OPEN LETTER TO THE NOVA SCOTIA MINISTRY OF ENVIRONMENT AND LABOUR
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Nova Scotia Environment & Labour
Attn: The Honourable Kerry Morash, Minister
5151 Terminal Road, 6th Floor
P.O. Box 697
Halifax, Nova Scotia
Canada , B3J 2T8
March 30,2005
Dear Mr. Minister
Re: Proposed Legislation for Nova Scotia Diving Industry.
Thank you for your response to my letter of January 22, 2005 concerning the status
of the proposed diving regulations for Nova Scotia.
Since our previous correspondence, our board has received numerous inquiries from our membership requesting additional intervention on this file. As previously stated, we are pleased that the Nova Scotia Government are moving ahead with this long overdue legislation. There remains, however, a sincere, common fundamental view that if the legislation goes ahead as proposed, occupational safety & health for underwater workers in Nova Scotia will be jeopardized and will result in fatalities.
The basic objective here, I'm sure you will agree, is to protect the worker.
The CSA standards are a minimum standard, a starting point, a safety net in risk management. The thirty plus years of development for these standards represents thousands of hours of objective as well as contrarian views shared by stakeholders with one common goal. " protecting the worker ".
You point out in your letter of February 23, that some of your stakeholders have suggested, that you adopt the Canadian Standards Association standards as the regulatory content and that many, have argued that the standards cannot be adopted without modification.
Based on the correspondence we have received from our Nova Scotia members, arguing against the modified version of the CSA standards, either there has been a change of heart, or perhaps representation at the development level failed to provide the logic deemed necessary for a responsible outcome. There is no sustainable argument that would justify the use of Scuba over Surface Supplied Diving in hazardous areas such as intakes, working with power tools, etc.
Margins, skill set deficiencies, ideology etc. have a tendency to expose themselves in the development process of occupational safety & health initiatives. Your department has a responsibility to ensure the appropriate management of these influences by invoking clarity where the effect impacts the health and safety of people in the work place.
Our responsibility as an association representing Canadian diving contractors is to represent our member's common interests with regards to safety and government intervention within our industry.
The Nova Scotia Government's proposed diving regulations are seriously flawed and do not meet the accepted National Standards.
We respectfully request that the Department of Environment & Labour intervene in these proceedings prior to the promulgation of this legislation. We urge the department to meet and hear the concerns of our Nova Scotia members and to re-evaluate the position taken on this file to date.
Our board stands ready to assist in any way that we can to ensure that Occupational Safety and Health standards meets or exceeds those that exist for other industry sectors in Nova Scotia.
An opportunity exists to meet with, many diving specialists from across Canada as they will be gathered in Quebec City April 27, 28 &29 for the Canadian Standards Association diving committee meetings. Several of our board members will be in attendance and would be pleased to have the opportunity to discuss Nova Scotia's diving regulations with a representative from your department.
Sincerely
John Mc Fadzen
President, Canadian Association of Diving Contractors
cc Jim Leblanc, Director of Inspection and Compliance Services.
Mille Mac Cormack , Administrative Assistant.
Members, Canadian Association of Diving Contractors, via CADC Website.
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Regards,
Doug Elsey - Webmaster UnderwaterINDUSTRY.com