Platforms and skids safety

Platforms and skids that extend from piers, transit sheds, or lofts and are used for landing or hooking on drafts must have guardrails meeting 1917.112(c) or an approved alternate means such as nets to protect employees from falls, per 1917.115(a).

• Use the guardrail option if you can meet the detailed requirements in 1917.112(c).
• If using an alternate method (for example, a net), ensure it provides equivalent protection to a guardrail and is maintained in safe condition.

You must protect employees working below a second-story platform or skid from falling objects by stretching a net from the platform or skid to the vessel, as required by 1917.115(b).

• The standard specifically requires a net stretched from the platform or skid to the vessel; other measures are not specified in the text, so use the net unless you can demonstrate an equally protective alternative.

Safe working loads on platforms and skids must have a minimum safety factor of five for any part, based upon maximum anticipated static loading conditions and the ultimate strength of the construction material, per 1917.115(c).

• These safe working loads must be posted or marked on or adjacent to the platforms and skids.

An employer must base the posted safe working load on the platform's maximum anticipated static loading conditions and the ultimate strength of the construction material, using a minimum safety factor of five, and post or mark that load on or adjacent to the platform or skid, as required by 1917.115(c).

Practical steps:

• Calculate the maximum static load the platform will carry (people, equipment, cargo).
• Determine the ultimate strength of the platform materials (manufacturer data or engineer calculation).
• Ensure the design load divided by the material's ultimate strength yields at least a 5:1 safety factor.
• Post a durable, legible sign on or adjacent to the platform that states the safe working load.

The standard specifies the minimum safety factor of five based on maximum anticipated static loading conditions and the ultimate strength of the construction material; it does not explicitly define dynamic load criteria, so employers should consider any dynamic effects when determining "maximum anticipated" loads, to ensure the posted safe working load remains protective, per 1917.115(c).

• If operations generate dynamic forces (impact, swinging loads, sudden shifts), include those effects in your load analysis or consult a qualified engineer.

Employers must provide and maintain platform and skid attachments that will prevent accidental movement of the skid or platform, as required by 1917.115(d).

Common practical examples of such attachments (employers should choose what fits the operation):

• Chocks, wedges or cleats to block wheels or runners.

• Pins, locks, or shackles that secure the platform to adjacent structure or vessel.

• Lashings, chains, or other positive securing devices rated for the loads expected.

• Maintain all attachments and inspect before use; if uncertainty exists, consult the equipment manufacturer or a qualified engineer.

Yes, 1917.115(a) allows alternate means such as nets instead of guardrails to protect employees against falls from platforms and skids used for landing or hooking on drafts.

• If you choose nets, ensure they provide equivalent protection to the guardrail and are properly installed, anchored, and inspected.

Yes—guardrails used on platforms and skids must meet the requirements of 1917.112(c), as referenced in 1917.115(a).

• Consult 1917.112(c) for the exact design, height, and assembly requirements for guardrails.

The employer is responsible for ensuring platforms and skids are strong enough, maintained in safe condition, and that safe working loads are posted or marked on or adjacent to the platform or skid, according to 1917.115(c).

• Employers should keep posted information legible and update it if load conditions change.

1917.115(c) requires platforms and skids be maintained in safe condition but does not specify an exact inspection frequency; employers must inspect and maintain them at intervals appropriate to use, exposure, and potential hazards to ensure continued safety, per 1917.115(c).

Practical guidance:

• Inspect before first use and after any incident or modification.
• Schedule routine inspections based on workload, environment, and manufacturer recommendations.
• Keep records of inspections and repairs where helpful for safety management.

Yes—platforms and skids made of wood may be used if they are strong enough to bear the loads handled, maintained in safe condition, and their safe working loads (with a minimum safety factor of five) are posted or marked, as required by 1917.115(c).

• Determine the ultimate strength of the wood used and ensure the design yields at least a 5:1 safety factor under maximum anticipated static loading.

The standard itself does not provide a precise definition of "second-story platform or skid," but 1917.115(b) requires protection (a net stretched from the platform or skid to the vessel) whenever an employee is working below a platform or skid that is effectively a higher-level work surface where falling objects could strike workers below.

• If there's doubt whether the platform constitutes a second-story exposure, treat the area as one that requires the net or consult OSHA or a qualified safety professional for clarification.

No—OSHA has interpreted that Part 1917's specific requirements do not apply to designated waterfront facilities used solely for bulk storage, handling, and transfer of liquids or gases; therefore 1917.115 would not apply at such a facility, as explained in the Letter of Interpretation "Applicability to waterfront facilities" (May 31, 2017) available at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31.

• If your operation is a designated waterfront facility, consult the Letter of Interpretation for details and verify which standards (if any) apply to your specific operation.

If the platform or skid is part of construction work (such as building a bridge), OSHA's construction standards (29 CFR Part 1926) generally apply rather than Part 1917, as explained in the Letter of Interpretation "Fall protection for bridge work" (Feb. 9, 2004) available at https://www.osha.gov/laws-regs/standardinterpretations/2004-02-09-0.

• For marine-terminal cargo operations, Part 1917 applies; for construction activities, Part 1926 (scaffolds and fall protection) will typically govern.

1917.115(b) specifically requires protection "by a net stretched from the platform or skid to the vessel," so a net is the prescribed method; if you propose an alternative that provides equivalent protection, you should be prepared to document its equivalence and consult OSHA enforcement guidance or a safety professional. The General Duty Clause and previous Letters of Interpretation indicate that where a standard prescribes a method, alternatives must provide equal protection (see the safety-latch hooks Letter of Interpretation for discussion of equivalent measures: https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0).

• If you use an alternative, document the design, analysis, and how it equals or exceeds the protection of a net.

No—an operator who becomes incapacitated or otherwise unable to complete the operation must not leave the controls while a load is suspended; OSHA requires the person assigned to operate the equipment be physically able to perform the task without unscheduled interruption, per the Letter of Interpretation "Crane operator medical condition scenario" (Sept. 13, 2013) available at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13.

• If an operator may be subject to sudden incapacitation, the employer must address the hazard through staffing, medical limitations, or other controls so the operation remains safe.

Yes—OSHA's maritime rules and interpretations support the use of latched or otherwise secured hooks to prevent accidental load disengagement; for example, 29 CFR part 1917 includes requirements that crane hooks be latched or otherwise secured (see the safety-latches Letter of Interpretation discussing maritime provisions and citing 29 CFR 1917.45(e)(2): https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0).

• Use safety latches where practical, and follow manufacturer recommendations or consensus standards for hook selection and use.

Safe working loads must be posted or marked on or adjacent to the platforms and skids so workers can see them, as required by 1917.115(c).

Practical tips for posting:

• Use durable, weather-resistant signs or markings.
• Make text large and legible from the work area.
• Include the safe working load value and date of determination or revision.

1917.115(c) requires safe working loads be based on the ultimate strength of the construction material, which means the maximum stress the material can withstand before failure; employers should rely on manufacturer data, material specifications, or a qualified professional (such as a registered professional engineer) to determine ultimate strength when necessary, per 1917.115(c).

• If you must modify equipment or are unsure about material strength, obtain written approval from the manufacturer or a qualified professional engineer (see guidance about modifications and engineering approval in related OSHA interpretations such as the strobe light/industrial truck Letter of Interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0).

Yes—1917.115(d) requires the employer to provide and maintain attachments that will prevent accidental movement of the skid or platform, whether temporary or permanent.

• Use appropriate positive securing methods (pins, shackles, chocks, lashings) rated for the expected loads and inspect them before use.

Reach stackers are considered powered industrial trucks and are exempt from the certification requirement of 29 CFR 1917.50, but they remain subject to the equipment requirements in Part 1917 and to powered industrial truck training requirements (for example, [29 CFR 1917.43] and [29 CFR 1910.178(l)]), per the Letter of Interpretation "Reach stacker certification exemption" (March 17, 2017) available at https://www.osha.gov/laws-regs/standardinterpretations/2017-03-17.

• Even though certification under 1917.50 is not required for reach stackers, employers must still ensure safe operation, maintenance, and operator training.

No—1917.115(c) requires safe working loads to be posted or marked on or adjacent to platforms and skids, so work should not proceed without that information being clearly posted unless an interim control (e.g., removing loads or stopping operations) eliminates the hazard.

• Post the required information immediately and verify the platform's capacity before resuming normal operations.

If modifications could affect capacity or safety, employers should obtain written approval from the equipment manufacturer or a qualified registered professional engineer; OSHA interpretations have advised that manufacturer or engineer approval is appropriate when changes affect safe operation (see the industrial truck/strobe light Letter of Interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0).

• Document approvals and any safety analyses performed before using modified equipment.

OSHA standards for employer payment for PPE cover maritime and other industries, and while Part 1917 requires certain protections for platforms and skids, the employer must follow the PPE payment rules in OSHA's payment regulation; employers generally must provide required PPE at no cost to the employee with limited exceptions (see OSHA's Letter of Interpretation on employer payment for PPE: https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13).

• If PPE is required by the employer to meet the hazards of work on platforms and skids, the employer should provide it unless a specific regulatory exception applies.

OSHA recognizes the importance of first-aid readiness and interprets first-aid training requirements variably across standards; marine terminals have requirements that at least one or more on-site individuals be trained in first aid, and OSHA has provided guidance on first aid and bleeding control in the Letter of Interpretation "First aid and bleeding control" (June 19, 2019) available at https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19.

• Employers should ensure appropriate first-aid training, supplies, and response planning for the hazards present at platforms and skids.