Workers’ Compensation · Primary-source case analysis

Valladolid: OCSLA Coverage Requires a Substantial Nexus to Offshore Operations

By Aneeta Mishra and Timothy Chan

Published September 6, 2026

Pacific Operators Offshore, LLP v. Valladolid involved a worker who spent about ninety-eight percent of his time on offshore platforms but died in a forklift accident at the employer’s onshore processing facility.

The fatal accident occurred onshore

Valladolid performed maintenance at an onshore facility when the accident occurred, although most of his work was on an offshore platform.

The lower agencies used a geographic limit

The administrative law judge and Benefits Review Board denied coverage because the injury did not occur on the Outer Continental Shelf.

The statute required causation, not an on-shelf situs

The Court rejected both a strict situs rule and an unlimited but-for rule, reading the text to require a substantial nexus.

The claim returned for application of the test

The Ninth Circuit was affirmed and the case remanded for a fact-specific determination whether the required significant causal link existed.

Key takeaways

• Map the employee’s offshore and onshore duties.
• Develop facts connecting the injury-producing task to shelf operations.
• Do not treat offshore employment status alone as sufficient.
• Analyze potential state and federal compensation coverage separately.