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OSHA 1917.11

Marine terminal housekeeping rules

Subpart B

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.11(a), what does it mean to keep active work areas "free of equipment and materials not in use"?

Yes — active work areas must be kept clear of tools, equipment, and materials that are not being used at that time. Per 1917.11(a), this means you should remove or relocate spare gear, empty pallets, loose packaging, and other items that could create tripping, puncture, or impalement hazards.

  • Keep temporary storage off the main work surface and out of walkways.
  • Remove loose debris, strapping, and any projecting nails or sharp objects unless they are actively needed for the work in progress.

Under 1917.11(a), how often should housekeeping be performed in active marine terminal work areas?

You must perform housekeeping as often as necessary to keep active work areas free of unnecessary equipment, materials, and debris. The standard in 1917.11(a) does not set a specific schedule, so frequency should be based on the volume and type of work and hazards present.

  • For high-traffic or high-turnover operations, clean-up may need to be continuous or done multiple times per shift.
  • For lower-activity areas, daily checks and cleanup may be sufficient if they keep aisles and access points clear.

Under 1917.11(b), how must hatch beams, covers, and pontoons be stowed in terminal working areas?

Hatch beams, covers, and pontoons must be stowed in stable piles secured against tipping or falling, or they may be laid on their sides, and if stacked more than one high the tiers must have dunnage or other suitable material under and between them. This is required by 1917.11(b).

  • Secure piles to prevent tipping or falling.
  • If stacked in tiers over one high, place dunnage or suitable material under and between tiers to distribute load and prevent shifting.

Under 1917.11(b), what does "dunnage or other suitable material" mean and why is it required between tiers?

Dunnage or other suitable material means material (for example, timber blocks, spacers, or other durable supports) placed under and between stacked items to stabilize loads and prevent shifting or crushing. 1917.11(b) requires this when beams and pontoons are stowed in tiers more than one high to reduce tipping and collapse hazards.

  • Dunnage evens load distribution and provides frictional resistance to movement.
  • "Suitable" means the material must be strong enough and sized properly for the load being stacked so the stack remains stable during handling and environmental changes (wind, vibration).

Under 1917.11(c), can cargo or materials block access to vessels, cranes, vehicles, or buildings?

No — cargo and material must not obstruct access to vessels, cranes, vehicles, or buildings, and means of access and egress inside buildings must also be kept unobstructed. This is explicitly required by 1917.11(c).

  • Keep aisles, gangways, stairways, exits, and vehicle access lanes clear at all times.
  • Plan storage and staging areas so emergency access and routine movement of equipment are never impeded.

Under 1917.11(c), what counts as a "means of access and egress" that must be kept unobstructed within buildings?

Means of access and egress include walkways, aisles, stairways, doors, and other routes employees use to enter, leave, and move about within a building, and these must be kept unobstructed per 1917.11(c).

  • This covers both normal travel paths and emergency exits.
  • Obstructions that reduce passage width or create tripping hazards are not allowed; plan storage so these routes remain clear.

Under 1917.11(d), what must be done with dunnage, lumber, or shoring material that has visibly protruding nails?

You must remove dunnage, lumber, or shoring material with visibly protruding nails from the immediate work area, or render the nails harmless if the material is to remain, as required by 1917.11(d).

  • "Render harmless" can include driving nails fully below the surface, removing the nail, cutting off exposed points, or otherwise physically neutralizing the hazard.
  • If the material is removed, place it in a designated scrap or storage area away from work paths.

Under 1917.11(d), what are common, safe ways to "render nails harmless" in dunnage or lumber left in the work area?

Common safe methods to render nails harmless include driving the nails flush or below the wood surface, removing the nails completely, cutting or grinding the protruding points off, or covering protruding nails with a durable cap or block; any of these controls meets the requirement in 1917.11(d) when they effectively eliminate the puncture or impalement hazard.

  • Always use proper tools (hammers, nail pullers, cutters) and PPE (gloves, eye protection) when performing these tasks.
  • If temporary measures are used (like caps), follow up with permanent repair or removal as soon as practical.

Under 1917.11, does the housekeeping standard apply at a facility designated as a "designated waterfront facility"?

No — specific Part 1917 marine terminal requirements, including 1917.11 housekeeping, do not apply to facilities OSHA considers "designated waterfront facilities" used solely for bulk storage, handling, or transfer of liquids or gases. OSHA explained this in its interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31.

  • If your site is a designated waterfront facility, Part 1917 generally does not apply; check which OSHA part governs your operation.
  • Even when Part 1917 does not apply, general safety obligations and other OSHA standards (or local rules) may still require good housekeeping.

Under 1917.11, if housekeeping requires use of personal protective equipment (PPE), who pays for that PPE?

Employers are generally required to provide required PPE at no cost to employees when the PPE is necessary to comply with OSHA standards, and this payment obligation covers PPE used for housekeeping hazards in covered standards; OSHA explained employer payment issues in its interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

  • If a specific marine terminal standard requires PPE for housekeeping tasks, the employer must provide it and may not shift the cost to employees (subject to the exceptions discussed in the interpretation).
  • Keep documentation of issued PPE and training to show compliance.

Under 1917.11, if beams or pontoons are stacked and begin to tip, who is required to secure them and how quickly?

The employer must ensure stacked beams or pontoons are stowed so they are secured against tipping or falling immediately when identified as an unstable condition; 1917.11(b) requires stable piles and securing to prevent tipping.

  • Correct the hazard without delay: secure the stack, move personnel away from the immediate hazard area, and use proper blocking or chocks or lay beams on their sides if needed.
  • Document corrective actions and inspect other stacks to prevent recurrence.

Under 1917.11, can an operator leave a vehicle or equipment parked where it obstructs access during loading or unloading?

No — cargo, material, or parked equipment must not obstruct access to vessels, cranes, vehicles, or buildings under 1917.11(c), so you must not leave vehicles or equipment in locations that block required access.

  • If equipment must be temporarily staged, place it where it will not impede traffic, emergency routes, or operations.
  • If an operator must leave equipment in an emergency, ensure it is secured and others are warned; note that separate OSHA guidance (for example, regarding crane operators) requires that operators not abandon controls while a suspended load creates a hazard (see https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13 for related crane operator guidance).

Under 1917.11, are there special considerations for housekeeping inside vessel holds compared with open terminal areas?

The same basic housekeeping rules apply — active work areas must be kept free of unnecessary equipment and debris and access must not be obstructed — but vessel holds may require additional controls for stability, securing stacked materials, and traffic due to confined space and noise; these obligations follow 1917.11(a)–(c).

  • Inside holds, stow beams and pontoons stable and secured against tipping per 1917.11(b).
  • Because vessel holds can amplify noise and limit visibility, use additional signaling, secure dunnage properly, and maintain clear egress routes.

Under 1917.11, what should you do if you find a pile of lumber with many protruding nails near a work gang?

Remove the pile from the immediate work area or render the protruding nails harmless right away to eliminate puncture and tripping hazards, as required by 1917.11(d).

  • If removing immediately is not practicable, isolate the area and post warnings until the nails are driven in, removed, or otherwise neutralized.
  • Use appropriate PPE (gloves, safety boots) and tools when handling or repairing the lumber.

Under 1917.11, how does proper housekeeping interact with preventing accidental load disengagement from crane hooks?

Good housekeeping helps prevent conditions that could lead to accidental load disengagement, and where cranes are used employers must also follow other marine standards (for example, crane hook securing requirements) in addition to housekeeping rules. 1917.11(c) keeps access clear, while OSHA's interpretation on safety latches explains that crane hooks in marine terminals must be latched or otherwise secured to prevent accidental load disengagement (see https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0).

  • Keep areas around cranes and hooks clear of loose material so rigging and load paths are unobstructed.
  • Follow both the housekeeping standard and specific equipment safeguards to reduce the risk of dropped or shifted loads.