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Recordkeeping for injuries aboard fishing vessels

Summary A seafood company asked whether injuries aboard tuna boats outside U.S. territorial waters belonged in its OSHA reporting data. OSHA said excluding them would conflict with the reporting scheme's purpose and instructed the company to include all its vessels for the full reporting period. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-04-16
Date issued
April 16, 1975
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Maritime
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 16, 1975

Mr. L. W. Olp
Bumble Bee Seafood Company
[Recipient address omitted]
Dear Mr. Olp:

Our Seattle Regional Office has informed us that your company has been selected by the Bureau of Labor Statistics, Occupational Safety and Health Statistics as a reporting unit. Because the answer to your question involving your tuna boats has National significance, they have referred your question to me for answering.

Recordkeeping and Reporting Requirements contain in 29 CFR Parts 1903 and 1904 (copy enclosed), which would include illnesses and injuries occurring aboard vessels within the jurisdiction of OSHA (territorial waters of the United States), but would exclude those occurring aboard the same vessels when they are outside the jurisdictions of OSHA (beyond the territorial limit) is inconsistent with the intent and purpose of the regulations. Therefore, to be in compliance with the reporting requirements of 29 CFR 1903 and 1904, your company would have to provide the information from all your vessels to complete the company record. This information would cover the entire reporting period regardless of the geographic location of the vessels.

A copy of this response is being forwarded to all our Regional Offices. If you have any other questions, please feel free to contact our Seattle Regional Office.

Sincerely,
Barry J. White
Associate Assistant Secretary for
Regional Programs

Enclosure

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