Access to vessels requirements

Under 1915.74(a)(1) a gangway must provide a walking surface of not less than 20 inches. See 1915.74(a)(1).

• The gangway must also be of adequate strength, maintained in safe repair, and safely secured per 1915.74(a).
• If a gangway is not practicable, provide a substantial straight ladder that extends at least 36 inches above the upper landing and is secured against shifting or slipping (see same paragraph).

Under 1915.74(a) a substantial straight ladder may be used instead of a gangway when a gangway is not practicable. See 1915.74(a).

• The ladder must extend at least 36 inches above the upper landing surface and be adequately secured against shifting or slipping (see 1915.74(a)(1)).

Under 1915.74(a)(2) each side of the gangway must have a railing with a minimum height of approximately 33 inches measured perpendicular from the rail to the walking surface at the stanchion, and it must include a midrail. See 1915.74(a)(2).

• Rails may be constructed of wood, pipe, chain, wire, or rope and must be kept taut at all times (see 1915.74(a)(2)).
• This requirement applies to gangways used to board or leave vessels except where the U.S. Coast Guard–inspected vessel’s regular gangway is being used (see 1915.74(a)(3)).

Under 1915.74(a)(3) gangways on vessels inspected and certificated by the U.S. Coast Guard are deemed to meet the OSHA gangway requirements, except when the vessel’s regular gangway is not being used. See 1915.74(a)(3).

• If you replace or alter the vessel’s regular gangway, verify the replacement meets the other requirements in 1915.74(a).

Under 1915.74(a)(4) keeping the gangway "properly trimmed" means adjusting it so the angle and placement provide safe, stable footing and the walking surface remains secure for the full length. See 1915.74(a)(4).

• Proper trimming includes ensuring the gangway is not excessively steep or loose and is secured at both ends so it does not shift while employees use it.
• If trimming cannot make the gangway safe, use an alternative means of access required by 1915.74(a).

Under 1915.74(a)(5) cleated duckboards must be laid over and secured to a fixed tread accommodations ladder when the ladder angle is low enough that employees must walk on the edge of the treads. See 1915.74(a)(5).

• Cleats give safer footing where treads are shallow or the ladder is nearly horizontal; secure them so they cannot slip while employees use the ladder.

Under 1915.74(a)(6) a net or other suitable protection must be rigged at the foot of the gangway to prevent employees from falling from the end of the gangway when the lower end overhangs the water and creates a fall hazard. See 1915.74(a)(6).

• The protection should be arranged so it effectively catches or prevents employees from falling into the gap between ship and dock.
• If conditions make a net impracticable, use another suitable means to prevent falls, consistent with the employer’s duty under 1915.74(a).

Under 1915.74(a)(7) if the foot of the gangway is more than one foot away from the edge of the apron, the space between them must be bridged by a firm walkway equipped with railings and midrails on both sides, with railing height approximately 33 inches. See 1915.74(a)(7).

• The walkway must be stable and provide unobstructed passage (see also 1915.74(a)(8)).

Under 1915.74(a)(8) supporting bridles must be kept clear so they do not obstruct passage for employees using the gangway. See 1915.74(a)(8).

• Keep bridles secured and positioned so they don’t create tripping hazards or narrow the usable width of the gangway.

Under 1915.74(a)(9) when the upper end of the means of access rests on or flush with the top of the bulwark, substantial steps properly secured and equipped with at least one substantial handrail approximately 33 inches in height must be provided between the top of the bulwark and the deck. See 1915.74(a)(9).

• The steps and handrail must be secure and suitable for safe passage to and from the deck.

Under 1915.74(a)(10) obstructions must not be laid on or across the gangway, and under 1915.74(a)(11) the means of access must be adequately illuminated for its full length. See both 1915.74(a)(10) and 1915.74(a)(11).

• Keep gangways free of tools, gear, or cargo that could trip or block workers.
• Ensure lighting provides sufficient visibility along the entire access route, including landings and connections to deck or dock.

Under 1915.74(a)(12) loads must not be passed over the means of access while employees are on it. See 1915.74(a)(12).

• The rule also requires locating the access so drafts of cargo do not pass over it when reasonably practicable.
• If cargo must be moved, ensure employees are clear of the access before suspending or passing loads overhead.

Under 1915.74(b) and 1915.74(c), gangways meeting the specified requirements must be provided for access from wingwall to vessel or between vessels, and ramps or safe walkways must be provided for barges and river towboats when employees cannot safely step to or from the wharf, float, barge, or towboat. See 1915.74(b) and 1915.74(c).

• For barges, ramps for vehicles must be of adequate strength, have side boards, be well maintained and properly secured (1915.74(c)(1)).
• If a walkway is impracticable, provide a straight ladder extending at least 36 inches above the upper landing, secured against shifting (1915.74(c)(2)).

Under 1915.74(c)(2) a Jacob’s ladder may be used for access to barges or river towboats when neither a ramp nor a safe walkway is practicable, but the Jacob’s ladder must meet the requirements in 1915.74(d). See 1915.74(c)(2).

• Jacob's ladders must be of the double rung or flat tread type, well maintained, and properly secured (1915.74(d)(1)).

Under 1915.74(d)(1) Jacob's ladders must be of the double rung or flat tread type and must be well maintained and properly secured. See 1915.74(d)(1).

• Use double-rung or flat-tread Jacob’s ladders only; single-rung or unsafe makeshift ladders are not acceptable for these access situations.
• Ensure secure attachment and regular inspections so the ladder remains safe for use.

Under 1915.74(a)(2) chains, wire, or rope are acceptable materials for gangway rails, provided they are kept taut at all times. See 1915.74(a)(2).

• Even when using flexible materials like rope or chain, maintain sufficient tension so the rail serves as a reliable handhold and fall prevention barrier.

Under 1915.74(a)(2) if a turn table is used as part of the gangway, each side of the gangway and the turn table must have railings approximately 33 inches high and a midrail. See 1915.74(a)(2).

• The rails for the turn table must meet the same material and tautness requirements as the rest of the gangway.

Under 1915.74(c)(1) ramps for vehicle access to or between barges must be of adequate strength, provided with side boards, well maintained, and properly secured. See 1915.74(c)(1).

• Design the ramp to carry expected vehicle loads, secure it at both ends, and install side boards to prevent wheels from slipping off the ramp.

Under 1915.74(a)(11) the means of access must be adequately illuminated for its full length so employees can see hazards and step safely. See 1915.74(a)(11).

• "Adequately illuminated" means sufficient, consistent lighting to identify footing, handholds, and obstructions along the entire access path, including at landings and transition points.

Under 1915.74(a)(12) the means of access should be located so drafts of cargo do not pass over it unless vessel construction makes that impossible, and in any case loads must not be passed over the access while employees are on it. See 1915.74(a)(12).

• If you cannot avoid draft paths, ensure employees are not on the access when loads are moved, and use alternative safe work procedures to eliminate the hazard.

Under 1915.74(a)(10) obstructions must not be laid on or across the gangway; employers should keep gangways clear of tools, cargo, or equipment to comply. See 1915.74(a)(10).

• Implement housekeeping and staging procedures so material and equipment are kept off means of access until the gangway is clear for use.

Under 1915.74(c)(3) the means of access to barges and river towboats must meet the requirements of 1915.74(a)(9), (10), and (11), meaning steps and handrails where the access meets a bulwark, no obstructions on the gangway, and adequate illumination for its full length. See 1915.74(c)(3).

• When planning access to barges, follow those same step, obstruction, and lighting rules that apply to vessels afloat.

Under 1915.74(a) and (d) a Jacob’s ladder may be used when neither a gangway nor a straight ladder is practicable, and the ladder must be of the double-rung or flat-tread type, well maintained, and properly secured. See 1915.74(a) and 1915.74(d)(1).

• Use Jacob's ladders only as a last resort when other specified means cannot be used safely.

Under Part 1915 the employer's competent person is responsible for recognizing unsafe conditions and specifying necessary protection and precautions, so a competent person may determine when an alternative access is acceptable. See 1915.74 and OSHA's Letter of Interpretation on competent person requirements (April 18, 2016) at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

• The competent person must be capable of recognizing unsafe conditions and specifying necessary protections under 1915.4(o) (see the April 18, 2016 Letter of Interpretation cited above for details).
• Employers must ensure the competent person meets any additional requirements specified in Part 1915 for the task at hand.

Under 1915.74(a)(12) if vessel construction makes it impossible to locate the means of access so that cargo drafts don't pass over it, the employer must at minimum ensure loads are not passed over the access while employees are on it. See 1915.74(a)(12).

• When design constraints exist, use administrative controls (e.g., scheduling, restricted access) and physical protections to prevent employees from being exposed to suspended loads above the access.