Director, Office of Workers' Compensation Programs v. Perini North River Associates

In 1972, Congress amended the Longshoremen’s and Harbor Workers’ Compensation Act, 44 Stat. (part 2) 1424, as *299amended, 33 U. S. C. §901 et seq. (1976 ed. and Supp. V) (hereinafter LHWCA or Act). Before 1972, LHWCA coverage extended only to injuries sustained on the actual “navigable waters of the United States (including any dry dock).” 44 Stat. (part 2) 1426. As part of its 1972 Amendments of the Act, Congress expanded the “navigable waters” situs to include certain adjoining land areas, § 3(a), 86 Stat. 1251, 33 U. S. C. § 903(a). At the same time, Congress added a status requirement that…