Barge and railcar movement

No — you may not move barges or railcars by using cargo runners (running rigging) from vessel cargo booms, cranes, or other equipment that are not suitable for that purpose. This is the plain requirement of 1917.19 (Movement of barges and railcars), and an employer can be cited if employees are directed to move barges or railcars using inappropriate running rigging or equipment designed for other tasks.

"Cargo runners" or "running rigging" generally means the ropes, lines, slings, and temporary gear used to rig and handle cargo — not machinery designed to tow or move large units like barges or railcars. 1917.19 (Movement of barges and railcars) prohibits using those running rigging methods from vessel booms or cranes when the equipment is not suitable for moving the barge or railcar, because such use creates a risk of uncontrolled movement, dropped loads, or equipment failure.

Suitable equipment is equipment designed, rated, and operated for moving barges or railcars — for example, tugs and towboats for barges and locomotives or specialized rail movers for railcars — or lifting/handling gear that the manufacturer or a qualified engineer has approved for that specific movement. The standard itself states only the prohibition; employers must ensure the method and equipment are appropriate under 1917.19 (Movement of barges and railcars). If you modify equipment or use it beyond its intended purpose, follow requirements for manufacturer or engineer approval (see guidance on equipment modifications and approvals in the strobe lights on industrial trucks interpretation).

Only if the crane, boom, and rigging are actually suitable, rated, and authorized for that specific task; otherwise no. 1917.19 (Movement of barges and railcars) prohibits moving barges or railcars with running rigging from vessel cargo booms or cranes that are not suitable for the purpose. If a crane or boom is to be used for an unusual task (such as moving a railcar), obtain and document the manufacturer's written approval or a professional engineer's analysis before proceeding (see related guidance about equipment modifications and approvals in the strobe lights on industrial trucks interpretation).

The employer is responsible for ensuring equipment is suitable for the intended movement and for authorizing only safe methods. 1917.19 (Movement of barges and railcars) sets the prohibition; operational judgments about suitability rest with the employer, who should rely on manufacturers' ratings or a qualified engineer's determination when doubt exists (see guidance on modifications and manufacturer approval in the strobe lights on industrial trucks interpretation).

No — supervision or worker training does not make it lawful to use running rigging from unsuitable booms or cranes to move railcars or barges. 1917.19 (Movement of barges and railcars) prohibits that method; the correct approach is to use equipment designed and approved for the movement.

Powered industrial trucks like reach stackers may be acceptable for moving containers or certain loads if they are designed for that task and operated under the applicable training and equipment rules. The reach stacker certification exemption memorandum explains reach stackers are considered powered industrial trucks (and thus are treated differently than certificated cranes). However, employers must still ensure the reach stacker is suitable for the specific move and comply with applicable training requirements referenced in that memorandum (see 1917.19 (Movement of barges and railcars)).

Yes — if the boom or crane is designed and rated by the manufacturer (or approved by a qualified engineer) to perform the towing or movement safely, then using it for that purpose would not violate 1917.19 (Movement of barges and railcars). If you alter or repurpose equipment, obtain the manufacturer's written approval or a professional engineer's written approval as required by related marine terminal provisions and guidance (see the strobe lights on industrial trucks interpretation).

Safe alternatives include using tugs or towboats for barges, shore-based winches or capstans designed for towing, locomotive power or dedicated rail-movers for railcars, or lifting/handling equipment specifically designed and approved for the task. Employers must choose methods and gear that are appropriate and rated for the load and operation consistent with 1917.19 (Movement of barges and railcars).

Possibly not — Part 1917's specific marine terminal requirements do not apply to certain "designated waterfront facilities" used solely for bulk storage, handling, and transfer of liquids or gases. The applicability to waterfront facilities letter of interpretation explains that Part 1917 may not apply in those situations, so you should confirm whether your operation is a marine terminal covered by Part 1917 before relying on 1917.19 (Movement of barges and railcars).

The operator must not leave the controls while a suspended or moving load could create a hazard — employers must ensure operators are physically able to perform their duties without unscheduled interruption. This principle is reinforced in OSHA guidance on crane operator responsibility; see the crane operator medical condition interpretation. Even when equipment is suitable under 1917.19 (Movement of barges and railcars), employers must assign operators who can safely complete the operation.

Hooks used to handle cargo should be latched or otherwise secured to prevent accidental disengagement where appropriate, and marine terminal standards require measures to prevent accidental disengagement of hoisting hooks. For related guidance on latches and when they are required, see the safety latches on sling hooks interpretation and other provisions referenced in that letter; employers should ensure hooks and attachments used in barge or railcar moves meet the applicable equipment rules and safe practice expectations described in 1917.19 (Movement of barges and railcars).

Workers must be trained and competent for the equipment they operate; for powered industrial trucks and similar equipment, employers must follow the applicable training requirements. For example, the reach stacker memorandum notes powered industrial trucks used at marine terminals remain subject to training rules. In addition, 1917.19 (Movement of barges and railcars) requires using suitable equipment — employers should ensure operators are trained, certified (if required by other applicable rules), and physically able to perform the assigned tasks safely.

OSHA can cite the employer for violating 1917.19 (Movement of barges and railcars) and issue other related citations if other standards are violated (for example, unsafe rigging practices or equipment misuse). Enforcement may include abatement orders, penalties, and follow-up inspections until the unsafe practice is corrected.