U.S.

Department of Labor-OSHA
Tampa Area Office
RE: SeaWorld Citation

To Whom It May Concern::

"Spare-air" is a phony solution for a phony problem.

Although the medical examiner's autopsy report lists drowning as a cause of

death, that is misleading. Dawn Brancheau did not die from oxygen
deprivation. She was brutalized. Her cause of death was acute multi-trauma,
including a broken neck, internal bleeding, scalping, epidural hemorrhage,
and liver lacerations. (My understanding is that DB was already deceased
when her arm was ripped off.) The 4 milliliters of water listed as "evidence for
drowning" could have easily been injected into her sphenoid sinus at any
point prior to her body being retrieved; as she was thrashed, bitten, dunked,
and forcefully propelled through the water.
[see translated copy of ME report, attached]

No amount of oxygen would have altered the outcome. Sea World is

generating a solution to a problem that did NOT exist with Dawn, as well as
with the majority of other incidents that are available (for all of us to watch)
on YouTube. Trainers are getting rammed (Alexis Martinez 2009), smashed
(John Sillick 1987), pummeled (Steve Aibel 2004), broken (Ken Peters 2006)
and dismembered (Dawn 2010). Note that the incidents listed were
perpetrated by 5 different animals, of different genders, and at different
facilities.

I hope that OSHA does not fall for this phony pitch.

Additionally, why is Congressman Alan Grayson attempting to derail OSHA's

efforts at protecting trainers? His efforts would be better served by learning
about the physically brutal and relatively hazardous life of orca trainers, not
to mention the poor wages, which border on exploitative, in my opinion.

For more on this spare-air topic: http://orcaaware.com/2010/08/22/could-

spare-air-save-marine-park-trainers-during-orca-attacks/

Jeffrey Ventre MD
Former Trainer