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OSHA 1917.111

Maintenance and load limits

Subpart F

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.111(a), who must maintain the structural integrity of docks, piers, wharves, terminals and working surfaces?

The employer must maintain the structural integrity of docks, piers, wharves, terminals and working surfaces. See the requirement in 1917.111(a).

  • Keep structures sound, free of significant damage, and safe for the intended cargo and worker traffic.
  • If you're unsure whether a condition threatens structural integrity, have a qualified person (for example, a structural engineer) evaluate it.

Under 1917.111(b), what load-limit information must be posted in cargo areas?

You must post the maximum safe load limits, in pounds per square foot and kilograms per square meter, for floors elevated above ground level and for pier structures over the water in all cargo areas. This is required by 1917.111(b).

  • Postings must be conspicuous and legible so workers and equipment operators can readily see and follow them.
  • If you change the load capacity (for example, after repairs or modifications), update the posted limits accordingly.

Under 1917.111(c), can the posted maximum safe load limits ever be exceeded?

No—posted maximum safe load limits must not be exceeded. That is the clear requirement of 1917.111(c).

  • Plan lifts and traffic so total loads (including concentrated loads) do not exceed the posted limits.
  • If an operation would exceed the limit, reduce the load, redistribute it, or obtain a structural re-evaluation and new posted limit before proceeding.

Under 1917.111(d), what condition must walking and working surfaces in a terminal area meet?

All walking and working surfaces in the terminal area must be maintained in good repair. That is required by 1917.111(d).

  • ‘‘Good repair’’ means surfaces are free of hazards such as holes, severe rot, loose boards, trip hazards, or other defects that could injure workers or compromise loads.
  • Defective surfaces should be repaired promptly or access restricted until corrected.

Under 1917.111(b), must load limits be posted in both imperial and metric units?

Yes—1917.111(b) expressly requires maximum safe load limits in pounds per square foot and in kilograms per square meter to be posted in cargo areas.

  • Include both units on each posting so anyone reading the sign can understand the limit regardless of unit preference.

Under 1917.111(b), how conspicuous must load-limit postings be and what are practical ways to make them conspicuous?

Load-limit postings must be conspicuous and clearly legible in all cargo areas as required by 1917.111(b).

Practical tips:

  • Place signs near entrances, ramps, and at points where loads are placed or moved.
  • Use weather-resistant, high-contrast materials and large lettering.
  • If lighting is poor, provide illumination or reflective signs so limits remain visible day/night.

If my facility is a "designated waterfront facility," does Part 1917 (including 1917.111) apply?

If your facility is a designated waterfront facility used solely for bulk storage, handling, and transfer of liquids or gases, Part 1917 does not apply. See the interpretation about applicability to waterfront facilities at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31 which explains that Part 1917's specific requirements do not cover such designated waterfront facilities.

  • If Part 1917 does not apply, other OSHA standards or industry-specific requirements may still be relevant.
  • Confirm your facility classification before assuming different standards apply.

Under 1917.111, who should determine the numeric maximum safe load limits to post?

The standard requires posting the maximum safe load limits but does not prescribe who must calculate them; employers should arrange for a competent, qualified person—typically a licensed structural engineer or qualified manufacturer representative—to determine those limits and post them as required by 1917.111(b).

  • When modifications or additions may affect capacity, obtain manufacturer approval or a qualified engineer's written evaluation (see the guidance on equipment modifications in https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0).
  • Keep documentation of the calculations and evaluations with your facility records.

Under 1917.111, are temporary work platforms or scaffolds used in cargo operations subject to the load-posting requirement?

If the temporary platform serves as a floor elevated above ground level or a pier structure over the water and is used in cargo areas, then the requirement to post maximum safe load limits applies under 1917.111(b).

  • If the temporary platform is part of construction activity rather than marine terminal cargo operations, construction standards such as those in Part 1926 may instead apply (see the discussion of overlapping scopes in https://www.osha.gov/laws-regs/standardinterpretations/2004-02-09-0).
  • When in doubt, have a qualified person evaluate the platform and specify safe loads.

Under 1917.111, what should you do immediately if you find a walking surface with holes, severe rot, or other dangerous defects?

You must repair or remove the hazard immediately and prevent access until the walking surface is restored to good repair, consistent with 1917.111(d) and the employer's duty to maintain structural integrity under 1917.111(a).

  • Barricade or block access to the affected area and post warnings.
  • Arrange for prompt repair by a qualified person and document the action taken.

Under 1917.111(b), how should employers handle concentrated (point) loads versus uniformly distributed loads when posting limits?

The standard requires posting maximum safe load limits but does not prescribe calculation methods; employers should have a qualified person evaluate both uniform and concentrated loads and establish safe limits before posting as required by 1917.111(b).

  • Concentrated loads (heavy equipment, stacked pallets) can exceed a structure's safe point capacity even if the uniform limit is not exceeded—get a structural evaluation.
  • Update postings or impose operational controls (load distribution, placement restrictions) when concentrated loads are present.

Under 1917.111, are there specified sign formats, sizes, or materials required for posting load limits?

No—1917.111(b) requires that load limits be conspicuously posted but does not specify a precise format, size, or material. The posting must be clearly visible and durable.

  • Use weatherproof, high-contrast signs with large lettering; place them where workers and equipment operators will see them.
  • Keep records showing where postings are installed and when they were last reviewed or replaced.

Under 1917.111, if load-limit signs are missing or unreadable, what must the employer do?

The employer must replace or restore the missing or unreadable postings so that maximum safe load limits are conspicuously displayed, and ensure the limits are not exceeded in the meantime as required by 1917.111(b) and 1917.111(c).

  • Until signs are restored, restrict or control traffic and loads to safe, conservative levels determined by a qualified person.
  • Document the replacement and any interim controls used.

Under 1917.111, who enforces these requirements and what can trigger an OSHA inspection related to load limits or structural integrity?

OSHA enforces the requirements in Part 1917, including 1917.111; complaints, incidents (e.g., structural failures or serious injuries), or routine inspections can trigger enforcement activity—see 1917 for the Part’s coverage.

  • OSHA inspectors may cite violations if load limits are exceeded, postings are missing, or walking surfaces are not maintained.
  • Maintain documentation of inspections, repairs, load calculations, and postings to demonstrate compliance during an inspection.

Under 1917.111, how often should walking and working surfaces be inspected to stay in "good repair"?

The standard does not set a fixed inspection frequency; it simply requires that walking and working surfaces be maintained in good repair under 1917.111(d). Employers should implement regular inspections based on use, exposure, and risk.

  • Practical guidance: inspect surfaces daily for high-use areas, and after extreme weather, heavy loading events, or any incident that could damage the structure.
  • Document inspection schedules, findings, and corrective actions to demonstrate a proactive maintenance program.

Under 1917.111(b), can an employer rely on manufacturer or vendor data when posting safe load limits?

Yes—employers may use manufacturer or vendor load ratings as the basis for posted safe-load limits, provided those ratings are reliable; when modifications or site conditions affect capacity, obtain manufacturer approval or a qualified engineer evaluation as discussed in the modification guidance at https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0 and follow 1917.111(b).

  • Keep manufacturer documentation or engineering reports on file to support posted limits.
  • If the manufacturer disclaims applicability for your configuration, get a written engineering evaluation before relying on the rating.

Under 1917.111, do gangways and gangplanks used for cargo handling need to be maintained and load-rated?

Yes—gangways and gangplanks are walking and working surfaces and must be maintained in good repair under 1917.111(d), and if they function as elevated floors or pier structures used in cargo areas, any applicable load limits should be posted under 1917.111(b).

  • If the gangway is temporary or part of construction activity, other standards (for example, construction scaffold rules) may also apply—see the scope discussion at https://www.osha.gov/laws-regs/standardinterpretations/2004-02-09-0.
  • Inspect gangways before each use and repair or remove unsafe ones immediately.

Under 1917.111, does the standard tell employers how to compute load limits (calculation method)?

No—1917.111(b) requires posting maximum safe load limits but does not prescribe calculation methods; employers should have a competent person (often a licensed structural engineer) compute the safe loads.

  • Keep the calculation documentation on file and base postings on that qualified evaluation.
  • If operations or structure change, obtain a new analysis and update the posted limits.

Under 1917.111, if a pier has been repaired or modified, do the posted load limits need to be re-evaluated?

Yes—if repairs or modifications could affect capacity, you must re-evaluate and update posted maximum safe load limits before returning the structure to service, consistent with the posting requirement in 1917.111(b).

  • For modifications affecting capacity, obtain manufacturer approval or a professional engineer's review as recommended in the modification guidance at https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0.
  • Document the evaluation and any new postings.

Under 1917.111, are employers allowed to place temporary barricades or controls to prevent loads that would exceed the posted limits?

Yes—using temporary barricades, signage, or administrative controls to prevent loads that would exceed posted limits is an appropriate interim measure to prevent violations of 1917.111(c) and to keep walking/working surfaces in good repair under 1917.111(d).

  • Use such controls until permanent repairs, re-rating, or stronger engineering solutions are in place.
  • Keep a record of temporary controls and the plan/timeline for permanent correction.

Under 1917.111, when posting loads for elevated floors inside terminal buildings, where should employers place the posted limits?

Employers should conspicuously post the maximum safe load limits in those cargo areas so they are visible to workers and equipment operators near the elevated floors, as required by 1917.111(b).

  • Place signs at entry points to elevated floors, at stairways, and where material is commonly placed or moved.
  • Ensure signs use both pounds per square foot and kilograms per square meter and remain legible and durable.