lymphangitis (inflammation of the lymph nodes) may
occur. Aeromonas infections are treatable with a variety of antimicrobials; therapy for serious
infections should include a combination of an aminoglycoside and either a fluoroquinolone or
third- or fourth-generation cephalosporins until culture and antibiotic sensitivities are reported.
3.1.2.2 Campylobacter
Campylobacter species are found worldwide as commensals (intestinal symbionts) in a large
number of wild and domestic animals. Species responsible for human infection include C. jejuni,
which has the broadest animal reservoir; C. coli; and C. fetus. Outbreaks of disease have been
associated with the consumption of contaminated food or water, and the fecal-oral route has been
implicated in person-to-person spread. The disease is diagnosed more often in children than
adults, and may account for about 9 percent of all diarrheal cases. Several clinical forms of C.
jejuni disease exist, from the most common enteritis (of one to seven days’ duration with fever,
headache, abdominal pain and diarrhea) to an acute colitis with fever, abdominal cramps, and
bloody diarrhea. C. fetus presents less often with enteric disease, more often as an acute
bacteremia. Most C. jejuni infections are self-limiting; effective antibiotic therapy is available.
3.1.2.5 Legionellae
Legionellae are the causative bacteria of legionellosis and Pontiac fever. The Legionellae are
composed of at least 48 species, although about 70 percent of human infections are due to L.
pneumophila. Legionnaires’ disease has been reported worldwide, both as endemic outbreaks
and sporadic cases. The natural habitat for the Legionella bacterium is water, including ponds,
lakes, water cooling towers, showers, nebulizers, whirlpools, etc., with transmission occurring
primarily from inhalation of contaminated aerosols. The bacterium can survive and multiply in
tap water for longer than one year; hyper-chlorination is required for microbial inactivation. This
opportunistic pathogen generally afflicts people with specific risk factors (e.g., elevated age,
smoking, alcohol consumption). Two distinct clinical conditions have been described: (1)
Legionnaires’ disease, a lower respiratory illness that can lead to systemic disease, with
extensive pulmonary involvement, respiratory failure, and death; and (2) Pontiac fever, a self-
limiting influenza-like illness without pneumonia. No vaccine is available; antibiotic therapy is
recommended for Legionnaire’s disease.
3.1.2.10 Salmonella
Salmonella species found as waterborne pathogens may cause three distinct clinical diseases:
Salmonellae can survive in seawater for several weeks. Several thousand serotypes of
Salmonella exist; the most relevant serotypes associated with human infections are:
3.1.2.12 Vibrio
Vibrio species are ubiquitous inhabitants of both saltwater and freshwater, with at least 34
identified species, 11 of which are human pathogens. The majority of human infections are
generally caused by the following three species:
• V. cholerae
• V. parahemolyticus
• V. vulnificus
The Vibrio species primarily responsible for gastroenteritis resulting from fecal-oral transmission
or ingestion of polluted water include:
• V. cholerae
• V. parahemolyticus
• V. mimicus
• V. hollisae
• V. fluvialis
• V. fournissais
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The Vibrio species responsible for soft-tissue infections, otitis and sepsis resulting from
penetrating trauma or contact include:
• V. vulnificus
• V. alginolyticus
• V. damsela
• V. metchnikovii
• V. cincinnatiensis
Although vibrios do exist naturally in the aquatic environment, the contribution of fecal
contamination from infected people and carriers is difficult to ignore in endemic and epidemic
regions of the world, especially where sanitation is inadequate or absent.
1. Wound infections, typically from contact with brackish water while harvesting oysters or
handling of shellfish. These infections, either from the contamination of pre-existing
wounds or injury in the marine environment, may become edematous (swollen) and
erythematous (red) within hours, accompanied by lymphadenopathy. Intense pain occurs
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at the infected site, with fever, chills and nausea; complications, especially in persons
with underlying disease like diabetes or immunosuppression, can result in a fatality rate
of 7-22 percent. Mechanical protection using puncture-resistant gloves is highly
recommended in these environments. Antibiotic treatment should be administered
promptly should signs of infection occur.
2. A primary septicemia, with malaise, fever, chills, vomiting, diarrhea, prostration and a
mortality rate of 50 percent, especially among people with pre-existing liver disease who
consume raw seafood. Antibiotic treatment should be administered promptly.
3. An acute, self-limiting diarrhea from the consumption of raw seafood.
3.1.3 Fungi
The most common fungal infections associated with the aquatic environment are the
dermatophytoses, caused by a large group of fungi collectively known as dermatophytes or
“ringworm” fungi. Another less frequently encountered fungal infection associated with polluted
waters is pseudallescheriasis.
3.1.4 Algae
3.1.4.1 Protothecosis
Protothecosis is an uncommon algal infection caused by two species of the genus Prototheca,
namely P. zopfii and P. wicker hamii. Although rare, cases have been reported from all regions
of the world, including the southeast United States. Species of Prototheca have been isolated
from both marine and fresh water; aquatic sediments; soil; and foods contaminated with polluted
water, soil, or animal feces. Infections involve the soft tissues of the extremities resulting from
penetrating trauma and exposure of existing lesions with contaminated water or soil. The course
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of infection is extremely indolent (slow to occur), lasting months or years, with little evidence of
self-healing. Surgery and antifungal medications have been used to treat cutaneous lesions.
3.1.5 Parasites
Various human and animal parasites are found as contaminants of both marine and fresh waters
worldwide. The majority of parasitic infections from exposure to the aquatic environment are the
result of contact with or ingestion of fecal contaminated water or food. The subsections below
briefly discuss some of the more important parasitic infections of humans that are associated
with fecal polluted water: amoebiasis, giardiasis, schistosomiasis and cryptosporidiosis.
Information on amoebic meningitis, a serious waterborne disease caused by exposure to free-
living pathogenic amoebae, is also presented.
3.1.5.1 Cryptosporidium
Cryptosporidium hominis and C. parvum are the protozoan parasites responsible for
cryptosporidiosis, which is transmitted by contact and through the ingestion of contaminated
water. Outbreaks and epidemics have been reported, with fecal-oral transmission implicated.
Animals can act as reservoirs. Clinical symptoms include watery diarrhea, fever, abdominal pain
and anorexia. The parasite is found worldwide, with normal water chlorination proving
ineffective in its destruction. Treatment is supportive and includes rehydration therapy and
maintenance of proper electrolyte balance. Antiparasitic therapy is available.
3.1.5.5 Schistosoma
Schistosoma species, including S. haematobium, S. mansoni and S. japonicum, have been
recognized as human parasites since antiquity. The clinical disease schistosomiasis occurs
worldwide in tropical regions of Africa, the Caribbean, South America, the Middle East,
Southeast Asia and India. More than 200 million people worldwide are infected. The larval fluke
(worm) responsible for schistosomiasis is transmitted from contaminated freshwater to humans
by penetrating the “unbroken” skin; a freshwater snail acts as the intermediate host. After
penetration, the larvae mature and the host experiences a rash, fever, malaise, cough, abdominal
pain and nausea; bloody diarrhea and enlargement of the liver can occur. The deposition of
human waste in bodies of water containing the intermediate snail host is the single most
important epidemiologic finding. Antiparasitic treatment is available.
3.2 Dermatoses
Various microscopic and macroscopic aquatic animals are responsible for dermatologic problems
among persons exposed to aquatic life while swimming, wading or diving in fresh or seawater.
Several of the more important organisms associated with dermatologic reactions in humans are
discussed below.
3.2.1 Cymothoidism
Cymothoidism, or sea louse dermatitis, is caused by the bite of free-swimming crustaceans or
cymothoids, i.e., sea lice that live as parasites on invertebrates and fish. They are found in the
shoal waters of both tropical and temperate shorelines, where they are buried in the sandy
bottom. The cymothoids will attack any organism near their domain, including humans. Sea lice
can quickly attach to any prey and inflict sharp bites that result in hemorrhagic wounds.
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(Revision 1.4, December 19, 2016)
Appendix L-19
Cymothoids are commonly found along the southern California coast. Wounds should be
cleansed with soap and water and an antibiotic ointment should be applied.
Shellfish allergies are often associated with ingestion of shellfish, but can also result from
contact with shellfish in the environment. Aquatic workers, divers and dive masters should be
aware of severe allergies that coworkers under their supervision may have, such as fish or
shellfish allergies. Workers with these types of allergies should be required to have EpiPens or
other countermeasures onsite in case of allergic reaction. They should also be required to wear
gloves and take whatever protective measures are needed to avoid contact with potential
allergens.
3.3 Intoxications
Dinoflagellates in the aquatic environment produce many toxins that may cause severe illness in
humans; most are the result of ingestion of the toxin. In addition, dinoflagellate toxins
bioaccumulate in filter-feeding marine animals such as oysters and clams. Consumption of
contaminated oysters and other marine animals, especially raw, can cause intoxication, with
symptoms ranging from numbness of the extremities, headache, nausea, vomiting and diarrhea in
milder cases to muscle paralysis, respiratory distress, memory impairment and, occasionally,
death in severe cases.
Exposure of divers and other personnel engaged in marine operations most often occurs through
the inhalation of aerosolized dinoflagellate toxins. The unarmored dinoflagellate Karenia brevis
U.S. Environmental Protection Agency
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(Revision 1.4, December 19, 2016)
Appendix L-21
(previously Ptychodiscus brevis) is associated with “red tide” outbreaks, with fish kills and
human exposures taking place during algal blooms. Ocean waves tend to lyse the dinoflagellates,
thereby releasing the toxin which can become airborne along coastal areas. The released toxins
possess both a hemolytic and a neurotoxic effect. Symptoms of respiratory exposure include
conjunctivitis, rhinitis (runny nose), bronchitis, and respiratory irritation. The use of respiratory
protection and goggles should limit exposure. Treatment is symptomatic.
3.4 Envenomations
Many varieties of aquatic animals can envenomate divers and other workers while engaged in
marine and fresh water operations. Both vertebrate and invertebrate animals can be involved in
envenomation, using different mechanisms and producing different toxins. Preventative
measures, including wearing wet and dry suits, hoods, gloves, and covering exposed skin, should
be emphasized for divers and aquatic workers to help avoid exposure.
While envenomations have rarely led to systemic symptoms and death, reactions to the sting
from the clinging jellyfish (Goniomemus sp.) in New England waters have caused respiratory
distress in divers and required hospitalization.
The DAN website contains up-to-date, comprehensive information on first aid for exposure to
nematocysts at http://www.diversalertnetwork.org/health/hazardous-marine-life/portuguese-man-
of-war. Poison centers are also sources for updated treatment; they can be reached at 1-800-222-
1222.
Irukandji syndrome results from small box jellyfish found near Australia, Carukia barnesi and
Malo kingi, and is responsible for an extremely painful symptomatic complex. These small
cubozoans’ bells measure only a few millimeters, but their tentacles are up 3 feet (1 meter) long.
Deaths from these smaller species are rare, but stings are extremely painful and can cause
systemic symptoms including cardiovascular instability that require immediate medical attention.
3.4.1.2 Echinoderms
Echinoderms, including starfish (or sea stars) and sea urchins, possess hard exoskeletons with
spines that can easily penetrate the human skin, even muscular layers or joints. Sea urchins are
probably the most imminent threat to divers. Most of them do not have any specific venom, but
puncture wounds can cause a variable degree of pain, redness and swelling. In some cases,
muscle weakness and paresthesias (i.e., sensations of burning, prickling or formication) may be
present, particularly on long-spined species of the genus Diadema. Cardiac arrhythmias and
other severe reactions are rare. The decision of whether to remove spines surgically is usually
based on joint or muscular layer involvement and whether there is pain with movement or signs
of infection. Spines will usually encapsulate in a short time, but they may not always dissolve. A
reactive granuloma is a common reaction to remaining small foreign bodies. Do not attempt to
remove spines embedded deeper in the skin; let medical professionals handle those. Deeply
embedded spines may break down into smaller pieces, complicating the removal process.
Ancillary treatment is supportive.
The DAN website contains up-to-date and comprehensive information on first aid for exposure
to sea urchin spines at http://www.diversalertnetwork.org/health/hazardous-marine-life/sea-
urchins.
The blue-ringed octopi are a small, venomous species that live in tropical tide pools from south
Japan to the coastal reefs of Australia and the western Indo-Pacific. These small octopi are the
only cephalopods known to be dangerous to humans. Treatment for mollusk envenomation is
primarily supportive.
3.4.1.4 Polychaetes
Several species of polychaete marine roundworms have biting jaws with venom glands. Bites can
cause swelling, pain and erythema (reddening), with spontaneous healing in several days. Some
species – called bristle worms – have bundles of bristles, called setae, on their sides that
resemble fiber optics. Contact with these bristles can result in localized numbness, redness and
moderate swelling that can be followed by vesiculation (blisters). Treatment is symptomatic.
Envenomations are associated with immediate and intense pain at the puncture site. Bleeding
from the penetrating wound is usually proportionate to what one would expect for the location.
Associated symptoms may include nausea and vomiting. Weakness, respiratory distress,
convulsions and numbness are rare. Deaths are very rare, and perhaps only from species of stone
fish (Synanceja verrucosa, S. horrida) and stingrays. Treatment of stung limbs involves
immersion of the limb in hot water (110-120°F/43-49°C) for 30-60 minutes. All embedded
spines, barbs or other foreign materials must be removed from the injured site. Antibiotics and
tetanus toxoid should be administered to patients stung by stingrays or fish, where larger
penetrating wounds are encountered. Antivenom is available for stonefish envenomations.
Supportive therapy is generally adequate.
Some venomous terrestrial snakes, such as the water moccasin (Agkistrodon piscivorous), also
like to live near water bodies.
The DAN website contains up-to-date and comprehensive information on general treatment
principles for vertebrate marine envenomations at http://www.alertdiver.com/?articleNo=491.
Many species of sharks have attacked divers and swimmers in temperate and tropical waters
around the world, inflicting severe and fatal injuries. Other potentially dangerous marine and
freshwater animals include barracudas, moray eels, alligators and crocodiles, electric eels,
piranhas, and several non-venomous snakes such as the brown water snake.
Some mammals may also be dangerous for humans, including the orca and sea lion. All wounds
from these animals should be thoroughly debrided; rabies prophylactic vaccination should be
considered.
Table 4 lists zoonotic infections from marine mammal encounters, while Table 5 presents
zoonotic infections transmitted from fish, amphibians and reptiles.
The DAN website contains a medical guide to handling interactions with marine creatures:
http://www.alertdiver.com/Bites_and_Attacks_.
Chapter 16 in the NOAA Diving Manual (NOAA 2017) describes hazardous aquatic animals,
identification of signs and symptoms, as well as treatment options.
Thus, risk reduction is the key. By understanding the biohazards present in the aquatic
environment, we can minimize or prevent exposure to these biohazards. Through the deployment
of a hierarchy of exposure control measures generally understood and accepted in the
management of biohazards – namely engineering practices, good work habits, medical
surveillance and prophylactic vaccination, and the use of appropriate protective equipment and
apparel – risk can be reduced.
The most important preventive strategy to avoid occupational disease while conducting aquatic
operations is “exposure control.” When conducting diving operations in known polluted waters,
the need for optimal protection from exposure to these waters is indicated. All body parts must
be protected by diving apparel, and extreme care must be exercised to avoid mucous membrane
and oral exposure to even minute quantities of water.
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DIVING SAFETY MANUAL
(Revision 1.4, December 19, 2016)
Appendix L-27
This section emphasizes good work habits, in conjunction with medical monitoring and the use
of personal protective equipment, to control and prevent exposure.
How long to wait to dive after a runoff event depends on many factors, including the flushing
rate of the water body and the type of dive gear being used (i.e., whether it includes a fully
encapsulating dry suit and full-face mask).
EPA maintains a website that allows the public to determine if beach areas are closed now or
have been closed in the past. The site can be found at https://www.epa.gov/beaches/find-
information-about-your-beach.
In general, when divers have open lesions or other wounds, they should not dive. However,
simple skin lesions can be treated with a petroleum-based antibiotic ointment and covered. The
wound should be thoroughly cleaned after the dive, with removal of all dressings and
medications.
Abrasions and open wounds can occur when certain body parts – e.g., the toes, knees, wrists and
axillae – chafe against the seams and collars of diving suits. Wearing a full-body skin under the
diving suit can prevent chafing.
In more contaminated environments, a dual or quad exhaust regulator (typical of a diving helmet
directly mated to the suit) or even exhaust to the surface may be necessary to fully control this
pathway.
Upper respiratory infections tend to swell the passages of the eustachian tube and the sinuses;
diving under these conditions can cause barotraumas of the sinuses or the middle ear. Pre-
existing lower respiratory infections can lead to pulmonary barotraumas and serious injury due to
mucous plugging of the small airways, thereby preventing the escape of air during ascent.
Anyone experiencing systemic illness should refrain from diving until fully recovered.
In addition, people who have underlying diseases or are immunocompromised are significantly
more susceptible to serious and life-threatening infection upon exposure to the aquatic
environment. Waterborne microorganisms can cause serious respiratory disease when the
normally sterile lung is contaminated through near-drowning or accidental aspiration of polluted
water.
Residues left on diving equipment from cleaning, decontamination and/or disinfection may cause
allergic responses or skin irritation. Thoroughly rinsing equipment should prevent these
problems.
Important exposure control measures to consider when collecting aquatic materials include the
complete avoidance of water potentially contaminated with pathogenic microorganisms. Workers
who must be exposed to these waters must use protective apparel that covers all exposed body
parts. All used protective apparel must be discarded in appropriate biohazard containers if
disposable, or properly decontaminated if it is to be reused. Since most collection will be done
with the hands, protective gloves and vigorous hand-washing are important principles of
infection control; topside personnel must also take these precautions where collected specimens
and sediments may be handled, processed and discarded.
In general, many persistent biological and chemical contaminants tend to concentrate in sediment
rather than in the water column (Hendrick et al. 2000; Hoffman et al. 2003; U.S. Navy 2004).
Therefore, simply avoiding contact with the sediment by remaining above it and taking care not
to suspend sediment inadvertently by finning action may reduce the diver’s potential exposure.
Among the vaccines that are recommended for all personnel engaged in diving and other aquatic
operations are those developed against the viral infections that cause hepatitis A, hepatitis B and
poliomyelitis, and against bacterial infections that cause typhoid fever, cholera and tetanus. In
addition, when workers are engaged in marine operations in semi-tropical and tropical waters –
especially where insect vectors of various viral, rickettsial, bacterial and parasitic diseases are
present – the need for additional vaccines, prophylactic medications and insect repellents needs
to be considered. If the diver may be operating in bat-infested caves, then consider prophylactic
rabies vaccination. If the diver is operating in a situation that may involve exposure to
bioterrorism agents, then other vaccinations are available for certain agents such as anthrax and
smallpox. More information on bioterrorism agents and diseases can be found at the CDC
website (https://emergency.cdc.gov/agent/agentlist.asp).
When an exposure to infectious agents is suspected, the exposed areas need to be thoroughly
cleansed and the worker monitored for the onset of clinical symptoms.
The exposure of diving personnel to the residual blood or body fluids of other divers (e.g., during
use of shared diving equipment) needs to be addressed through training described below and
must include information on the risk of hepatitis B, hepatitis C and HIV.
For all occupational exposures, employees involved in diving and other operations need to be
monitored periodically until the injury has healed or recovery from infection or illness is
complete. Diving personnel may need to be restricted from diving operations until the medical
provider deems it safe for the employee to resume diving.
EPA’s Scientific Diver and Dive Master Training, as well as required field safety training,
provide instruction on these topics. In addition, the DAN provides training that includes
bloodborne pathogens and hazardous marine life injuries and first aid. The curriculum for these
courses is available at https://www.diversalertnetwork.org/training/.
Other health and safety training required for field workers or provided as a part of the EPA
Scientific Diver Training includes:
Scientific Dive Units may also consider additional regional training on:
Diaz, J.H. 2014. Skin and Soft Tissue Infections Following Marine Injuries and Exposures in
Travelers. Journal of Travel Medicine, 21:207-213.
Diaz, J.H., and F.A. Lopez. 2015. Skin Soft Tissue and Systemic Bacterial Infections Following
Aquatic Injuries and Exposures. American Journal of Medical Sciences; 349:269-275.
Hendrick, W., A. Zaferes and C. Nelson. 2000. Public Safety Diving. Fire Engineering Books &
Videos. Saddle Brook, New Jersey.
Heymann, D.L. 2014. Control of Communicable Diseases Manual. 20th edition. American Public
Health Association. APHA Press, Washington, D.C.
Hoffman, D.J., B.A. Rattner, G.A. Burton Jr. and J. Cairns Jr. 2003. Handbook of Ecotoxicology.
2nd edition. Lewis Publishers, CRC Press LLC, Boca Raton, Florida.
Melnick, J.L., C.P. Gerba and C. Wallis. 1978. Viruses in Water. Bulletin of the World Health
Organization, 56(4):499-508.
NOAA (National Oceanic and Atmospheric Administration). 2017. NOAA Diving Manual:
Diving for Science and Technology. 6th edition. United States Department of Commerce. David
Dinsmore, editor. Best Publishing Company, Flagstaff, Arizona.
Otten, T.G., and H.W. Paerl. 2016. Best Practices for Cyanobacterial Harmful Algal Bloom
Monitoring. Chapter 3.1.2 in: Manual of Environmental Microbiology. 4th edition.
U.S. EPA (Environmental Protection Agency). 2016. Standard Operating Procedures for Diver
Decontamination. Appendix Q in: EPA Diving Safety Manual. Revision 1.3. Prepared by S.
Grossman, A. Humphrey, J. McBurney and S. Sheldrake.
Waltzek, T.B., G. Cortes-Hinojosa, J.F. Wellehan Jr. and G.C. Gray. 2012. Marine Mammal
Zoonoses: A Review of Disease Manifestations. Zoonoses and Public Health, 59:521-535.
PMCID: PMC2395640.
Yates, M.V. 2016. Drinking Water Microbiology. Chapter 3.1.7. in: Manual of Environmental
Microbiology. 4th edition.
U.S. Navy (United States Navy). 2004. Guidance for Diving in Contaminated Waters. Technical
Manual #SS521-AJ-PRO-010. Naval Sea Systems Command, Washington Navy Yard,
Washington, D.C.
Antibiotics: Also called antibacterials, a type of antimicrobial drug used in treating and
preventing bacterial infections. Includes aminoglycosides, fluoroquinolones, cephalosporins,
penicillins, tetracyclines, to name a few.
Enteric bacteria: Bacteria arising from the intestinal tract, primarily gram-negative organisms
(e.g., E. coli) but also gram-positive (e.g., enterococci).
Envenomation: Poisoning.
Erysipelas: An acute infection, typically with a skin rash. Usually caused by Streptococcus
bacteria on scratches or otherwise infected areas.
Erythema: Reddening.
Macular or maculopapular rash: A type of rash characterized by a flat, red area on the skin that
is covered with small confluent bumps.
Memorandum of Agreement on
EPA's Diving Safety Program
Appendix N-1
EPA MEMORANDUM OF AGREEMENT
BETWEEN THE
SAFETY, HEALTH AND ENVIRONMENTAL
ENVIRONMENTAL MANAGEMENT
MANAGEMENT DIVISION
DIVISION
AND
DIVING SAFETY BOARD
Background
Purpose
Roles
Responsibilities
1.
1. Attending
Attendingannual
am1Ual DSB
DSB meetings
meetings
2. Maintaining
2. Maintainingheadquarters
headquartersreports
reportsofofthe
theDiving
DivingSafety
SafetyProgram,
Program,including:
including:
(a) DSB annual
aImual reports
reports
(b) Audit reports
3.
3. Recommending
Recommendingchanges
changesininpolicy
policytotothe
theDSB
DSB
Roles
The DSB has autonomous and absolute authority over EPA's EPA's Diving
Diving Safety
Safety Program's
Program 'sscientific
scientific
operations. All
Allrecommendations
reconm1endationsfor forrevisions
revisions of
ofthe
thepolicy,
policy,diving
diving rules,
rules,or
orother
other requirements
requirements
associated with this program
program must
must be
be agreed
agreed upon
upon byby consensus
consensus of
ofthe
thevoting
votingmembers
membersofofthe the
DSB.
DSB . As determined by by the
the DSB
DSB Chairman,
Chairman, all
all voting
voting members
members ofofthe
theDSB
DSBwill
willbe
bepolled
polledififthe
the
business at hand can
can be
be delayed,
delayed, and
and the
the absent
absent vote(s)
vote(s) would
woulddetermine
determinethe thedecision.
decision.
Responsibilities
1. Recommending policy
policy and
and changes
changes in
in operating
operatingprocedures
procedureswithin
withinEPA
EPAtotoensure
ensureaasafe
safe
and efficient Diving Safety
Safety Program
Program
2. Reviewing existing
existing policies,
policies, procedures,
procedures, and
and training
training needs
needs to
to ensure
ensureaacontinually
continuallyhigh
hi gh
level of
of technical skills
skills and
and knowledge
knowledge throughout
tlu-oughoutthe
the Diving
DivingSafety
SafetyProgram
Program
3. Planning,
Plam1ing, programming,
programming, and and directing
directing policy
policy pertaining
pertainingto to the
theinitial
initialcertification
certificationofofnew
new
divers and refresher training
training of
ofexperienced
experienced divers
divers in
in cooperation
cooperationwith
withthe
theDiving
DivingSafety
Safety
Program's
Program 's Technical
Teclmical and
and Training
Training Directors
Directors
4. Approving changes
changes in
in operating
operating policy
policy
5. Serving as an appeal board
board in
in cases
cases where
where aa diver's
diver'scertification
certificationhas
hasbeen
beensuspended
suspended
6. Planning,
Plam1ing, programming,
programming, and
and directing
directing diver
diver workshops,
workshops, seminars,
seminars,and
andother
otheractivities
activities
considered essential to
to maintaining
maintaining aa high
high level
level of
ofcompetency
competencyand
andsafety
safetyamong
amongdivers
divers
7. Reviewing EPA diving
diving accidents
accidents or
or potentially
potentially dangerous
dangerousincidents
incidentsand
andreporting
reportingon
on
preventive measures
measures to
to ensure
ensure safe
safe diving
diving
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, 2016)
Appendix N-4
-3-
Duration of Agreement
1/2 //1 ()
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U.S. Enviro erlall
U.S. Enviro e Protection
ProtectionAgency
Agency (Date)
Wesley 1.
J. Carpenter, Acting Director
Director
Safety, Health and Environmental
EnvirolID1entai Management
Management Division
Division
.S.
.S. Environmental Protection Agency
CL30V--- J..{/z-z/(O
,
(Date)
7
CONTENTS
1.0 OBJECTIVE
2.0 APPLICABILITY
3.0 DESCRIPTION
4.0 RESPONSIBILITIES
4.1 Divemaster
4.2 Diver
4.3 Stand-by Diver
4.4 Dive Tender
4.5 Surface Supply Control Box Operator
5.0 REFERENCES
This standard operating procedure (SOP) states the United States Environmental Protection Agency
(USEPA) policy concerning surface supplied diving operations. Procedures for general dive operations are
specified the USEPA Diving Safety Manual. This SOP in not intended to be a substitute for actual hands-on
training.
2.0 APPLICABILITY
Surface supplied diving applies to diving operations during which divers are supplied with breathing gas
through an umbilical hose from the surface. These procedures apply to EPA employees and contractors
working directly for EPA, that are engaged in surface supplied diving operations. This SOP presumes and
requires prior training and experience with surface supplied diving.
NOTE: The need for the use of surface supplied systems should be carefully considered when planning for
dive operations. Further, the dive planning and preparation process should consider risk management analysis
when evaluating the need for surface supply systems. Surface supplied diving is not an operational necessity
in much of EPA diving. Employment of this equipment should be carefully assessed with regard to safety,
operational efficiency, and the technical requirements of the dive site. The benefit to be gained in conducting
the dive must be weighed against the added burden (physical and psychological) placed on the diver. The
diver should acknowledge and accept the risk that his primary air supply is under the control of the surface
operator. In addition, there may be an increased risk of entanglement.
3.0 DESCRIPTION
All divers must be dive certified and medically qualified to perform their diving duties, as specified
in USEPA Diving Safety Manual.
Each component of a diver’s equipment shall be maintained in a safe operating condition, and shall
be inspected, tested, serviced and logged as specified in the USEPA Diving Safety Manual. All
appropriate safety equipment shall be available at the dive site as specified in the Dive Safety Plan
and USEPA Diving Safety Manual.
3.3 Documentation
Project-specific Dive Plans and Dive Safety Plans shall be issued prior to performing dive
operations, and all dives shall be logged as specified in the USEPA Diving Safety Manual. The
Unit Dive Officer (UDO) shall maintain logs of each diver’s certifications, medical clearance to
dive, and all health and safety training (e.g., cardiopulmonary resuscitation [CPR], first aid and
oxygen administration) as specified in the USEPA Diving Safety Manual.
The breathing gas may be air or enriched air (e.g., nitrox up to 40% oxygen) depending on
the planned dive profile, if the control box and umbilicals are approved by the manufacturer
for that usage and/or have been oxygen cleaned. Gas may be supplied by means of
pressurized tanks, low pressure/high volume compressors or a compressor/tank system.
All breathing gases must be either generated on-site with a compressor, or purchased
through a reputable dive shop or commercial gas supplier. Dive shops and commercial
suppliers are required to have their breathing gas analyzed for impurities regularly.
Compressor-generated breathing gas is also required to be analyzed to CGA grade E
standards at least once every six months. Dive operations shall not be initiated unless there
is a sufficient supply of breathing gas for all divers, including stand-by divers and
emergency reserve.
3.4.1.2 Compressors
All breathing gas compressors must be properly maintained, with regularly logged
maintenance records. Compressors must be capable of supplying breathing gas
at a satisfactory volume (at least double the volume required) and pressure (at
least 25% greater than the maximum pressure requirement anticipated) for the
number of divers potentially supplied at the deepest depth potentially encountered
at a work site.
Surface supplied control boxes are capable of running two divers simultaneously on
separate umbilicals, and can accept breathing gas either from compressed gas cylinders
(working pressure can range from 3,000 pounds per square inch [psi] to 3,500 psi; check
the manufacturer specifications for details) or from a low pressure/high volume
compressor. Air is the only breathing gas approved by some manufacturers for use with
their control boxes without special cleaning, while other manufacturers allow the use of
Nitrox mixes up to 40%. One should check the specifications of their control box before
using Nitrox.
These boxes typically have an internal rechargeable 12-volt gel cell battery that must be
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, April 15, 2016)
Appendix O-4
charged prior to dive operations, and indicator lights that indicate the battery charge level.
The box requires very little power, and a fully charged battery should last for up to 20 hours
of continuous service. If the unit does not show full charge (all indicator lights lit) after an
overnight charge, the battery may need to be replaced.
While using the control box plugged into an electrical source is possible, some
manufacturers cautions the user to never connect the charger during a dive due to the
potential of electrical shock to the diver.
The surface supplied control box must be operated by a qualified technician. When there
are one or more divers in the water on surface supplied air, the box operator can have no
duties other than monitoring the breathing gas supply to the diver, maintaining
communications with the diver, and logging the diver’s bottom time and depth.
Surface supply umbilicals provide breathing gas, communications, the diver’s depth and a
strength member between the tender and the diver. Diving umbilicals may either be the
sinking or floating type. The sinking type is negatively buoyant and more likely to snag
on bottom obstructions or disturb contaminated sediments. The floating type is positively
buoyant and more likely to be affected by surface current or vessel traffic. The buoyancy
of the umbilical can be modified in the field by adding floats or weights as required.
Decontamination compatible floating umbilicals, ranging in length from 150 to 300 feet
are typically used. The umbilicals are typically comprised of three separate spiral-wound
hoses, although straight (not spiral wound) hoses may be utilized as well in order to use
components separately if needed. This smooth polyurethane umbilical and twists, rather
than tape, is ideal for operations in potentially contaminated water because it can be
effectively decontaminated.
The primary hose is the diver’s breathing gas supply hose, which runs between the surface
supply control box and the diver’s emergency manifold block (see Section 3.4.4).
The breathing gas supply hose should be rated to a working pressure of at least 300 psi.
The hose is typically 3/8 inch inside diameter, but some lightweight systems may utilize a
1/4 inch diameter breathing gas hose. To ensure a sufficient air supply, users should be
aware that the diameter of the breathing gas supply hose may restrict the safe operation of
the system at greater depths, umbilical lengths, or breathing rates. The manufacturer should
be consulted to identify any possible limitations of the breathing gas system (Dive Lab
Surface Supply Breathing Requirements and Recommendations for Kirby Morgan Helmets
and Band Masks, 2008).
The second component of the umbilical is the diver’s hard-wired communication line (com
line), which allows open, two-way communication between the diver and surface support
personnel. The com line runs between the surface supply box and the diver’s mask-
integrated communication system (microphone and earphones). The com line is usually
also equipped with a strength member capable of towing or lifting many times the diver’s
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
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Appendix O-5
weight. The hard-wired umbilical may be eliminated if using a reliable wireless comm.
system, although a strength member is still required.
The third component of the umbilical is the pneumofathometer (pneumo) hose, a gas line
that is open on the diver’s end. The 1/4 inch inner diameter pneumo runs from the surface
supply control box down to the diver, with its open end attached in the area of the diver’s
chest. The pneumo line is a simple capillary tube type of depth gauge, which allows surface
personnel to monitor the diver’s depth. The control box operator can open the pneumo
valve to blow gas through the pneumo hose, and when the valve is closed, the water
pressure will back up the hose allowing the pneumo gauge to read depth. In some instances,
the diver can also use the pneumo as a tool to inflate a lift bag or to blow sediment out of
a small work area. In the event of an emergency, some manufacturers suggest the diver
can also use the pneumo as an alternative breathing gas supply. The pneumo hose may be
eliminated in situations where the diver monitors and controls his/her own depth and dive
profile with a depth gauge or dive computer.
For polluted water diving, configuration of the umbilical on the vessel should allow for
easy decontamination of the hose in the “hot zone.” Moving the umbilical into the
contamination reduction zone should be avoided.
The diver’s harness-mounted manifold block typically has two ports for attachment of
incoming gas supply, one port for the dry suit inflator hose, one port for attachment of the
breathing regulator, and two low pressure ports for auxiliary equipment. The primary
incoming port is for attachment of the umbilical breathing gas line. This port must have a
functioning non-return valve to ensure that a loss of umbilical line pressure, combined with
depth pressure, won’t suck the gas out of the diver’s lungs or out of the emergency gas
supply tank. This ensures that in the event of umbilical air supply loss, the diver will
receive air from the emergency gas supply (EGS). Prior to attaching the umbilical hose to
the manifold block, the non-return valve should be tested by pressurizing the EGS and
checking for any air leakage past the non return.
The second incoming port on the manifold block is for attachment of the emergency gas
supply (A “bail-out” bottle).
In the event of a loss of air from the surface, the manifold block has a knob that the diver
turns to open the EGS. At the start of the dive, the knob must be in the closed position
(fully turned clockwise). During the dive the diver should periodically confirm the knob
is fully closed and the submerged pressure gauge (SPG) for the EGS is full. It should be
noted that as little as a quarter turn may begin depleting the EGS. All divers must be aware
of the operation and placement of the manifold block, so they can find it in an emergency.
No other equipment may block the diver’s access to the knob.
While dive planning must involve provision of sufficient air for the dive operation
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including ascent and exigencies, independent emergency breathing gas (EGS) must also be
provided for all surface supplied diving operations. The size of the bail-out bottle is
determined based upon the type of water, i.e. contaminated vs. non-contaminated, working
depth, type of equipment, i.e. FFM vs. helmet and the air consumption rate of the individual
diver. The bail-out bottle is typically mounted with the valve down which allows the diver
to turn the tank valve on, should the knob be inadvertently closed. The larger the bail-out
bottle, the longer the diver has to surface in the event of a loss of surface supplied gas. The
deeper the diver is working and the more potential hazards present, the larger the bail-out
bottle required. A SPG for the EGS must be accessible to the diver at all times. The first-
stage regulator on the pony bottle must have an over-pressure relief valve.
Sometimes it is necessary to fill the bail-out bottle in the field. In those instances, a filling
whip (a length of high pressure air hose with tank yoke fittings on both ends) is used to
connect the bail-out bottle to a full SCUBA tank. The empty bail-out bottle valve should
be completely opened, and then the full SCUBA tank valve should be opened very slowly
so that the bail-out bottle does not heat up. Depending on the size of the bail-out bottle, it
may be necessary to use several SCUBA tanks to get a satisfactory fill (greater than 2500
psi).
EPA divers typically wear a full face mask (FFM) when using surface supplied gas, but
diving helmets may also be used. Both the FFM and the helmet are equipped with
communication equipment (microphones and earphones).
The decision to use either a helmet or full face mask depends on the resources and training
available to each dive team, the dive objective, pollution/contamination level, or other
environmental factors.
A harness should be worn by the diver for all surface supplied dive operations. The harness
is used as an attachment point for both the umbilical line and the diver’s emergency
breathing gas supply. The com line must be clipped to the diver’s harness prior to the start
of the dive. This safety feature allows the diver to pull the umbilical along or for the diver
to be towed back to the point of entry without straining any vital gas or communication
links.
The control box should be secured in an area where its presence, and that of the operator,
will not impede operations of the surface support crew. The box should be held open and
secured to a fixed object (e.g., boat rail or a dock piling). The breathing gas source should
be within easy reach of the operator. In inclement weather, the box should be set up in an
area out of the rain (e.g., in the boat cabin or under a tarp).
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When the surface supply control box is set up, the main power switch should be turned on
and the battery power checked. The gas outlets should be uncapped and the breathing gas
line and the pneumo line should be attached. Since the two lines are different diameters,
they can only be attached to their respective outlets. The control box has gas outlets for
two sets of umbilical lines, one set is marked in red and the other is marked in white. The
control box operator must be sure to attach both lines from one umbilical to either red or
white. Each umbilical line (breathing gas and pneumo) has a bronze Joint Industrial
Conference (JIC) hose fitting which screws onto its gas outlet. These fittings should be
lightly tightened with a wrench to prevent gas leaks, but not tight enough to put torque on
the fittings. Both of the diver gas supplies (e.g. red and white sides) have a gate lever that
can be opened or closed to allow gas flow to the outlets.
SCUBA tanks can be used as a source of breathing gas for surface supplied diving. The
control box has a selector valve handle that is used to switch between two incoming gas
lines. While the incoming lines are typically each attached to a single SCUBA tank, the
team may opt to use a manifold block to attach several tanks to each incoming line. The
tanks on both incoming lines must be open. After the gas tanks are attached to the system,
the operator should blow out the breathing gas line by briefly opening the outlet gate to
allow gas to blow out any dust or particles. The end of breathing gas line can then be
attached to the diver’s gas supply manifold block.
3.5.2 Communications
3.5.2.1 Voice Communications
The control box communications system can be operated either with a microphone and
the built-in speaker so all surface personnel can hear the diver or the box operator can
wear headphones to block out external noise (e.g., machinery, wind, extraneous
conversation). When using headphones, the operator may turn off the speaker switch so
that only the box operator can hear the diver. When in this mode, the operator must relay
information to dive tender and other surface personnel. The set up should be close
enough to the dive operation and tenders to allow clear communication between the
Communications Box Operator and dive tender.
Prior to donning the helmet or FFM, the diver and control box operator must perform a
communications check. The surface end of the com line is wired with connectors for
attachment to the control box, and the diver end of the com line is wired to attach to the
diver’s communication line (microphone and earphones). The control box has adjustment
knobs for surface-to-diver and for diver-to-surface volume. Proper two-way
communications should be established prior to initiating dive operations.
In the event of loss of voice communications, the dive unit should practice backup line
signals to ensure the dive can be safely and efficiently aborted. Example standard line-pull
signals are included below from the US Navy Dive Manual, revision 6, Table 8-3.
Big Circular Motion: I am entangled here (indicate where the entanglement is by putting
the backup diver hands on it).
Place primary’s hand back I am leaving now but will be back. The standby diver goes
on his carabineer and give back to return with additional air to allow more time
three squeezes. to deal with the problem.
The area in which the diver dresses and then uses for access to the water should be kept
clear of all debris and items that could present slip, trip or fall hazards to the diver. The
tender should always be available to physically assist the fully dressed diver.
The tender should assist the diver in donning all equipment and ensure all belts, clips and
harnesses are securely fastened. The dive tender and/or the box operator should ensure
that all air systems and communications are functioning properly. The tender should
complete all predive checks as specified in the Surface Supplied Air Checklist (Attachment
1).
The tender should assist the diver with entering the water and always maintain a grip on
the umbilical. If the diver jumps into the water, it is the tender’s responsibility to ensure
that there are no obstacles in the diver’s landing area. The tender should also give the diver
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enough slack in the umbilical to get into the water just below the surface. Immediately
after the diver has entered the water, the tender should pull the diver back to the surface.
Once back at the surface, the diver should ensure that he or she is properly weighted, do
another communication check, and the tender and the diver should assess the diver for leaks
(bubbling, particularly around the mask). Once the diver is ready to submerge, the tender
should give the diver enough slack to descend. Since the tender is usually in the best
position to witness the diver submerging, the tender should also call out to the box operator
and/or divemaster when the diver has submerged so the submergence time can be recorded.
When a diver is in the water, the box operator must maintain regular, open communication.
Once the diver has descended to the work site, the operator should monitor the diver’s
depth using the pneumo. Using the correct pneumo gauge (red or white) for the diver’s
umbilical, the operator should open the pneumo valve below the gauge by turning it in a
counter clockwise direction until the depth gauge reads a depth that is known to be deeper
than the diver, or until the diver reports bubbles coming from the open end of the pneumo
hose. The operator should then close the valve, monitor the depth gauge and record the
diver’s depth (measured in feet of sea water [fsw]) when the gauge needle stabilizes. The
operator should monitor the diver’s depth frequently, especially when the diver is moving
around. The Divemaster or designee records this information on the tending form during
the dive. The diver may also choose to use a computer or depth gauge to monitor their
depth in lieu of using a pneumo hose.
The control box operator should ensure that the diver is getting sufficient breathing gas
pressure at depth. The umbilical pressure gauge on the control box should read between
115 psi and 225 psi depending upon the specifications of the mask or dive helmet being
utilized, bottom depth, and particular control box instructions. Lower umbilical pressure
results in more effort required on the diver’s part to breathe. The USEPA typically
maintains umbilical pressure at 150 psi for light to moderate work loads. If the diver is
performing manual labor (e.g., pounding sediment cores or moving heavy objects) and is
breathing hard, it may be necessary to increase the umbilical pressure by turning the
umbilical pressure knob until the diver reports that gas flow is comfortable.
The control box operator must maintain careful watch over the pressure gauge on the line
that is supplying gas to the diver. When the gauge reads approximately 500 psi, the
operator should flip the selector handle to the other incoming gas line. The selector handle
must be turned all the way to its stop for breathing gas to flow properly. As soon as is
practical, the operator, or designee, should replace the spent gas cylinder with a full
cylinder. When using SCUBA tanks, the spent tank valve should be closed, and the
pressure should be bled out of the hose between the tank and the control box using the
bleed valve on the yoke. Upon removing the spent tank and replacing it with a full tank,
the bleed valve should be closed and the tank valve should slowly be fully opened. The
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operator should ensure that the pressure gauge on the control box indicates a full tank. This
procedure should be followed each time a spent tank is replaced. It is the responsibility of
the control box operator to ensure that a sufficient gas supply is readily available for all
diving.
Prior to switching the gas source, the operator should notify the diver to suspend the current
activity, locate the EGS manifold block and be ready to switch to emergency gas. Once
the diver has responded to the operator and has put a hand on the manifold block, the
operator can switch the gas source. In the event that a gas line or a seal (O-ring or fitting)
should fail upon changing pressure, the diver will be prepared to immediately switch to
emergency breathing gas. If a seal should fail and gas pressure to the system is lost, the
operator must switch back to the previous tank and inform the diver to be ready to switch
to the EGS. The box operator should replace the failed tank with a new tank as quickly as
possible and switch to the replacement tank. Once the situation has been resolved, it is the
divemaster’s decision to either continue or terminate the mission.
It is the responsibility of the divemaster, the diver and the tender to each ensure that the
valve of the bail-out bottle is opened after it is connected to the manifold block and that
the manifold block knob is closed. The bail-out bottle pressure should be checked and
recorded prior to every working dive. The EGS should be mounted upside down, and the
divemaster should verify that the diver can reach the tank valve to re-open it, should it
become closed.
At the termination of each dive, the operator should notify the surface support crew that
the diver is ready to ascend. If conditions permit the diver to control the ascent, the tender
should slowly pull in the slack from the umbilical as it becomes available. The umbilical
should be coiled neatly in a pile either in its shipping box or on the deck/dock/ground
behind the tender. The umbilical should be coiled in alternating over-under loops to
facilitate the next deployment. If conditions do not permit the diver to control the ascent
(e.g., low visibility or mid-water current), the tender should gently pull in all slack
umbilical and the operator should have the diver swim on the bottom in the direction of the
umbilical. Once the diver is close to or below the boat/platform, the diver should exhaust
air in their suit to become negatively buoyant and the tender should use the umbilical to lift
the diver up to the surface. The tender must maintain an ascent rate of no more than 30
feet per minute, and the operator must continually communicate with the diver to ensure
that the ascent rate is not causing discomfort (e.g., reverse squeeze). The box operator can
monitor the diver’s rate of ascent simply by watching the pneumo gauge. The operator
should warn diver if any surface hazards are present.
Once the diver is on the surface, the tender should call out to the divemaster or box operator
who should record surface time on the dive log. Once at the dive platform, the tender
should assist the diver exiting the water. When diving in contaminated water, proper
decontamination methods should be utilized prior to undressing the diver.
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3.5.9 Switching Divers
When switching divers, the same harness rig is typically worn but the next diver’s personal
FFM should be used. To switch FFMs, the box operator should close the gate on the
umbilical gas outlet, and the tender should push the purge button on the first diver’s FFM
to bleed the pressure out of the breathing gas hose. The FFM should then be removed and
the next divers mask put on the system. Dive computers must not be shared
When the day’s dive operations have been completed, the control box should be properly
stowed. The main power switch should be turned off, and the battery power should be
checked. If the battery is low , the box should be charged overnight prior to the next dive
operation. The microphone should be disconnected and stowed in the battery
compartment, and the com line connectors should be gently pulled. The gas supply tank
valves should be closed and the bleed valves on the tank yokes should be opened to
depressurize the supply hoses. The SCUBA tanks should be taken off the system, and any
tanks that have not been exhausted should be capped for use on future dives. Tanks that
have been exhausted should not be capped, and should be kept separate from the full tanks
so that they can be refilled. The FFM purge button should be pushed to bleed the gas out
of the umbilical. The gas supply gate should then be closed. Using a wrench, the umbilical
lines (both breathing gas and pneumo) should be removed from the box. The breathing gas
hose should be capped immediately upon being disconnected from the box. The gas outlets
should then be capped, finger-tight, with their brass caps. The control box should then be
closed, and latched so that the o-ring seal on the lid makes the control box water-tight.
After decontamination, the umbilical should be coiled neatly in its shipping box. The
harness should be disconnected by unclipping the umbilical and using a wrench to
disconnect the breathing gas supply hose. The supply hose should be capped immediately
after being disconnected. The pony bottle valve should be closed, and the valve on the
manifold block should be briefly opened to bleed the hose pressure so that the regulator
first stage can be removed from the bottle and capped. After all gear has dried, the
umbilical, harness, pony bottle and regulator should be stowed in the umbilical shipping
case, and all of the latches should be tightened. Prior to shipping the case by air, the pony
bottle must either be removed or emptied.
At the conclusion of daily dive operations, the panels of the control box should be wiped with a
damp cloth. After the project is completed all equipment should be allowed to air dry prior to being
stored.
The control box should be serviced by a qualified technician on an annual basis. All batteries used
in the control box, should be maintained according to the manufacturers recommendations. When
batteries no longer take a full charge or the battery life is diminished, they should be replaced
according to the manufacturers procedures.
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The breathing gas hose must be pressure tested to 1.5 times its working pressure by a qualified
facility on an annual basis. The breathing gas hose must be kept clean, inside and out. It is important
to ensure that both ends of the hose are properly capped when the hose is not in use to prevent dust
and particulate contaminants from getting into the breathing system.
4.0 RESPONSIBILITIES
Each member of the surface supplied dive team will have the experience or training necessary to perform the
tasks assigned to them in a safe and efficient manner. This experience and training will include the use of
tools and equipment needed for the specified tasks and techniques required for surface supplied diving. Each
member of the dive team will also have training in the emergency procedures required in the event of a diving
accident. Each dive team member will only be assigned tasks in accordance with that person’s training and
experience.
A simple surface supplied diving operation (a single diver, shallow, short duration dives) requires a minimum
of four people; a diver, a stand-by diver, a tender, and control box operator/divemaster. However, dive
projects requiring multiple dives, depths greater than 30 feet, and multiple divers may require a larger
minimum crew. If two divers are in the water simultaneously, the minimum of five people are required; two
divers, two tenders, , and a control box operator/divemaster. These minimum numbers assume that all
personnel, with the exception of tenders, are qualified divers who could switch duties from surface support
to in-water operations. The responsibilities of the dive team are described in the EPA Diving Safety Manual,
but those responsibilities specific to surface supplied diving follow:
4.1 Divemaster
The divemaster carries the overall responsibility for the safety and performance of the dive
operation. On small operations, the divemaster may also assume the responsibilities of another
surface support person or even perform in-water duties if there is a qualified divemaster available
to assume the divemaster surface responsibilities.
4.2 Diver
Divers are primarily responsible for performing the in-water work. The diver is also responsible for
ensuring all dive equipment is present, and in working order. While in the water, the diver is
responsible to carry out work duties as instructed, and to maintain open communication with surface
personnel. The surface supply control box operator and the Divemaster should be aware of the
diver’s status at all times. It is the diver’s responsibility to ensure that he/she is clear objectives of
the dive and is aware of all safety equipment and procedures that may be required.
For all surface supplied diving operations, at least one qualified member of the team will be
designated as a stand-by diver. The stand-by diver will be ready to enter the water promptly in
case of an emergency. Two surface supplied divers may be in the water conducting work each
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acting as a standby diver for the other, if both are able to render the other aid within 3 minutes at
all times, allowing for no decompression limits.
The primary responsibility of the dive tender is to assist the diver while preparing for, conducting,
and recovering from in-water operations. The dive tender will maintain control of the surface supply
air umbilical, ensuring that the diver has enough umbilical to work freely, but not so much umbilical
that an entanglement hazard is posed. The dive tender will also be responsible for visually tracking
the diver’s location while in the water. The dive tender and all surface personnel are responsible
for advising other vessels of the dive operation and warning off any vessels that may pose a hazard
to the diver. Although the tender does not need to be a certified diver, the tender must be trained to
perform the required duties and have an understanding of the equipment utilized by the diver.
A qualified and trained person will be dedicated to running the surface supply control box. This
person shall have no other duties that may distract them from their primary responsibility of
maintaining sufficient breathing gas delivery and communications with the diver. The dive control
box operator in conjunction with the divemaster must be aware of the diver’s profile (maximum
allowable depth and bottom time) and actual bottom time and depth to ensure that all diving is
performed in a safe manner and the diver does not exceed the no-decompression limits (NDL) or
the dive-specific profile limits. The control box operator is directly responsible for the safety of the
diver. In certain circumstances, at the discretion of the divemaster, the surface supply control box
operator may also maintain the dive logs.
The boat operator is responsible for all boat operations in support of the dive operation. The boat
operator must have experience or training in operating the vessel during dive operations and
performing emergency procedures that may be required. During the dive, if the boat is secured in
position (anchored or docked), this person may also perform the duties of one of the surface support
personnel. .
5.0 REFERENCES
Diving Systems International (DSI). 1996. Dive Control System - 2A, Operations and Maintenance Manual.
Dive Labs, Surface Supply Breathing Requirements and Recommendations for Kirby Morgan Helmets and Band
Masks, 2008, 37 pp, http://www.kirbymorgan.com/PDF/Checklists/Surface_Supply_Requirements_02-17-2009.pdf.
Kirby Morgan Dive Systems Inc. 2009, Kirby Morgan Air Control System 5 Operations and Maintenance Manual.
1.0 OBJECTIVE
2.0 APPLICABILITY
3.0 DESCRIPTION
4.1 Diver
4.2 Tender/Divemaster
4.3 Standby Diver
5.0 REFERENCES
This standard operating procedure (SOP) states the United States Environmental Protection Agency
(USEPA) policy concerning tethered diving operations. Procedures for general dive operations are
specified the USEPA Diving Safety Manual. This SOP in not intended to be a substitute for actual
hands-on training.
2.0 APPLICABILITY
Tethered SCUBA diving is a tended diving method where one diver in the water is line tended by
surface personnel and directed to perform a variety of underwater tasks, which could include light
work or scientific tasks. OSHA also requires that standby divers for working dives be line tended.
This method is much like that of surface supplied diving in many ways other than the virtually
unlimited air supply. Typical tethered diving equipment, personnel, and procedure is described
below. These procedures apply to EPA employees and contractors working directly for EPA that
are engaged in surface supplied diving operations. This SOP presumes and requires prior training
and experience with tethered diving.
3.0 DESCRIPTION
All divers must be dive certified and medically qualified to perform their diving duties, as
specified in USEPA Diving Safety Manual.
3.3 Documentation
Project-specific Dive Plans and Dive Safety Plans shall be issued prior to performing dive
operations, and all dives shall be logged as specified in the USEPA Diving Safety Manual.
The Unit Dive Officer (UDO) shall maintain logs of each diver’s certifications, medical
clearance to dive, and all health and safety training (e.g., cardiopulmonary resuscitation
[CPR], first aid and oxygen administration) as specified in the USEPA Diving Safety
Manual.
Tethered SCUBA diving equipment nominally includes standard diver dress, e.g.
wetsuit/drysuit, fins, and weight belt, as well as particular equipment to tethered
diving needs. These other items include a full face mask with communications,
strength member with quick release snap shackle tether, hardwired or wireless
communications, and man-rated safety harness for rated for lifting the diver from
EPA divers may wear a standard dive mask but will typically wear a full face
mask (FFM) for to provide vox communications. The FFM is typically equipped
with communication equipment (microphones and earphones) for this application.
The FFM allows for hardwired communication and in conjunction with a drysuit
with hood and drygloves will give the diver some protection from polluted water,
when using the positive pressure version to minimize leakage. When diving in
non-polluted water, a wetsuit may be utilized. Typically, the mask is used with
an ear/microphone attachment, such that the diver may be in constant hardline
communication with the surface.
A diver harness is necessary to connect the diver securely to the tether line for all
tethered dive operations. This allows the diver to be towed back to the point of
entry. The harness is worn underneath the BCD or backpack on top of the wetsuit
or dry suit. The harness should be rated to pull the diver from the water, in the
event of an emergency on the surface or beneath the water. The harness may also
allow for an attachment for a hard-wire communication (com) line to prevent
straining of the communication links. The com line must be clipped to the diver’s
harness prior to the start of the dive.
3.4.4 Tether
While any kind of line may be used in conjunction with line signals, typically a
com rope is used to allow for constant communications with the diver. Care must
be taken in tending the diver when moving in arc patterns (discussed below), that
the line is not hung up and frayed on sharp underwater objects. The tether should
be fitted with a quick release snap-shackle to allow the diver to egress to the
surface should the tether become irreconcilably entangled in bottom debris. The
tether may also be marked in intervals for measuring distances used in search
patterns, for example. Tethers can be made in most any length, though 200 and
300 foot tethers are typical for their dive operations. Generally, the tether required
must be the distance from the dive platform added to the depth to the dive site
multiplied by 1.5 (NOAA, 2009), e.g. 50 feet from the dive site at a 50 foot depth
would be 150 foot of tether. A tether longer than 300 foot can present some span
of control problems with a dive platform under anchor, in adequately fending off
nearby vessel traffic in a timely fashion. The tether should be stowed in a bucket
or bag of some kind, with the tender end going in first, diver end last, to keep it
from being stepped on and damaged, and to avoid tripping/falling hazards on the
dive platform. The container should allow for easy decontamination and
segregation of contaminated line from other gear.
Note: This is different than a non FFM configuration, where the pony bottle is
normally left off (e.g. NOAA mouthpiece reserve air supply system) to prevent a
free flow from emptying the reserve supply. The size of the bail-out bottle is
determined based upon the type of water, i.e. contaminated vs. non-contaminated,
working depth, type of equipment, i.e. FFM vs. helmet and the air consumption
rate of the individual diver.
The EGS should be mounted upside down such that the diver can reach the tank
valve, should it accidentally be left closed. A submerged pressure gauge must
also be in plain view of the diver so that they may see the current status of their
EGS bottle. For example, if the manifold block is bumped, the diver may start
breathing off the EGS without their knowledge. Frequent checking of the primary
gas supply SPG, bailout block and EGS SPG will help to ensure that the diver is
continuously breathing off the primary air supply. Also, as tethered diving is often
used for low visibility situations, analog gauges should be used as digital gauges
cannot be read when pressing the gauge directly against the FFM in true blackout
conditions. For diving with a dry suit, the inflator whip should be connected to
the manifold block such that suit inflation may still be achieved when using the
EGS.
3.5.1 Procedures
As noted above, the tethered diving operation normally involves at least three
divers. This allows for safe and efficient diving by rotating through the crew of
3, especially for deeper dive profiles. The 3 person rotation allows for ample
surface intervals for the diver who has just dived, and then becomes the
Divemaster/Tender, the diver who has been out of the water for the duration of
the last dive, who becomes the standby diver, and the diver, who has been out of
the water for at least two dives worth of time.
Both the tender and standby diver should assist the diver in donning gear if
needed. Special attention is paid to placement and setting of the manifold
block/EGS and verification that the diver can reach the block and EGS valves
easily, and without looking, as tethered diving is often used in low visibility
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environments. The primary and EGS tank pressures are checked and recorded.
Comm. checks are performed and volumes/ear piece placement adjusted as
needed. The diver is deployed with an extra loop of line available (to avoid
jerking the diver during descent) and the tender arrests their descent into the water
via the tether line and holds them at the surface until they can complete a mask
check.
The tender uses both hands to tend the line, so as to ensure that the diver is firmly
held in place. The tether line is never wound around the tender in any way for
two reasons: 1) the line may be contaminated, and this could leave polluted water
and sediment on the tender, and 2), the tender could be pulled into the water with
the line wound around them. The tender should use gloves to prevent chafing,
and these should be covered by disposable gloves if there is any chance of
contamination in surface water or sediment.
Directing the diver is undertaken in a different manner than in buddy type SCUBA
operations, where movements are relative to the tethered line itself. For example,
the tender may instruct the diver to swim “toward the line,” “away from the line,”
“take a 90 right,” “take a 90 left,” and so on. The diver trusts that the surface can
direct them where they need to go, as in conducting a search pattern, “Hold line
tension, and swim with the tether at your left.” Surface may ask the diver to
conduct search patterns via an arc, sweep, or out and back methods, using these
line signals. Based on whether there is visibility on the bottom, this will determine
the distance between diver sweeps. (Hendrick, 2000). The surface will regularly
ask for pressure checks from the diver, and the diver should also volunteer these
to the surface. If asked during a crucial task for a pressure check, the diver should
ask the surface to “standby.” The surface will hold tension at all times, and release
tension only when requested by the diver. Without tension, the surface loses good
information on the status of the line, i.e. tangled or untangled, and may actually
cause the line to tangle by allowing it to drag on the bottom. Absence of tension
also prevents backup communications from happening as discussed in emergency
procedures, below. Equipment may be conveyed to a stationary diver nearby the
platform via a loop in the line. If this is done, tension should be maintained in the
line should verbal communications fail, and once the tool is conveyed, all slack
should be removed.
The surface may control the diver’s ascent, if the diver cannot control their own
ascent due to weighting, currents, etc. Using the tether, the tender will give at
least a 2 second count for every foot of line they pull in. When the diver nears the
platform, the tender will instruct the diver to put up their hand for the last part of
the ascent to protect their head from the hull of the vessel. The tender will remain
on comm. until the diver is aboard and decontaminated, as needed. The line will
be managed in the dive platform’s “hot zone” with gloves such that it can be
decontaminated at the end of dive operations, and otherwise managed to avoid
material tracking throughout the vessel.
3.5.2 Communications
The voice communications unit is utilized by the tender while tending the diver’s
line to maintain constant verbal communication with the diver and standby diver.
Communication may be one-way, surface-to-diver, or two way allowing the diver
to speak with the surface either by hard-wire coupled with the tether or by
through-water (e.g., acoustic or sonic) transmission. The voice communications
unit may be operated with either a “voice operated switch,” also known as VOX
(or Voice Operated eXchange) or in a “push-to-talk” mode in which the diver’s
and operator’s microphone are button activated. The VOX is a switch that
operates when sound over a certain threshold is detected. It is used to turn on a
transmitter when the diver speaks and is turned off when they stop speaking. The
tender communications unit allows the tender to talk with the diver via a headset
and belt clip communications unit.
The tender unit typically uses replaceable batteries, which should be changed out
on a daily basis to ensure constant communications. The vessel should have one
set of batteries per day for the dive operation, plus one spare set. Care should also
be taken when installing batteries in the unit, as the battery compartment soldering
can be quite fragile. Rechargeable batteries are beneficial for this purpose to
minimize waste generation from daily dive operations. When connecting the
headset to the belt clip unit, a “squeal” should initially be heard as the unit powers
on. Absence of this sound can indicate that the batteries are dead, or that the unit
is otherwise not functioning. When the unit is not in use, the headset should be
disconnected from the belt clip unit to conserve battery power.
In the event of loss of voice communications, the dive unit should practice backup
line signals to ensure the dive can be safely and efficiently aborted. Example
2-2-2 I am in a difficulty but I am OK, I need assistance, send the backup diver.
.
3-3-3 I am entangled and OK, I am stopping to handle it myself but ready the backup diver
Tap Standby’s Hand on Primary Divers Chest I am injured here (indicate the injury location).
Place primary’s hand back I am leaving now but will be back. The standby diver goes
on his carabineer and give three squeezes back to return with additional air to allow more time to
deal with the problem.
Vessel operations necessitate important tethered diving safety procedures, which include:
As the dive platform cannot fend off other boat traffic by means of physical presence, care
should be given how far channel ward a tethered diver is allowed to travel. Consideration
of notice to mariners, broadcast of an encumbered vessel status either via VHF and/or
automatic identification system (AIS) could also be considered.
Before the tethered diver undertakes a working dive, it is important that they have practiced
how to free an entangled line, disconnecting from the tether, unconscious diver rescue, and
clearing a flooded mask in a training situation. During the dive briefing, backup
communication line pull signals must be reviewed and memorized by the dive crew. See
the US Navy Revision 6 Table 8-3 line pull signal table below.
It is also important that the dive crew review what it sounds like for the communications
cable wet connection for the hard line com to become disconnected underwater at the diver
end. Absence of sound for the diver should indicate that they need to reconnect the plug,
and/or begin using line pull signals to communicate their status to the surface. A fresh set
of batteries should be on hand topside, in the event of communications loss, to ensure that
voice communications can be re-established. A fully redundant tender headset and
communications box might be kept on board in the event that these become flooded or
cease operating.
A diver recall could also be kept on hand to supplement line pull signals should hard line
communications be lost. The diver must also be prepared to disconnect from the tether, in
consultation with the surface. The diver should not disconnect from the tether without first
telling the surface, “going off comm.” to ensure that the surface understands that
communications will be lost for a period of time. Unplanned loss of communication (voice
and line pulls) of the tethered diver should lead to immediate deployment of the standby
diver unless the divemaster determines that conditions are too hazardous for rescue to be
undertaken.
For retrieval of an unconscious diver on the bottom, the standby diver would be deployed
on tether, and follow the primary diver’s tether to the bottom. Once with the unconscious
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diver, the victim should be oriented head up, and the surface notified that they may haul
the pair up.
For trapped diver situations, a “rescue bottle” could be maintained for the standby diver
to convey to a trapped primary tethered diver. The rescue bottle could be outfitted with a
quick disconnect coupling (female), so that the bottle may be connected underwater to the
trapped diver’s SCUBA bailout block manifold quick disconnect fitting (male), along
with a mouthpiece second stage and SPG. The latest decompression tables should be
carried aboard the dive platform, or dive computers capable of completing decompression
calculations for exigent circumstances that require an immediate response.
Typically tethered diving operations consist of a three person team, the diver, the standby diver, and
the divemaster/tender.
4.1 Diver
The diver, unlike in the conventional SCUBA diving buddy system, will be diving alone.
This takes some adjustment for the diver, and reminders from their divemaster that they
will be in constant communication with the surface. Taking the dive slowly and not rushing
through tasks is key to avoiding panic, but also in minimizing air consumption. While the
diver is still responsible for checking their air supply and reporting this to topside support,
unlike surface supplied diving, other adjustments are needed. Often the dive may be
controlled from the surface depending upon the task being performed. If the dive is
primarily surface controlled, the diver will need to adjust to not being primarily in control
of their dive, i.e. the divemaster will be in constant communication with them, and will
instruct the diver what to do, and when to do it. As with all dives, the diver or divemaster
may end the dive for any reason.
4.2 Tender/Divemaster
The divemaster/tender will assist the diver in dressing in, tending the line, and doffing gear
at the end of the dive. The tender should also be a diver prepared to dive each day,
especially for deeper dive profiles. Divemaster responsibilities are the same as generally
defined for buddy type SCUBA operations e.g. the divemaster continues to be in charge of
the overall dive, except that they can hear the diver throughout the dive, and should be
monitoring the diver constantly for signs of anxiety. Breathing rate of the diver is a clue
to their mental status. As needed, the tender should ask the diver to stop what they are
doing, rest, and breathe (e.g. more deeply or slowly). As with all dives, the Divemaster
must remain undistracted such that they can monitor the surface for danger from incoming
boat traffic and any other hazards.
All tethered diving operations require a standby diver. The standby diver must be ready to
get into the water within several minutes, and be dressed in their dry suit or wetsuit either
half way, or fully at the Divemaster’s discretion.
Disclaimer: This SOP is an illustration of steps to be taken to conduct tethered SCUBA diving operations
and minimize the diver’s exposure to polluted water conditions and is not the official view of the USEPA.
REFERENCES
AAUS Symposium Proceedings, Use of Tethered SCUBA Diving to Improve Safety and Efficiency,
http://www.oseh.umich.edu/articles/tethered.pdf, http://nsgd.gso.uri.edu/michu/michut87003.pdf, pp. 345-
355, 1990.
Barsky SM. Diving in High-Risk Environments, 3rd ed, Santa Barbara, CA: Hammerhead Press, 1999; 197
pp.
Contents
1.0 OBJECTIVE
This standard operating procedure (SOP) states the policy concerning decontamination of personnel involved in
contaminated water diving. This SOP is not intended as a substitute for actual hands-on training.
2.0 APPLICABILITY
These procedures apply to all personnel, including subcontractors under Environmental Protection Agency (EPA)
supervision, engaged in diving operations. This SOP presumes and requires prior experience with diving and
decontamination procedures.
3.0 DESCRIPTION
For this SOP, contaminated water is defined as any body of water that is suspected of containing chemical
or biological agents in concentrations that could potentially harm an unprotected diver and/or surface
support personnel. Unless a body of water is known to be clean, some degree of contamination must be
assumed. The level and type of contamination will determine the decontamination procedure required.
Since a river or a large body of water (e.g., a lake or ocean) has flow or circulation allowing for removal or
dilution of suspected contaminants, these are generally of less concern than diving in a closed body of water
(e.g., a pond or a flooded quarry) which has no flow and significantly less potential for dilution of
contaminants.
In general, most persistent biological and chemical contaminants tend to concentrate in sediment rather than
in the water column (Hendrick, et al. 2000, Hoffman, et al. 2003; US Navy 2004). Therefore, simply
remaining above and not coming into contact with the sediment may reduce the diver’s potential exposure.
It is the responsibility of the Divemaster in charge, with concurrence of the Unit Dive Officer (UDO), to
determine whether sufficient contaminant information is available and whether conditions are appropriate
for diving. All contaminated water diving will be performed using appropriate exposure protection. For
contaminated water diving, this document assumes all divers will wear, at a minimum, a full-face mask and
a dry suit with mating dry gloves. The dry suit material should have a smooth outer surface which does not
trap contaminants and is capable of being thoroughly decontaminated. Some dry suit manufacturers have
had their suit materials tested against a variety of contaminants in the laboratory using ASTM methods
(Viking 2001Barsky, 2007).
To minimize the number of personnel potentially exposed when performing dive operations in
contaminated water, it is common US EPA Dive Team practice to use a single diver, on surface supplied
air with hard-wired communications (see SOP Surface Supplied Diving Operations). During boat
operations, it is easier to decontaminate one diver at a time. Additionally, surface supplied divers can share
some dive gear (weight harness, fins, helmet, emergency gas supply [EGS]), limiting the amount of
contaminated equipment. It is the Divemaster’s responsibility to determine whether surface supplied diving
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and/or the use of a single diver is the safest/most effective means of completing the dive operation.
Chemical contaminants include any chemicals which have leaked, spilled or dumped, or have been
otherwise found in a body of water. Lists of the chemical substances most commonly spilled in inland and
coastal waterways of the United States are available from a number of sources. The chemical spill lists
were summarized for the US Navy’s Experimental Diving Unit by Southwest Research Institute (Henkener
and Ehlers, 2000). These chemicals may be located in the sediment, on the sediment, on the water surface,
dissolved in the water column, or associated with particulates in the water column. Chemicals may pose
risk from ingestion, inhalation and/or dermal contact (NIOSH 2005).
Biological contaminants include harmful algal blooms (e.g., red tide), bacteria (e.g., fecal coliforms),
viruses and parasites which could potentially harm an unprotected diver. A summary of potential biological
hazards to Navy divers and swimmers was prepared for the US Navy’s Experimental Diving Unit by
Southwest Research Institute (Henkener and Ehlers, 2000). Biological contaminants may be present in
storm water runoff and pose hazards to divers and to surface support personnel, especially when diving in
near shore, urban areas within 36 hours of a storm event.
Site area definitions are modified from the EPA’s Standard Operating Safety Guides (EPA, 1992).
Modifications were made to make the definitions applicable to dive operations. Figure 2 shows the flow
and procedures at each stage of decontamination.
The Exclusion Zone (EZ), also called the Hot Zone, is the area believed to be contaminated.
This is the area in which site work will normally be performed. Each site will require
definition of this zone. In some cases when divers are entering the water from the shoreline,
performing their duties and returning to the shore, the body of water and a portion of the
shoreline may be considered the EZ. In the case of boat operations, the body of water and
that portion of the boat that a contaminated diver contacts may be considered the EZ. It is
imperative that no personnel enter the EZ without the proper personal protective equipment
(PPE). It is also imperative that no personnel, equipment or samples pass from the EZ to
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the Support Zone without going through the Contaminant Reduction Zone.
The SZ is defined as the clean area outside of both the EZ and the Contamination Reduction
Zone. No one should be allowed to leave the EZ and enter the SZ without completing the
decontamination procedure, except in the event of a diving accident.
A separate area should be set aside between the EZ and SZ for emergency
decontamination operations. In the case of a diving accident, it may not be possible to
perform the complete decontamination procedure prior to initiating first aid (see Section
5.4).
When performing dive operations from a boat, the EZ is typically considered to be the
water, the swim platform/ladder and a container on the boat used as the equipment drop.
The other zones have to either be contained in the limited space available on the boat or
completed at another location. It is the responsibility of the Divemaster to determine
whether the space available on the boat is sufficient for the level of decontamination
required. It is also the Divemaster’s responsibility to determine whether conditions are
appropriate for decontamination on the boat (e.g., sea state, weather).
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For dive operations on a small boat involving low levels of contaminants and a simple
decon, it is often the case that Contaminant Reduction is initiated on the dive platform or
on the swim ladder and the area of the boat immediately around the platform/ladder. All
hand-held equipment must be passed to the dive tender, who sets everything in an area
designated for potentially contaminated equipment (e.g., a labeled container). The entire
diver decontamination process is then carried out on the platform or ladder, and the dry
suit is removed as soon as the diver is on the boat. The diver is considered to be in the SZ
as soon as he or she is out of the dry suit and away from the immediate area of the
platform/ladder.
It is the Divemaster’s responsibility to determine whether contaminant levels and sea state
conditions are low enough to perform decontamination on the back of a small boat (or
ladder/platform). If the vessel size/sea conditions warrant a decontamination procedure
that cannot be done on the ladder or threatens to spread contamination within the vessel,
the Divemaster must make alternate arrangements (e.g., using a second vessel or
transporting the diver to shore for complete decontamination). Any decontamination
process involving multiple steps, or the use of decontamination solutions that cannot be
directly discharged into surface water, cannot be safely accomplished on a small, open
boat. Additional factors to consider are the diver’s air supply integrity during
decontamination, the diver’s fatigue and stress levels while holding on to a ladder for
several minutes, and the potential for the spread of contamination to other parts of the
vessel and personnel.
During some dive operations, a second boat or a barge is available to use as the CRZ. The
second vessel should be securely rafted to the primary vessel. Divers may enter the water
from the primary vessel, but always exit the water onto the CRZ vessel, and are
decontaminated there before re-entering the primary vessel. During such operations, the
barge is considered the CRZ and the primary boat is considered the SZ. Additional
considerations include surface-supplied air source and placement. Under no circumstances
should the supplied air source be on a different vessel than the diver. This may require a
segregated space on the CRZ vessel for the source and operator. Likewise, divers using
shared equipment (i.e., harnesses, tools) will both enter and exit the water from the CRZ
vessel as these items are considered contaminated and should not enter the SZ until the
final dive and complete decontamination. In most cases, when using two adjacent vessels
for the dive operation, decontamination washes will be contained and transported off-site
for temporary storage, testing, and disposal considerations.
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It may not be feasible to perform diver decontamination on some smaller vessels, especially
when a more complex decon is required For these situations the vessel shall be considered
part of the EZ throughout the dive operation and the diver can be brought to the shore or a
larger vessel for decontamination. If this is the case, the boat must be treated as part of the
EZ throughout the entire operation until it has been decontaminated. All equipment and
personnel leaving the vessel would also be required to pass through the CRZ before
returning to the SZ. On a small boat, sufficient decontamination equipment should be
available to remove gross contamination from the diver and the diver’s face/neck seal area
to allow the diver to safely remove the helmet/mask while returning to shore for full
decontamination. If multi-day, repetitive diving is conducted this scenario would not be
appropriate.
Dive personnel shall include a decontamination plan as part of every Dive Plan dealing with contaminated
water. The Dive Plan shall be referenced in the site-specific Health and Safety Plan (HASP). The Dive
Plan should detail the steps required to properly decontaminate divers based on the known or suspected site
contaminants. Included in the plan will be allowances for gross decontamination, equipment
decontamination, and required decontamination solutions. Special concerns and procedures will be
outlined in the Dive Plan.
If, during contaminated water dive operations, it is discovered that contamination is more severe than
originally believed, it is the Divemaster’s responsibility to determine whether appropriate decontamination
equipment is available and whether conditions permit safe dive operations.
Equipment required for decontamination activities will be dependent on the level of decontamination required at
each site. The equipment should be chosen from the following list based on need.
Potable water
Decontamination solutions (e.g., soap, water, bleach, etc.)
Soft bristled brushes/sponges
Paper towels
Plastic sheeting
Marking tape
Water collection basins
Hudson sprayer
Decontamination shower
Disinfectant wipes
Stools
Hand soap
Emergency breathing gas supply
Chemical/Water resistive suits
Face shields/eye protection
Rubber gloves/boot covers
Rubber boots
Other PPE
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Basins/Containers/Buckets
Prior to any dive operation, the level of decontamination shall be determined by the Divemaster with
concurrence of the UDO and Health and Safety Officer, based on the information available. The anticipated
decontamination procedure will be spelled out in the site-specific Dive Plan. During the dive operation,
the Divemaster may alter the decontamination procedure, based on site conditions and any additional
information available. Since real-time contaminant levels are rarely available, the Divemaster must use
professional judgment, weighted on the conservative side of safety.
This SOP addresses decontamination of divers and equipment after operations in moderately contaminated
water. Some locations may be contaminated to an extent that makes diving unsafe regardless of the
exposure protection available. In those locations, it is the Divemaster’s responsibility to ensure that divers
do not enter the water, and operations must be performed using remotely operated vehicles (ROV), sonar,
remote sampling equipment (e.g., Ponar dredge, Kemmerer bottle, etc.), or other non-diving methods to
fulfill the project objectives.
The level of decontamination can range from simply rinsing the diver with clean water to having the diver
pass through a formal decontamination corridor. The major variables to consider when decontaminating
dive equipment include the nature of the surface (smooth surfaces are easier to clean than porous surfaces);
and the type and concentrations of contaminants encountered.
Since many persistent chemical contaminants of concern are present in sediments and most EPA scientific
diver studies occur on or near the sediment zone, gross decontamination of a diver or removal of all visual
contamination (sediment, mud, vegetation, etc) can be a critical decontamination step. All equipment,
especially diver fins, diver boots (including soles), diver dry suits from the thigh downward, and any areas
where contaminants may become trapped should be inspected for visual contamination before any gear is
moved to a clean area.
In some situations, where the diver’s dry suit will likely suffer gross contamination (oil spills) that may not
be possible to clean, the diver may wear coveralls, Tyvek or similar PPE over the dry suit. The coveralls
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must be modified to not interfere with the proper operation of the dry suit (e.g., holes have to be cut for the
suit inflator and exhaust valves). While the coveralls will provide only minimal protection to the dry suit,
it may be possible to complete a multi-day dive operation before discarding any dive equipment that can’t
be sufficiently decontaminated. Coveralls may also be worn when diving near potentially sharp or jagged
edges to prevent tearing the dry suit. Any PPE materials which become visually contaminated should be
removed and replaced between dives.
Each member of the decontamination team shall have the experience or training necessary (e.g.,
EPA Diver Training, Occupational Safety and Health Administration 40 hour Hazardous Waste
Operations and Emergency Response Training (OSHA 1910.120 40hr HAZWOPER) to perform
the tasks assigned to them in a safe and efficient manner. This experience and training shall include
the use of tools and equipment required for efficient and effective decontamination. Each member
of the decontaminaton team shall also have training in emergency procedures (first aid,
cardiopulmonary resuscitation (CPR) and automated external defibrillator (AED)) Each
decontamination team member shall only be assigned tasks in accordance with that person’s
training and experience.
The duration of the decontamination process is an important consideration during any dive
operation. Having the diver remain encapsulated to walk through a decontamination corridor is
tiring and stressful. During cold weather, the diver may risk hypothermia walking through a
decontamination line. During warm weather the diver may risk hyperthermia the longer he or she
is in the dry suit on the surface (particularly if dressed for cold water diving). Additionally, the
surface support/decontamination personnel will be exposed to the weather. It is important to get
the diver through the decontamination process and out of the dry suit as quickly as possible (NOAA
2001).
There is a high likelihood that the surface support/decontamination personnel will be splashed by
surface water, sediment and/or by the decontamination solutions. Surface personnel should wear
impermeable, disposable outerwear and face shields or similar PPE as specified in the HASP. Care
must be taken when rinsing contaminated sediment from the diver in windy conditions. Wind
direction should be a consideration in setup of the decon zones. The EZ should be downwind of
the CRZ and support zone.
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Choice of PPE for surface support personnel is driven by both the expected site contaminants and
by the choice of decontamination solution. Though certain decontamination solutions don’t require
any special PPE (e.g., soap), the potential for being splashed by site sediment or water mandates
proper PPE. Conversely, some decontamination solutions (e.g., bleach) mandate proper PPE
regardless of the site contamination (see Attachment 1). The appropriate PPE should be defined in
the site-specific Dive Plan.
When assisting the diver donning clean dive gear, the tender needs no PPE. However, as successive
divers reuse the same equipment (e.g., weight harness, buoyancy compensation device (BCD),
emergency gas supply (EGS) harness, fins), the tender must wear appropriate PPE when handling
the equipment that has not been fully decontaminated.
In order to prevent cross-contamination, when the same tender that assisted a contaminated diver
from the water is required to assist the next diver into clean gear, the tender must first change out
of his/her potentially contaminated PPE (see Section 5.6).
In order to expedite the decontamination process on a small vessel, it is often more efficient to
scrub and rinse the diver’s decon compatible equipment with sufficient quantities of potable water
in order to wash the biological agents off, so equipment can be efficiently removed. Potable water
has been shown to effectively remove microbial contaminants from decon compatible material.
Non decon compatible equipment can remain in the EZ for later use, and be provided to the next
diver or soaked in an antimicrobial soap solution, bleach, or other appropriate decontamination
solution if daily operations are completed.
Some decontamination situations may call for covering surrounding areas with plastic sheeting in
order to contain contaminants or decontamination solutions. Care must be taken that the sheeting
is properly anchored and does not pose a slip, trip and fall hazard to either the diver or the support
personnel. Additionally, once the plastic is wet and/or soapy, it may become more slippery. An
appropriate number of support personnel are required to steady the diver to prevent accidents.
The major considerations when choosing a decontamination solution are; 1) effectiveness against the
expected site contaminants; 2) compatibility with dry suit materials and other equipment; 3) safety of
exposure to both the diver and the tenders; 4) availability and cost; 5) use of biodegradable decontamination
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There are numerous decontamination solutions to choose from. Unfortunately, some of the most effective
decontamination solutions are very aggressive, corrosive and toxic (LBL 2006). Attachment 1, DIVER
DECONTAMINATION SOLUTIONS lists some decontamination solutions along with their general
effectiveness against biological and chemical contaminants and their safety/compatibility for use on divers
and dive equipment.
The following sections list decontamination steps, some of which may be minimized, combined or omitted
at the Divemaster’s discretion, based on the contaminants and situation. These steps must be performed in
the most efficient, effective manner possible to avoid undue stress on the diver. The planned
decontamination stages should be included in the Dive Plan.
As the diver exits the water, all non-life support equipment (e.g., tools, cameras, dive
lights) should be dropped in the EZ for later use or decontamination. The equipment should
be taken by the tender and set aside so that it is out of the way, but available for the next
diver or staged for decontamination. If available space allows, the equipment should be
put in a container to prevent the spread of contamination. If the equipment is going to be
immediately used by the next diver, it does not need more than gross decontamination until
dive operations are completed for the day. The potentially contaminated equipment must
remain in the EZ and should only be handled by the tender and the divers. The tender must
wear appropriate PPE for the contaminant and situation (e.g., chemically/water resistive
suit, rubber boots/booties, face shield/eye protection, gloves).
While the samples may be the reason for the dive operation, the safety and well-being of
the diver is the tender’s primary responsibility. Samples collected by the diver should be
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grossly decontaminated and encapsulated (e.g. placed inside resealable plastic bags) or
placed into a sample cooler prior to being transferred from the EZ. Samples and sample
containers are to be considered contaminated and should only be handled by personnel
wearing appropriate PPE.
The diver should hand sampling equipment to the tender who should either set the
equipment down in a designated area in the EZ or pass the equipment on to other personnel
for decontamination or disposal. Sampling equipment has been in direct contact with the
contaminated media being sampled and should only be handled by personnel wearing
appropriate PPE. After the diver has completed the decontamination process, the sampling
equipment can be decontaminated as specified in the field sampling plan.
While still in the EZ, the diver should be grossly decontaminated to remove visible
contamination including sediment, algae, plant life, etc. The tender may be responsible for
gross decontamination. However, if the primary tender is required to move away from the
diver, a second tender may be required to stay with the diver to ensure that the diver does
not slip, trip or fall. If available, a hose with a spray nozzle may be used to rinse the diver
with potable water, or material may be removed from the diver by hand.
If a hose is used to spray the diver, it should not be a high-pressure hose (e.g., a pressure
washer). The tender should also take care not to direct the spray toward the seals around
the diver’s mask/helmet or gloves, to minimize the chance of forcing contaminants into the
diver’s suit. When spraying near the diver’s mask/helmet, the tender should adjust to a
gentle spray from the diver’s face toward the back of his or her head (so the water goes
over the seal instead of under it). When spraying the diver’s hands, the spray should be
directed from the diver’s hand toward the elbow (so the water is not forced into the diver’s
gloves). The tender should take extra care to rinse out sediment or contaminants from
wrinkles in the diver’s suit and the areas around the glove cuffs and mask/helmet seals.
Spraying should be systematic, starting at the head and working downward to the feet.
Upon leaving the Exclusion Zone, the diver will enter the Contaminant Reduction Zone. In this
zone, the diver will be thoroughly decontaminated. If the dive operation is land-based all wash
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water should be captured in a basin for proper disposal as specified in the site-specific HASP.
One suitably dressed person is required to perform decontamination. However, using two
or more people ensures that decontamination is quick and that at no time will the diver be
left unattended. If necessary, the tender from the gross decontamination step should remain
on the edge of the Exclusion Zone to minimize contamination of the Contaminant
Reduction Zone.
The diver should be scrubbed with an appropriate decontamination solution, taking extra
care around the diver’s mask/helmet and gloves. Tenders should start at the diver’s head
and work down to the diver’s feet, scrubbing in a downward motion. Soft-bristled brushes
and/or sponges should be used to scrub the diver, since stiff-bristled brushes and harsh
scrubbing may damage the dry suit. A strong solution of antibacterial soap does not require
any contact time beyond that required to scrub the diver. The soap should be rinsed off
with water while it is still wet to more effectively carry away any biological agents.
If a decontamination solution other than soap is used, it should be washed away with a
soapy water scrub to ensure that the decontamination solution is completely removed from
the diver. The soap will also act as a secondary decontamination solution.
After the diver has been scrubbed with decontamination solution, a final rinse with potable
water is required. This step may be performed in a decontamination shower, with a hose,
a Hudson sprayer, or using buckets. At no time should the diver move backward in the
decontamination line.
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During small boat operations, the contaminant reduction area will usually be on the dive
platform or swim ladder. In these instances, all wash water will go directly overboard into
the EZ. If extensive decontamination must be performed or decontamination solutions
can’t be released into the environment (e.g., TSP, quats) the decontamination would need
to occur on shore or on a larger vessel with a designated decontamination area.
For small boat operations, the entire decontamination process may take place with the diver
standing on the dive platform or on the swim ladder (if conditions permit). In addition to
proper PPE, Tenders should wear a personnel floatation device (PFD). At no time should
Tenders put themselves at risk by leaning overboard attempting to decontaminate a diver.
If the Tender cannot safely accomplish the decontamination with the diver on a ladder, it
is the Divemaster’s responsibility to find an alternative location (e.g. aboard the vessel, on
a second vessel, or on the shore). For the purpose of this SOP, the area of the boat in which
the diver is being decontaminated will become the Contaminant Reduction Zone after the
diver has been grossly decontaminated.
This step is required after every contaminated water dive. Up to the point where the
decontamination solution is rinsed off, the diver has remained completely encapsulated.
After the diver has been scrubbed, the BCD or EGS harness can be removed without
removing the mask/helmet. The BCD/EGS can be set safely on a table or bench so that the
mask/helmet does not have to be removed and the weight harness can be removed (the
harness can either be decontaminated or kept in service for the next diver). If necessary, a
second tender should hold the BCD/EGS while the first tender scrubs the area of the dry
suit that had been covered by the other equipment. At this point, all contaminants should
have been removed from the diver or neutralized.
Care should be taken when removing the diver’s mask/helmet and dry suit. At this stage,
a tender other than the one who scrubbed the diver should take over if needed. If a second
tender is not available, the primary tender should change into fresh PPE (at a minimum the
tender should don fresh gloves) before continuing to avoid recontamination of the diver.
When removing either the helmet or the mask, the area of the seal is critical. With the full-
face mask, the area where the mask sits on the latex face seal of the dry suit hood will retain
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water. This water may still contain contaminants from the dive. Therefore, as soon as the
mask has been removed, a paper towel should be used to wipe up the extra moisture to
keep it from dripping into the diver’s face. This should be followed immediately by a
disinfectant wipe (e.g., alcohol wipes).
When wearing a helmet, the seal is around the diver’s neck and the water left in the seam
is less likely to drip onto the diver. However, this area should be wiped and disinfected
immediately.
During this stage, the tender should assist the diver with removing all gear except the dry
suit and dry gloves. The life support equipment (BCD/EGS) should be set aside for more
thorough decontamination or kept in service for the next diver.
Dry suit outer gloves should be removed first by the tender by pulling the gauntlet over the
diver’s hand so the glove is inside-out. The inner gloves should be left on the diver and
removed as the final stage of the decontamination process.
The tender should wipe the area of the zipper with paper towels and unzip the dry suit, and
assist the diver with removing it. It is important that the tender only touch the outside of
the suit, to prevent possible contamination of the inside of the suit.
The diver, with assistance from the tender, should take off the hood and pull their head
through the neck seal. Once the suit has been pulled off of the divers head and arms, the
diver should stand to pull the suit down past his or her waist and then sit on a clean seat
(not the same one that had contact with the dry suit) facing the Contaminant Reduction
Zone so the tender can assist pulling the dry suit off of the diver’s legs and feet. Though
the suit should be clean, it should be pulled off inside-out to reduce the chances the diver
will contact the outside of the suit. The last apparel that should be removed from the diver
are the inner gloves. The diver should then rotate on the seat to put his or her feet down
on the side of the seat facing the Support Zone.
If the diver or tender notices a wet spot (as opposed to obvious sweat marks) on the diver’s
undergarments after removal of the suit, it is possible that the suit leaked. If the suit leaks
in contaminated water, the inside of the suit must be decontaminated as well. The
undergarments must be washed or discarded and the diver should shower as soon as
possible. The suit must also be repaired before it can be put back in service.
While the dry suit should be clean at this point, the areas that had been covered by the full-
face mask straps and by the BCD/harness during decontamination should be gently
scrubbed with the same decontamination solution used earlier. The dry suit can be moved
to the Support Zone or reused after decontamination has been completed.
Once the dry suit has been removed, the diver has completed contaminant reduction, and
can enter the Support Zone, where resources should be available for the diver to wash his
or her hands and face. If available, a full shower with soap is preferred.
The diver should remain in the Support Zone for thirty minutes for observation. During
this time, the diver should be given water or other non-caffeinated drinks and allowed to
rest in a comfortable area. During the warmer months, a tent or other shaded area should
be used if available. During colder weather, a sheltered area, preferably indoors should be
used if available.
In the case of an emergency during a dive or during any stage of the decontamination process, an emergency
decontamination procedure should be used. The Divemaster will determine the extent of decontamination
required based on the level and type of contamination encountered versus the risk involved in delaying
medical treatment. Efforts should be made to minimize exposure of the diver and emergency personnel to
residual contamination. Information on the type and level of contamination associated with the site must
be forwarded to the attending medical personnel so they may take appropriate precautions to protect
themselves and others from exposure.
Before leaving the Contaminant Reduction Zone, the tender must remove all potentially contaminated PPE.
At the edge of the Contaminant Reduction Zone and the Support Zone, the exposure suit (e.g., Tyvek suit,
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etc.) should be pulled off inside out, taking care not to contaminate the tender’s undergarments or skin.
After the suit has been pulled down past the tender’s waist, the tender should sit on a clean seat facing the
Contaminant Reduction Zone and pull the suit off his or her legs. As each boot cover is pulled off inside
out, the tender should turn and place the uncovered foot down on the side of the seat facing the Support
Zone. Gloves should then be pulled off inside out and left in the Contaminant Reduction Zone. The tender
should then wash his or her hands and face with soapy water. All PPE should be discarded with the other
site-derived waste.
At the end of each day, the full-face mask should be completely decontaminated following the
procedure recommended by the manufacturer. For AGA masks the following procedure should be
utilized:
• The AGA mask should be immersed in warm potable water and cleaned to remove any
gross contamination and debris from the mask.
• The front cover assembly (or communications unit) should be removed by unscrewing the
two thumb screws. The regulator (breathing valve) should be removed from the mask body
by rotating one half turn clockwise and pulling outward. Dismantle the breathing valve by
unscrewing the locking ring to remove the positive pressure unit. Only turn the locking
ring, since turning the positive pressure unit may damage the o-ring used to seal the unit to
the body of the breathing valve. The positive pressure unit assembly should be
disassembled by removing the diaphragm assembly and separating the components
(diaphragm assembly, spring and guide disk, and sealing disk). Do not disassemble the
diaphragm assembly. Check for debris and damage to the diaphragm.
• Immerse all parts (with the exception of the communications unit) in a mild
cleaning/disinfecting solution. Allow at least ten minutes contact time, remove and rinse
all parts thoroughly with potable water. Place all parts on a clean towel and allow to air
dry.
• After all parts have dried, check all parts for visible damage, degradation or contamination.
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Lubricate the o-rings and the sealing disk shaft with oxygen-compatible silicone grease.
Reassemble the breathing valve and attach it to the AGA mask. The AGA mask function
should be tested prior to storage. After testing function, screw the dust cap onto the hose
connection, and place the mask into a large plastic bag for storage.
At the end of each day, the diving helmet should be completely decontaminated following the
procedure recommended by the manufacturer and as generally outlined below.
• The helmet should be immersed in warm potable water and cleaned to remove any
remaining gross contamination and debris on the external surfaces helmet.
• If the helmet is shared between divers liners and nose cups should be replaced or
decontaminated as necessary.
The dry suit should be inspected and additional decontamination and/or repairs should be
performed as needed. The suit should be inspected carefully for tears, abrasions, holes or areas
where chemical damage may have occurred. Brittleness, stickiness, color changes, or swollen
materials could indicate significant chemical damage. Any suit exhibiting these conditions should
be removed from service and returned to the manufacturer for evaluation and/or repair.
As practical, all other equipment (BCDs, weight harnesses, EGS harnesses, fins, knives, tools, etc.)
should be decontaminated based on the contaminant.
• Gross contamination should be removed by rinsing or brushing with potable water. Greasy
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• Hard-surfaced equipment (e.g., knives, tools) generally doesn’t require soaking, but
porous-surfaced equipment (e.g., nylon webbing harnesses, BCDs) should be soaked in an
appropriate decontamination solution for a minimum of 10 minutes. It should then be
scrubbed, rinsed with potable water, and examined. The procedure should be repeated until
the equipment is clean. The equipment should also be examined for damage. Any
equipment showing signs of damage should be removed and evaluated before being reused.
Of particular importance is equipment used for life support or diver safety. This includes
BCD bladders, harness webbing, etc.
6.0 REFERENCES
Barsky, S.M., Diving in High-Risk Environments, 4th Edition, 2007, Hammerhead Press, Ventura, California.
CDC (Centers for Disease Control and Prevention). 2002. Guideline for Hand Hygiene in Health-Care Settings:
Recommendations of the Healthcare Infection Control Practices Advisory Committee and the HICPAC/SHEA/APIC/IDSA
Hand Hygiene Task Force. Morbidity and Mortality Weekly Report, volume 51, number RR-16, October 25, 2002.
DUI (Diving Unlimited International, Inc.). 2009. Public Safety Diving Equipment, Personal Incident Decontamination
System. Information downloaded September 2009. Available at www.DUI-Online.com.
EPA (United States Environmental Protection Agency). 1985. Interim Protocol for Diving Operations in Contaminated
Water. Author, R.P. Traver, U.S. EPA Office of Research and Development, Hazardous Waste Engineering Research
Laboratory, Cincinnati, Ohio. EPA/600/2-85/130.
EPA (United States Environmental Protection Agency). 1992. Standard Operating Safety Guides. U.S. EPA Office of
Emergency and Remedial Response, Washington, DC. EPA/540/6-92/XXX.
EPA (United States Environmental Protection Agency). 2010. Sheldrake, Pedersen, Humphrey et. al. EPA three part
polluted water diving module presentations, AAUS 2010
Hendrick, W., A. Zaferes, and C. Nelson. 2000. Public Safety Diving. Fire Engineering Books & Videos. Saddle Brook,
New Jersey.
Henkener, J.A., R. Ehlers. 2000. Study to Identify Chemical and Biological Threats to U.S. Navy Divers and Swimmers.
Final Report. Prepared for the Naval Experimental Diving Unit, Panama City, Florida by Southwest Research Institute, San
Antonia, Texas under contract number N6133198D00006/0021.
Hoffman, D.J., B.A. Rattner, G.A. Burton Jr, J. Cairns Jr. 2003. Handbook of Ecotoxicology. Second Edition. Lewis
Publishers, CRC Press LLC, Boca Raton, Florida
Interspiro. Undated. Instruction Manual Divator MKII Face Mask. Publication number 95283-01. Interspiro, Inc.,
Branford, Connecticut.
Jagminas, L. and D.P. Erdman. 2006. Chemical, Biological, Radiological, Nuclear and Explosives (CBRNE) - Chemical
Decontamination. Available at http://emedicine.com/emerg/topic893.htm.
LBL (Lawrence Berkeley National Laboratory). 2006. Biosafety Manual: Decontamination. Lawrence Berkeley National
Laboratory, Environment, Health and Safety Division, Biosafety Program. Available at
http://www.lbl.gov/ehs/biosafety/manual/index.shtml.
NIOSH (National Institute for Occupational Safety and Health). 2005. NIOSH Pocket Guide to Chemical Hazards. NIOSH
Publications, Cincinnati, OH. NIOSH Publication 2005-149.
NIH (National Institutes of Health). 2006. Guide to Biodecontamination. National Institutes of Health, Division of Safety,
Office of Research Services. Available at: www.nih.gov/od/ors/ds/pubs/biodecontamination/index.html.
NIJ (National Institute of Justice). 2001. Guide for the Selection of Chemical and Biological Decontamination Equipment
for Emergency First Responders, NIJ Guide 103-00. National Institute of Justice, Law Enforcement and Corrections
Standards and Testing Program, National Law Enforcement and Corrections Technical Center, Rockville, Maryland.
October 2001.
NOAA (National Oceanographic and Atmospheric Administration). 2001. NOAA Diving Manual - Diving for Science and
Technology, Fourth Edition. United States Department of Commerce. J.T. Joiner, editor. Best Publishing Company,
Flagstaff, Arizona.
Purdue (Purdue Products LP). 2005. Betadine Solution (10% povidone iodine), Material Safety Data Sheet. Purdue
Products LP, Stamford, Connecticut. MSDS prepared July 2005.
US Navy (United States Navy). 2004. Guidance for Diving in Contaminated Waters. Technical Manual #SS521-AJ-PRO-
010. Naval Sea Systems Command, Washington Navy Yard, DC. August 2004.
USVA. (United States Department of Veterans Affairs). 2006. Chemical Terrorism General Guidance Pocket Guide. US
Department of Veterans Affairs, Office of Quality and Performance, Clinical Practice Guidelines. Available at
www.oqp.med.va.gov/cpg/cpg.htm.
Viking. 2001. Diving in Contaminated Water, 3rd Edition: Chemical and Biological Tests of
Viking Dry Suits and Accessories. Trelleborg Viking, Inc., Portsmouth, New Hampshire. Available at
http://www.vikingdiving.com/filearchive/2/2177/DCW144.pdf.
• Shower
NOTES:
Figure 2: Example Vessel configurations delineating Exclusion Zone (red), Contamination Reduction Zone (yellow) and Support Zone
(green) Note wind direction relative to the EZ.
The major considerations when choosing a decontamination solution are; 1) effectiveness against the expected site
contaminants; 2) compatibility with dry suit materials and other equipment; 3) safety of exposure to both the diver and the
tenders; 4) availability and cost; 5) use of biodegradable decontamination solutions or containment and disposal of used
non-biodegradable solutions. Decontamination solutions and procedures should be described in the HASP prior to going
on-site.
There are numerous decontamination solutions to choose from. Unfortunately, many of the most effective decontamination
solutions are very aggressive, corrosive and toxic (LBL 2006). Many disinfectants and sterilants are well suited to cleaning
hospital surfaces and equipment, but are not safe to use on divers or some dive equipment. The objective of decontaminating
the diver is to remove the contamination from the diver’s suit so that the suit can be safely removed. There is no necessity
to use solutions that are potentially dangerous to the diver or the equipment when other less dangerous solutions will yield
satisfactory results. Removing the contaminants from the diver is more important than neutralizing chemical contaminants
or killing biological contaminants. Killing biological contaminants on the divers suit/equipment will usually not be the goal
of the initial stage of the decontamination process (while the diver is still dressed), due to the wet contact time required to
achieve this. A secondary definitive decontamination of dry suits and equipment may be required after the dry
suit/equipment has been removed. Since some of the contaminants at a site may be unknown, it is necessary to use a
decontamination solution that is effective for a variety of contaminants (EPA 1985).
Decontamination solutions prepared from concentrated products (e.g., soap or bleach) should be diluted with potable water
and not site water, since site water may negatively impact the final strength of the prepared decontamination solution.
It is recommended that prior to the start of site activities the contaminants of concern should be identified and care should
be given to select the most appropriate decontamination solution(s). If contaminants are anticipated but not well documented
a very conservative approach should be used in selecting the most effective broad based decontamination solution(s).
Antimicrobial soap is generally a very effective decontamination solution since it will kill some biological contaminants
and is also a surfactant which will remove most contaminants from the diver’s suit. When the diver’s suit is contaminated
with oil and/or grease a decontamination solution with degreasing properties such as Simple Green may be effective as a
single decontamination solution or in conjunction with other decontamination solutions. Although an iodine based
decontamination solution such as Betadine or alcohol may not be useful as a primary decontamination solution, it may be
most effective for use decontaminating various pieces of dive equipment such full face masks (i.e., AGA masks). Harsher
or more aggressive decontamination solutions such as tri-sodium phosphate (TSP) and quaternary-ammonium compounds
(quats) may not be an ideal primary decontamination solution, but may be useful in performing a secondary definitive
decontamination on certain equipment after it has been removed from the diver. Certain commercially available
decontamination solutions such as DF200 have been tested and shown to be effective on specific biological and chemical
contaminants. Although this solution is more expensive than many of the other decontamination solutions listed below,
when those contaminants are present DF200 would likely be the most reliable decontamination solution available.
As noted above, the most important decontamination solution is potable water (EPA, 2010). A plentiful supply of
potable water, preferably from a low-pressure hose hooked up to a municipal water supply or a large water tank is
the first and last step of all decontamination procedures. If a large tank is not available, smaller containers (e.g., 5-
gallon buckets, collapsible plastic containers, Hudson sprayers) of potable water should be available. Water from
a hose should not be under pressure any higher than typical municipal water pressure (40 to 70 pounds per square
inch). High pressure hoses (e.g., pressure washers) may damage the diver’s suit or force contaminants into seams
or contaminate nearby surface support personnel. In some instances a thorough rinse with potable water is all the
decontamination the diver needs (e.g., after diving in salt water).
A strong solution of soap/cleaning solutions (dish soap typically has more surfactant than hand soap) is the next
most commonly used decontamination solution. Commercial soaps/cleaning solutions are readily available and
produced by numerous companies using different various synthetic and/or natural active ingredients. When
selecting a soap/cleaning solution the following properties should be considered:
1) Surfactant Effectiveness – The greater the surfactant effectiveness the easier the solution will remove
contaminants and oil/grease during the decontamination process. A soap’s surfactant action will remove most
organic contamination, and scrubbing with soapy water will remove sediment-associated inorganics (e.g.,
metals). Soap will also wash away biological contaminants (when biological contaminants are washed off,
they are not killed, but their physical remove can result in an effective decontamination). When
decontaminating oils and grease, the surfactants effectiveness is usually a key consideration when selecting an
appropriate decontamination solution.
2) Antimicrobial Properties – Some soap/cleaning solutions include antimicrobial additives. The active
ingredient used in most antimicrobial soaps is triclosan. Triclosan works, even at very low concentrations, by
blocking enoyl-acyl carrier-protein reductase (ENR), preventing bacteria and fungi from producing fatty acids
needed for cell membranes and other vital functions (Senese 2005). Humans don’t have the ENR enzyme,
and so triclosan is harmless enough for use in a wide variety of consumer goods including cosmetics and
toothpaste (Senese 2005). Because of its effectiveness and safety, antimicrobial dish soap is often the
solution of choice for decontaminating patients arriving at hospital emergency rooms (USVA 2006; Jagminas
2006). In hand-washing experiments, antimicrobial soap was shown to be more effective at removing
biological agents than soap with no antimicrobial additive (CDC 2002).
3) Biodegradability - Many biodegradable products are readily available. When decontamination solutions may
be released into the environment during the decontamination process a biodegradable product should be used.
When the decontamination solutions are controlled and contained, this criterion is of less importance. The
products biodegradability is usually specified on the products label or the associated Material Safety Data
Sheet (MSDS).
Biodegradable antimicrobial soap is a useful decontamination solution because it has wide applicability, ready
availability, it is safe for use on both the diver and the diver’s suit, and it requires no special PPE or disposal. The
leftover soap solution can be used to clean the decontamination zone, the boat or other equipment.
Numerous other safe, effective and biodegradable decontamination soap/cleaning solutions (with or without
antimicrobial agents) are available and should be considered based on decontamination requirements. These
products include Simple Green® All-Purpose Cleaner (general all purpose cleaner/degreaser), Citrus Klean (natural
citrus based cleaner/degreaser), BioSol (Organic solvent degreaser), ZEP Big Orange (natural citrus based
cleaner/degreaser), ZEP Acclaim (liquid hand soap), Orange Blossom (natural citrus based cleaner/degreaser) and
Citrus Magic (natural citrus based cleaner/degreaser). These products contain various natural and synthetic active
ingredients including citrus terpenes [d-Limonene], sodium silicate/metasilicate, linear alcohol ethoxylate, sodium
iminodisuccinate, monoethanolamine, dipropylene glycol methyl ether, dipropylene glycol monomethyl, and
sodium dodecylbenzene suflonate.
Bleach
Sodium hypochlorite, in the form of chlorine bleach, is a biocide that is readily available in most supermarkets.
Household bleach is approximately 6% sodium hypochlorite (Clorox 2005). A 5% solution of bleach
(approximately six ounces mixed into a gallon of water) will kill most bacteria, fungi and viruses on a hard, non-
porous surface after a five minute contact time (Clorox 2006). In order to overcome the consumption of free
chlorine by organic matter in the site water, a 10% solution of bleach (12 ounces in a gallon of water) should be
used for diver decontamination. Contact time, in this case, is defined as the length of time the wet solution is in
contact with the surface to be cleaned. Contact time should be adjusted to at least ten minutes to adjust for the
differences between dive equipment and hard surfaces. It is difficult to keep the diver wet for the entire contact
time so bleach is not the best choice to decontaminate the diver’s suit. However, it is quite simple and effective to
soak the diver’s fins, harness, BCD, etc. Care must be taken when using bleach as a decontamination solution,
since it will burn eyes and mucous membranes in a 10% solution. Bleach straight from the bottle can burn
unprotected skin and can damage clothes and dive equipment. Proper PPE (e.g., disposable rain suits, face shield,
surgical gloves) is mandatory when using bleach as a decontamination solution.
Calcium hypochlorite is also used as a biocide, and it is readily available in powder form (e.g., swimming pool
chlorine granules). A 10% calcium hypochlorite solution has greater available chlorine than a sodium hypochlorite
solution. However, the powder is not readily soluble in water, and should be mixed thoroughly in warm, preferably
soft to moderately hard water prior to use. This makes it difficult to achieve a desired concentration. Calcium
hypochlorite granules can burn unprotected skin and can damage clothes and dive equipment. The powder also
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poses an inhalation risk (Arch Chemicals 2002). Proper PPE (e.g., disposable rain suits, face shield, respirator
mask, surgical gloves) is mandatory when using calcium hypochlorite as a decontamination solution.
Betadine
Betadine is a brand name for a 10% povidone-iodine solution commonly used in hospitals to disinfect wounds and
prepare skin for surgery. Undiluted Betadine will kill most pathogens after ten minutes of contact time. Contact
time, in this case, is defined as the length of time the wet solution is in contact with the surface to be cleaned. The
diver must effectively be kept wet with undiluted Betadine for the entire contact time to prevent the solution on the
suit from drying. Iodophors such as Betadine use povidone to slow the release of iodine, while using surfactants to
increase penetration (Abedon 2003). Since the solution is reddish-brown, it may be easy to see if any areas of the
diver’s suit have been missed. Care must be taken when using Betadine as a decontamination solution since
prolonged contact of large skin areas can lead to excessive absorption of iodine (Purdue 2005). Betadine will also
burn eyes and mucous membranes, and will stain clothing, dive equipment, and boats. Proper PPE (e.g., disposable
rain suits, face shield/eye protection, gloves) is mandatory when using Betadine, and it is recommended that all
surrounding surfaces be covered with disposable plastic sheeting to prevent permanent staining.
Pre-mixed iodine based solutions with a cleaning agent such as Multi-Wash™ Mini have been tested and are
commercially available. These types of solutions may not be ideal for primary diver decontamination but are
effective in cleaning and disinfecting certain types of dive gear such as full-face masks (Scott Health and Safety
2009).
Quaternary-Ammonium Compounds
Many commercial and household cleaners are based on quaternary-ammonium compounds (quats). These products
(e.g., Zepamine A) are designed primarily for deodorizing and sanitizing general household areas, kitchens,
cafeterias, food processing equipment/utensils. Additional uses include algae control in pools and cooling systems
(Zep 2006). Quats are highly toxic to fish and aquatic plants, and care should be taken not to allow decontamination
liquids to enter any body of surface water. If quats are mixed with chlorine bleach, the exothermic reaction is
potentially explosive and the resultant chlorine gas may be hazardous. Quats are also corrosive to skin and eyes,
and proper PPE and disposal of wash fluid is required.
TSP
TSP is an acronym for tri-sodium phosphate, a strong cleaner/degreaser. However, in the 1970s use of phosphate-
containing products was limited. Some products on the market today that are sold as TSP may contain other
ingredients and can be less than half TSP (Savogran 2001a). Other products sold as TSP or TSP-substitutes may
contain no phosphate and may be acutely corrosive to skin and eyes (Red Devil 2006, Savogran 2001b). TSP
products are commonly used to prepare surfaces for painting, remove mildew from home siding, and remove stains
from patios or driveways. While TSP is a common household cleaner, it is not appropriate for some materials. TSP
will stain metals and can etch glass and fiberglass. When using TSP solutions, care should be taken to cover the
surrounding area with plastic sheeting and the decontamination liquids should not be allowed to enter any body of
surface water. Proper PPE and disposal of wash fluid is mandatory when using TSP products.
Isopropyl alcohol (IPA) is also a good biocide (NIH 2006), and while it is not appropriate for decontaminating the
diver’s entire suit and/or equipment, it is ideal for wiping down the areas under the seals of the diver’s AGA mask
(the latex seal around the diver’s face where the mask meets the dry suit), or around the area where the diver’s
helmet mates to the dry suit. IPA is readily available in supermarkets as a 70% IPA/30% water solution, or as
individually packaged wipes. Contact time is immediate. Care should be taken not to get IPA on the diver’s face
or in the diver’s eyes. The readily available 70% IPA solution should not be diluted further before use. Tenders
should wear at least eye protection and gloves when working with IPA.
DF200
There have been several recently developed commercial decontamination solutions that have been demonstrated to
be effective in neutralizing chemical and biological warfare (CBW) agents. DF-200 is one of these products that
have been shown to be very effective against CBW agents while being environmentally safe, work on a wide range
of material surfaces and need contact times ranging from about 1 to 30 minutes depending on the organism (DUI
2009).
EasyDECON™ DF200 by Intelagard, a DF200 based decontamination solution distributed by Diving Unlimited
International (DUI), was developed as a decontamination solution for use with CBW agents, but it has also been
shown to be effective with a select number of toxic industrial chemicals (i.e., organophosphates, chlorine, ammonia,
hydrogen cyanide and malathion) and other biological pathogens (E. coli, Salmonella, Pfiesteria, Giardia, fungus
and molds) (DUI 2009). Although DF200 will neutralize biological contaminants and select chemicals (i.e.,
organophosphates) it will also act as a surfactant, removing but not neutralizing other chemicals, such as oil/metals
etc. Although DF200 may be most effective in some decontamination procedures, unlike many of the other
solutions listed, it is not readily available in the field and would be one of the most expensive decontamination
solutions evaluated.
For crude oil/grease on a dry suit or other dive equipment, a variety of cleaning solutions or wipes impregnated
with cleaning agents/degreasers are available. For disinfecting the area under a diver’s AGA mask seal or where
the helmet mates with the dry suit a variety of individually sealed wipes are readily available (e.g., Saniwipes,
benzalkonium chloride wipes, etc.). For chemical and biological agents from terrorism-related incidents, the
National Institute of Justice lists other decontamination solutions that may be investigated for suitability (NIJ 2001).
Before using any cleaning solvent, its safety for skin contact and compatibility with dry suit and equipment materials
must be assessed.
REFERENCES
Abedon, S.T. 2003. Sterilization and Disinfection - Chapter Review for Micro 509 course at Ohio State University.
Available at www.mansfield.ohio-state.edu/~sabedon/black12.htm.
Arch Chemicals, Inc. 2002. Material Safety Data Sheet: HTH Dry Chlorine Granular. Arch Chemicals, Inc., Norwalk,
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, April 15, 2016)
Appendix Q-33
Connecticut. MSDS prepared February 2002.
Clorox (The Clorox Company). 2005. Clorox Regular Bleach, Material Safety Data Sheet. The Clorox Company,
Oakland, California. MSDS prepared May 2005. Available at www.clorox.com.
Clorox (The Clorox Company). 2006. Clorox Bleach, Frequently Asked Questions. The Clorox Company, Oakland,
California. Information downloaded February 2006. Available at www.clorox.com.
CDC (Centers for Disease Control and Prevention). 2002. Guideline for Hand Hygiene in Health-Care Settings:
Recommendations of the Healthcare Infection Control Practices Advisory Commitee and the
HICPAC/SHEA/APIC/IDSA Hand Hygiene Task Force. Morbidity and Mortality Weekly Report, volume 51, number
RR-16, October 25, 2002.
DUI (Diving Unlimited International, Inc.). 2009. Public Safety Diving Equipment, Personal Incident Decontamination
System. Information downloaded September 2009. Available at www.DUI-Online.com.
EPA (United States Environmental Protection Agency). 1985. Interim Protocol for Diving Operations in Contaminated
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Laboratory, Cincinnati, Ohio. EPA/600/2-85/130.
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Final Report. Prepared for the Naval Experimental Diving Unit, Panama City, Florida by Southwest Research Institute,
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Jagminas, L. and D.P. Erdman. 2006. Chemical, Biological, Radiological, Nuclear and Explosives (CBRNE) - Chemical
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NIH (National Institutes of Health). 2006. Guide to Biodecontamination. National Institutes of Health, Division of
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NIJ (National Institute of Justice). 2001. Guide for the Selection of Chemical and Biological Decontaminatioin
Equipment for Emergency First Responders, NIJ Guide 103-00. National Institute of Justice, Law Enforcement and
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Red Devil. 2009. Material Safety Data Sheet: TSP-90 Heavy Duty Cleaner. Red Devil, Inc., Union, New Jersey. MSDS
prepared March 2009.
U.S. Environmental Protection Agency
DIVING SAFETY MANUAL
(Revision 1.3, April 15, 2016)
Appendix Q-34
Savogran. 2001a. Material Safety Data Sheet: TSP. Savogran, Norwood, Massachusetts. MSDS prepared August 2001.
Available at: http://www.savogran.com/Information/TSP_MS.pdf.
Savogran. 2001b. Material Safety Data Sheet: Liquid TSP Substitute. Savogran, Norwood, Massachusetts. MSDS
prepared September 2001. Available at: http://www.savogran.com/Information/TSP_Liquid_Sub_MS.pdf
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Health and Safety, Monroe, North Carolina. Information downloaded October 2009. Available at
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Sunshine Makers. 2006. Material Safety Data Sheet: Simple Green, also for: Simple Green Scrubbing Pad. Sunshine
Makers, Inc., Huntington Harbour, California. MSDS prepared January 2006.
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Deodorant/Sanitizer. Zep Manufacturing Company, Atlanta, Georgia. Product number 1823. Information downloaded
March 2006. Available at www.zep.com.