Applicability to specialized terminals

Yes — the rule explicitly says the provisions of Subpart D apply to specialized terminals. The plain text of 1917.70 states that Subpart D applies to specialized terminals in addition to any other applicable requirements of Part 1917. Employers at specialized terminals must therefore follow Subpart D requirements along with any other relevant provisions in Part 1917 (Part 1917 overview).

Yes — specialized terminals must comply with Subpart D plus any other Part 1917 requirements that apply to their operations. 1917.70 makes this explicit, and the broader Part 1917 contains other specific machine- and operation-related rules that may still apply at the same facility. In practice this means you must:

• Identify which Subpart D rules apply to your specialized terminal operations;
• Also identify other Part 1917 provisions (e.g., equipment, cargo handling, or crane rules) that are relevant;
• Comply with both sets of requirements where they overlap.

No — Part 1910 does not automatically apply to marine terminals, including many specialized terminals; you must check for specific exceptions. OSHA explains in a letter of interpretation that Part 1910 standards generally do not apply to "marine terminals," and a designated waterfront facility that falls within the marine terminal definition is not covered by Part 1910 (see the 2017 LOI on applicability to waterfront facilities). That said, some Part 1910 requirements are explicitly incorporated into Part 1917 by reference or exception, so you must:

• Review Part 1917 to see which specific Part 1910 provisions are incorporated by reference (Part 1917 overview);
• If a Part 1910 requirement is not incorporated, do not assume it applies without confirmation; consult OSHA guidance or the applicable Part 1917 citation.

Not always — OSHA has interpreted that Part 1917's specific marine terminal requirements do not apply to certain "designated waterfront facilities." In a 2017 Letter of Interpretation OSHA confirmed that facilities used solely for bulk storage, handling, and transfer of liquids or gases (often called designated waterfront facilities) may not be subject to Part 1917 requirements. Practical steps:

• Determine whether your facility is a "marine terminal" as defined in Part 1917 and whether it functions as a designated waterfront facility;
• If your facility meets the designated waterfront facility description, consult the 2017 LOI and OSHA regional offices to confirm applicability;
• Remember other OSHA parts (for example, general industry or process safety standards) may still apply even if Part 1917 does not.

Employers at specialized terminals must ensure there are persons on-site who are adequately trained in first aid when the operation requires it. OSHA's guidance notes that maritime standards (including marine terminals) require that one or more on-site individuals be trained in first aid, and OSHA emphasizes bleeding-control preparedness as a component of workplace first-aid programs (see OSHA's First aid and bleeding control interpretation, June 19, 2019). Practical actions include:

• Identify the first-aid needs based on hazards at the specialized terminal;
• Ensure one or more on-site employees are "adequately trained" per OSHA's interpretation;
• Maintain appropriate first-aid supplies and consider bleeding-control kits where uncontrolled bleeding is a recognized hazard (Part 1917 overview).

Yes — reach stackers are treated as powered industrial trucks and are exempt from the 29 CFR 1917.50 certification requirement. OSHA's March 17, 2017 memorandum concludes that reach stackers fall within the powered industrial truck exception to the certification rule and therefore are exempt from the 1917.50 certification requirement, but they remain subject to other powered industrial truck rules (see the 2017 memo on reach stacker certification exemption). Compliance steps:

• Do not apply 1917.50 certification to reach stackers, per the 2017 memo;
• Still follow other applicable requirements such as safe operation under Part 1917 and powered industrial truck training in 29 CFR 1910.178(l) as referenced by OSHA.

Generally no — employers must provide required personal protective equipment without cost to employees, with limited exceptions set by the employer-payment final rule. OSHA's interpretation of the employer payment rule explains that PPE payment requirements in Parts 1910, 1915, 1917, 1918, and 1926 require employers to pay for PPE they must provide, subject to specific, narrow exceptions (see the 2014 LOI on employee PPE payment methods). Practical points:

• If Part 1917 requires the employer to provide the PPE, the employer must generally pay for it;
• Employers may use deposit/return systems only if they do not result in an actual cost to the employee, per OSHA guidance;
• Check the specific PPE rule or Part 1917 citation to confirm whether an item is required to be provided by the employer (Part 1917 overview).

Yes — modifications that could affect a vehicle's capacity or safety generally require prior written approval from the manufacturer or a qualified professional engineer. OSHA's guidance for marine terminals and longshoring states that modifications affecting capacity or safety must have manufacturer or engineer approval, and installing a strobe light may be allowed if that approval is obtained (see the 2004 LOI about strobe lights on industrial trucks). Practical steps:

• Obtain the manufacturer's prior written approval or a written approval from a registered professional engineer who has consulted the manufacturer;
• Provide refresher training and evaluation for operators if the modification affects safe operation, as per OSHA guidance;
• Document approvals and training to show compliance (Part 1917 overview).

Yes — OSHA expects crane hooks at marine terminals to be latched or otherwise secured to prevent accidental load disengagement. OSHA's interpretation notes that Part 1917 contains an explicit provision requiring crane hooks to be latched or otherwise secured (see the 2006 LOI on safety latches on sling hooks), and the maritime-specific rule 29 CFR 1917.45(e)(2) requires that crane hooks be latched or otherwise secured. Practical actions:

• Use latch-equipped hooks or other positive means to prevent accidental disengagement;
• Where a latch is impractical, document the rationale and use an alternative positive method consistent with manufacturer guidance and industry standards;
• Inspect hooks and latches regularly and maintain records as appropriate.

No — an operator must be physically able to complete the load handling operation and must not leave the controls while a load is suspended. OSHA's interpretation across maritime and other sectors makes clear that an operator who becomes incapacitated or leaves controls while the load is suspended creates an unacceptable hazard and the employer may be cited (see the 2013 LOI on crane operator medical condition scenarios). Practical steps for employers:

• Ensure assigned equipment operators are medically and physically capable of completing operations without unscheduled interruption;
• Do not permit operators to abandon controls with suspended loads;
• Have procedures and backup personnel trained so operations can be safely transferred without leaving a suspended load unattended.

No — using compressed air to clean personnel is prohibited in the maritime context and is strongly discouraged in general industry; compressed air for cleaning must be reduced and guarded where allowed. OSHA's interpretation advises that maritime rules explicitly prohibit compressed air for personnel cleaning and cites the general industry requirement that compressed air for cleaning must be reduced to less than 30 psig and used with effective chip guarding and PPE (see the 1994 LOI on compressed air and the standards referenced therein). Practical steps:

• Do not allow compressed-air cleaning of personnel at specialized terminals;
• Where compressed air is used for equipment cleaning, reduce pressure below 30 psig, use chip guards, and require appropriate PPE;
• Follow maritime-specific rules such as Part 1917 provisions that address similar hazards.

Yes — powered industrial trucks at marine terminals remain subject to training and safety requirements, even if certain certification requirements do not apply. OSHA's reach stacker memo clarifies that while reach stackers are exempt from the 1917.50 certification requirement, powered industrial trucks used at marine terminals are still subject to [29 CFR 1917.43] and the operator training requirements in [29 CFR 1910.178(l)], as referenced by OSHA (see the 2017 reach stacker memo). Practical actions:

• Ensure operators receive required training and evaluations under 29 CFR 1910.178(l);
• Maintain training records and perform refresher training as conditions or equipment change;
• Follow Part 1917 equipment rules such as [29 CFR 1917.43] for safe equipment modification and operation (Part 1917 overview).

Yes — OSHA standards set minimum requirements and employers may adopt more stringent protective measures than Subpart D requires. OSHA has repeatedly stated that its standards establish minimum requirements and do not prevent employers from implementing greater protections; this principle is reflected in OSHA's general interpretive guidance (for example, see OSHA's discussion in the 2019 first-aid and bleeding control LOI). Practical points:

• You may adopt safer practices, more training, or additional equipment beyond Subpart D;
• Document enhanced policies and train employees accordingly;
• Enhanced measures can reduce risk and may be persuasive evidence of good faith in the event of an inspection.