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U.S. Department of Labor-OSHA Tampa Area Office 5807 Breckenridge Parkway, Suite A Tampa, Florida 33610 Ph: (813) 868-5206 Fax: (813) 626-7015 To Whom It May Concern: With the recent OSHA citations against SeaWorld, I am compelled to write to you regarding the issue of “spare air” that SeaWorld has offered as a potential solution for providing trainer safety while doing ‘waterwork’ or while working closely with whales on submerged ledges. Spare are could potentially cause problems for trainers who are forced to use it during an incident with a whale who has decided to pull a trainer under water. As you know, the depth of the performing pool is roughly 40’. Forcing a trainer to take in air at that or near that depth, and then having them potentially be rushed to the surface by a fast moving whale, would have devastating consequences (lung expansion, death). Additionally, in the midst of a thrashing by a whale, it is unreasonable to think a trainer would have the ability hold and keep a regulator in his/her mouth while being bitten, pulled, dunked, rammed, and thrashed about at high speeds. Most importantly, though, spare air is not even relevant to the recent Dawn Brancheau casualty, or the majority of the other reported and recorded incidents in the past several years. No amount of spare air would have saved Dawn from the physical beating she encountered with Tilikum. No amount of spare air would have kept Ken Peters’ bones from breaking. No amount of spare air would have prevented Alexis Martinez from dying after getting rammed. Lack of oxygen is not the issue; therefore, spare air is not a solution. Please don’t let SeaWorld convince you that this is an answer! Carol Ray Former trainer