Dry dock and railway access

Under 1915.75(a) the walking surface must be at least 20 inches wide, of adequate strength, kept in safe repair, and securely fastened. Employers must provide a gangway, ramp, or permanent stairway that meets these minimums for access between a floating dry dock and the pier or bulkhead (Requirement in 1915.75(a)).

• Inspect the walking surface regularly for rot, loose fastenings, or structural damage and repair immediately.
• "Adequate strength" means it must support normal foot traffic and any expected loads; document inspections and repairs as part of your maintenance program.

Reference: 1915.75(a).

Under 1915.75(b) railings with a midrail must be provided on each side of gangways, ramps, and permanent stairways; gangway and ramp railings should be approximately 42 inches high, while permanent stairway railings must be approximately 30 to 34 inches high (Requirement in 1915.75(b)).

• Rails may be made of wood, pipe, chain, wire, or rope and must be kept taut.
• A midrail is required in addition to the top rail on every side.

Reference: 1915.75(b).

Under 1915.75(c) yes — railings that meet the requirements of 1915.75(b) must be provided on the means of access to and from graving dock floors (Requirement in 1915.75(c)).

• That means access routes to graving dock floors should have top rails and midrails at the heights specified in 1915.75(b).

Reference: 1915.75(c).

Under 1915.75(d) sections of the approximately 42-inch railings may be temporarily removed only when necessary to permit line handling while a vessel is entering or leaving the dock (Requirement in 1915.75(d)).

• Remove only the minimum section needed and reinstall the railing immediately after the operation.
• Use alternative controls (spotters, temporary barriers away from the opening, life lines) during removal to protect employees.
• A competent person should supervise removals and reinstallation (see employer/competent person duties in Part 1915) — for guidance on the competent person role see OSHA's competent person interpretation.

Reference: 1915.75(d).

Under 1915.75(e) the end of a floating dry dock must be equipped with portable stanchions and 42-inch railings with a midrail when employees could fall into the water; if a railing is impracticable or ineffective, the employer must provide other effective means to prevent falls (Requirement in 1915.75(e)).

• "Other effective means" could include personal fall arrest systems, lifelines, safety nets, or personal flotation devices, but the employer (and competent person) must determine what's appropriate for the task and hazard.
• The competent person may specify protections when the standard does not prescribe a particular solution; see OSHA's competent person guidance.

Reference: 1915.75(e) and OSHA interpretation on competent persons.

Under 1915.75(f) access to wing walls from dry dock floors must be by ramps, permanent stairways or ladders that meet the applicable requirements of 1915.72 (Requirement in 1915.75(f)).

• Follow the specific construction, tread, riser, handrail, and guard requirements found in 1915.72.
• Inspect and maintain these access means in safe repair as required by 1915.75(a).

References: 1915.75(f) and 1915.72.

Under 1915.75(g) catwalks on stiles of marine railways must be at least 20 inches wide and have, on at least one side, a guardrail and midrail meeting the requirements of 1915.71(j)(1) and (2) (Requirement in 1915.75(g)).

• Ensure the guardrail and midrail meet the sizing and strength criteria in 1915.71(j) and the specific elements in 1915.71(j)(1) and 1915.71(j)(2).

References: 1915.75(g) and 1915.71(j).

Under 1915.75(b) yes — rope and chain are listed as acceptable materials for rails provided they are kept taut and otherwise meet the guardrail requirements (Requirement in 1915.75(b)).

• Make sure rope or chain rails are taut, in good condition (no fraying, corrosion, or broken links), and securely fastened.
• They must perform as a top rail and be complemented by a midrail at the correct height.
• For performance expectations (strength, spacing), follow the guardrail elements in 1915.71(j).

Reference: 1915.75(b) and 1915.71(j).

Under 1915.75(d) yes — sections of railing may be temporarily removed only to permit line handling while a vessel is entering or leaving the dock, so they should be replaced as soon as the need for the opening ends (Requirement in 1915.75(d)).

• Limit the time the opening is unguarded, and use alternate fall protection (spotters, safety lines, temporary barriers) while the opening is present.
• Supervise removals and reinstallation through a competent person to ensure employee safety (see OSHA interpretation on competent persons).

References: 1915.75(d) and competent person guidance.

Under 1915.75(e) the employer (typically through a qualified or competent person) must determine and provide the "other effective means" to prevent falls when a 42-inch railing is impracticable or ineffective (Requirement in 1915.75(e)).

• A competent person, as defined in Part 1915, can evaluate hazards and specify appropriate protection (harnesses, lifelines, safety nets, flotation devices); see OSHA's competent person interpretation.
• Document the hazard evaluation and the chosen controls so you can show they were selected as effective alternatives to the railing.

Reference: 1915.75(e) and competent person guidance.

Under 1915.75(a) and (b) the employer is responsible for providing and maintaining gangways, ramps, permanent stairways and their railings in safe repair and securely fastened (Requirement in 1915.75(a) and 1915.75(b)).

• Employers should assign a competent person to conduct periodic inspections and direct repairs; see OSHA's guidance on the competent person role at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.
• Keep inspection and repair records to demonstrate ongoing maintenance.

References: 1915.75(a) and competent person guidance.

Under 1915.75(g) catwalk guardrails must meet the guardrail requirements found in 1915.71(j); specifically, catwalks must have a guardrail and midrail that conform to the sizing and installation elements in 1915.71(j), 1915.71(j)(1) and 1915.71(j)(2)).

• Confirm top rail height, midrail placement, and structural integrity per those provisions.
• Maintain at least one side with the required guardrail and midrail; where needed for the task, provide protection on both sides.

References: 1915.75(g) and 1915.71(j).

Under 1915.75(b) chain or wire rails must be kept taut and in safe repair to be compliant; employers must inspect them for wear, corrosion, broken links, or slack and correct defects promptly (Requirement in 1915.75(b)).

• Replace corroded or damaged chain/wire rather than trying to repair in place if integrity is compromised.
• Ensure midrails are present and at the correct height when using chain or wire as the top rail.

Reference: 1915.75(b).

Under 1915.75 the standard does not prescribe a specific inspection interval; it requires that gangways, ramps and stairways be of adequate strength, maintained in safe repair and securely fastened, which means employers must inspect and maintain them as frequently as necessary to ensure safety (Requirement in 1915.75(a)).

• Use a risk-based inspection frequency (e.g., before each shift, after severe weather, after heavy use) and assign a competent person to perform and document inspections; see OSHA guidance on competent persons.
• Keep records of inspections and repairs to demonstrate compliance.

References: 1915.75(a) and competent person guidance.

Under 1915.75(f) access to wing walls may be by ramps, permanent stairways, or ladders, but if ladders are used they must meet the applicable requirements of 1915.72 (Requirement in 1915.75(f)).

• If using ladders, follow the construction, anchoring, clearance and safety requirements in 1915.72.
• Where practicable, consider ramps or stairways for safer, higher-capacity access.

References: 1915.75(f) and 1915.72.

Under 1915.75(b) yes — a midrail is required on each side of gangways, ramps and permanent stairways in addition to the top rail (Requirement in 1915.75(b)).

• The midrail provides intermediate fall protection and must be installed at the appropriate height and strength consistent with guardrail guidance in 1915.71(j).

References: 1915.75(b) and 1915.71(j).

Under 1915.75(d) yes — railings may be temporarily removed where necessary to permit line handling while a vessel is entering or leaving the dock (Requirement in 1915.75(d)).

• Limit removal to what is strictly necessary and restore guardrails as soon as the operation ends.
• Use spotters, alternative fall protection, and competent person oversight during the time the railing is removed.

Reference: 1915.75(d).

Under 1915.75(e) portable stanchions and railings are required to be 42 inches with a midrail when employees are exposed to falling into the water; the standard uses the approximate 42-inch height elsewhere as well (Requirement in 1915.75(e)).

• Because the rule uses the term "42 inch railings," aim for the common industry tolerance (approximately 42 inches). Ensure midrail placement and overall performance align with 1915.71(j).

Reference: 1915.75(e) and 1915.71(j).

Under 1915.75(e) employers may use other effective means besides a 42-inch railing when a railing is impracticable or ineffective; PFDs can be an effective component of a fall-prevention plan if chosen by the employer (and competent person) after hazard evaluation (Requirement in 1915.75(e)).

• Document why a railing is impracticable, the hazard evaluation, and why PFDs (or other controls) provide equivalent protection.
• Have a competent person determine the adequacy of the alternative measures; see OSHA's competent person interpretation.

References: 1915.75(e) and competent person guidance.

Under 1915.75(a) gangways must be "securely fastened," which means they should be anchored or attached at both ends so they cannot shift or detach during use, and they must be maintained in safe repair (Requirement in 1915.75(a)).

• Secure fastening includes bolting, locking cleats, or other reliable attachments appropriate to the gangway design.
• Check fastenings before each use and after any event (weather, heavy load) that could loosen connections; document inspections.

Reference: 1915.75(a).