Is It Recordable?
Scenario Q226

Off-Shore Drilling: is it recordable?

Verdict: Not recordable
Published 2021-10-10

Question

A Honduran mobile off-shore drilling unit is operating within the US coastal waters. If an employee is injured and receives medical treatment, work restrictions or days away is it recordable?

Answer

NO. The Occupational Safety and Health Act of 1970, 29 U.S.C. 651 et seq., (OSH Act) does not apply to the operators of foreign-flag Mobile Off-Shore Drilling Units (MODUs) operating in the United States territorial waters with respect to their crews.

Letter of Interpretation

Illustration for the scenario: Off-Shore Drilling
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This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.