University Policy
Title
University of North Carolina at Chapel Hill Policy on Diving for Scientific Research Purposes
Introduction
Purpose
This policy provides those using scuba diving to conduct underwater scientific research, hereafter referred to as “scientific diving”, with the resources needed to perform their university-sanctioned scientific diving efficiently and at the levels of training, safety and oversight established by the American Academy of Underwater Sciences (AAUS) that are required to claim the Scientific Exemption from the Occupational Safety and Health Administration (OSHA) Commercial Diving Standards outlined in 29 CFR Part 1910 Subpart T. A list of regulations and guidance documents are included in this policy to ensure that the audience is provided access to the requirements for scientific diving at the University.
Each regulatory document is intended to protect the welfare of university faculty, students and staff conducting scientific diving. Non-compliance can result in the University losing its Organizational Membership with AAUS and no longer being able to claim the Scientific Exemption from the OSHA Commercial Diving Standards outlined in 29 CFR Part 1910 Subpart T. Dependent upon the funding source, the potential impact for non-compliance with this policy may result in external reporting to Federal regulatory agencies (OSHA), accrediting bodies (AAUS), reimbursement of research funds, and suspension of scientific diving privileges.
Scope
All University of North Carolina at Chapel Hill (UNC-Chapel Hill) persons involved with scientific diving, but not limited to Principal Investigators, researchers, and students.
Policy
Policy Statement
This policy defines the expectations of the University’s Scientific Diving Control Board (DCB) with regards to adherence to federal regulations, state and University standards, and the UNC Chapel Hill Scientific Diving Program Diving Safety Manual (henceforth UNC-Chapel Hill Scientific Diving Safety Manual).
Environment, Health and Safety (EHS)
EHS is responsible for establishing policy and providing guidance to facilitate compliance with the standards for Scientific Diving established by the American Academy of Underwater Sciences and required to claim the Scientific Diving Exemption to the OSHA Commercial Diving standards.
University Programs and/or Departments
Programs and/or Departments ensure employees/students who are conducting scientific diving are compliant with this policy.
Scientific Diving Control Board (DCB)
The DCB is responsible for operational control; developing and maintaining the UNC-Chapel Hill Scientific Diving Safety Manual, reviewing and approving dive plans; and notification and revocation of unapproved dive plans. The board consists of active University scientific divers, a Diving Safety Officer (DSO), EHS and other relevant designated personnel. The DCB has autonomous and absolute authority over the University scientific diving program’s operations.
Principal Investigator
PIs are responsible for adhering to Scientific Diving policies, communicating scientific diving policies to their research groups, and ensuring that members of their research groups communicate with the DSO regarding dive plans before submission to the DCB. PIs are also responsible for updating their lab safety plans, denoting all personnel performing scientific dives, and communicating training and medical clearance requirements to these personnel. Additionally, Principal Investigators are responsible for annual submission of the EHS Worker Registration form, completing required training, obtaining medical clearance, ensuring required dive gear servicing, and timely submission of required documentation for scientific dives. More information can be found about the EHS Worker Registration form in Chapter 2 of the Laboratory Safety Manual.
Employees
Employees are responsible for annual submission of the EHS Worker Registration form, completing required training, obtaining medical clearance, ensuring required dive gear servicing, and timely submission of required documentation for scientific dives.
Students
Students are responsible for annual submission of the EHS Worker Registration form, completing required training, obtaining medical clearance, ensuring required dive gear servicing, and timely submission of required documentation for scientific dives.
Compliance and Exceptions
Anyone involved in scientific diving at the University is expected to comply with the following:
- AAUS Standards for Scientific Diving
- The UNC-Chapel Hill Scientific Diving Safety Manual
Requests for exceptions to any of the above must be reviewed and approved by the Scientific Diving Control Board.
Definitions
OSHA: Occupational Safety and Health Administration: Part of the United States Department of Labor with the mission to assure America's workers have safe and healthful working conditions free from unlawful retaliation. OSHA carries out its mission by setting and enforcing standards; enforcing anti-retaliation provisions of the OSH Act and other federal whistleblower laws; providing and supporting training, outreach, education, and assistance; and working collaboratively with state OSHA programs.
AAUS: American Academy of Underwater Sciences: A group of scientific organizations and individual members who conduct scientific and educational activities underwater. The mission of the AAUS is to facilitate the development of safe and productive scientific divers through education, research, advocacy, and the advancement of standards for scientific diving practices, certifications, and operations. These are the consensual guidelines for scientific diving programs in the US, and are recognized by Occupational Safety and Health Administration (OSHA) as the "Standard" for scientific diving. These standards are followed by all AAUS Organizational Members allowing for reciprocity between institutions. Each institution is responsible for upholding the standards within its program and among its divers, and thereby claiming the Scientific Exemption from the OSHA Commercial Diving Standards outlined in 29 CFR Part 1910 Subpart T.
DCB: Diving Control Board: Responsible for oversight of scientific diving conducted under the University’s auspices.
Manuals: The UNC-CH Scientific Diving Safety Manual is the version of the AAUS Scientific Diving Standards Manual adapted to the specific conditions and needs of scientific divers at the University. The Manual is also intended to assist investigators in fulfilling their obligations to plan and conduct scientific diving in accord with standards that underpin safe and productive underwater research.
Exception: The DCB requires that a PI formally apply for an ‘exception’ when wishing to deviate from standards and guidelines of the UNC Scientific Diving Manual and University standards. All requests for exceptions must be reviewed and approved by the DCB and the PI must receive written approval prior to implementation.
University Standard: The minimum acceptable standards or rules used to achieve Policy implementation, enforceable by the DCB.
Related Requirements
External Regulations
- American Academy of Underwater Sciences Scientific Diving Standards
- OSHA Standard 1910.401(a)(2)(iv) outlining requirements of a scientific diving program for exemption from OSHA standards for Commercial Diving Operations
University Policies, Standards, and Procedures
Contact Information
Any questions regarding this standard should be directed to the Department of Environment, Health and Safety:
Unit: Environment, Health and Safety
Title: EHS Director and/or Workplace Safety
Website: ehs.unc.edu
Phone: 919-962-5507
Primary Contact
Name: Steve Broadhurst
Title: Diving Safety Officer, and Member, UNC-Chapel Hill Diving Control Board
Email: unc.dso@unc.edu
Telephone: (252) 622-5562
Other Contacts
Name: Johanna Rosman, Associate Professor
Title: Chair, Diving Control Board
Unit: Department of Earth, Marine and Environmental Sciences (EMES)
Email: jrosman@email.unc.edu
Phone: (252) 726-6841 extension 224
Name: Niels Lindquist, Professor
Title: Member, Diving Control Board
Unit: Department of Earth, Marine and Environmental Sciences (EMES)
Email: nlindquist@unc.edu
Phone: (252) 726-6841 extension 136
Name: Karl Castillo, Associate Professor
Title: Member, Diving Control Board
Unit: Department of Earth, Marine and Environmental Sciences (EMES)/Environment, Ecology and Energy Program
Email: kdcastil@email.unc.edu
Phone: (919) 843-8752