Railcar safety requirements

Work may be performed inside a railcar only when the railcar floor is visibly safe for the work and equipment being used. See the requirement in 1917.17(a).

• "Visibly safe" means the floor should be free of obvious hazards such as large holes, rotten or heavily corroded decking, slippery contaminants (oil, ice), or unstable loose boards that could cause slips, trips, or falls.
• Inspect floors before entry, correct or barricade hazards, and do not rely solely on assumptions about structural strength.

Employees must be able to pass between railcars without going under, over, or through them, and cars on the same track must not be placed less than 10 feet (3 m) apart for passage. See 1917.17(b).

• If cars are closer than 10 feet, establish and enforce alternative safe routes so employees do not have to pass between the close cars.
• Post warning signs and use physical barriers or reroute traffic where necessary to prevent employees from attempting to pass in unsafe gaps.

No—employers must direct that no employees remain in railcars after work is concluded. See 1917.17(c).

• Employers should provide clear instructions and supervision to ensure workers exit railcars at the end of their task.
• If someone must stay for a legitimate operational reason, the employer should document the reason and ensure appropriate protections are in place before allowing an exception.

Railcars must be chocked or otherwise prevented from moving while dockboards or carplates are in position and while employees are working within, on, or under the railcars or near the tracks at the ends of the cars. See 1917.17(d) and its subsections 1917.17(d)(1) and 1917.17(d)(2).

• Chocks, derails, wheel blocks, or other positive restraints are acceptable means to prevent unintended movement.
• Ensure chocks are properly sized and placed, and verify restraint effectiveness before employees step onto or into the car.

"Positive means" requires physical controls that reliably prevent railcars from moving into the work area and striking employees, such as chocks, derails, locked hand brakes, or secured mechanical stops. See 1917.17(e).

• Use mechanical wheel chocks, derails, or secured hand brakes and verify they are in place before work begins.
• Supplement with administrative controls (communication, spotters, lockout/tagout of car movement where applicable) and clear signage to warn approaching equipment operators.

Before cars are moved, unsecured and overhanging stakes, wire straps, banding, and similar objects must be removed or placed so they will not create hazards. See 1917.17(f).

• Remove any loose material that might fall or snag during movement, or secure it so it cannot shift or become a projectile.
• Inspect cars for protruding items that could strike workers or equipment during transit and correct them before movement.

Employers must institute all necessary controls during railcar movement to safeguard personnel, and when winches or capstans are used employees must stand clear of the hauling rope and not stand between the rope and the cars. See 1917.17(g).

• Controls include communication protocols, trained signalpersons, spotters, exclusion zones, and physical barriers as needed.
• If winches or capstans are employed, mark and enforce safe stand-off areas so no one stands in the rope snap zone or between the rope and cars.

Before fully opening railcar doors, open them slightly first to ensure the load has not shifted, and take special precautions if the doors appear damaged. See 1917.17(h).

• Open doors a crack from a safe position to check for load shift, falling material, or other hazards; do not lean or place body parts in the doorway.
• If doors are visibly damaged, use remote or mechanical methods to open them, ensure bystanders stand clear, and consider additional PPE or blocking to protect against falling material.

Only powered industrial trucks equipped with door-opening attachments—or designated railcar door openers—may be used to open railcar doors, and employees must stand clear while doors are being opened or closed. See 1917.17(i) and 1917.17(j).

• Use only approved door-opening attachments and follow manufacturer guidance for safe attachment use.
• If a door is jammed, use only proper door openers or powered industrial trucks with the correct attachment—do not improvise tools or methods.
• Operators and nearby employees should be trained on safe door-opening procedures; see the reach stacker interpretation which clarifies powered industrial trucks used in marine terminals are subject to powered truck training requirements.

No—employees must not remain in or on gondolas or flat cars when drafts that create overhead, caught-in, caught-between, or struck-by hazards are being landed in or on the railcar, and raised end gates must be secured. See 1917.17(k).

• Personnel should be kept clear of the drop zone and landing areas until all material handling is complete and secure.
• If end gates are raised, lock or secure them to prevent accidental movement that could injure employees.

Operators of railcar dumps must have an unrestricted view of dumping operations and an emergency means to stop movement. See 1917.17(l).

• Provide clear sightlines or spotters so the operator can see the dump area and personnel.
• Ensure there is a reliable, accessible emergency stop (e.g., remote stop control or localized emergency stop device) and train operators in its use.

Recessed railroad switches must be enclosed to provide a level surface where employees walk or work. See 1917.17(m).

• Enclose or cover recessed switch areas with plates or other durable materials to eliminate tripping hazards and create a continuous walking surface.
• Inspect enclosures regularly and repair any damage that could create a new hazard.

Employers must post warning signs where doorways open onto tracks, at blind corners, and similar places where vision is restricted, and also post signs if insufficient clearance for personnel exists between railcars and structures. See 1917.17(n) and 1917.17(o).

• Signs should be conspicuous, use clear wording or pictograms, and be placed where they can be seen by approaching workers and equipment operators.
• Combine signs with physical controls (mirrors at blind corners, barriers at low-clearance areas) and training so workers understand and follow the warnings.

If no dockboard or carplate is in position and no employees are working within, on, or under the railcars or near the tracks at the ends of the cars, chocking is not specifically required by 1917.17(d), but employers should still take steps to prevent unintended car movement as part of an overall safety program. See 1917.17(d).

• Even where the regulation does not explicitly require chocks, use of wheel blocks, handbrakes, or other restraints may be prudent when cars are unattended to prevent runaways.
• Employers must evaluate hazards and implement controls appropriate to the operation and local risk; documented procedures and training help ensure consistent safe practices.

Yes—powered industrial truck operators who use trucks to open railcar doors are subject to powered industrial truck training requirements, including the training referenced for powered industrial trucks used in marine terminals. See 1917.17(i) and the Reach stacker certification exemption LOI which explains powered industrial trucks at marine terminals are covered by applicable truck training requirements.

• Ensure operators have current training and evaluation consistent with 29 CFR 1910.178(l) (operator training standard referenced in the interpretation).
• If a truck is modified (for example, to add door-opening attachments), verify manufacturer approval or engineering review as required by other Part 1917 provisions before use.

No—employees shall not stand between the hauling rope and the cars and must stand clear of the hauling rope while winches or capstans are being used. See 1917.17(g).

• The hauling rope can snap or the load can shift violently; maintain exclusion zones and mark the potential snapback area.
• Use trained signalpersons and clear communication so all personnel know when ropes are being tensioned or released.

If railcar doors are visibly damaged, take special precautions such as opening from a safe distance, using mechanical or remote door-opening tools, clearing the area of personnel, and wearing appropriate PPE before attempting to open the door. See 1917.17(h).

• Consider using a powered door opener with an appropriate attachment, spotters, and shields to protect personnel from falling or shifting cargo.
• Document the damage and, if needed, have maintenance or a qualified technician secure or repair the door before normal operations resume.

Before modifying a powered industrial truck in a marine terminal setting, the employer must obtain the manufacturer's prior written approval or written approval from a professional engineer experienced with the equipment if the modification could affect capacity or safety. See 1917.17(i) and the Strobe lights on industrial trucks LOI.

• Obtain written approval from the manufacturer where possible; if the manufacturer disapproves or does not respond, a qualified Registered Professional Engineer may perform a safety analysis and provide written approval.
• After modification, ensure operators receive refresher training and evaluation consistent with powered industrial truck training requirements.

No—only railcar door openers or powered industrial trucks equipped with proper door-opening attachments shall be used to open jammed doors. See 1917.17(j).

• Using improvised methods increases the risk of injury from shifting loads or door failure; use designed tools and follow manufacturer procedures.
• If a jam cannot be safely cleared with approved equipment, bring in qualified maintenance personnel or follow lockout/secure procedures before attempting further action.

If end gates on gondolas or flat cars are raised, they must be secured so they cannot move unexpectedly. See 1917.17(k).

• Secure end gates with pins, latches, or other reliable means before allowing employees to work on or near the car.
• Regularly inspect the securing devices and gates for wear or damage and repair them promptly.

OSHA's maritime and longshoring standards may require on-site personnel trained in first aid depending on the specific standard and hazards present; employers at marine terminals should ensure adequate first-aid readiness for operations, including work in railcars. See the First aid and bleeding control LOI which discusses first-aid expectations and references maritime first-aid requirements.

• Where a specific maritime standard requires on-site trained first aiders (for example, certain marine-terminal provisions), employers must ensure adequate trained personnel and appropriate first-aid supplies.
• Even where a particular rule is not prescriptive, employers should assess hazards (including potential uncontrolled bleeding from cargo or railcar incidents) and provide timely first-aid response, training, and kits as appropriate.

An emergency means of stopping movement must be a reliable, readily accessible control that allows the operator or a designated person to immediately halt dumping motion (for example, a remote stop, emergency stop button, or mechanical lockout device). See 1917.17(l).

• The emergency stop should be clearly marked, tested periodically, and known to operators and attendants.
• Backup methods (secondary stops or lockouts) are recommended where single-point failure could lead to an uncontrolled dump.

If a railcar floor's structural integrity is hidden or uncertain, the employer must not allow work until the floor is inspected and repaired or secured to a visibly safe condition. See 1917.17(a).

• Perform a competent inspection (by maintenance or a qualified person), repair or replace damaged floor components, or provide alternative safe platforms before permitting entry.
• Document inspections and corrective actions and train employees to recognize signs of floor deterioration.