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OSHA 1917.2

Definitions for marine terminals

Subpart A

23 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.2, what does the term "apron" mean and when does it apply at a marine terminal?

Under 1917.2, an "apron" is the open area of a marine terminal that sits immediately next to a vessel berth and is used for direct transfer of cargo between the terminal and the vessel. See the Definition of "Apron" in 1917.2 for the exact wording.

  • Practical point: if work or equipment is located on the open area right next to a berth and is used to move cargo directly to or from a ship, treat that area as the apron and apply terminal procedures accordingly.
  • Compliance tip: identify apron boundaries in site plans and include them in operational safety checks and traffic control.

Under 1917.2, who is considered an "authorized" employee for a particular assignment?

Under 1917.2, an employee is "authorized" when the employer has specifically selected that person for a given task or assignment. See the Definition of "Authorized" in 1917.2.

  • Practical point: document which employees are authorized for specialized tasks (e.g., operating gear, entering confined spaces) so you can demonstrate training and assignment decisions.
  • Compliance tip: written designation or roster helps show who is authorized when an inspection or incident review occurs.

Under 1917.2, what qualifies as a "cargo door (transit shed door)"?

Under 1917.2, a "cargo door (transit shed door)" is a door specifically designed to allow cargo to be transferred to and from a marine terminal building. See the Definition of "Cargo door" in 1917.2.

  • Practical point: transit shed doors are intended for moving freight, so loading/unloading procedures, clearances, and guarding should treat these as cargo access points.
  • Compliance tip: inspect cargo doors for proper operation and ensure they are not used as pedestrian shortcuts during cargo movements.

Under 1917.2, what does "cargo packaging" include and what does it exclude?

Under 1917.2, "cargo packaging" includes methods of containment for shipment such as cases, cartons, crates, and sacks; it expressly excludes large units like intermodal containers, vans, or similar devices. See the Definition of "Cargo packaging" in 1917.2.

  • Practical point: treat small packages (cartons, crates, sacks) differently than large unit loads (intermodal containers) for handling, securing, and equipment selection.
  • Compliance tip: verify that procedures and equipment are appropriate to the packaging type you handle (e.g., pallet jacks for cartons vs. cranes for containers).

Under 1917.2, how is a "confined space" defined and what are examples in marine terminals?

Under 1917.2, a "confined space" is a space that has all of: small size, severely limited natural ventilation, capacity to accumulate a hazardous atmosphere, exits that are not readily accessible, and is not designed for continuous human occupancy; examples include intermodal tank containers, bailwater tanks, and portable tanks. See the Definition of "Confined space" in 1917.2.

  • Practical point: if a space meets all listed characteristics, apply confined-space entry procedures (permit system, atmospheric testing, rescue plan).
  • Relevant standard: apply respiratory and atmosphere rules such as those in 29 CFR 1910.134 when addressing oxygen-deficient or hazardous atmospheres.
  • Compliance tip: document confined-space determinations for tanks, railcars, or other spaces before anyone enters.

Under 1917.2, what is the difference between an "enclosed space" and a "confined space" at a marine terminal?

Under 1917.2, an "enclosed space" is an indoor space (not a confined space) that may contain or accumulate a hazardous atmosphere due to inadequate ventilation—examples include trailers, railcars, and storage rooms—whereas a "confined space" must meet all five specific characteristics (size, limited ventilation, potential to contain hazardous atmosphere, exits not readily accessible, and not designed for continuous occupancy). See the Definitions of "Enclosed space" and "Confined space" in 1917.2.

  • Practical point: enclosed spaces may require atmospheric monitoring and controls, but they are not automatically confined spaces unless they meet all confined-space criteria.
  • Compliance tip: perform a formal determination for each space and apply the appropriate entry and monitoring procedures accordingly; cite 1917.2 in your documentation.

Under 1917.2, what does "conveyor" mean and when should this definition guide equipment decisions?

Under 1917.2, a "conveyor" is a device designed exclusively to transport bulk materials, packages, or objects along a predetermined path with fixed or selectable loading and discharge points. See the Definition of "Conveyor" in 1917.2.

  • Practical point: if a machine moves material along a set path (e.g., belt, roller conveyor), treat it under conveyor safety rules (guards, nip-point protections).
  • Compliance tip: label equipment and confirm operator training and guarding based on the conveyor definition in 1917.2.

Under 1917.2, what is meant by a "danger zone" around machinery and what hazards are included?

Under 1917.2, a "danger zone" is any area around a machine where an employee could be struck by or caught between moving parts or exposed to burns or electric shock; examples include nip points, shear lines, drive mechanisms, and areas beneath counterweights. See the Definition of "Danger zone" in 1917.2.

  • Practical point: identify and mark danger zones on or near machines and use guarding, lockout/tagout, and exclusion procedures to protect workers.
  • Compliance tip: incorporate danger-zone mapping into machine-specific hazard assessments and training.

Under 1917.2, what is a "designated person" and when should employers use one?

Under 1917.2, a "designated person" is someone with specialized abilities in a particular area whom the employer assigns to perform a specific task. See the Definition of "Designated person" in 1917.2.

  • Practical point: use designated persons for complex or high-risk tasks (e.g., rigging, specialized inspections) where particular skills are needed.
  • Compliance tip: document the qualifications and assignment of designated persons to show the employer selected appropriately trained personnel.

Under 1917.2, how does OSHA define a "dock" and how is it different from a loading dock?

Under 1917.2, a "dock" means a wharf or pier forming part of a waterfront facility (including marginal or quayside berthing) and should not be confused with a loading dock at a transit shed or container freight station; the two are different types of structures. See the Definition of "Dock" in 1917.2.

  • Practical point: apply marine-terminal rules to waterfront docks (berthing locations) and use other standards (e.g., warehouse/loading dock rules) for transit shed loading docks.
  • Compliance tip: when assessing hazards, clearly label areas as "dock" versus "loading dock" in safety plans.

Under 1917.2, when are "dockboards" allowed and what fall height limit do they reference?

Under 1917.2, "dockboards" (car and bridge plates) are devices used to span short distances between rail cars or highway vehicles and loading platforms and are permitted only when they do not expose employees to falls greater than 4 feet (1.22 m). See the Definition of "Dockboards" in 1917.2.

  • Practical point: if the span creates a potential fall greater than 4 feet, use other means (ramps, covered openings, guardrails) rather than a dockboard.
  • Compliance tip: measure vertical exposure before allowing dockboard use and document the decision based on the 4-foot limit in 1917.2.

Under 1917.2, what are "ramps" and how are they different from dockboards?

Under 1917.2, "ramps" are flat-surface devices used to pass between levels and across openings that are not covered under the definition of "dockboards." See the Definition of "Ramps" in 1917.2.

  • Practical point: use ramps when you need a more permanent or larger means of accessing different levels or spanning openings that exceed dockboard limits.
  • Compliance tip: select ramps that meet slope, width, and guard requirements appropriate to the traffic (people, forklifts, pallet jacks) using them.

Under 1917.2, what does "enclosed space" include and does it automatically equal a confined-space hazard?

Under 1917.2, an "enclosed space" is an indoor area (not a confined space) that may contain or accumulate a hazardous atmosphere due to poor natural ventilation; examples include trailers, railcars, and storage rooms. It does not automatically equal a confined-space hazard unless it also meets all confined-space criteria. See the Definition of "Enclosed space" and "Confined space" in 1917.2.

  • Practical point: you must evaluate each enclosed space for characteristics of a confined space before applying confined-space entry procedures.
  • Compliance tip: when atmospheric hazards are possible, follow monitoring and control practices such as those in 29 CFR 1910.134 for respiratory protection and atmosphere testing.

Under 1917.2, what is the difference between "examination" and "inspection" for material handling devices?

Under 1917.2, "examination" for certificated material handling devices is a comprehensive survey using criteria outlined in 29 CFR 1919.71(d) (and may include a unit proof test for quadrennial surveys), while "inspection" means a complete visual examination of all visible parts of the device. See the Definitions of "Examination" and "Inspection" in 1917.2.

  • Practical point: inspections are routine visual checks; examinations are deeper, formal, and tied to certification schedules and testing requirements in 29 CFR 1919.71(d).
  • Compliance tip: follow inspection checklists daily/weekly and schedule examinations per 1919.71(d) to maintain certification records.

Under 1917.2, what qualifies as a "flammable atmosphere" at a marine terminal?

Under 1917.2, a "flammable atmosphere" is one that contains more than 10 percent of the lower flammable limit of a flammable or combustible vapor or dust mixed with air. See the Definition of "Flammable atmosphere" in 1917.2.

  • Practical point: atmospheric monitoring should trigger controls or evacuation when a concentration exceeds 10% of the LFL (lower flammable limit).
  • Compliance tip: document LFL values for materials handled and use calibrated gas detectors appropriate for the substances present.

Under 1917.2, what are "front-end attachments" for industrial trucks and cranes?

Under 1917.2, "front-end attachments" on power-operated industrial trucks are devices like roll clamps, rotating and side-shifting carriages, magnets, rams, crane arms/booms, load stabilizers, scoops, buckets, and dumping bins attached to the load end; for cranes, the term means attachments that perform functions such as lifting, clamshell, or magnet services. See the Definition of "Front-end attachments" in 1917.2.

  • Practical point: attachments change how equipment handles loads; employer must ensure compatibility, safe operation, and operator training for each attachment.
  • Compliance tip: maintain records of attachment capacities and conduct pre-use inspections per the equipment manufacturer's guidance.

Under 1917.2, what is a "fumigant" and why does its definition matter in terminal operations?

Under 1917.2, a "fumigant" is a substance or mixture used to kill pests that is a gas or becomes gaseous during treatment, even if some non-gaseous matter remains; it matters because fumigation can create hazardous atmospheres in cargo spaces. See the Definition of "Fumigant" in 1917.2.

  • Practical point: when cargo is fumigated, restrict access, post warnings, and test atmospheres before allowing workers to enter.
  • Compliance tip: coordinate with fumigation handlers and follow atmospheric monitoring and respiratory protection rules such as 29 CFR 1910.134 if airborne hazards are present.

Under 1917.2, how is "hazardous cargo, material, substance or atmosphere" defined for marine terminals?

Under 1917.2, "hazardous cargo, material, substance or atmosphere" includes: (1) any substance listed in 29 CFR part 1910, subpart Z; (2) substances listed in the DOT Hazardous Materials Table at 49 CFR part 172; (3) articles properly classified under 49 CFR part 173; and (4) any atmosphere with oxygen content below 19.5%. See the Definition in 1917.2.

  • Practical point: treat materials that fit any of these criteria as hazardous and apply relevant handling, labeling, and PPE rules (e.g., 1910.1200 Hazard Communication).
  • Compliance tip: use MSDS/SDS, DOT shipping papers, and atmospheric testing for oxygen levels to classify hazards and control exposures.

Under 1917.2, what are "house falls" and when are they used?

Under 1917.2, "house falls" are spans, supporting members, winches, blocks, and standing and running rigging that are part of a marine terminal and used with a vessel's cargo gear to load or unload by means of married falls. See the Definition of "House falls" in 1917.2.

  • Practical point: when using house falls, ensure rigging components are inspected and that operators are trained on married-fall operations and load limits.
  • Compliance tip: follow inspection and examination requirements for loose gear and lifting equipment as referenced in 1917.2 and related lifting-device standards.

Under 1917.2, what is an "intermodal container" and what is explicitly excluded from that term?

Under 1917.2, an "intermodal container" is a reusable, rigid, rectangular cargo container designed for easy transfer among transport modes and includes enclosed units, open-top units, fractional height units, and units with liquid or gas tanks; it explicitly excludes cylinders, drums, crates, cases, cartons, packages, sacks, and unitized loads. See the Definition of "Intermodal container" in 1917.2.

  • Practical point: treat intermodal containers as large unitized cargo requiring appropriate lifting gear, ventilation checks, and confined-space considerations for tank-type units.
  • Compliance tip: do not confuse small packages (cartons, sacks) with intermodal containers when applying handling and safety procedures.

Under 1917.2, what is "loose gear" and why should terminals track it?

Under 1917.2, "loose gear" refers to removable and replaceable components used with assembled material-handling units (for connections, changing line direction, or multiplying mechanical advantage), with examples including shackles and snatch blocks. See the Definition of "Loose gear" in 1917.2.

  • Practical point: loose gear is critical to safe lifts—use appropriate rated gear, inspect before use, and store securely to prevent loss or damage.
  • Compliance tip: maintain inspection records and a gear inventory to ensure only certified loose gear is used with lifting operations.

Under 1917.2, what does the term "marine terminal" include and what does it exclude?

Under 1917.2, a "marine terminal" includes wharves, bulkheads, quays, piers, docks, other berthing locations, and adjacent storage or areas used for primary movement of cargo or passengers to/from vessels, including maintenance areas; it excludes production or manufacturing areas and storage facilities directly associated with those production areas. See the Definition of "Marine terminal" in 1917.2.

  • Practical point: apply marine-terminal specific rules to berthing and adjacent cargo-handling areas, but do not apply them to separate manufacturing operations on the same property.
  • Compliance tip: map your site to clearly show which areas are covered as "marine terminal" to apply correct standards and trainings.

Under 1917.2, what are "ship's stores" and when are they treated differently from cargo?

Under 1917.2, "ship's stores" are materials aboard a vessel for upkeep, maintenance, safety, operation, or the comfort of passengers and crew; they are distinguished from cargo because they are intended for the vessel's use rather than for shipment. See the Definition of "Ship's stores" in 1917.2.

  • Practical point: treat ship's stores per vessel procedures and label/secure them appropriately during transfer, but be aware they may still present hazards (flammability, chemicals) that require handling controls.
  • Compliance tip: consult the vessel's inventory and safety data sheets for ship's stores to apply correct PPE and transfer procedures.