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The NSS-CDS Is Updating How It Teaches Cave Diving

Founded in 1973, the graybeards of Florida cave diving, the National Speleological Society-Cave Diving Division, are rethinking how to teach cave diving. Here CDS chair, Renee Power, along with CDS stalwart, Lamar Hires, explain the reasoning and results, with a bit of underground history thrown in.

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By Reneé Power and Lamar Hires
Header photo L2R: Reggie Ross, Harry Averill, Lamar Hires, Paul Heinerth, Renee Power, Steve Forman, Pam Wooten at DEMA 2019. Photo courtesy of NSS-CDS
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“If you do not change direction, you may end up where you are heading.”  Lao Tzu

Most will agree that change is not always easy.  It is more comfortable to just keep the boat steady and for Heaven’s sake, don’t rock it!  Often when there is directional change in an organization’s structure or processes, philosophies are challenged, egos get bruised, and we find ourselves clinging desperately to “the way we’ve always done it” because “if it ain’t broke, don’t fix it!” Maybe this object of change wasn’t broken ten or twenty years ago, but could it be now?  Could we recognize it and are we open to self and process evolution?  

The National Speleological Society-Cave Diving Section (NSS-CDS) cave diver training program has a long and storied history. Over the years, the cave training organization, which is one of the few training agencies in the world solely devoted to cave diving, has made changes in their teaching approach along the way that made sense at the time. However, when Reggie Ross (instructor # 286) was elected NSS-CDS Training Director in 2019, the Training Committee decided to take a step back and look at its entire training program. 

The committee discovered that most of the programs and training levels were not a good fit for today’s cave and technical diver and, if we were honest, really needed an overhaul in philosophy and presentation. The four-level modular program that we used until the fall of 2019 was instituted many years ago and allowed divers to progress at a comfortable pace, gaining experience between levels. The program was based on North Florida cave diving as it was three decades ago when the springs had higher outflows and longer flood seasons.  Sadly, the North Florida springs now have reduced flow that more mirror Mexico and other destinations. 

Eric Albinsson, Dave Robbins and Chris Brock. Photo courtesy of NSS-CDS.

The entire training program needed to be adjusted in order to accommodate newer styles of cave diving as well as other environmental considerations. It was decided to update the format and progression of the past three decades to provide more bottom time in the configuration that the student planned to dive in, versus simply have them progress from a single cylinder to a back mounted or side mounted doubles configuration.  

Historically, the NSS-CDS Cavern Diver Course was the first step in overhead training and was conducted in a single tank or a double tank configuration with limited gas use. Cavern limits kept students on a single line and taught them to manage their reel, their lighting and their basic overhead diving skills.  Over the years, it transitioned from a stand alone course for safe cavern diving to the gateway to a cave diving program. 

The next level of cave training was the Intro-To-Cave Course that was again conducted in a single cylinder. The Basic Cave Course was the same course only it was conducted in a double tank configuration using limited gas. The limited gas usage rules limited penetration, to avoid decompression, especially the popular North Florida training caves. The course focused on perfecting buoyancy and trim, basic cave dive planning and confident execution of emergency skills and drills, as a prerequisite to advancing further.

The next two levels in the NSS-CDS cave training program were, Apprentice Cave and Full Cave with focus on progressively complex navigation, gas management, decompression strategies and dive planning. With a “temporary” Apprentice Cave rating, the student diver was expected to gain experience prior to enrolling in the Full Cave Course. 

When dive computers and Enriched Air Nitrox came along in the 90s, it became obvious that divers would likely go further into the caves, ignoring the gas limitations set for their level of training. After all, what could go wrong by going into the cave “just a little bit more.”  

Remember Y2K? This “Millennium Bug” was prophesied to negatively rock our world.  Thankfully, the predictions were largely incorrect. However in the diving world, a limit-crushing cylinder configuration came out of the closet and, like it or not, went viral. Hello sidemount! 

Initially, sidemount was a tool utilized by cave explorers to traverse much smaller passages that was simply not possible using traditional back mounted doubles. But then sidemount mutated from a useful exploration tool to a lifestyle choice, at least some of it due to back problems, and the consolidated weight of back mounted doubles.

Students at all levels wanted to train in this configuration. Fast forward to today: sidemount, backmount and rebreather divers all want to dive together, presenting new challenges for traditional training that had to be addressed. 

Out With The Old; In With The New

The Cavern Course

Today, the Cavern Course is again an awareness and safety program. It is strictly a survival course utilizing restricted training limits to help the student develop awareness of overhead environment dangers, how to prevent problems and how to manage them should they occur. Students are taught finning techniques and gas management suitable for the cavern environment along with very basic guideline handling.

Arguably, the course is a critical step in a recreational diver’s mind shift as they learn more about trim and buoyancy while task loaded, and how to manage critical data such as depth, time, and gas supply. Equally important they will experience why these skills are important through discovery learning. This single cylinder course is no longer a prerequisite nor does it count toward further cave training.

The Cave Program

The new NSS-CDS Cave Program is now a two-step process; Apprentice Cave and Cave.  

Apprentice Cave is the first step leading to full NSS-CDS Cave Diver certification. It takes the place of the old Cavern, Basic, and Intro-to-Cave Diver courses.

  • The focus is primarily on limited penetration along the main line. It is also where students learn, and master critical emergency skills.
  • Usable gas supply is limited putting a heavy emphasis on gas matching and dive planning.
  • Provides students with the opportunity to gain limited experience and practice fundamental cave diving skills prior to completing the requirements for Cave Diver certification.

After spending time in the Apprentice Course training, the instructor may deem the student qualified and ready for an extension of limits. The new Apprentice Cave Diver “Statement of Understanding” form initiates this process. This is where the instructor specifies what the extended limits are, and the range the student must stay within.  These extended limits may include gas use, distance, limited decompression and navigation. 

The CDS Basics Orientation Course 

A new prerequisite for enrolling in the Apprentice Cave is certification or proof of experience in the use of back mount or sidemount doubles, and demonstrated proficiency in buoyancy, trim, and the appropriate propulsion techniques needed for cave diving. If the student is unfamiliar to the instructor, the CDS Basics Orientation Course is used as a prep course that includes academics, dry-land and in-water exercises. Completion of this course allows entry into the Apprentice Cave course, but is not a certification. The best part is that this orientation course may be conducted in a swimming pool!

Cave

This is the second and final step toward an NSS-CDS full Cave Diver certification. Usable gas volume is increased, advanced navigational challenges are added and decompression strategies are discussed and executed. Dive planning is expanded to include multilevel dives and more elaborate gas planning. After completing a four to six day cave program, the divers are now trained and confident enough to plan and execute complex navigation cave dives. 

All of the NSS-CDS Training Standards and Procedures are getting an overhaul section by section to include Special Programs, Specialty Courses and Leadership Standards.  This is an extensive project taken on by the Training Committee.  We expect this undertaking to take some time but we are off to a positive start.

And those aren’t the only changes! We also created:

  • A beautiful new website that looks and works better.
  • A brand new subdomain dedicated to the Training Program. 
  • Regular issues of Training Program News.
  • Better branding with a stunning new logo that is instantly recognizable.
  • A painless renewal process for instructors (yay!).
  • Simplified forms and payment for student registration.
  • International outreach. 

Although Reggie Ross has left this earth, his vision lives on. [Ed.note: Reggie passed on December 24, 2019] Max Kuznetsov was elected as the new NSS-CDS Training Director.  Max and his Training Committee, will undoubtedly continue to lead us boldly into an even better future.

End Note: The NSS-CDS training committee consists of Max Kuznetsov, Harry Averill, Chris Brock, Paul Heinerth, Lamar Hires, Ted McCoy, and Ken Sallot.

Additional Resources:

Check out the History of NSS-CDS

The first issue of what is now Underwater Speleology, circa March 1974
Underwater Speleology May/June 1995 Vol 22 No. 3-Note articles on the “new” Apprentice Cave course by Lamar Hires, and a story on the Hogartian Method by Jarrod Jablonski who went on to become NSS-CDS Training Director before starting Global Underwater Explorers (1998).


Reneé Power conducts computerized tomography at a hospital in Florida and has over 30 years of professional experience. She has served on the Cambrian Foundation dive team since 1999 and has been involved with cave exploration and research diving in Mexico, Bermuda and Florida serving at times as the expedition Dive Safety Officer.  

She is a cave and technical instructor with the NSS-CDS, TDI, and NAUI. Renee is a PADI Master Instructor and IDC Staff Instructor.  She is currently the chair of the Board of Directors for the NSS-CDS and is a member of Karst Underwater Research. Reneé is the owner and founder of Dive By Design and mentors divers to develop skills in a safe and positive learning environment that facilitates growth through performance based progression.

Dive Rite CEO, Lamar Hires started his diving career in North Florida in 1979. Within his first five years of diving, Lamar had logged in excess of 1000 dives. In 1984, the year Dive Rite was established, Lamar earned his open water instructor rating as well as his cave diving instructor rating. He has explored and mapped a number of cave systems in North Florida and around the world. Lamar’s motivation to explore and challenge himself has led to the development of several Dive Rite products and influenced diving techniques, such as sidemount diving.

Lamar’s diving experience includes exploring a variety of cave systems around the world, wrecks of the Great Lakes and the oceans, the warm waters of the Caribbean, and the frigid waters of Antarctica. Along with exploration, Lamar has a passion for teaching and passing along his vast knowledge of diving. He actively teaches rebreather, sidemount, cave diving, and a variety of technical diving specialties. His involvement in the diving community has earned him numerous awards and recognitions.

Latest Features

OSHA vs. The Houston Aquarium: What Constitutes A Scientific Dive?

The Houston Aquarium recently won a pitched legal battle against the Occupational Safety & Health Administration (OSHA). At stake was whether the aquarium’s fish-feeding, scientific divers should be required to meet the more rigorous commercial diving regulations. As British dive journalist Victoria Brown explains, the case has served as a wake-up call for diving scientists to modernize their diving standards and establish global buy-in.

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by Victoria Brown
Header photo courtesy of the Downtown Houston Aquarium

Disgruntled employees, unwanted Santa outfits, 19th Century brotherhoods, and knowledge of different types of algae? We take a detailed look at the almost decade-long litigation that has plagued a very public, but little-known, tentacle of the scientific diving community. The good news? This saga could inadvertently prove to be the catalyst for modernizing this self-regulating community of divers.

Landry’s Downtown Houston Aquarium has recently won an eight-year long legal dog fight against the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA). The latest ruling, one that has not and now cannot be challenged by the Department, ruled in favor of the Aquarium, finally putting the matter to rest. Despite this being described as “the battle of our time” by the Houston Aquarium’s Corporate Dive Program Manager, Todd Hall, scientific divers across the USA—and the world—have been relatively silent on the matter, and the win has been under-celebrated. 

If OSHA had challenged the ruling. it would have seen the case tried in the Supreme Court, the highest court in America. In this article, we dive under the surface of the case and draw attention to how this landmark ruling could benefit the global scientific diving community in years to come. 

Scientific Diving Guidelines

The guidelines governing scientific diving were born out of challenges to the original 1977 OSHA publication of standards for commercial diving operations. These applied to any diving in the natural or artificial inland body of water, as well as diving along the coast of the US and other listed territories. These standards made no provisions for diving performed solely for scientific research and development purposes, despite many dive programs operating safely and independently before the publication of the standards. 

Surface-supplied aquarium divers. Photo by Todd Hall

The educational institutions who championed this niche in diving quickly argued for exemption on the grounds that there were already standards in place before the OSHA publication, pointing to the University of California Guide for Diving Safety adopted in 1973. Furthermore, and perhaps more poignantly, they cited their impeccable safety record which was a result of efficient self-regulation. 

The main crux of their argument was that the educational/scientific and commercial diving conditions are not congruent, therefore they cannot be subject to the same standards. This pressure led to OSHA deciding, in August 1979, to officially look into the matter, as they wanted to better understand the issue at hand. This move on the part of OSHA opened the gateway for non-educational scientific diving organizations such as the American Academy of Underwater Science (AAUS) to be formed, strengthening the case for exemption. 

The scientific diving community proved victorious on November 26, 1982, when OSHA, after extensive consultation and public hearings on both the east and west coasts, granted a dispensation to divers that met their definition of scientific diver. [Recreational diving instruction was also deemed exempt from commercial regulation]. They also stipulated that scientific divers must operate under a diving program that utilized a safety manual and that had an adequate diving control board in place. In a bizarre twist, this was challenged by the Brotherhood of Carpenters and Joiners Union, which filed for a judicial review, seeking further guidance on what type of enterprises could be exempt. 

This legal challenge led to the publication and adoption of the guidelines in place today, fatefully titled, “Commercial Diving Operations-Exemption for Scientific Diving-Final guidelines.”

These guidelines stated that the exemption is valid as long as the diving programs operated under a diving control board with autonomous and absolute authority, utilised a diving manual covering all diving operations specific to the program including standards and practices, emergency assistance plans that cover recompression and evacuation, as well criteria for diver training and certification. 

The Case Against The Aquarium

Fast forward to 2012, and this exemption became the fighting ground for an appeal by the Downtown Houston Aquarium for relief from approximately $20,000 worth of penalties issued by an OSHA inspector, who during an inspection had applied commercial diving standards to the program despite its scientific status. It was not the cost of the penalties that spurred the appeal but the implications of accepting the inspector’s citations. This included the associated costs of adapting the program to commercial diving standards and, more importantly, the potential increased risk to divers of applying those standards. 

Photo courtesy of he Downtown Houston Aquarium

It was a tough pill for this little known part of the scientific community to swallow given its good safety record, and there was also the danger of a domino effect with other programs being treated in the same way, something which would seriously hinder future research from both a financial and safety point of view. 

Indeed, this created unrest among aquarium programs causing some to make the costly switch to commercial standards in anticipation. Mauritius Bell, the president of the Association of Dive Program Administrators (ADPA) and program administrator at California Academy of Sciences,  reported in an interview that in a recent ADPA survey of their members, more than 50% of zoos and aquariums were operating under commercial standards. He believed that the percentage would have been much lower before the citation. 

The Landry’s Houston Aquarium operates a six-acre entertainment complex with a 500,000-gallon aquatic tank that houses over 300 species from all around the globe, reptile and bird exhibits, large dining halls, and a selection of white Bengal tigers amongst their jam-packed entertainment attractions. Despite this touristic facade, Landry’s Aquarium also operates as a scientific research center and the tanks are maintained as best as possible to replicate the natural ecosystems for marine life. 

In 2011, a employee who was partaking in the diving program was asked to leave his post apparently after a disagreement relating to a Santa outfit. This disgruntled employee, in turn, complained to OSHA and accused Houston Aquarium of not following the commercial diving standards on dives they executed as part of the daily aquarium operations. He sent OSHA portions of the Code of Federal Regulations, along with his complaint detailing his concerns with the diving practices, and accusing Houston Aquarium of not following commercial diving standards on dives that, it could be argued, were not for the purposes of data capture. 

Note the bailout tanks. Photo by Todd Hall

OSHA—and rightfully so—has a policy of deploying an inspector to investigate any complaints of this nature. Mark Chapman, the local Compliance Health and Safety Officer, was assigned to the case, and after visitation, deemed that everything was in order according to the scientific diving exemption of the commercial diving regulations. Chapman documented the aquarium’s stringent record-keeping across a long history, that their appropriate dive medicals were in place and up to date, and that all safety equipment was in the right place.

These findings were challenged by the ex-employee who lodged a further complaint with the national OSHA office, leading to a second investigation in February 2012. During this inspection, Chapman uncovered new evidence that formed the basis of the Citation and Notification of Penalty that was issued on July 10, 2012. It was determined that divers who clean the tanks and feed the animals were not conducting scientific dives, and, as a result, those dives were subject to the more stringent commercial diving operation standards. This is the only time OSHA has issued such a citation to an aquarium program that claims scientific status. 

It was determined that divers who clean the tanks and feed the animals were not conducting scientific dives, and, as a result, those dives were subject to the more stringent commercial diving operation standards. This is the only time OSHA has issued such a citation to an aquarium program that claims scientific status. 

What is a Scientific Dive?

The aquarium realized the potential impact on the broader scientific community, as well as their program, and decided to appeal. This led to the case being heard by an Administrative Law Judge (ALJ) in February 2019, a little less than seven years later.

The proceedings identified three types of dives: feeding/cleaning dives, event dives, and mortality dives (during which dead animals are removed and taken to the Aquarium’s lab for examination). During the initial three- day hearing, the ALJ ruled some activities did not fall within the exemption, namely the feed, clean, and event dives. Consequently, on February 15, 2019, the majority of OSHA’s Review Commission panel affirmed the ALJ’s determinations that these did not meet the plain text definition; interestingly, the Chairman of the Commission dissented. 

The aquarium conceded that the event dives were extraneous to the scientific research being conducted, but strongly disagreed that the feed and clean dives could be seen in the same light, chiefly because these dives underpinned the research conducted by the aquarium. It was reported at the time that Landry’s general counsel and executive vice president, Steve Scheinthal, was of the opinion that OSHA had overstepped its bounds and vowed to appeal. His challenge to the ruling was launched on April 16, 2019, when the aquarium, led by senior diving officer Todd Hall, petitioned a higher court to review the judge’s ruling, focusing on the decision to side with the lay testimony of an OSHA Compliance Officer whilst excluding expert testimony. 

Photo courtesy of he Downtown Houston Aquarium

Furthermore, they took issue with the OSHA declaration that the application of commercial diving safety regulations should be enforced on the aquarium because they were not performed by “employees whose sole purpose for diving is to perform scientific research tasks,” despite it being substantiated during the hearing that the Aquarium’s employees all hold scientific bachelors and masters degrees. Another citation was issued for not having decompression tables at the exhibits, but they were proven to be nearby in the dive locker which was fully accessible by the divers. All in all, there were many grounds for a challenge.

And so we arrive back at the landmark decision reached by the fifth circuit Federal Court Of Appeals (just below the Supreme Court) in July of this year, which can no longer be contested by OSHA. The court was sensitive to the fact that the divers completing these activities are trained scientists and learned that there was a requirement for them to observe animal health and behaviors, eating patterns, and the types of algae growing in the tank. 

Furthermore, during the appeal it was proven that this information was recorded upon completion of their dives, thus meeting the criteria of data capture which is the basis for the criteria of what defines a scientific dive. The court also listened and agreed with expert testimony stating that adhering to the OSHA commercial standards in the context of a scientific dive would make the divers and animals “less safe.” Indeed, Todd Hall had testified from the beginning that this was the case, pointing out that a diver could get to the surface quicker than switching to a second air supply and that extra equipment in the exhibits created a hazard to the animals. When asked to comment on the ruling Hall said, “It took eight and a half years to come full circle. The take away was that we were right all along because the judge used our exact logic from day one of why we were safe and why more equipment doesn’t make us safer.”

The Quest for Global Scientific Diving Standards

This was not just a victory for one aquarium, as over the last few months many that had made the switch to the OSHA commercial standards have quickly reverted to the more appropriate and safer scientific standards that they followed before the 2012 citations. It could also be argued that this was also a win for the scientific diving community as a whole which, through organizations such as the American Academy of Underwater Sciences (AAUS), has been vocal that there is a need for more clarity from OSHA on the criteria for exemption. 

Jessica Keller, a NOAA employee and the current secretary of AAUS, believes this is a long-standing issue. “There’s a question of when to apply commercial diving standards vs. when to apply the scientific exemption. We needed clarification in these grey areas.” 



When speaking with her colleague Derek Smith, President of AAUS and a previous expert witness for the Aquarium put forward by ADPA, he echoed Keller’s sentiment and sees this very much as the beginning rather than the end of the matter. “Celebrating the victory is short-lived, as this landmark is cementing the practices followed not only by the Houston Aquarium, but a large majority of aquariums across the USA and the world,” he said.  “It’s a silent victory about practices they have carried out for years and years. I believe there is now the opportunity to dive headfirst into a new battle and push for updating of the standards for Commercial Diving Operations (CDO) and its exemptions.”

It must be noted—and this was highlighted by Derek Smith—that the ruling pertains to the three states that the Fifth Circuit has jurisdiction over, and cannot fully be used as a precedent. Having said that, he went on to say that it is certainly a case that can be referenced. The AAUS has offered to work with OSHA in assessing exemption claims; as an organization that oversees the standards for one hundred and fifty-two scientific diving programs, AAUS argues that they are better placed to make the call on what is exempt, since they have access to  decades of accrued data. 

Photo by Todd Hall

Derek Smith confirmed that the AAUS has begun this partnership work and is hopeful that this will prevent any other aggressive and baseless enforcement against programs claiming exemption. Keller also celebrated this move, stating, “The most important thing is now we have opened the lines of communications, and I’m glad that OSHA is interested in having a better pulse on what’s happening in the field.” 

This case has also given rise to conversations around the modernisation of the standards followed by scientific divers and the benefits to science this could yield. For example, Todd Hall believes that using a rebreather would allow for closer and improved observation of the animals, as well as minimising the impact on the ecosystem. 

The ripple effect has not stopped there, as the global scientific community looks to the US when setting standards. Smith and the AAUS are certainly playing a role in painting what that future looks like for the community as a whole. When asked to talk about what is next, Smith passionately explained: 

We are trying to unify everyone on a world level. I’m heading up (for the AAUS) a scientific diving training council which is akin to the recreational scuba training council, we have all the major scientific diving standard-setting organizations across the world to agree to a common standard that we will all follow. It’s at the stage now where it’s going out to all our boards, Canada, the US, Mexico, and we have about 100 countries represented so far. [We are seeking] unified training standards so we can enjoy some level of formal recognition of prior training so scientists can move freely across the world to work.

According to Smith, the goal is to establish a global organization that will mirror the role that The World Recreational Scuba Training Council (WRSTC) plays in recreational diving in protecting the worldwide safety of the recreational diving public, primarily through the development of worldwide minimum training standards. The World Scientific Diving Training Council (WSDTC) was established last year, putting foundations for minimum training standards  into the ground. This is a tall task, as there are no doubt some territories that have their own entrenched standards. For example, the Health and Safety Executive in the UK has a strong hold on this type of diving dating back to the Diving at Work Regulations 1997, Approved Code of Practise and Guidance. 

The World Scientific Diving Training Council (WSDTC) was established last year, putting foundations for minimum training standards  into the ground. This is a tall task, as there are no doubt some territories that have their own entrenched standards.

What will be the impact of this global action? Keller was quick to point to the the potential benefits, both in the short and longer term, of this new consolidated way of working in the scientific community:

Photo by Todd Hall

Let’s create this global minimum standard for science so that reciprocity and international collaboration can be easier and so we can trade information. Our oceans are in trouble with sea level rise, and we need to understand it better. Moving forward we need it to be easier. If we can get our own house in order that will help us globally, [and] having an organization to help set these standards will help save the world.

This is yet to be proven, but what is more certain at this point is that this sensational court case has drawn attention to the fact that scientific diving has self-regulated without incident for the pastthree decades. It could be viewed that the case was an unnecessary eventuality born out of a plot of revenge by a disaffected actor; but, it could also be viewed as a necessary evil that may just have ensured that this community of divers continues to keep each other safe.


Additional Resources




Avidly exploring the underwater world since she was twelve, Victoria Brown has been a professional diver for sixteen years and is now based back in the UK following many years touring the snowiest peaks and deepest green seas. From safety diving on media projects to creating content for the coolest brands in the diving industry, she has diving written all over her.

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