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OSHA 1918.21

Gangway general requirements

Subpart C

17 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.21, who is responsible for making sure employees do not board or leave a vessel until gangway requirements are met?

The employer is responsible and must not permit employees to board or leave a vessel until the applicable requirements of this subpart are met. Employers must confirm the means of access and related conditions comply before allowing boarding or leaving. See 1918.21.

Under 1918.21, does the rule that employees cannot board or leave apply to barges or river towboats?

No. The prohibition in 1918.21—that an employer shall not permit employees to board or leave a vessel until applicable requirements are met—does not apply to a barge or river towboat, because the text explicitly excepts those vessel types.

Under 1918.21(a), can suspended loads be passed over a gangway or other means of access while employees are on it?

No. Suspended loads shall not be passed over the means of access while employees or others are on it. Where possible, the means of access should be located so suspended loads do not pass over it at all. See 1918.21(a).

Under 1918.21(a), is it ever allowed to have suspended loads pass over the means of access when no one is on it?

Yes. The standard advises locating access so suspended loads do not pass over it if possible, but it only prohibits passing suspended loads over the means of access while employees or others are on it. So passing suspended loads above the access when it is unoccupied is not prohibited by 1918.21(a), though you should use safe rigging and other applicable load-handling rules.

Under 1918.21(b), what must be provided when the upper end of the gangway rests on or is flush with the top of the bulwark?

You must provide substantial steps, properly secured and trimmed, with at least one substantial handrail 33 inches (0.84 m) in height between the top of the bulwark and the deck. See 1918.21(b).

Under 1918.21(b), how high must the handrail be on the steps between the bulwark and deck?

The handrail must be 33 inches (0.84 m) in height. The standard specifies at least one substantial handrail of that height for the steps between the top of the bulwark and the deck. See 1918.21(b).

Under 1918.21(b), what do "substantial steps, properly secured and trimmed" mean in practical terms?

They must be strong and stable, fastened so they cannot shift or slip, and fitted so treads and risers are safe for footing (no loose, broken, or uneven treads). In short: use solid, well-attached steps with safe tread surfaces and at least one handrail. The requirement comes from 1918.21(b).

Under 1918.21(c), must a gangway or means of access be lit along its entire length?

Yes. The means of access must be illuminated for its full length in accordance with 1918.92. See 1918.21(c).

Under 1918.92 as referenced by 1918.21(c), what is the required average light intensity for a gangway?

The required average light intensity is five foot-candles (54 lux). 1918.92 sets this level and 1918.21(c) requires the means of access to be illuminated in accordance with that section.

Under 1918.21, what should an employer do if gangway lighting fails while employees need to board or leave?

The employer must not permit employees to board or leave until the applicable requirements—including illumination for the full length as required by 1918.21(c) and 1918.92—are restored. Ensure temporary lighting or other controls meet the required average light intensity of five foot-candles (54 lux) before permitting access.

Under 1918.21, does the standard require more than one handrail on the steps between the bulwark and deck?

No. 1918.21(b) requires at least one substantial handrail of 33 inches (0.84 m) in height; it does not mandate multiple handrails, though adding more can improve safety.

Under 1918.21, should employers try to route lifting operations so suspended loads never pass over gangways?

Yes. The standard says the vessel's means of access should be located so suspended loads do not pass over it if possible; this is the preferred practice to reduce the hazard to people using the access. See 1918.21(a).

Under 1918.21 and the crane operator interpretation, what should be done if an operator becomes incapacitated while a load is suspended over a gangway?

An operator must not abandon controls while a load is suspended because leaving the controls can create an unsafe condition; the employer must ensure operators are physically able to complete lifts without unscheduled interruptions. If an operator becomes incapacitated, do not leave the controls; have procedures in place to safely secure or complete operations. See 1918.21(a) and OSHA's interpretation on crane operators leaving controls (Crane operator medical condition scenario) at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13.

Under 1918.21, who must ensure the gangway steps are "properly secured" before boarding?

The employer must ensure steps are properly secured before permitting employees to board or leave. 1918.21(b) places responsibility on the employer to meet the requirements of the subpart before boarding occurs.

Under 1918.21, does the lighting standard require a specific measuring method or just the average foot-candle level?

The rule references 1918.92, which requires an average light intensity of five foot-candles (54 lux) among other lighting requirements. Employers should measure illumination to ensure the average intensity along the access meets that level per 1918.21(c).

Under 1918.21, can an employer rely on the vessel crew to fix gangway deficiencies before allowing longshoring employees to board?

An employer cannot permit boarding until the applicable requirements of this subpart are met, regardless of who performs the work; therefore, the employer must verify that the gangway and related conditions comply before employees board. See 1918.21.

Under 1918.21, is it acceptable to use temporary or portable lighting to meet the illumination requirement on a gangway?

Yes, provided the temporary or portable lighting brings the means of access to the required illumination level and meets the criteria in 1918.92 (an average of five foot-candles/54 lux) for the full length of the access before allowing boarding, consistent with 1918.21(c).