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OSHA 1917.128

Signs and marking requirements

Subpart F

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.128(a), what basic wording and legibility requirements must signs meet?

Signs must be clearly worded and legible and must include a key word or legend indicating the reason for the sign. This is required by 1917.128(a).

  • Use plain, readable words and fonts so anyone in the terminal can understand them at a glance.
  • Ensure signs are maintained so they stay legible (not faded, damaged, or obscured).

(Requirement: 1917.128(a).)

Under 1917.128(a)(1), what counts as an acceptable "key word" on a sign?

Acceptable key words are single attention-getting words such as Danger, Warning, and Caution. The standard gives these as examples of key words. See 1917.128(a)(1).

  • Put the key word prominently (top or bold) so viewers immediately understand the level of hazard.

(Reference: 1917.128(a)(1).)

Under 1917.128(a)(2), what is a "legend" and what are examples I should use?

A legend is a specific explanation that clarifies the key word, for example "High Voltage," "Close Clearance," or "Pedestrian Crossing." The standard defines legends as these more specific explanations. See 1917.128(a)(2).

  • Use a short, direct legend that tells workers exactly why the sign is posted.

(Requirement: 1917.128(a)(2).)

Under 1917.128(b), who must post the required signs and where must they be posted?

Every marine terminal must conspicuously post the signs listed in the standard so they are readily visible to people on the terminal. That requirement is stated in 1917.128(b).

  • "Conspicuously posted" means placed where workers and visitors are likely to see them (entry points, break rooms, near equipment, muster areas), and kept legible.

(Requirement: 1917.128(b).)

Under 1917.128(b)(1), what must I post about first aid facilities?

You must conspicuously post the location(s) of first aid facilities at the marine terminal. That is required by 1917.128(b)(1).

  • The sign should clearly point to or identify onsite first aid stations, medical rooms, or designated first aid kits.
  • While 1917.128(b)(1) specifies posting locations, employers also need to ensure that required first aid readiness (trained personnel and supplies) is met; see OSHA's interpretation on first aid and bleeding control at First aid and bleeding control | 2019-06-19.

(Reference: 1917.128(b)(1); additional context: First aid and bleeding control | 2019-06-19.)

Under 1917.128(b)(2), what must I post about telephones?

You must conspicuously post the location(s) of telephones at the marine terminal. That is required by 1917.128(b)(2).

  • Signs should show where telephones are located (for example, building name, room, or nearest landmark) so they can be found quickly in an emergency.

(Requirement: 1917.128(b)(2).)

Under 1917.128(b)(3), which emergency telephone numbers must be posted at a marine terminal?

You must conspicuously post telephone numbers of the closest ambulance service, hospital or other source of medical attention, police, fire department, and emergency squad (if any). This is required by 1917.128(b)(3).

  • Make sure the numbers are current and legible; place them where employees can find them quickly (near telephones, first aid stations, and entry points).

(Requirement: 1917.128(b)(3).)

Under 1917.128(b)(4), what firefighting and emergency equipment and exit information must be posted?

You must conspicuously post the locations of firefighting and emergency equipment and the locations of fire exits at the marine terminal. That is required by 1917.128(b)(4).

  • Signs should clearly mark fire extinguisher stations, hose cabinets, alarm pull stations, and all designated fire exit routes and doors.

(Requirement: 1917.128(b)(4).)

Under 1917.128(a), can pictograms or symbols alone satisfy the sign requirements?

No—signs must be clearly worded, so words are required; pictograms or symbols can be used to supplement the wording but should not be the only content. This follows from the plain-language requirement in 1917.128(a).

  • If you use pictograms, include the required key word and legend (for example, "Danger: High Voltage") so the reason for the sign is explicit.

(Requirement: 1917.128(a).)

Under 1917.128, how "conspicuous" must signs be and does the standard give size or placement specifications?

The standard requires signs to be "conspicuously posted," meaning they must be readily visible and legible to people in the terminal, but 1917.128 does not set specific size, color, or mounting-height dimensions. See 1917.128(b).

  • Use practical judgment: place signs where people naturally look (entrances, muster points, near equipment) and make them large and illuminated enough to be read under expected lighting.
  • If more detail on placement or size is needed, use industry best practices or other relevant OSHA guidance.

(Reference: 1917.128(b).)

Under 1917.128, who is responsible for posting and maintaining the required signs?

The marine terminal (employer/terminal operator) is responsible for posting and maintaining the required conspicuous signs at the terminal. This duty follows from the requirement that "Every marine terminal shall have conspicuously posted signs" in 1917.128(b).

  • Maintain a program to inspect signs periodically and replace or repair any that are faded, damaged, or unreadable.

(Requirement: 1917.128(b).)

Under 1917.128, does the standard require signs in a particular language or allow multiple languages?

The standard requires signs to be clearly worded and legible but does not mandate a specific language; employers should post signs in a language(s) and format that terminal workers can understand. See 1917.128(a).

  • If your workforce includes non‑English speakers, provide translations or bilingual signs so the message remains clear and legible to everyone.

(Reference: 1917.128(a).)

Under 1917.128, does the signage requirement apply to a "designated waterfront facility"?

No—signage requirements in Part 1917, including 1917.128, do not apply to a designated waterfront facility that falls outside the scope of the marine terminals regulation. OSHA explains this in its interpretation on applicability to waterfront facilities: Applicability to waterfront facilities | 2017-05-31. See also Part 1917 scope.

  • If your facility is a designated waterfront facility, Part 1917 generally does not apply; other OSHA standards or local rules may still require signage.

(Reference: Applicability to waterfront facilities | 2017-05-31; scope: 1917.)

Under 1917.128(b)(3), may I post emergency telephone numbers on a central directory or map instead of individual signs?

Yes—emergency telephone numbers required by 1917.128(b)(3) may be posted on a central, conspicuous directory or map provided that the posting is readily visible and legible to terminal users in an emergency.

  • The key is conspicuousness and legibility: the directory or map must be placed where employees can quickly find it (near telephones, entrances, and first aid stations).

(Requirement: 1917.128(b)(3).)

Under 1917.128(b)(1) and the 2019 LOI, must signs identify whether a first aid responder is trained or only show the facility location?

The text of 1917.128(b)(1) requires only that the location(s) of first aid facilities be conspicuously posted; it does not require that signs state who is trained. OSHA's interpretation on first aid and bleeding control provides additional guidance on training and readiness but does not add a signage requirement. See First aid and bleeding control | 2019-06-19.

  • You may choose to include names or shifts of trained responders on signs or lists for quicker response, but 1917.128(b)(1) itself only mandates posting the facility location.

(Reference: 1917.128(b)(1); context: First aid and bleeding control | 2019-06-19.)

Under 1917.128(b)(3), if there is no on-site ambulance, which medical contact should be listed?

You must post the telephone number of the closest ambulance service, hospital, or other source of medical attention—so if there is no on-site ambulance, list the nearest external ambulance service or hospital. That is specified in 1917.128(b)(3).

  • Identify the provider that can most quickly reach or advise your site in an emergency and keep the number up to date.

(Requirement: 1917.128(b)(3).)

Under 1917.128(b)(4), do signs for fire exits satisfy other fire-safety requirements?

Signs showing fire exit locations satisfy the posting requirement in 1917.128(b)(4), but they do not replace other applicable fire‑safety requirements (for example, means of egress standards). You must meet any other OSHA or local fire-code requirements in addition to posting signs.

  • Use signs to clearly mark routes and exits, and ensure routes remain unobstructed and compliant with any other applicable standards.

(Reference: 1917.128(b)(4).)

Under 1917.128, can required signs be electronic or digital displays?

Yes—electronic or digital displays can be used if they are clearly worded, legible, and conspicuously posted consistent with 1917.128(a) and 1917.128(b).

  • Ensure electronic signs remain visible during power outages or provide a reliable backup method, so the required information stays available in an emergency.

(Requirement: 1917.128(a); 1917.128(b).)

Under 1917.128, may I combine multiple required items (for example, first aid locations and telephone numbers) on a single conspicuous sign or board?

Yes—you may combine multiple required items on a single conspicuous, legible sign or information board so long as each required element (first aid locations, telephone locations, emergency numbers, firefighting equipment and fire exits) is clearly presented. The standard requires each item be conspicuously posted; it does not mandate separate signs for each item (1917.128(b)).

  • Keep the combined display organized (headings, bold key words) so each required item can be found quickly in an emergency.

(Reference: 1917.128(b).)

Under 1917.128, what should I do if required signs become damaged, faded, or illegible?

You should repair or replace signs immediately so they remain clearly worded and legible, because the standard requires signs to be legible and conspicuously posted (1917.128(a) and 1917.128(b)).

  • Inspect signs routinely and after events (storms, collisions, maintenance) that could damage them, and document repairs or replacements.

(Requirement: 1917.128(a); 1917.128(b).)