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Minimum teams for commercial scuba and surface-supplied dives

Summary A diving contractors' association asked for minimum team sizes for scuba and surface-supplied air dives. OSHA said each described setup required at least three people, with the roles and tending duties differing by method. A standby diver might also be required for surface-supplied work if the dive hazard assessment called for one; OSHA now archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-10-29
Date issued
October 29, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 29, 1996

Mr. Ross Saxon, Executive Director
Association of Diving Contractors, Inc.
[Recipient address omitted]
Dear Mr. Saxon:

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 air dives using scuba equipment and surface-supplied diving equipment. In establishing the required number of dive team members required for a particular situation, proper consideration must be given to §1910.421(d) - "Planning assessment", §1910.421(e) - "Hazardous activities", and §1910.422(b)(3) which requires providing a means to assist an injured diver from the water or into a bell.

Commercial scuba air diving requires a minimum of three (3) dive team members as follows: designated person-in-charge (DPIC) sometimes referred to as the diving supervisor [§1910.410(c)], a standby diver [§1910.424(c)(1)], and a line-tended diver [§1910.424(c)(2)]. The standby diver can be the DPIC provided that he/she is a qualified diver, and that the third 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.

Commercial surface-supplied air diving requires a minimum of three (3) dive team members as follows: DPIC sometimes referred to as the diving supervisor [§1910.410(c)], and a diver who "shall be continuously tended (by a tender) while in the water" [§1910.425(c)(1)]. For surface-supplied air diving which is 100 feet or less and does not involve scheduled decompression, a standby diver is not a specified requirement for all dives. Also, based upon the requirements of §1910.421(d), "Planning and assessment", the hazard analysis/assessment of the dive may dictate the use of a standby diver even though not specifically required (e.g., underwater debris, suctions, no free access to the surface, possibility of diver entanglement, bottom conditions unknown).

Should you require additional clarification please contact Mr. Steve Butler at (202) 219-8131 x154 or myself at (202) 219-7234 x141.

Sincerely,

Larry Liberatore
Director, Maritime Safety Standards

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