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OSHA 1917.44

Vehicle rules at marine terminals

Subpart C

29 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.44(a), what vehicle operations in a marine terminal does the rule cover and are there any exceptions?

The rule applies to general vehicle use within marine terminals, but paragraphs (c) and (l) do not apply where they are preempted by applicable Department of Transportation regulations. See 1917.44(a) for the applicability and exception. Employers should interpret this provision so they enforce the vehicle rules in the terminal while recognizing that DOT rules may override certain trailer-immobilization and vehicle-floor provisions when those DOT regulations apply.

Under 1917.44(b), where may employees park their private vehicles while at a marine terminal?

Private vehicles may be parked only in areas designated by the employer within the marine terminal. See 1917.44(b). Employers should mark and communicate the designated parking areas to employees and visitors to prevent unauthorized parking and maintain safe traffic flow.

Under 1917.44(c), when must a trailer's road wheels be immobilized in relation to disconnecting it from a tractor at a loading dock?

Trailer road wheels must be immobilized before the trailer is disconnected from the tractor and remain immobilized until braking is again provided. See 1917.44(c). Also note the section exception that DOT brake rules may preempt this paragraph, as explained in 1917.44(a).

Under 1917.44(c), what additional supports are required when a trailer is entered by a material handling vehicle?

Employers must use supplementary front-end support when necessary to prevent tipping and rear-end support if the trailer's rear wheels are so far forward that tipping can occur when entered. See 1917.44(c). Use appropriate blocks, stands, or other supports and train material-handling operators in their use.

Under 1917.44(d), what must employers require of motor vehicle operators regarding speed limits and traffic signs?

Employers must direct motor vehicle operators to obey any posted speed limits, traffic control signs or signals, and written traffic instructions within the terminal. See 1917.44(d). Employers should post limits, provide written traffic rules, and ensure drivers are informed and supervised for compliance.

Under 1917.44(e), when are stop signs required at structures inside a terminal?

Stop signs must be posted at main entrances and exits of structures where visibility is impaired and at blind intersections unless an equivalent traffic-control or warning system is provided. See 1917.44(e). If you use mirrors or active traffic control that give equal or better protection, you may substitute those systems.

Under 1917.44(f), what should employers do about vehicular routes and parking areas in the terminal?

Employers must establish, identify, and require use of vehicular routes, traffic rules, and parking areas. See 1917.44(f). Clearly mark routes, use signage and pavement markings, and train employees to follow the designated patterns to reduce collisions and pedestrian exposure.

Under 1917.44(g), what must vehicle drivers do to alert employees working in traffic lanes?

Vehicle drivers must warn employees in traffic lanes of the vehicle's approach. See 1917.44(g). Warnings can be given by horn, flashing lights, spotters, or other reliable means, and drivers should be trained to check for and communicate with nearby workers before moving.

Under 1917.44(h), where must signs indicating pedestrian traffic be posted?

Signs indicating pedestrian traffic must be clearly posted at vehicular check-in/check-out lines and similar locations where employees may be working. See 1917.44(h). Use visible signage and consider additional controls like marked crosswalks or barriers to separate pedestrian and vehicle flows.

Under 1917.44(i), what minimum spacing must be kept between vehicles in check-in or loading lines where employees work between them?

A distance of at least 20 feet must be maintained between the first two vehicles (and between any subsequent vehicles) in check-in, check-out, roadability, or vessel loading/discharging lines where employees are required to work between vehicles. See 1917.44(i). Maintain and enforce this spacing to give workers room to move safely and reduce pinch or crush hazards.

Under 1917.44(j), can an employer leave an unattended vehicle with its engine running in the terminal?

No, an unattended vehicle may not be left with its engine running unless it is secured against movement; powered industrial trucks have specific rules at 1917.43(b)(3). See 1917.44(j) and 1917.43(b)(3). Employers should ensure parking brakes, chocks, or other controls are used when engines are left running and the operator is absent.

Under 1917.44(k), what must be done when the rear of a vehicle is raised to load or unload?

When a vehicle's rear is elevated for loading or discharging, the employer must provide and secure a ramp, and the vehicle must be secured against accidental movement during the operation. See 1917.44(k). Use wheel chocks, brakes, dock locks, and ensure ramps are properly fastened to prevent slips or separations.

Under 1917.44(l), what requirement applies to highway vehicle floors used in the terminal?

Only highway vehicle floors that are in safe condition may be used in the terminal. See 1917.44(l). Employers should inspect floors for rot, holes, loose boards, or other hazards and repair or remove unsafe vehicles from service.

Under 1917.44(m), how must cargo that can roll or spread be controlled on flatbeds or similar conveyances?

Cargo that could spread or roll and endanger employees must be contained to prevent movement during loading or discharging of flatbeds, platform containers, or similar conveyances. See 1917.44(m). Use straps, chains, chocks, blocking, or other securement devices appropriate for the load and inspect their condition before use.

Under 1917.44(n), what requirements apply to vehicles used to transport employees within a terminal?

Vehicles used to transport employees within a terminal must be maintained in safe working order and must not have safety devices removed or made inoperative. See 1917.44(n). Keep brakes, lights, guardrails, seat belts, and other safety features functioning and perform regular maintenance checks.

Under 1917.44(o), which OSHA standard covers servicing of multi-piece and single-piece rim wheels and where is that scope referenced?

Servicing of multi-piece and single-piece rim wheels is covered by 1910.177, and that coverage is referenced in 1917.44(o) with a cross-reference to 1917.1(a)(2)(xii). Employers servicing such wheels in marine terminals must follow 1910.177 procedures and training requirements.

Under 1917.44(o)(1)-(2), what wheels and rims are covered by the servicing provisions in this section?

Paragraph (o) applies to servicing vehicle wheels that contain tube-type tires mounted on multi-piece rims, and defines a "multi-piece rim" as a rim consisting of two or more parts including a side locking ring that holds the tire by tension when inflated. See 1917.44(o)(1) and 1917.44(o)(2).

Under 1917.44(o)(3)(i)-(ii), who may be assigned to service multi-piece rim wheels and how must they demonstrate competence?

Only employees trained in the procedures of paragraph (o)(4) and who have demonstrated their ability to service multi-piece rim wheels may be assigned the duties; competence is shown by safe performance of specified tasks such as tire demounting, component inspection, mounting, inflation using a restraining device, handling, inflation when mounted, and wheel installation/removal. See 1917.44(o)(3)(i) and 1917.44(o)(3)(ii). Employers must document training and practical demonstration of these skills before assigning duties.

Under 1917.44(o)(4)(i)-(ii), what must be done with tires and valve cores before demounting or removing a wheel from an axle?

Tires must be completely deflated by removing the valve core before demounting, and the valve core must be removed before the wheel is removed from the axle if the tire has been operated at 80% or less of recommended pressure or if damage to tire/wheel components is suspected. See 1917.44(o)(4)(i) and 1917.44(o)(4)(ii). These steps reduce the risk of sudden release of pressure during service.

Under 1917.44(o)(4)(v)-(vii), what precautions must be taken when partially inflating a tire and when using restraining devices?

When seating a locking ring or rounding out a tube during partial inflation without a restraining device, air pressure must not exceed 3 psig; while the tire is pressurized components must not be struck or forced, and employees or equipment must not contact the restraining device during inflation. See 1917.44(o)(4)(v), 1917.44(o)(4)(vi), and 1917.44(o)(4)(vii). Follow these steps to avoid violent component failures and ensure employee clearance.

Under 1917.44(o)(4)(ix) and (o)(5), what inspection and reference materials must be available before assembling multi-piece rim wheels?

Wheel components must be inspected before assembly and damaged rim components must not be reused; employers must also provide a chart with NHTSA safety instructions and a current manufacturer's rim manual in the terminal service area. See 1917.44(o)(4)(ix) and 1917.44(o)(5)(i)-(ii). Keep these references accessible so technicians can match components and follow correct procedures.

Under 1917.44(o)(6)-(6)(ii), what are the requirements for restraining devices used during tire inflation?

Tire inflation must be performed within a restraining device (cage, rack, etc.) capable of withstanding forces generated by an explosive wheel separation at 150% of the wheel's maximum specification pressure, and the device must be kept in good repair to prevent rim components from being thrown outside it. See 1917.44(o)(6)(i) and 1917.44(o)(6)(ii). When inflating wheels mounted on vehicles, a restraining device may not be required if the tire already has more than 80% of recommended pressure and remote control inflation equipment is used with employees clear of the danger area; see 1917.44(o)(6).

Under 1917.44(o)(7), what features must inflation hoses and control valves have for safe inflation?

Inflation hoses must have a manual clip-on chuck with enough length for the employee to remain clear of the danger zone and use an inline manual valve with gauge or a preset pressure regulator for inflation. See 1917.44(o)(7). This lets the operator control pressure from a safe distance and prevents manual over-inflation.

Under 1917.44(o)(8), what tools and component practices are required when servicing multi-piece rim wheels?

Only tools recommended in the rim manual for the specific wheel type shall be used, and wheel components must not be interchanged except as allowed by the applicable chart or manual. See 1917.44(o)(8)(i)-(ii). Follow manufacturers' guidance and matching charts to avoid mismatches that can cause failures.

How does OSHA's 2024 Letter of Interpretation on 'Scope of rim wheel servicing' affect whether C-type or LT light-truck tires fall under 1910.177 when serviced in a marine terminal?

OSHA's 2024 interpretation confirms that 1910.177 covers servicing of multi-piece and single-piece rim wheels used on large trucks, tractors, trailers, buses and off-road machines, but not routine automobile or LT-designated truck tires; however, C-type light truck tires may be treated similarly to LT tires depending on their actual service characteristics and equipment used. See "Scope of rim wheel servicing" (Aug 1, 2024) and 1910.177. Employers should evaluate whether servicing C-type tires requires the same procedures and equipment as LT tires and follow 1910.177 when the rims and service methods fall within its scope.

When can a tire mounted on a vehicle be inflated without a restraining device under 1917.44(o)(6)(i)?

A tire mounted on a vehicle can be inflated without a restraining device only if it already has more than 80% of the recommended pressure and remote-control inflation equipment is used with employees clear of the danger area. See 1917.44(o)(6)(i). Employers must ensure remote inflation systems and clearance procedures are reliable before omitting the restraining device.

How should employers document training and ability for employees servicing multi-piece rim wheels under 1917.44(o)(3)?

Employers should provide training in the procedures of paragraph (o)(4) and document that employees have demonstrated ability through safe performance of the listed tasks (demounting, inspection, mounting, inflation with restraining device, handling, inflation on vehicle, installation/removal). See 1917.44(o)(3)(i)-(ii) and 1917.44(o)(3)(ii). Keep training records and competency assessments in the terminal's service area for supervisory review.

What charts and manuals must be available in the terminal service area per 1917.44(o)(5)?

Employers must provide an NHTSA-based chart with safety instructions for mounting/demounting tube-type truck/bus tires and a current rim manual with the manufacturer's instructions for the exact multi-piece rim wheels being serviced, both available in the terminal's service area. See 1917.44(o)(5)(i)-(ii). These references allow technicians to match components and follow safe procedures.

How does 1917.44 interact with DOT rules on trailer immobilization and vehicle floor condition as mentioned in the standard footnotes?

1917.44 contains provisions about trailer immobilization and vehicle floor condition, but paragraphs (c) and (l) do not apply where preempted by Department of Transportation regulations (e.g., DOT rules addressing trailer brakes and vehicle flooring). See 1917.44(a) and the footnote discussion within the standard text. Employers should check applicable DOT requirements when the motor carrier is engaged in interstate commerce or specific hazardous transport.