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OSHA 1918.1

Scope and application

Subpart A

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.1(a), what operations does Part 1918 apply to?

Part 1918 applies to longshoring operations and related employment aboard vessels. See 1918.1(a).

  • This means work done on vessels related to loading, unloading, or otherwise handling cargo aboard the vessel is covered by Part 1918.
  • Cargo transfer that uses shore‑based material handling devices (for example, shore cranes moving cargo) is not covered by Part 1918 but is covered by Part 1917 of OSHA’s standards, as stated in 1918.1(a).

Under 1918.1(a), are cargo transfers using shore-based material handling devices covered by Part 1918 or Part 1917?

Cargo transfers accomplished with the use of shore‑based material handling devices are covered by Part 1917, not Part 1918. See 1918.1(a).

  • If the cargo handling is shore‑based (shore cranes, shore forklifts moving cargo to/from a vessel), follow Part 1917.
  • Part 1918 applies mainly to operations that take place aboard the vessel (longshoring and related employment aboard vessels).

Under 1918.1(b), which specific provisions of 29 CFR 1910 continue to apply to longshoring?

Part 1910 generally does not apply to longshoring, except for the specific provisions listed in 1918.1(b).

Those provisions that do apply include: access to employee exposure and medical records (1910.1020) under 1918.1(b)(1); commercial diving (Subpart T) under 1918.1(b)(2); shore‑based electrical installations powering vessels under 1918.1(b)(3); hazard communication (1910.1200) under 1918.1(b)(4); ionizing radiation (1910.1096) under 1918.1(b)(5); noise (1910.95) under 1918.1(b)(6); nonionizing radiation (1918.1(b)(7)); respiratory protection (1910.134) under 1918.1(b)(8); toxic and hazardous substances (Subpart Z) with specified exceptions under 1918.1(b)(9); and powered industrial truck operator training (1910.178(l) ) under 1918.1(b)(10).

  • Consult each cited provision for the specific duties and how they apply to longshoring activities.

Under 1918.1(b)(1), which recordkeeping standard applies to longshoring for access to employee exposure and medical records?

Access to employee exposure and medical records for longshoring is covered by 1910.1020, as specified in 1918.1(b)(1).

  • Employers in longshoring must allow access to exposure and medical records consistent with 1910.1020.
  • Keep records, training documentation, and release information as required by that standard.

Under 1918.1(b)(4), does the Hazard Communication standard (1910.1200) apply to longshoring activities?

Yes. Hazard communication requirements in 1910.1200 apply to longshoring activities as stated in 1918.1(b)(4).

  • Employers must maintain labels, safety data sheets (SDSs), and worker training where hazardous chemicals are present during marine cargo handling.
  • Use the 1910.1200 requirements to determine what information, communication, and training you must provide.

Under 1918.1(b)(6), does the OSHA noise standard (1910.95) cover longshoring operations?

Yes. The OSHA occupational noise standard, 1910.95, applies to longshoring as specified in 1918.1(b)(6).

  • Employers must implement hearing conservation, monitoring, and protection measures when noise exposures meet or exceed the action levels in 1910.95.
  • Use audiometric testing and training requirements in 1910.95 where applicable.

Under 1918.1(b)(7), when are exposures to nonionizing radiation from commercial vessel radar considered hazardous?

Exposures to nonionizing radiation from commercial vessel radar are considered hazardous when the radar is transmitting and either (a) the scanner is stationary and the exposure distance is 19 feet (5.79 m) or less, or (b) the scanner is rotating and the exposure distance is 5 feet (1.52 m) or less, per 1918.1(b)(7).

  • If exposures meet these conditions, employers should treat them as hazardous under the nonionizing radiation guidance in 1918.1(b)(7).
  • Consider engineering controls, restricted access, signage, and worker training to reduce exposures below hazardous distances.

Under 1918.1(b)(8), does the Respiratory Protection standard (1910.134) apply to longshoring activities?

Yes. Respiratory protection requirements in 1910.134 apply to longshoring, as stated in 1918.1(b)(8).

  • When workers aboard vessels or during marine cargo handling face respiratory hazards, employers must follow 1910.134 for medical evaluation, fit testing, training, and written respiratory protection programs.
  • Implement the required respiratory protection program elements in 1910.134 when exposures warrant respirator use.

Under 1918.1(b)(10), does powered industrial truck operator training in 1910.178(l) apply to longshoring, and what about the compliance dates?

Yes. Powered industrial truck operator training in 1910.178(l) applies to longshoring, as stated in 1918.1(b)(10).

  • Note the rule text includes a compliance‑date note saying the December 1, 1999 compliance dates in 1910.178(l)(7) were stayed until March 1, 2000 for longshoring; see 1918.1(b)(10).
  • Employers must follow the training, evaluation, and documentation requirements in 1910.178(l).

Under 1918.1(b)(9), when does Subpart Z (toxic and hazardous substances) not apply to marine cargo handling activities?

Subpart Z applies to marine cargo handling activities except when the substance or cargo is contained within a sealed, intact means of packaging or containment that complies with Department of Transportation or International Maritime Organization requirements, as stated in 1918.1(b)(9)(i).

  • Other explicit exceptions listed in 1918.1(b)(9) include bloodborne pathogens (1910.1030), carbon monoxide and hydrogen sulfide addressed via 1910.1000 with cross‑references to 1918.94(a) and 1918.94(f), and hexavalent chromium (1910.1026 and 1915.1026).
  • If cargo is sealed and intact per DOT/IMO rules, many Subpart Z workplace requirements for the packaged material won’t apply during typical marine cargo handling, but employers must still address hazards that arise if containers are opened or damaged.

Under 1918.1(b)(9)(ii), which standard covers bloodborne pathogens for marine cargo handling?

Bloodborne pathogens encountered during marine cargo handling are covered by 1910.1030, per the exception in 1918.1(b)(9)(ii).

  • Employers handling potentially infectious materials must follow the bloodborne pathogens standard (1910.1030) for exposure control, training, hepatitis B vaccination, and recordkeeping.

Under 1918.1(b)(9)(iii) and 1918.94(a), how does OSHA treat carbon monoxide exposures in marine cargo handling?

Carbon monoxide exposures in marine cargo handling are governed by 1910.1000 with the specific marine reference in 1918.1(b)(9)(iii) and further guidance in 1918.94(a).

  • Use the permissible exposure limits and monitoring requirements in 1910.1000 when assessing CO hazards on vessels or during cargo operations.
  • See 1918.94(a) for additional shipboard breathing hazard guidance that cross‑references the general industry limits.

Under 1918.1(b)(9)(iv) and 1918.94(f), how does OSHA treat hydrogen sulfide exposures in marine cargo handling?

Hydrogen sulfide exposures in marine cargo handling are addressed by the general industry airborne contaminant limits in 1910.1000 with marine‑specific references in 1918.1(b)(9)(iv) and further guidance in 1918.94(f).

  • Employers must evaluate H2S hazards, monitor where necessary, and follow the exposure limits and protective measures found in 1910.1000.
  • Consult 1918.94(f) for shipboard considerations tied to these exposures.

Under 1918.1(b)(9)(v) and 1918.1(c), which standard applies to hexavalent chromium exposures in workplaces covered by Part 1918?

Hexavalent chromium exposures in workplaces covered by Part 1918 are regulated by 1915.1026, and 1918.1(c) confirms that 1915.1026 applies to occupational exposures to hexavalent chromium under this part.

  • Although Subpart Z includes 1910.1026 for general industry, 1918.1(c) directs employers in maritime contexts to follow the shipyard‑related 1915.1026 requirements.

Under 1918.1(b)(3), if shore-based electrical installations provide power for use aboard vessels, which OSHA provisions apply?

When shore‑based electrical installations provide power for use aboard vessels, the electrical requirements in Subpart S of Part 1910 apply to those shore‑based installations, as noted in 1918.1(b)(3).

  • Employers should follow the relevant electrical safety rules and standards in Part 1910 (Subpart S) for shore power systems, connections, and work on those installations.
  • Coordinate with vessel operators and shore electrical personnel to ensure compliance when shore power is used aboard ships.

Under 1918.1, does Part 1910 generally apply to longshoring activities?

No. Part 1910 generally does not apply to longshoring, except for the specific provisions listed in 1918.1(b).

  • Use Part 1918 as the primary source for longshoring operations and consult the specific Part 1910 provisions identified in 1918.1(b) when they are relevant.

Under 1918.1(b)(10), what does the note about compliance dates mean for longshoring employers regarding powered industrial truck training?

The note means that the compliance dates in 1910.178(l)(7) that were originally set for December 1, 1999, were stayed specifically for longshoring until March 1, 2000, as stated in 1918.1(b)(10).

  • Longshoring employers must comply with the powered industrial truck operator training requirements in 1910.178(l), respecting the special compliance‑date note in 1918.1(b)(10).
  • Check the specific paragraphs of 1910.178(l) for training content, evaluation, and documentation requirements.

If cargo is in sealed, intact packaging that complies with DOT or IMO rules, does Subpart Z apply during typical marine cargo handling under 1918.1(b)(9)(i)?

If the cargo is contained in sealed, intact packaging or containment that complies with DOT or IMO requirements, then Subpart Z workplace substance rules generally do not apply to that packaged cargo during normal marine cargo handling, according to 1918.1(b)(9)(i).

  • This exception covers properly sealed containers transported and handled without opening or damage.
  • If containers are opened, damaged, or leaking, Subpart Z obligations (and other applicable standards) may apply; employers must then evaluate hazards and apply the relevant 1910 requirements.

How should longshoring employers handle situations where on-vessel tasks create potential overhead falling-object hazards—do crane operators aboard vessels need head protection?

Yes. If a crane operator or other employee aboard a vessel has potential to be struck by falling objects, the employer must ensure head protection is used, consistent with OSHA guidance in the head protection letter of interpretation (June 6, 2024). See the OSHA interpretation on head protection for crane operators and the employer’s duty to assess hazards per OSHA standards.

  • The interpretation explains that where there is potential for injury from falling objects (for example when lifting loads with cranes or hoists), employers must require protective helmets for affected employees.
  • Employers should follow consensus standards for helmets referenced in that interpretation and perform a hazard assessment to decide who must wear head protection.