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OSHA 1918.26

Barge access and safety requirements

1918 Subpart C

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.26(a), what ramp standards apply when a ramp is used only for vehicle access to or between barges?

Under 1918.26(a) ramps used solely for vehicle access to or between barges must meet the requirements of 1918.25.

  • Consult the full 1918.25 text for the specific construction, guarding, and maintenance details that apply to vehicle ramps.
  • Note the exception in 1918.26(a) that excludes application of 1918.25(b)(2) to ramps used solely for vehicle access.

Under 1918.26(b), when must an employer provide a ramp versus a safe walkway between a wharf and a float, barge, or river towboat?

Under 1918.26(b) an employer must provide either a ramp meeting 1918.25 or a safe walkway meeting 1918.22(f) whenever employees cannot step safely to or from the wharf and the float, barge, or river towboat.

  • If neither a ramp nor a walkway can be used, the employer must provide a straight ladder meeting 1918.24 that extends at least three feet above the upper landing and is secured.
  • When a straight ladder is not feasible, a Jacob's ladder meeting 1918.23 must be provided.

Under 1918.26(b), what are the minimum requirements for a straight ladder used where a ramp or walkway cannot be used?

Under 1918.26(b) a straight ladder provided in lieu of a ramp or walkway must meet the requirements of 1918.24 and must extend at least three feet (0.91 m) above the upper landing surface and be adequately secured or held against shifting or slipping.

  • Ensure the ladder is fastened or otherwise stabilized so it cannot slip while employees are using it, as required by 1918.26(b).

When must a Jacob's ladder be provided under 1918.26, and what standard governs it?

Under 1918.26(b) and 1918.26(c) a Jacob's ladder meeting the requirements of 1918.23 must be provided when neither a walkway nor a straight ladder can be used, and when a barge or raft is being worked alongside a larger vessel unless another safe means of access is provided.

  • Per 1918.26(c), provide a Jacob's ladder for each gang working alongside, but no more than two Jacob's ladders are required for any single barge or raft.

Under 1918.26(c), how many Jacob's ladders are required when a barge or raft is worked alongside a larger vessel?

Under 1918.26(c) an employer must provide a Jacob's ladder for each gang working alongside a larger vessel unless another safe means of access is provided, but no more than two Jacob's ladders are required for any single barge or raft.

  • See 1918.26(c) for the specific per-gang and maximum-per-barge requirements.

What does 1918.26(d) require employers to do during longshoring operations on barges?

Under 1918.26(d) when longshoring operations are in progress on barges, employers must ensure the barges are securely made fast to the vessel, wharf, or dolphins.

  • Securely making fast prevents movement of the barge during cargo handling and is a specific requirement in 1918.26(d).

Under 1918.26(b), what is the Mississippi River System exception and what must the employer show to use it?

Under 1918.26(b) the exception allows barges operating on the Mississippi River System to be provided with other safe means of access when the employer shows that the normal ramp, walkway, or ladder requirements cannot reasonably be met due to local conditions.

  • The employer must demonstrate that local conditions make the standard access requirements impractical and then provide an alternative means of access that is safe, as described in 1918.26(b).

Under 1918.26, what is the order of preferred access methods between a wharf and a barge when stepping safely is not possible?

Under 1918.26(b) the preferred order is: first provide a ramp meeting 1918.25, if that is not feasible provide a safe walkway meeting 1918.22(f), if neither can be used provide a straight ladder meeting 1918.24 extending at least three feet above the landing, and if even a straight ladder cannot be used provide a Jacob's ladder meeting 1918.23.

Under 1918.26(a), how does the reference to 1918.25(b)(2) affect vehicle ramps used between barges?

Under 1918.26(a) vehicle-only ramps must meet 1918.25 except for the provisions of 1918.25(b)(2), which do not apply to ramps used solely for vehicle access.

  • Consult the referenced sections—1918.26(a) and 1918.25(b)(2)—to confirm which specific subsection is excepted for vehicle-only ramps.

Under 1918.26(b), if a straight ladder is provided, how much must it extend above the upper landing surface and why?

Under 1918.26(b) a straight ladder must extend at least three feet (0.91 m) above the upper landing surface to provide a secure handhold for employees as they step on or off the ladder, and it must be adequately secured against shifting or slipping.

Under 1918.26(c), what does "for each gang working alongside" mean in practice when deciding how many Jacob's ladders to provide?

Under 1918.26(c) "for each gang working alongside" means that each distinct work crew (gang) operating along the side of the larger vessel must have a safe means of access—typically a Jacob's ladder—unless another safe access method is provided, but in no case must the employer provide more than two Jacob's ladders for any single barge or raft.

  • The rule and its limit are stated in 1918.26(c) and the construction of Jacob's ladders is governed by 1918.23.

If a barge is worked alongside a larger vessel and a gang has a safe alternative access, does 1918.26(c) still require a Jacob's ladder?

Under 1918.26(c) a Jacob's ladder is required for each gang working alongside a larger vessel only "unless other safe means of access is provided," so if the employer provides an equivalent safe access method for that gang, a Jacob's ladder is not required.

  • The conditional language and exception are in 1918.26(c).

Where can I find the detailed construction requirements for a safe walkway referenced in 1918.26(b)?

The detailed construction and safety requirements for a safe walkway referenced in 1918.26(b) are in 1918.22(f).

If the employer cannot secure a barge to the wharf during longshoring, does 1918.26(d) allow any alternatives?

Under 1918.26(d) the standard requires that barges be securely made fast to the vessel, wharf, or dolphins during longshoring operations; if an employer cannot secure the barge as required, they must provide an alternative means to ensure equivalent safety, because the rule's purpose is to prevent hazardous movement during cargo handling.

  • The affirmative requirement is in 1918.26(d), and any alternative must provide the same level of protection implied by that requirement.

Under 1918.26, can an employer substitute other safe means of access in places other than the Mississippi River System exception?

Under 1918.26 the standard generally requires ramps, walkways, straight ladders, or Jacob's ladders in the specified order, but the text permits other safe means of access specifically for barges operating on the Mississippi River System when the employer shows the standard requirements cannot reasonably be met due to local conditions; for locations not on the Mississippi River System, other safe means are not explicitly authorized by 1918.26 and the employer should instead meet the listed options or document equivalent safety by other applicable standards.

  • See the exception language in 1918.26(b) and the primary access requirements in 1918.26.