Carol Ray, M.A.

, CCC-SLP
carolray@aol.com

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