July 6, 1992

MEMORANDUM FOR:  JAMES W. LAKE
                Regional Administrator

FROM:            PATRICIA K. CLARK, Director
                Directorate of Compliance Programs

SUBJECT:         Review of Draft Regional Interpretation, OSHA Commercial
                Diving Standard

The basic issue that has to be resolved with respect to your memorandum is whether a diver-worn "dive computer" provides an acceptable means of establishing a dive profile (depth/time relationships) and maintaining diving records. Unless evidence is available to support a conclusion that a dive computer is as safe or safer than the U.S. Navy Standard Diving Tables, such devices will not be considered to be in compliance with 29 CFR 1910.422(e) and .423(d). In a phone conversation between Mr. Joel Dovenbarger of the Diver's Alert Network (DAN) and Mr. Steve Butler of OCMCA, Mr. Dovenbarger advised us that all dive computers allow for increased diver exposure levels. Therefore, dive computers are inherently less safe than the U.S. Navy Standard Diving Tables. This does not mean that such devices are unsafe, but they are not as safe as the standard diving tables so they cannot be considered as providing equivalent protection without further investigation.

We have requested available information and studies on dive computers from DAN and the U.S. Navy in order to evaluate this matter properly. Upon completion of our evaluation we will advise you further.