Bud's Offshore Energy (BOE)

This should not surprise experienced OSHA regulators given the absence of clear legislative authority.

Offshore regulators in the US have used “work-arounds” in the form of Notices to Lessees, Conditions of Approval, and other types of guidance documents. However, there was a general understanding that requirements imposed by these methods would not survive legal challenges unless they were clearly authorized by legislation or regulations. Most work-arounds aren’t challenged because the regulatory authority is reasonably clear, their issuance is at least minimally acceptable to the regulated industry, or the perceived cost of challenges exceeds the cost of compliance.