Training Standards:

Understanding the “Why” Behind What Divers are Taught

By Alex Brylske

When it comes to training, the scuba diving community has much to be proud of because we have created one of the finest examples of industry self-regulation found anywhere.

I was never a particularly good student until I got to college. Countless times my parents would return from the dreaded “parent-teacher conference” having heard the same tired refrain, “Alex has such potential, but he just doesn’t apply himself.” Of course, mom and dad never bought my explanation: Any dedication that most of my teachers once had was beat out of them long ago, and I was bored out of my mind. Anyway, as I suffered the inevitable punishment for “not trying,” I often pondered the paradox of exactly why a kid who absolutely loved to learn had absolutely no interest in school. It was sometime during my uninspired high school experience, I believe, that I began to put some of the pieces of the puzzle together. Yet, a complete answer never gelled until many years later when I was in graduate school studying educational theory. The essential problem is that I’m what some term a “rebellious learner.” In other words, I hate to be told when, how and what to learn. And as an adolescent, especially, I questioned not only what, but also why, I was being taught something.
It dawned on me recently that some portion of those taking scuba classes must share my trait as a rebellious student. Luckily, with all the computer-based and video technology available, there’s lots of flexibility in how you learn the theory of diving. But what’s rarely, if ever, addressed in scuba courses isn’t what’s taught, but why. Where was it, or more precisely, who, decided to include — or exclude —certain content in scuba courses?

Diving’s Legacy

When it comes to training, the scuba diving community has much to be proud of because we have created one of the finest examples of industry self-regulation found anywhere. And what’s even more amazing, this commitment to effective education was made without any prodding or threat of government intervention. Today, our system of training is the envy of many.
But this still doesn’t answer the question of why we teach what we do, or more succinctly, who exactly sets training standards. You might think that it’s a function of the alphabet soup of diver training organizations, and to a great extent that’s true. The basic content for all open water scuba courses is similar regardless of what initials appear on the certification card. And as a condition of issuing a c-card, an instructor must conduct the course according to the requirements and standards prescribed by his or her certifying organization. But that’s far from the whole story. First, it may surprise you that while governments of many other countries impose regulatory control of recreational scuba diving and diver training, that’s not so here in the United States. So the question begs, given that there are so many training organizations, and the government imposes no control, how is such standardization possible? The answer is quite interesting and requires a brief look at our history.

Once Upon a Time Underwater

The basic system for diver training used today started soon after scuba was introduced. The 1950s saw some important steps in formalizing diver training, and by the next decade most of today’s diver training organizations were in existence, and had instituted extensive standards and curricula. Even with no initial objective to achieve uniformity, the essential content of most scuba programs was nonetheless relatively consistent. This probably isn’t surprising in that all diver training evolved from a very small cadre — fewer than a dozen or so people — of early enthusiasts. (For more information, see “A Retrospective on Diver Education,” Dive Training, July 1996.). Classroom or theory training involved the essentials of diving physics and physiology, the elemental mechanics of scuba equipment, and rudimentary oceanography. Skills training generally involved developing physical stamina, familiarization with equipment, and dealing with out-of-air emergencies. There was no such thing as a buoyancy compensator (BC) so the only training in “buoyancy control” was how to select the correct amount of weight. (The idea was to wear enough so that you were slightly positive at the surface; and a quick headfirst “power dive” soon got you to a depth where you were more or less neutral.)
The first attempts at standardized practice among the training organizations began in 1961 when the American National Standards Institute (ANSI) established the Z86 Committee on Underwater Safety. The Compressed Gas Association (CGA) served as the committee’s first “secretariat.” This is the entity officially designated to administer the development of a standard that ANSI formally approves. (For more information on ANSI, see sidebar.)
Seeing its mission as closer to the issue of training than that of the CGA, in 1968 ANSI transferred the secretariat to the Council for National Cooperation in Aquatics (CNCA). (This was also the organization responsible for the widely used textbook, “The Science of Skin and Scuba Diving.”) Then, as today, CNCA represented all major aquatic organizations. And it was under CNCA direction that the first ANSI-approved standard for entry-level scuba instruction was developed in 1972.

A Rude Awakening

By the 1970s, things were cooking along smoothly; diver training had become an effective, self-regulated system. But, as the saying goes, all things must pass. Suddenly, out of a blue Southern California sky in the fall of 1974, a meteor fell. The Los Angeles Times ran a series of sensational and badly researched stories about the increasing number of local scuba fatalities. Politicians, being what they are, saw an opportunity and rose (or sunk, depending on your perspective) to the occasion. Capitalizing on the growing public concern, the Los Angeles County Commission hastily passed a Draconian ordinance that regulated almost every aspect of recreational diving, from training to the operation of dive charter boats.
As the situation calmed down, the local diving community began voicing strong opposition. Soon after, the public lost interest and, seeing the political benefit wane, the Commission repealed most of the ordinance. But the effect would never go away. Like a swift kick in the head, the diver training organizations suddenly realized that diving had indeed come of age; and if their system of self-regulation was to survive another bureaucratic assault, they’d have to organize. Still, agreement was difficult given that there wasn’t even a formal means of communication among the concerned parties. That would soon change.
Sparked by the controversy over the L.A. County ordinance, representatives of the National Association of Scuba Diving Schools (NASDS), National Association of Underwater Instructors, (NAUI), Professional Association of Diving Instructors (PADI), and the YMCA met at the 1974 CNCA National Conference in Phoenix. Spurred by concerns that other governmental entities might follow L.A. County’s lead, the group formed the National Scuba Training Council (NSTC) in 1976.
The NSTC’s purpose was simple: to provide an improved communications mechanism between the organizations, and to create a uniform system for diver training. Based on this cooperative effort, a newer and more thorough national standard was prepared and submitted to ANSI for approval. As the urgency caused by the L.A. County ordinance waned, however, the NSTC ceased functioning and eventually disbanded. But an important step had been taken. Organizations that most often viewed each other as competitors could indeed work together.

A Ruder Awakening

It’s funny how life constantly plays tricks on us. For example, we’ve all been in situations where something bad happens, and as we start to put it behind us, lo and behold, something even worse pops up. That’s exactly what happened to the diving instructional community in 1976. While diving was still reeling from the L.A. County controversy just two years previously, the U.S. Occupational Safety and Health Administration (OSHA) decided to “help us out.” Actually, its regulatory actions were aimed at the commercial diving industry. But, give a bureaucrat a chance to define something, and you’ll soon discover the definition includes everything, and I mean everything. So, while no scuba instructor in the world considered him or herself a commercial diver, in logic understandable only by other bureaucrats, OSHA did precisely that — it made every diving instructor in America a “commercial diver.” It declared that anyone who earned income from diving — including those employed full- and part-time as recreational scuba instructors and the employers they worked for — to be under its legal jurisdiction. (In OSHA’s definition, all “diving operations conducted in connection to all types of works and employments.”)
It was as though the L.A. County debacle was only a warm-up exercise. If implemented, the regulations would have imposed enormous hardship on recreational diving instructors and operators, set the industry back decades and probably put many dive operations out of business. Just one example of the absurd rules was the requirement to have a recompression chamber on site during all diver-training activities.
Once again, the dive community stepped up to the plate and said enough is enough. In a show of unparalleled commitment and solidarity, it was able to convince the Federal government that its help wasn’t necessary (no easy task, as you can imagine). But its rationale was without flaw; the diving community already had in place one of the most effective systems of self-regulation ever seen. While it was never a legal requirement, no sane diver questioned the need for training, and proof of that training came in the form of a c-card. In the end, an exemption from OSHA regulations was granted for recreational scuba instructors and their employers. Similarly, diving activities done as part of public safety and university research programs were given exemptions, as well.
There is, however, one important condition of the OSHA exemption of which many dive professionals remain blithely ignorant even to this day. The exemptions apply only within certain definitions and guidelines. OSHA defines recreational diving as: 1) using only open-circuit equipment; 2) diving within no-decompression limits; and 3) using only compressed air. Most recently, at the industry’s initiative, OSHA amended the guideline, taking into account the burgeoning use of enriched air and closed-circuit technology in the recreational community. Today, the revised exemption allows the use of an enriched air mixture of up to 40 percent oxygen, and rebreathers during instructional activities. However, a point that’s escaped many dive professionals is that training activities involving breathing pure oxygen, enriched air mixtures above 40 percent oxygen, and any activity below 130 feet or exceeding no-decompression limits, are outside the bounds of the OSHA exemptions. (Remember, these are occupational rules, so they apply only to instructors while they’re working, not to those they teach or in any recreational context.) Still, the result was a victory. No other diving industry in any developed country of the world has maintained such autonomy, and thwarted governmental intervention to such an extent. This was, and continues to be, possible only because of cooperation and effort on the part of the diver training organizations.

What’s Happening Today

With the L.A. County and OSHA issues now resolved, the situation finally appeared to be getting back to normal. Still, much was happening to maintain the solid safety record of diver training. In 1982, the Diving Equipment Manufacturers Association (DEMA) — renamed in 1998 the Diving Equipment and Marketing Association — assumed secretariat duties for the Z86 Committee, which in 1984 became fully accredited by ANSI.
There were also other trends occurring in our society that greatly affected diving and the dive industry. The 1980s brought with it Michael Milken, the self-indulgent excess of the “Me Generation,” and the idea that the courts should solve all problems. Lawyers salivated while lawsuits became as common in the ’80s as polyester was in the discotheques of the previous decade. Unfortunately, even though we viewed what we did as recreation, attorneys still had their way with us (literally and figuratively.) The diving community couldn’t escape the new reality of a litigious society. Terms that none of us had even heard, such as “defensive teaching,” “community standard,” and the “reasonably prudent person principle,” soon became as much a part of instructional language as bottom time, atmospheres and squeeze.
Another trend that had an almost disastrous effect on diving was the economy. By the late 1980s it was on the fast track to the dumper. That was bad enough, but the souring economy had other more subtle and insidious effects. As government budgets shrunk, bureaucrats scrambled to justify their existence and various states’ agencies looked at regulating recreational diving and instruction. Thwarted attempts in California and Florida to place scuba instruction under their departments of professional regulation — requiring state-issued licenses — re-ignited fears of heavy-handed government entering the recreational scuba industry. This specter of government encroachment also sparked the former members of the NSTC to begin a series of meetings to discuss issues of common concern. While the situation was one we didn’t ask for, it proved that the threat of government involvement is a wonderful motivator. Within a year, the diver training organizations agreed on and published an updated industry standard for entry-level scuba instruction. It was submitted to ANSI soon after and final approval came in 1989.
Meanwhile, seeing the need to maintain a sustained dialog, the training organizations in 1986 formed a permanent organization called the Recreational Scuba Training Council (RSTC). They immediately hired as the organization’s secretary Ken Brock, a highly respected YMCA administrator and former executive director of both the National YMCA Scuba Program and NAUI, as the organization’s secretary.  Brock still holds the position today. At about the same time, seeking to get back to its original mission of manufacturer and marketing support, DEMA requested to be relieved of the ANSI secretariat position.
In 1990, the RSTC applied to ANSI to assume the role of secretariat, and requested that a new committee be formed to take responsibility for training within the changing scuba community. The request was granted in 1991. The RSTC became the new ANSI secretariat and a new Committee on Scuba Diving Instructional Standards and Safety, designated the Z375 Committee, was named. (See the sidebar for a list of committee members.) A primary concern of the ANSI Committee currently is reapproval of the entry-level training standards, which expired after reaching their 10-year limit in 1999. A draft of the new standards is nearly complete and is in review.
Throughout the 1990s, the scuba community, through the RSTC, has compiled a list of accomplishments. Currently, there are published industry standards for training recreational diving supervisors (divemasters), assistant instructors, instructors and even instructor trainers. The most recent agreement involves minimum content standards for introductory (resort) scuba training. These, like the entry-level standards, will eventually be submitted for ANSI approval.
With the global popularity of scuba diving, attention has begun to focus on development of international standards. To accomplish this, RSTC counterparts exist, or are in development, in many regions of the world. So, what you’re taught in a scuba course isn’t based on some whim, uninformed opinion or happenstance. The exceptional safety record of diving — and especially of diver training — is based, in part, on the collective and collaborative experience of the past 50 years. Furthermore, when one considers that scuba diving does involve risk to life, and the consequences of injury can be catastrophic, it’s inconceivable to most that the government has absolutely no involvement in diver education. In fact, I know of no other endeavor of such a serious and complex nature that can make the same claim. Yet it’s not inconceivable to me, because I’ve observed the standards development process intimately for more than 30 years. And I’m proud to say that I’ve participated in that process for more than half that time. We live in a world that’s often haphazard, usually suspicious and sometimes dangerous. But there’s one time when we can rest easy and be assured that what we’re doing is based on a solid foundation of experience, trust and safety. And that’s when you earn a c-card.

Training Standards:

So What’s The Difference?
With a common approved standard for entry-level scuba instruction, some have asked the question, why are there so many training organizations? Moreover, how is it that the courses offered by the various training organizations differ if there’s a uniform standard? To understand the answer requires a more thorough understanding of what the ANSI standards are, and what they are not.
First, all industry standards, be they ANSI or RSTC, are termed “minimum content standards.” In other words, they stipulate what topics are to be included in a particular scuba course. For example, the standards prescribe what subjects are to be covered, but do not delve into specific performance requirements or behavioral objectives. Nor do ANSI or RSTC standards address matters of educational philosophy. This is an important point because an organization’s educational philosophy is what, more than anything else, determines its approach to learning and instruction.
While under the broad wing of the ANSI or RSTC minimum content standards, development of performance criteria, behavioral objectives and philosophy are the responsibility of the individual training organization. So, while the topical content of all scuba courses is the same, they often vary considerably in terms of approach, the depth and complexity of the material presented, and the instructional materials used to conduct training.
The fact remains, however, that while scuba courses differ in some important respects, they all arrive at the same point. As diving’s safety record attests, the programs create good divers because all programs follow accepted industry standards.


What’s ANSI?

The American National Standards Institute (ANSI) is a nonprofit, nongovernmental organization. It operates on a completely voluntary basis and has no power of law, but the system is a useful and effective mechanism to implement industry-accepted standards.
It’s important to understand that ANSI does not develop standards nor does it give an interpretation of any of its standards. Development and interpretation are a function of the secretariat of the committee created within that industry. ANSI simply administers the process of development.
But ANSI approval is certainly no rubber-stamp process. Approval of a standard requires verification by ANSI that the requirements for due process, consensus and other criteria for approval have been met by the standards developer. According to ANSI, consensus is established when, in the judgment of the Board of Standards Review, substantial agreement has been reached by directly and materially affected interests. Substantial agreement means much more than a simple majority, but not necessarily unanimity. The ANSI requirement for consensus mandates that all views and objections be considered, and that a concerted effort be made toward their resolution. The use of American National Standards is completely voluntary; their existence does not in any respect preclude anyone, whether he has approved the standards, from manufacturing, marketing, purchasing or using products, processes, or procedures not conforming to the standards. An ANSI standard may be revised or withdrawn at any time, and procedures require that action be taken periodically to reaffirm, revise or withdraw these standards.
Within the scuba industry, instructional standards are developed by a committee appointed by the ANSI secretariat, the Recreational Scuba Training Council. Formally termed the Z375 Committee on Scuba Diving Instructional Standards and Safety, it’s composed of members from all segments of the scuba community. Members are listed in the accompanying sidebar. Current RSTC members include the International Diving Educators Association (IDEA), Professional Association of Diving Instructors (PADI), Professional Diving Instructors Corporation (PDIC), Scuba Schools International (SSI) and the National YMCA Scuba Program. For more information, contact ANSI at 1430 Broadway, New York, NY, 10018. Communications to the RSTC should be sent to 3047 Joan St., Land O’Lakes, FL, 34639.