Prohibited terminal operations

No. 1917.158(a) states that "Spray painting and abrasive blasting operations shall not be conducted in the vicinity of cargo handling operations."

• This is a straight prohibition in the marine terminals standard; employers should plan painting and blasting activities so they do not occur where cargo is being handled.
• If you need to know whether a specific work location counts as "in the vicinity," you should document the safety assessment showing why the work is or is not near cargo handling.

No—except when the hot work is part of the cargo operation. 1917.158(b) says "Welding and burning operations shall not be conducted in the vicinity of cargo handling operations unless such hot work is part of the cargo operation."

• That means welding/burning near cargo is generally prohibited unless the welding or burning is integral to the cargo task itself (for example, a specific cargo handling process that requires hot work).

"Part of the cargo operation" means the welding or burning is executed as an integral element of handling, preparing, or securing the cargo rather than as a separate, unrelated repair or maintenance task. 1917.158(b) is the controlling provision.

• The standard does not list examples or a formal checklist, so employers should document and be able to justify why the hot work is integral to the cargo operation.
• When in doubt, treat the activity as prohibited unless you can clearly show it qualifies as part of the cargo operation and take appropriate safety measures.

Possibly—but only if the activity is not being conducted "in the vicinity of cargo handling operations" as prohibited by 1917.158(a).

• The standard forbids those operations when they are in the vicinity of cargo handling; if cargo handling is not occurring and the work area is not in the vicinity of cargo handling operations, the prohibition in 1917.158(a) would not apply.
• Employers should document the situation (e.g., cargo handling stopped, defined boundaries of the cargo area) and ensure other applicable safety rules and controls are met before proceeding.

The employer is responsible for making that determination and ensuring compliance with 1917.158.

• The standard places the duty on the workplace to avoid the prohibited operations near cargo handling; employers should assess work locations, document findings, and control activities accordingly.
• For facilities whose regulatory scope is unclear, the OSHA letter "Applicability to waterfront facilities" explains where Part 1917 applies and can help clarify whether these marine-terminal rules govern your site: Applicability to waterfront facilities (2017-05-31).

No—the rule plainly prohibits abrasive blasting operations in the vicinity of cargo handling operations. 1917.158(a) states that "Spray painting and abrasive blasting operations shall not be conducted in the vicinity of cargo handling operations."

• The standard does not include an exception for containment or dust control, so employers should arrange abrasive blasting away from cargo handling areas or when cargo handling is not occurring and the work site is demonstrably outside the "vicinity."

No—spray painting in the vicinity of cargo handling operations is prohibited by 1917.158(a).

• If cargo is being handled in or near the vessel hold, spray painting would be disallowed. If cargo handling is not occurring and the hold is not "in the vicinity," the prohibition would not apply, but employers should document that determination and follow other safety requirements.

Not necessarily—Part 1917's specific requirements do not apply to designated waterfront facilities used solely for bulk storage, handling, and transfer of liquids or gases. The OSHA letter "Applicability to waterfront facilities" (2017-05-31) explains that such facilities can fall outside the scope of Part 1917.

• That letter notes that a designated waterfront facility may be treated differently and that Part 1910 (general industry) may not apply to marine terminals in some cases. Employers should review that LOI and confirm which OSHA part governs their site.

Yes—if the welding is truly part of the cargo operation, it is allowed by 1917.158(b), which permits welding and burning in the vicinity of cargo handling only when such hot work is part of the cargo operation.

• Employers should be prepared to show how the welding is integral to the cargo task and ensure all other applicable safety measures are in place.

No—1917.158 itself sets the prohibition but does not prescribe specific means such as signage or barricades. See 1917.158(a) and 1917.158(b).

• While the rule does not mandate signs, employers may use signage, barricades, written procedures, and coordination to ensure prohibited activities do not occur near cargo handling and to document compliance with the standard.

No—having a fire watch or other controls does not override the prohibition. 1917.158(b) disallows welding and burning in the vicinity of cargo handling unless the hot work is part of the cargo operation.

• The presence of additional controls does not create an exception in 1917.158; only hot work that is part of the cargo operation is permitted in the vicinity.

No—1917.158(a) specifically prohibits "spray painting and abrasive blasting" in the vicinity of cargo handling; it does not explicitly prohibit brush or roller touch-up painting. See 1917.158(a).

• However, employers should assess whether even non-spray painting creates hazards (fumes, ignition sources) near cargo handling and should take appropriate precautions or move the work away from cargo handling areas.

No—welding and burning are not allowed in the vicinity of cargo handling unless the hot work is part of the cargo operation, per 1917.158(b).

• If the welding is maintenance or repair unrelated to the current cargo handling activity (i.e., not part of the cargo operation), it would be prohibited in the vicinity and should be scheduled away from cargo handling.

Not if the blasting is "in the vicinity of cargo handling operations." 1917.158(a) prohibits spray painting and abrasive blasting in the vicinity of cargo handling operations.

• If the container is in an area used for active cargo handling, the abrasive blasting would be prohibited. The contractor and employer should arrange to perform blasting away from cargo handling areas or when cargo handling is not occurring and document the arrangements.

No—Part 1917 applies to marine terminals and related terminal operations, but certain waterfront facilities (for example, "designated waterfront facilities" used solely for bulk storage and transfer of liquids or gases) may fall outside Part 1917. See 1917 for the Part and the OSHA letter "Applicability to waterfront facilities" (2017-05-31) which explains situations where Part 1917's requirements do not apply.

• Employers should confirm whether their site meets the definition of a marine terminal under Part 1917 or qualifies as a designated waterfront facility addressed in the LOI before relying on or applying 1917.158.

You may perform the hot work only if it truly qualifies as part of the cargo operation under 1917.158(b); beyond that, the standard implies the employer must manage safety for that work.

• The standard itself does not list procedures, so employers should document why the hot work is part of the cargo operation and apply appropriate safety controls, written procedures, and monitoring consistent with other applicable requirements and good practice.
• For regulatory scope questions (e.g., which OSHA part applies), consult the OSHA LOI "Applicability to waterfront facilities" (2017-05-31).