Coopering safety requirements

No. Repair and reconditioning of damaged or leaking cargo packaging (coopering) must be done so as not to endanger employees, as required under 1917.15.

• Do a hazard assessment before starting coopering work and stop work if conditions become unsafe.
• Use appropriate controls (isolation, ventilation, containment), safe tools, and work procedures to eliminate or reduce risks.
• Provide and require suitable personal protective equipment (PPE) and training for employees performing coopering.

The employer must ensure coopering is planned and done safely so employees are not endangered under 1917.15.

• Identify hazards (chemical exposure, fire, pressure releases, sharp edges, falling loads).
• Establish written safe work procedures and train employees on them.
• Provide required PPE (and follow employer-payment guidance in the OSHA PPE payment letter).
• Implement engineering and administrative controls (ventilation, spill containment, barriers) before relying on PPE.

Yes. Employers must assure adequate first-aid readiness where hazards exist that could cause serious injury during coopering; marine terminal operations commonly require on-site trained first aid responders as explained in OSHA guidance. See 1917.15 and OSHA's letter on first aid and bleeding control (2019-06-19).

• Ensure one or more on-site individuals are trained to render first aid when operations present risks of serious injury.
• Keep first-aid supplies and bleeding-control materials accessible and employees trained in their use, consistent with the OSHA first aid interpretation.

No, employers generally must provide required PPE at no cost to employees; any payment or deposit system must not result in employees effectively paying for PPE. This is applicable to marine terminal operations covered by 1917.15 and explained in OSHA's PPE payment letter (2014-11-13).

• Employers may use deposit systems only if they do not circumvent the rule or cause employee expense for required PPE.
• Employers may require return of employer-owned PPE at termination but cannot charge for normal wear related to work.

No. Employers should not permit use of compressed air for cleaning employees; maritime guidance and OSHA standards restrict this practice to prevent injury. See 1917.15 and OSHA's interpretation about compressed air and maritime standard 1917.154 (1994-01-14).

• Compressed air for cleaning must be reduced and guarded if used for equipment cleaning, but cleaning personnel with compressed air is prohibited in maritime operations.
• Use alternative cleaning methods and proper PPE.

Yes. When coopering involves hoisting or attaching loads, employers must ensure attachments prevent accidental disengagement so employees are not endangered; OSHA guidance emphasizes using latched or otherwise secured hooks where appropriate. See 1917.15 and OSHA's letter about safety latches on hooks (2006-01-10).

• Use safety-latch hooks or other positive means to secure slings and bridles whenever practical.
• Follow equipment manufacturer recommendations and industry practice (ASME) when choosing hooks and latches.

Before modifying powered industrial trucks used in coopering, an employer must obtain the manufacturer's written approval or the written approval of a qualified professional engineer, because modifications can affect vehicle safety. See 1917.15 together with OSHA guidance on truck modifications (2004-12-21).

• If manufacturer's approval is not available, a registered professional engineer may perform a safety analysis and provide written approval.
• After modifications, evaluate operator training needs and provide refresher training as required.

Reach stackers used in marine terminal activities are treated as powered industrial trucks and are exempt from the 29 CFR 1917.50 certification requirement, but they remain subject to powered industrial truck safety and training rules. See 1917.15 and OSHA's reach stacker exemption memorandum (2017-03-17).

• Even if exempt from the certification requirement, reach stackers must comply with safe operation rules in Part 1917 and operator training requirements cited in the exemption guidance.

No. An operator must not leave the controls while a load is suspended; the employer must ensure operators are physically capable of completing assigned tasks without unscheduled interruption to protect employees. See 1917.15 and OSHA's crane operator medical condition interpretation (2013-09-13).

• Plan lifts so a qualified backup operator is immediately available if needed; do not abandon suspended loads.
• Address medical or fitness-for-duty conditions before assigning lifting tasks that could affect safety.

Employers must control chemical hazards during coopering so employees are not endangered, using engineering controls, safe practices, PPE, and emergency planning as needed under 1917.15.

• Isolate and ventilate the work area; use spill-containment methods.
• Provide appropriate chemical-resistant PPE and ensure employees are trained in its use; follow employer-payment guidance in OSHA's PPE letter (2014-11-13).
• Maintain accessible first-aid and bleeding-control supplies per OSHA's first aid interpretation (2019-06-19).
• Keep Safety Data Sheets (SDSs) available for chemicals involved; see OSHA's MSDS interpretation (1995-10-06).

Not always. Whether Part 1917 applies depends on the facility's classification; designated waterfront facilities used solely for bulk storage/transfer of liquids or gases may be outside Part 1917's scope. See 1917.15 and OSHA's interpretation on applicability to waterfront facilities (2017-05-31).

• Confirm whether your site is a "marine terminal" under Part 1917 definitions; if not, other OSHA parts (for example Part 1910 or Part 1926) may apply.
• If in doubt, consult OSHA regional staff for guidance on which part of OSHA rules covers your coopering activity.

Employers should maintain SDSs when available and make them accessible to employees; for chemicals purchased before certain dates, OSHA has explained obligations in its SDS/MSDS guidance. See 1917.15 and OSHA's MSDS interpretation (1995-10-06).

• If you have SDSs for older chemicals, it's good practice to keep them available to employees as part of hazard communication and emergency response.
• If an SDS is not available because a product is obsolete and unsupported by the manufacturer, document your efforts to obtain it as recommended in OSHA guidance.