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OSHA 1918.2

Definitions for longshoring

Subpart A

25 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.2, what does the term 'barge' mean?

A barge is an unpowered, flat‑bottomed, shallow‑draft vessel such as river barges, scows, carfloats, and lighters, but it does not include ship‑shaped or deep‑draft barges. See the definition in 1918.2 for the exact wording.

Under 1918.2, what is meant by 'bulling' during cargo handling?

Bulling means dragging cargo horizontally across a surface while none of the cargo's weight is supported by the fall (the lifting gear). This definition is in 1918.2 and helps distinguish safe lifting from unsafe sliding or dragging practices.

Under 1918.2, how is a 'danger zone' defined around machinery or equipment?

A danger zone is any place in or about a machine where an employee could be struck by or caught between moving parts, between moving and stationary parts, caught between material and a moving part, burned by hot surfaces, or exposed to electric shock. The definition and examples (nip points, shear lines, drive mechanisms, areas under counterweights) are in 1918.2.

Under 1918.2, what is a 'designated person' and when must they be used?

A designated person is someone the employer assigns who has specialized abilities in a specific area to perform a specific task. The employer must assign a designated person when a task requires those specialized abilities, as defined in 1918.2.

Under 1918.2, what are 'dockboards' and what height limit applies to them?

Dockboards (also called car or bridge plates) are devices that span short distances between, for example, two barges, and they are limited to uses where the span is not higher than four feet (1.22 m) above the water or the next lower level. See the definition in 1918.2.

Under 1918.2, who counts as an 'employee' for longshoring operations?

An employee is any longshore worker or other person engaged in longshoring or related employments, excluding the master, ship's officers, crew of the vessel, or any person employed by the master to load or unload vessels under 18 net tons. This coverage language appears in 1918.2.

Under 1918.2, what does 'employer' mean in the longshoring context?

An employer is any person who employs employees in longshoring operations or related employments as defined in the section; this identifies who holds responsibilities under the longshoring rules. See the definition in 1918.2.

Under 1918.2, how is an 'enclosed space' on a vessel defined and why does it matter?

An enclosed space is an interior space in or on a vessel that may contain or accumulate a hazardous atmosphere because ventilation is inadequate (examples: holds, deep tanks, refrigerated compartments). This matters because enclosed spaces can create hazardous atmospheres that require special precautions under 1918.2.

Under 1918.2, when does the term 'fall hazard' apply in longshoring?

A fall hazard exists when (1) employees are working within three feet (0.91 m) of an unprotected edge of a work surface that is 8 feet or more (2.44 m) above the adjoining surface and 12 inches (0.3 m) or more horizontally from the adjacent surface, or (2) when weather conditions may impair vision or footing of employees working on top of containers. The precise conditions are specified in 1918.2.

Under 1918.2, what does 'fumigant' mean in ship or cargo operations?

A fumigant is a substance or mixture used to kill pests that is a gas or becomes gaseous quickly (though some nongaseous particles may remain and be dispersed). This definition is in 1918.2 and matters because fumigation can create hazardous atmospheres requiring controls.

Under 1918.2, what counts as a 'gangway'?

A gangway is any ramp‑like or stair‑like access provided to let people board or leave a vessel, including accommodation ladders, gangplanks, and brows. See the definition in 1918.2.

Under 1918.2, what is a 'hatch beam' or 'strongback' and when is it used?

A hatch beam or strongback is a portable transverse or longitudinal beam placed across a hatchway that acts as a bearer to support hatch covers; it is used when temporary support of hatch covers is needed, as defined in 1918.2.

Under 1918.2, how is 'hazardous cargo, materials, substance or atmosphere' defined and what cross‑references apply?

Hazardous cargo/materials/substances/atmospheres include: (1) any substance listed in 29 CFR part 1910, subpart Z, (2) materials listed in DOT's Hazardous Materials Table at 49 CFR part 172, (3) articles classified under 49 CFR part 173, or (4) any atmosphere with oxygen content below 19.5% or above 23%. The full definition appears in 1918.2 and links to general industry hazardous substance rules in 1910 and hazard communication concepts in 1910.1200.

Under 1918.2, what is an 'intermodal container' and what items are excluded?

An intermodal container is a reusable, rigid rectangular cargo container designed for handling and transfer between transport modes; it includes enclosed units, open‑top units, tank units, and other variations, but it does not include cylinders, drums, crates, cases, cartons, packages, sacks, or unitized loads. See the detailed definition in 1918.2.

Under 1918.2, what activities are classified as 'longshoring operations'?

Longshoring operations mean loading, unloading, moving, or handling cargo, ship's stores, gear, or other materials into, in, on, or out of any vessel. This is the operational scope defined in 1918.2 and tells you what the longshoring rules cover.

Under 1918.2, what geographic area does 'Mississippi River System' cover?

The 'Mississippi River System' includes the Mississippi River from the head of navigation to its mouth and designated navigable tributaries such as the Illinois Waterway, Missouri, Ohio, Tennessee, Allegheny, Cumberland, Green, Kanawha, and Monongahela Rivers, and others where barge operations extend. See the specific list in 1918.2.

Under 1918.2, what is a 'public vessel' for longshoring rules?

A public vessel is one owned and operated by a government and not regularly employed in merchant service; this classification is in 1918.2 and affects whether certain rules apply to that vessel.

Under 1918.2, how is a 'ramp' different from a 'dockboard'?

A ramp is any flat surface device for passage between levels and across openings not covered under the term dockboards; dockboards are short‑span devices limited to heights not over four feet above the water or next lower level. The definitions distinguishing the two appear in 1918.2.

Under 1918.2, what does 'related employments' include?

Related employments are jobs performed incidental to or in conjunction with longshoring operations, including but not limited to securing cargo, rigging, and work as a porter, clerk, checker, or security officer. This scope is defined in 1918.2.

Under 1918.2, what distinguishes a 'river towboat' from other towing vessels?

A river towboat is a shallow‑draft, low‑freeboard, self‑propelled vessel designed to tow river barges by pushing ahead; it does not include other types of towing vessels. See the definition in 1918.2.

Under 1918.2, what are 'Ro‑Ro operations' and what special hazards should employers consider?

Ro‑Ro operations are cargo handling and related activities (like lashing) on Roll‑On/Roll‑Off vessels where cargo is driven on and off by ramps and moved within the vessel by ramps or elevators. This definition is in 1918.2. Employers should consider vehicle movement, ramp edge fall hazards, and the need for traffic control and PPE when planning Ro‑Ro operations; for example, head‑protection expectations for crane or lifting operators are explained in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

Under 1918.2, what is meant by 'ship's stores' on a vessel?

Ship's stores are materials aboard a vessel for upkeep, maintenance, safety, operation, navigation, or for the safety or comfort of passengers and crew; see the definition in 1918.2.

Under 1918.2, what is a 'small trimming hatch' and when does the definition not apply?

A small trimming hatch is a small opening in an intermediate deck used for trimming dry bulk cargoes and is not the large hatchways through which cargo is normally handled; the definition and its limit are in 1918.2.

Under 1918.2, how is 'vessel' defined for longshoring regulations?

A vessel includes every description of watercraft or other artificial contrivance used or capable of being used for transportation on water, including special purpose floating structures not primarily designed for transportation; see the broad definition in 1918.2.

Under 1918.2, what does 'vessel's cargo handling gear' include and can it cover powered equipment?

Vessel's cargo handling gear includes permanent equipment on a vessel used for handling cargo (other than bulk liquids), covering stationary or mobile appliances used to suspend, raise, lower, or move loads while suspended or supported; it explicitly includes cargo elevators, forklifts, and other powered industrial equipment. See the definition in 1918.2 and note that when that gear creates overhead hazards employers must consider head protection responsibilities discussed in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.