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Minimum scuba dive team with two divers underwater

Summary A marine service asked how many team members commercial scuba work needed with two divers underwater. OSHA said the stated arrangement needed at least four people: a person in charge, a standby diver and the two working divers, with added conditions for tending and emergency response. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-02-22
Date issued
February 22, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. Its page carries a 2005 correction.
Status last verified October 9, 2026

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. Its page carries a 2005 correction. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 22, 1996
Mr. Rudy C. Watts
H. T. Marine Services
[Recipient address omitted]
Dear Mr. Watts:
This is in response to your request for an interpretation of OSHA's Commercial Diving standards (29 CFR Part 1910, Subpart T), regarding the minimum number of dive team members required to support scuba diving when two (2) divers are in the water.
In establishing the required number of dive team members required for a particular situation, proper consideration must be given to §1910.421(d) - "Planning and assessment," §1910.421(e) - "Hazardous activities," and §1910.422(b)(3) which requires providing a means to assist an injured diver from the water (e.g., diver stage, small boat, stokes stretcher) or into a bell.
Commercial scuba air diving with two (2) divers in the water requires a minimum of four (4) dive team members as follows: designated person-in-charge (DPIC) [§1910.410(c)], a standby diver [§1910.424(c)(1)], and two (2) divers [§1910.424(c)(2)]. The two (2) divers must be in continuous visual contact of each other or connected by a buddy line. The two (2) divers do not require a tending line to the surface unless they are required to work against a current exceeding one (1) knot. When required or deemed necessary, one (1) tending line to the surface is sufficient when the two (2) divers are connected by a buddy line. With respect to deployment of the standby diver, it is required that the standby diver be line-tended from the surface. The standby diver can be the DPIC provided that he/she is a qualified diver, and that the fourth dive team member is trained and capable of performing all necessary functions of the DPIC while the DPIC is in the water as the standby diver. The standby diver can also be the tender provided that he/she is a qualified diver; in this case the DPIC would assume tending duties when the standby diver is in the water.
Should you require additional clarification please contact [the Office of Maritime Enforcement at (202) 693-2399].
Joe Nolan, Chief
[Office of Maritime Enforcement]
[Corrected 6/2/2005]

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