Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

April 16, 1975

Mr. L. W. Olp
Bumble Bee Seafood Company
Box 60
Astoria, Oregon 97103

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.


Barry J. White
Associate Assistant Secretary for
Regional Programs