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OSHA 1917.16

Line handling safety requirements

Subpart B

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.16(a), can cargo or vehicles be left on the stringpiece or apron where mooring and unmooring crews need to handle lines?

No — cargo or vehicles must not be stowed where they block the work surface used for handling lines during mooring and unmooring. This is required by 1917.16(a).

  • Practical steps: move cargo or vehicles off the stringpiece/apron before mooring/unmooring, mark or cordon off the clear work area, and schedule vehicle placement to avoid interfering with line handling.
  • Employers are responsible for ensuring the work surface is kept clear so employees have safe access while handling lines (see 1917.16).

Under 1917.16(b), when must grab lines or rails be installed on the sides of permanent structures?

Grab lines or rails must be installed on the sides of permanent structures when the stringpiece or apron width is insufficient to provide safe footing. This is required by 1917.16(b).

  • "Stringpiece" means the narrow walkway between the water edge of a berth and a shed or other structure; if that walkway doesn't allow safe footing, grab lines or rails are required.
  • Employers should evaluate footing conditions and install rails or grab lines before workers are required to use a narrow walkway for mooring or unmooring operations (see 1917.16).

Under 1917.16, what is a "stringpiece" and why does it matter for line handling?

A "stringpiece" is a narrow walkway between the water edge of a berth and a shed or other structure, and it matters because safe footing must be available for handling lines; if the stringpiece is too narrow, grab lines or rails must be installed per 1917.16(b).

  • Knowing this term helps identify when the requirement to install grab lines or rails applies.
  • Employers should inspect stringpieces and aprons used during mooring/unmooring and correct unsafe footing conditions in line with 1917.16.

Under 1917.16(a), what should an employer do if line-handling access is obstructed during a vessel mooring?

The employer must ensure the obstruction is removed or relocated so the work surface is clear for safe access to handle lines, because cargo or vehicles shall not be stowed where they obstruct the work surface used for mooring and unmooring per 1917.16(a).

  • Actions: stop operations if necessary, clear the stringpiece/apron, reassign parking or storage, and establish procedures to keep line-handling areas clear.
  • Documenting and communicating these procedures to terminal staff, truck drivers, and vessel crews helps prevent repeat obstructions (see 1917.16).

Does Part 1917 apply at a "designated waterfront facility," or can employers there ignore 1917.16 line-handling rules?

If a site is a "designated waterfront facility" used solely for bulk storage/transfer of liquids or gases, Part 1917 specific requirements do not apply to that facility, so the marine terminal rules like 1917.16 may not apply in that situation, according to OSHA's interpretation in Applicability to waterfront facilities.

  • Practical implication: verify whether your facility meets the definition used in that interpretation; if it does, Part 1917 may not cover it and other standards could govern.
  • When in doubt, contact OSHA regional offices or legal counsel to confirm which standards apply to your waterfront operation (see Applicability to waterfront facilities).

Under 1917.16(b), does the standard specify an exact minimum width for a stringpiece or apron?

No — 1917.16(b) does not set a numeric minimum width for stringpieces or aprons; it requires that when the width is insufficient for safe footing, grab lines or rails must be installed (1917.16(b)).

  • This means employers must evaluate whether footing is safe in practice and take corrective action when it is not (install grab lines/rails or otherwise make footing safe).
  • Use risk assessments, local conditions (weather, surface condition), and worker feedback to determine when footing is "insufficient" and to document corrective steps (see 1917.16).

Under 1917.16, are temporary measures acceptable instead of installing grab lines or rails on permanent structures?

For permanent structures where the stringpiece or apron is too narrow for safe footing, 1917.16(b) requires grab lines or rails to be installed on the sides of those permanent structures; temporary measures may be used only as interim protections until the required installation is completed (1917.16(b)).

  • Interim options: provide additional supervision, limit use, post spotters, or install temporary handholds—but these should not replace the required permanent installation when the structure is permanent.
  • Employers should plan and budget to install the required grab lines/rails to comply with 1917.16(b).

Under 1917.16, who is responsible for determining whether cargo or vehicles obstruct line-handling work surfaces?

The employer is responsible for ensuring that cargo or vehicles do not obstruct the work surface used for handling lines; compliance with 1917.16(a) is an employer duty.

  • The employer should establish inspection routines, assign personnel to keep the stringpiece/apron clear, and train staff to recognize and correct obstructions.
  • Record corrective actions and communicate expectations to visiting drivers and vessel crews to prevent reoccurrence (see 1917.16).

Under 1917.16, does the rule address the use of guard hooks or latches for line-handling equipment?

1917.16 focuses on access for handling lines and the installation of grab lines or rails when footing is unsafe; it does not specifically address hook latches. However, OSHA's marine crane hook guidance indicates crane hooks shall be latched or otherwise secured to prevent accidental load disengagement (see the safety-latches interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0).

  • Practical note: while 1917.16 governs access and footing, ensure line-handling hardware (hooks, slings) is secured per relevant maritime equipment rules and interpretations (see Safety latches on sling hooks).

Under 1917.16, should workers handling lines receive first-aid training or bleeding-control preparedness?

Yes — employers in marine terminal operations should ensure that one or more on-site individuals are trained in first aid, which covers preparedness for injuries like uncontrolled bleeding; OSHA notes this requirement for marine terminals in its first-aid interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19.

  • Practical steps: maintain trained first-aiders on site during terminal operations, provide first-aid supplies and bleeding-control materials where line-handling and mooring hazards exist, and document training and equipment availability.
  • While 1917.16 addresses access and footing, first-aid requirements for marine terminals are discussed in OSHA guidance (see First aid and bleeding control).

During line-handling operations that use powered equipment, can an equipment operator leave controls while a line or load is suspended?

No — an operator who becomes incapacitated or leaves the controls while a suspended load or line is in use creates an unsafe condition and must not abandon their position; OSHA has interpreted that operators must be physically able to perform assigned tasks without unscheduled interruption in similar situations (see https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13).

  • Apply this principle to cranes and other powered equipment used during line handling: ensure the operator can complete the operation or transfer control safely to another qualified operator before leaving.
  • Employers should assess medical fitness and provide procedures for immediate relief or shutdown to prevent unsafe abandonment of suspended loads (see Crane operator medical condition scenario).

Under 1917.16, what should a terminal do in advance to prevent vehicles from blocking line-handling work surfaces?

A terminal should establish traffic and storage procedures that keep stringpieces and aprons clear during mooring/unmooring, because 1917.16(a) prohibits stowing cargo or vehicles where they obstruct the work surface used for handling lines (see 1917.16(a)).

  • Recommended practices: designate no-parking zones, use signage and barriers, schedule deliveries away from mooring times, and train drivers and stevedores on clearance requirements.
  • Document and enforce the procedures so that they are followed consistently and can be shown to comply with 1917.16.

Under 1917.16(b), how should terminals evaluate whether existing grab lines or rails are adequate?

Terminals should inspect grab lines and rails to ensure they provide secure handholds and reliable footing support when the stringpiece or apron is narrow, because 1917.16(b) requires installation where width is insufficient for safe footing (see 1917.16(b)).

  • Inspection checklist: check attachment points, corrosion, continuity along the walking route, and clearance from obstructions; test for secure anchorage and proper height for users.
  • If inspection reveals inadequacy, repair or replace grab lines/rails promptly and document corrective actions to comply with 1917.16(b).

Under 1917.16, are terminals required to keep records of actions taken to remove obstructions or install grab lines/rails?

While 1917.16 does not explicitly require written records, employers should document inspections, corrective actions (like removing obstructions or installing grab lines/rails), and training to demonstrate compliance with the access and footing requirements in 1917.16.

  • Good practice: keep inspection logs, work orders, photos, and training records so you can show proactive safety measures.
  • Documentation supports compliance and helps with continuous improvement of safe line-handling operations (see 1917.16).