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OSHA 1917.71

Intermodal container terminal rules

Subpart D

27 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.71(a), what markings must every intermodal container have before handling at a terminal?

Every intermodal container must be legibly and permanently marked with its empty weight, its maximum cargo weight, and the sum of both (the container plus cargo). See the marking requirements in 1917.71(a).

Under 1917.71(b)(1), what must an employer do before a crane hoists a container to determine if it is loaded or empty?

The employer must ascertain from the carrier whether the container to be hoisted is loaded or empty before any hoisting begins. This duty is stated in 1917.71(b)(1).

Under 1917.71(b)(3), when must every outbound loaded container that is received ready to load aboard a vessel be weighed?

Every outbound loaded container received at a marine terminal ready to load aboard a vessel must be weighed to obtain the actual gross weight before being hoisted. See 1917.71(b)(3).

Under 1917.71(b)(4)(ii), if a terminal has no scales how may the actual gross weight of a container be determined?

If the terminal has no scales, the actual gross weight may be calculated by adding the weight of the container when empty to the weight of its contents and then posting those calculated weights on the container with the name of the person who made the calculation and the date. See 1917.71(b)(4)(ii) and the posting requirement in 1917.71(b)(5).

Under 1917.71(b)(2), what are the two acceptable ways to provide the actual gross weight of a loaded container to the crane operator and supervisors?

You must either plainly mark the actual gross weight on the container so it’s visible to the crane operator and supervisors, or provide a cargo stowage plan or equivalent permanent display that contains the actual gross weight and the container’s identification to the crane operator and supervisors. See the two options in 1917.71(b)(2)(i) and 1917.71(b)(2)(ii).

Under 1917.71(b)(6), when are closed dry van containers carrying vehicles exempt from the weighing requirement in paragraph (b)(4)?

Closed dry van containers carrying only completely assembled vehicles and no other cargo, that are marked externally so employees can readily tell they contain vehicles, and whose vehicles were loaded at the marine terminal, are exempt from the paragraph (b)(4) weighing requirement. See the three exemption conditions in 1917.71(b)(6)(i)–(iii).

Under 1917.71(b)(8), what standard must scales meet when used in the United States to weigh containers?

Any scale used within the United States to weigh containers for these requirements must meet the accuracy standards of the state or local public authority where the scale is located. See 1917.71(b)(8).

Under 1917.71(c), can a container be hoisted if its actual gross weight exceeds the marked maximum cargo weight or the crane’s capacity?

No — a container may not be hoisted if its actual gross weight exceeds the container's marked maximum cargo weight in 1917.71(a)(2) or if it exceeds the capacity of the crane or hoisting device to be used, as stated in 1917.71(c).

Under 1917.71(d), what must employers provide for safe passage of employees in container handling areas?

Employers must set aside marked or designated areas within a container or roll-on/roll-off terminal for employees to pass to and from active cargo transfer points unless the employer provides transportation to those points; they also must direct employees to stay clear of areas beneath suspended containers. See 1917.71(d)(1) and 1917.71(d)(2).

Under 1917.71(e) and (f), what high-visibility protection must employees wear in container handling areas, and what are acceptable examples?

Each employee working near container handling equipment or in terminal traffic lanes must wear a high visibility vest or equivalent protection such as high-visibility/retro-reflective coveralls that make the worker visible by day and at night. The requirement is in 1917.71(e), and acceptable material areas (for example background and retro-reflective minimums) are described in 1917.71(f) and its explanatory text.

Under 1917.71(f)(1)(i)–(ii), how must loaded containers 20 feet or longer be hoisted by their top fittings?

Loaded containers 20 feet or more in length hoisted by their top fittings must have lifting forces applied vertically from at least four such fittings; if hoisting from bottom fittings, the hoisting connections must bear only on the fittings and make no other contact with the container. See 1917.71(f)(1)(i) and 1917.71(f)(1)(ii).

Under 1917.71(f)(1)(i)(A)–(F), when is a less-than-vertical lift permitted and what safeguards are required?

A less-than-vertical lift is permitted only if the container is an ISO closed box in sound condition, hoisting and lowering speeds are moderated for heavily laden containers, the lift angle is 80–90 degrees, the spreader-to-load clearance and spreader beam lengths meet the specified minimums, and other listed conditions are met. See the full set of conditions in 1917.71(f)(1)(i)(A)–(F).

Under 1917.71(f)(2)(i)–(ii), what requirements apply to container spreaders and twistlock systems to prevent accidental release?

Employers must take all precautions to prevent accidental release when spreaders use lanyards for activation, and spreader twistlock systems must be designed and used so that a suspended load cannot accidentally be released. See 1917.71(f)(2)(i)–(ii).

Under 1917.71(g), what inspections are required before handling intermodal containers and what must be done with unsafe containers?

Intermodal containers must be inspected for defects in structural members or fittings before handling, and any container found unsafe must be identified, removed from service, and repaired before being returned to service. See 1917.71(g)(1)–(2).

Under 1917.71(h), what must be done with engaged chassis twist locks before a container is hoisted?

Before hoisting a container, all engaged chassis twist locks must be released so that containers are not hoisted while still locked to a chassis. See 1917.71(h).

Regarding vertical tandem lifts (VTLs), under 1917.71(i)(2)–(3), how many containers may be lifted and what condition must they meet before the lift begins?

No more than two intermodal containers may be lifted in a VTL, and the employer must ensure that the two containers are empty before the lift begins. See 1917.71(i)(2)–(3).

Under 1917.71(i)(1), who must be trained for VTL operations and what must that training cover?

Each employee involved in VTL operations must be trained and competent in the safety-related work practices, safety procedures, and other requirements in 1917.71 that pertain to their job assignments. See 1917.71(i)(1).

Under 1917.71(i)(4)(i)–(iii), what crane features are required for performing VTLs?

VTLs must be performed using a shore‑based container gantry crane or another crane that has precision control to restrain unintended rotation, can handle the load volume and wind sail potential of VTLs, and is specifically designed to handle containers. See 1917.71(i)(4)(i)–(iii).

Under 1917.71(i)(7), when are VTL operations not allowed because of wind?

VTL operations are prohibited when wind speed exceeds the lesser of 55 km/h (34 mph or 30 knots) or the crane manufacturer's recommended maximum wind speed. See 1917.71(i)(7)(i)–(ii).

Under 1917.71(i)(8)(iv)(A)–(B), what testing and certification requirements must interbox connectors meet for VTLs?

Each interbox connector used in VTLs must be tested and certificated as having a load-bearing surface area of 800 mm2 when connected to a 65.0 mm corner casting opening and a safe working load of 98 kN (10,000 kg) with a safety factor of five when loaded via two 65.0 mm corner castings (or equivalent). This testing/certification requirement is in 1917.71(i)(8)(iv)(A)–(B).

Under 1917.71(i)(9), what inspections must be performed on containers, corner castings, and interbox connectors immediately before use in a VTL?

Each container, corner casting, and interbox connector used in a VTL must be inspected immediately before use: connectors need visual checks for cracks, functional checks that locks work with adequate spring tension, and corrosion checks; containers and corner castings must be checked for cracks, corrosion, enlarged openings, bad welds, or debris like ice or mud. See the inspection items in 1917.71(i)(9)(ii)–(iii).

Under 1917.71(j)(2) and 1917.71(k), what written plans and zones must an employer have for transporting vertically connected containers?

The employer must develop, implement, and maintain a written transport plan for vertically connected containers that establishes safe operating and turning speeds, covers terminal conditions affecting safety, and includes a defined safe work zone where employees may not be present while vertically connected containers are in motion. See 1917.71(j)(2) and 1917.71(k).

Regarding modifying powered industrial trucks used in terminals, which Letter of Interpretation explains when adding a strobe is allowed and what approvals or training may be needed?

OSHA's December 21, 2004 Letter of Interpretation explains that installing a strobe light on powered industrial trucks is allowed if you obtain the manufacturer's written approval or written approval from a professional engineer when required, and operators may need refresher training under [29 CFR 1910.178(l)]. See the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0 and the powered industrial truck training requirement referenced in 1917.1(a)(1)(xiv).

Regarding reach stackers at marine terminals, which Letter of Interpretation explains whether they must be certificated under 1917.50?

OSHA's March 17, 2017 memorandum explains that reach stackers are considered powered industrial trucks and are therefore exempt from the certification requirement in [1917.50], but they remain subject to [1917.43] and the powered industrial truck training requirements in [29 CFR 1910.178(l)]. See the memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2017-03-17 and 1917.50.

Regarding crane operator incapacity, which Letter of Interpretation addresses whether an operator may leave controls while a load is suspended?

OSHA's September 13, 2013 Letter of Interpretation states that an operator who becomes incapacitated may not leave the controls while a load is suspended; the employer must ensure operators are physically able to perform assigned tasks without unscheduled interruptions. See the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13 and the related requirements in 1917.

Under 1917.71(f)(3)–(4), what equipment features must chassis, flatbeds, and trailers used to move containers have?

Flatbed trucks and container chassis must have pins, flanges, or other positive means to prevent container shifting, and after July 27, 1998, flat beds, low boy trailers and similar equipment used to transport containers must be marked with their cargo capacities and must not be overloaded. See 1917.71(f)(3) and 1917.71(f)(4).

Under 1917.71(i)(8)(v)–(vi), what documentation and markings must interbox connectors have for VTL use?

Each interbox connector must have a certificate available for inspection attesting it meets the strength criteria in [1917.71(i)(8)(iv)], and it must be clearly and durably marked with its safe working load for lifting and an identifying number or mark that links it to its test certificate. See 1917.71(i)(8)(v)–(vi).