Doesn't this refer to MODUs and production units working on the OCS/EEZ?
(2) Determinations in paragraph (c)(1) of this section for all MODUs and fixed and floating OCS facilities, as those terms are defined in 33 CFR 140.10,
The vessels we are talking about here are not engaged in carrying cargo from US ports to units as mentioned above.
To my knowledge all MODUs working there on long contracts are complying, whether they are owned and operated by US companies or not.
PS> I count those companies nominally registered in the same little village in Switzerland as US companies for this purpose.
The waters within the OCS/EEZ are international and free navigation is allowed according to UNCLOS.
The gray area is obviously when a shelf state can regulate crewing on a foreign vessel working within their EEZ. Only Australia demand that everybody, incl. the Master is Australian, which does not work for US or NOR vessels etc. where the flag state demand that the Master is their national. The compromise has been to have an Australian Master as well as one National, but how that would work in case of an accident and court case it not clear. Many companies also keep at least their own Chief Engineer as well. In Australia this is mainly a union demand, the Government is not that keen on it.
Other nations, like Brasil, demand that crew and junior officers are their nationals, but do not demand EVERYBODY is. The same goes for many other Shelf states. There are some US flag boats working in West Africa I believe? Do they have full local crews, incl. Master?
The question is still, where should the vessels to do the work now performed by foreign vessels come from, if you guys managed to drive them out??
I believe there are many Americans working on these vessels as Charterer's or 3rd Party personnel. That is high paying positions that wouldn't be there if these vessels were not there. Concentrate on getting US vessels in place that is able to do the jobs in stead.
In the meantime, maybe it would be better to try to get jobs on the foreign vessels that is there based on merits, not demand that they have to take crew based on nationality?