Column: What Is OSHA’s Authority Offshore?Source: Lifeline Strategies | 28 February 2014
One of the questions I get most often when I teach my workshop on Safety and Environmental Management Systems (SEMS) compliance is whether companies need to follow US Occupational Safety and Health Administration (OSHA) regulations offshore. It is a complex question, because it depends on a confusing interpretation of the law plus the expectations of the oil and gas industry.
Most of the answers are found in an OSHA instruction: OSHA Authority Over Vessels and Facilities on or Adjacent to U.S. Navigable Waters and the Outer Continental Shelf (OCS). The basic rule of thumb on OSHA is that it does not have authority if another agency regulates safety issues. The clearest example is that the Coast Guard regulates inspected vessels, so OSHA does not have authority over them. But, when you look at uninspected vessels (towboats, barges, etc.), it is a lot murkier. The OSHA instruction goes into great detail on how vessel jurisdiction is to be determined.
Whether OSHA regulations apply to offshore facility is a complex one that may be in flux.