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This is an update and almost a conclusion to my query to the net about OSHA certification for divers. I called the local OSHA office and, through an amazing stroke of luck, managed to contact the right person within four hours of placing my first call. It turns out that OSHA does not have a specific certification for divers. It *does* have a detailed set of instructions for divers that includes imperatives for dive planning, dive procedures, and post-dive reporting. These are in the mail and should arrive by Tuesday. If anybody is interested, I'll post a summary. (One thing federal and state government employees seem to be consistent about is getting things in the mail once they've said they'd send them.) There *are* OSHA certification courses for Emergency Response Units. In a nutshell, an "emergency" is an uncontrolled spill or other emission of hazardous or toxic substances in a public or working environment. In order to be part of an official (i.e., designated and paid) Emergency Response Unit, workers must have the appropriate OSHA- sanctioned training in handling the specific type of spill or emission. Similarly, any work to be performed on a listed Hazardous Waste Site or EPA Super Fund Site must be done by "OSHA-certified" employees. The outcome of my conversation with the OSHA representative was this: 1. The waters in which we find these barrels are not listed Hazardous Waste Sites nor EPA Super Fund Sites. (We wouldn't be in there, if they were.) No special training is therefore required of us. 2. The barrels we find do not constitute an "emergency." That is, they are not uncontrolled spills or emissions of hazardous or toxic substances. If we can get them out of the water before the barrels rupture, they will never become "emergencies." No special training is therefore required of us. 3. We are not paid employees of any governmental agency, so no agency can be held responsible for any mishaps that occur while we retrieve a barrel from the water. What this all means is that, in the bureaucratic reluctance to help us remove these barrels from our waterways, the statement that "OSHA- certified divers will have to be called in" is either a misunderstanding by the government employee or a deliberately placed obstacle to doing the right thing. I believe the former is the case. These OSHA-certified divers that have been hired in the past are apparently divers who have been trained to submerge in high-tech isolation suits in waters dangerously polluted by industrial spills (to seal a leak in a chemical-waste holding tank, for example) in full compliance with OSHA-mandated safety requirements. This is clearly overkill for what we're trying to accomplish. So it looks like we may have just shaved about $4,000 off the cost of removing a barrel from our local waterways. Now, if there's any further interest in the nuts & bolts of performing one of these barrel-removal operations, you can read on. I'm using Lewis Johnson's comments as the template. ==================================================================== > How will you control the barrels you remove to prevent leaks? We'll use an "overpack" or "containment" barrel. This is an 85-gallon drum (bright yellow, with "Salvage" printed in red letters in five languages on the side). The substrate determines the best way to get the offending 55-gallon drum into the overpack barrel. If the drum is on a silt bottom, which is usually the case, we'll first determine the depth of silt. Then we figure out which is the "bung end" of the 55- gallon drum. Then we slide the overpack drum around the 55-gallon drum, starting at the bottom end. (This makes it easier for the expert on shore to siphon off the water and determine the contents right there on site. If we put the drum in the overpack barrel upside down, they have to cart it off and do the tests in a controlled environment.) Then we put the top on the overpack barrel and seal it. At that point, we put a harness made of weightbelt webbing around the barrel, attach a 200-pound lift bag, and raise the overpack barrel to the surface. (We have about 1000 pounds of lift available in bags of various sizes, so if the 200-pound lift bag isn't enough, we'll just add bags until we do have enough.) My local fire department, which got an earful from a bunch of people last year when they were unable to help extract a barrel we found in our local drinking water supply, donated an overpack barrel to the DES just last week. > What about air reactive chemicals? We're not worried about air-reactive chemicals. All our work is done underwater. Water-reactive metals are a potential problem, though. The kinds of drums water-reactive metals are placed in *should* be recognizable, though. We'll cross that bridge when we come to it. We're trying to get these barrels, most of which have long since lost their contents, out of the water. Even empty, they remove DO from the water in their normal oxidation process. From our perspective, as aquatic environmentalists, these barrels constitute an unnatural threat to the habitat even when they're empty. Unfortunately, we have to treat every intact barrel as if it contained hazardous or toxic waste. Hence the dance with government environmental agencies every time we find one. > Where will you store your recovered barrels? We won't. That's why the EPA and DEP will be on site and ready to assume possession of suspect barrels as soon as they come up. We'll work out a way for them to replace our overpack barrel if they need to haul it away. > How will you identify the contents? We won't. An expert from one of the environmental agencies will do that. > How will you pay for disposal (that can run $5,000 alone)? We won't. All we're doing is lopping $4,000 off the price of removing a barrel. I believe we have succeeded. The ~$5,000 cost of disposal will only be incurred if it is determined that the contents are indeed toxic. That will come out of one or another agency's budget set aside for this purpose. > Will you preserve evidence useful in identifying responsible parties? Well, we'll try. All we're doing, though, is removing the barrels and handing them over to the appropriate experts on land. A couple years ago, on a survey of the Concord River within the boundaries of Minuteman National Park, our divers came across some ruptured barrels that had destroyed the benthic communities just downstream. That is, the bottom just downstream from the ruptured barrels were wastelands littered with mussel shells. One diver managed to pull part of a label off one of the barrels, but subsequent investigation by the Park Service failed to detect useful information on the remains of the label. > Will you get permits necessary to prevent legal action to yourself? The issue of permits arises on a case-by-case basis. The question about OSHA certification came up because of just such a suspected requirement. It turns out to be a moot point. John Hicks-Courant Divers' Environmental Survey jhc@wo*.st*.co* (800) 645-1470
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