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OSHA 1918.31

Hatch cover safety requirements

1918 Subpart D

23 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.31(a), can employees load or unload cargo from a partially opened intermediate deck?

No — employees may not perform loading or unloading at a partially opened intermediate deck unless the hatch is sufficiently covered or there is an adequate landing area for the prevailing conditions. See 1918.31(a).

  • If neither a proper cover nor an adequate landing area exists, work must not be done at that partially opened deck.

Under 1918.31(a), what does the standard mean by the working area extending "for a distance of 10 feet... fore and aft and athwartships"?

It means the available floor or landing for employees must provide at least 10 feet of clear working space both along the ship's length (fore and aft) and across its width (athwartships). See 1918.31(a).

  • This is a minimum; employers must account for the actual conditions (cargo size, equipment, and stability) when determining if the area is sufficient.

Under 1918.31(b), can cargo be landed or handled over a covered hatch if hatch beams are missing?

No — cargo shall not be landed on or handled over a covered hatch or 'tween-decks unless all hatch beams are in place under the hatch covers. See 1918.31(b).

  • Missing beams create unsupported covers that can collapse under load, so do not place cargo over covered hatches without the beams in position.

Under 1918.31(c), what must employees do if they find missing, broken, or poorly fitting hatch covers?

They must report the unsafe covers immediately to the officer in charge of the vessel, and no work shall be performed in the section with those covers or adjacent sections until the flooring is made safe or the vessel repairs/replaces the covers. See 1918.31(c).

  • The requirement applies pending replacement or repair by the vessel; it protects employees from falling through or load failures.

Under 1918.31(c), may work continue in adjacent sections when hatch covers are unsafe if temporary flooring is installed?

Yes — work in the affected or adjacent sections may continue only if the flooring is made safe (for example by installing secure temporary flooring) before work proceeds. See 1918.31(c).

  • The temporary flooring must be adequate for the prevailing conditions and loads involved.

Under 1918.31(d), can hatch covers and hatch beams of different sizes be mixed and used interchangeably?

No — hatch covers and hatch beams that are not of uniform size shall be placed only in the hatch, deck, and section in which they fit properly. See 1918.31(d).

  • This prevents improper seating or gaps that could create fall hazards or fail under load.

Under 1918.31(e), when must small trimming hatches in intermediate decks be covered or guarded?

Small trimming hatches in intermediate decks must be securely covered or guarded while work is going on in the hatch where they are found, unless the trimming hatches are actually in use. See 1918.31(e).

  • If a trimming hatch is needed for trimming operations it can remain open, but otherwise it must be covered or guarded to prevent falls.

Under 1918.31(a), what is an "adequate landing area" and who decides if it is adequate?

An adequate landing area is a landing or working surface suitable for the prevailing conditions that provides safe space to land and handle cargo; the employer and the vessel's officer in charge must ensure it is adequate before work proceeds. See 1918.31(a).

  • Factors include size, load-bearing capacity, stability, and clearance around working employees and equipment.

Under 1918.31(b), what does "all hatch beams are in place under the hatch covers" require the vessel to provide?

It requires that the structural supports (hatch beams) be correctly installed beneath hatch covers before cargo is landed or handled over them, so the covers have the intended support to bear the weight. See 1918.31(b).

  • Without beams the covers may not support loads; the vessel is responsible for providing and placing beams that fit properly (see 1918.31(d)).

Under 1918.31(c), who is the "officer in charge of the vessel" to whom unsafe hatch covers must be reported?

The "officer in charge of the vessel" refers to the vessel's responsible officer or supervisor who oversees safe operations onboard; employees must report missing, broken, or poorly fitting hatch covers to that person immediately. See 1918.31(c).

  • Reporting promptly ensures the officer can arrange repairs, replacements, or safe flooring to protect workers.

Under 1918.31(d), what must you do if you only have hatch covers or beams that fit a different hatch or section?

You must not place those non-uniform covers or beams in a hatch where they do not fit properly; use them only in the hatch, deck, and section for which they were designed or sized. See 1918.31(d).

  • Using wrong-size covers or beams can leave gaps or unsupported areas and create fall or load-failure hazards.

Under 1918.31(e), what are acceptable methods to "securely cover or guard" trimming hatches while work is ongoing?

Acceptable methods include properly sized hatch covers, strong temporary planking or decking secured in place, or fixed guardrails that prevent workers and cargo from falling through the opening. See 1918.31(e) and 1918.31(b).

  • Whatever method is used, it must be secure for the current work and loads and must remain in place unless the hatch is actively being used for trimming.

Under 1918.31, if hatch covers are poorly fitting but work must continue elsewhere on deck, what steps must an employer take?

The employer must ensure the poorly fitting covers are reported to the officer in charge and ensure that no work is performed in the unsafe section or adjacent sections until the flooring is made safe or repairs are completed. See 1918.31(c).

  • If work elsewhere continues, the employer should isolate or guard the unsafe area and verify temporary flooring or guards adequately protect workers.

Under 1918.31, are hatch covers allowed to be stacked or mixed during storage if they are different sizes?

While 1918.31(d) focuses on use rather than storage, the rule that non-uniform hatch covers and beams be used only where they fit properly implies employers should identify and store covers so they are returned to the matching hatch, deck, and section. See 1918.31(d).

  • Best practice: clearly mark and segregate covers and beams by hatch section to avoid installing mismatched components.

Under 1918.31, can cargo be passed over a covered 'tween-deck during continuous lifting operations if hatch beams are in place but covers are worn?

No — if hatch covers are missing, broken, or poorly fitting such that they would not protect employees, they must be reported and work halted until made safe; worn covers that do not protect must be treated as unsafe. See 1918.31(c).

  • Even with beams in place, the covers themselves must be in condition to protect workers and loads.

Under 1918.31(a), does the 10-foot working area requirement apply to the total length of a cargo landing area or only to clear space adjacent to a partially opened hatch?

The 10-foot requirement applies to the working area available for employees at the partially opened intermediate deck and must extend 10 feet or more both fore and aft and athwartships (i.e., clear space around the working area). See 1918.31(a).

  • Employers should ensure the clear working area accommodates safe movement of employees and handling equipment in all directions specified.

Under 1918.31, who is responsible for making hatch flooring "safe" when hatch covers are found to be unsafe?

The vessel is responsible for replacing or repairing unsafe hatch covers, and pending that the employer (and officer in charge) must ensure work is not performed in the unsafe or adjacent sections unless the flooring is made safe. See 1918.31(c).

  • Practically, the vessel's officers coordinate repairs while the employer ensures jobsite controls (barriers, temporary flooring) to protect employees.

Under 1918.31, are there exceptions that allow handling cargo over a covered hatch without hatch beams in place?

No — the standard makes no exception: cargo shall not be landed on or handled over a covered hatch or 'tween-decks unless all hatch beams are in place under the hatch covers. See 1918.31(b).

  • Any deviation would require ensuring the cover and backing can safely bear the load, but the language requires beams under covers as the safe condition.

Under 1918.31, what is a practical way to confirm hatch covers "fit properly" before using them?

A practical confirmation is to visually and physically check that each cover seats evenly without gaps, rests on the appropriate coamings or supports, and that the matching hatch beams fit snugly beneath; use the requirement in 1918.31(d) as the standard for fit. See 1918.31(d).

  • If in doubt, report the cover as unsafe per 1918.31(c) and do not perform work over the hatch until verified safe.

Under 1918.31, are hatch beams required to be uniform size, and what should you do if you find non-uniform beams?

Hatch beams and covers should be used only in the hatch, deck, and section in which they fit properly; if beams are non-uniform, they must only be placed where they fit, and mismatched beams should not be used elsewhere. See 1918.31(d).

  • If non-uniform beams are discovered, mark and segregate them and obtain the correct beams for the hatch in question.

Under 1918.31, may a vessel operator or crane operator leave a suspended load over a hatch to get another operator to finish the lift?

No — an operator must not leave a suspended load unattended in a way that endangers employees; the employer must assign an operator who can complete the lift without unscheduled interruption. See OSHA's interpretation on crane operators which explains that an operator who becomes incapacitated and leaves the controls while a load is suspended creates an unsafe situation (see Crane operator medical condition scenario) and also consult 1918.31(a).

  • Employers must ensure competent and physically able operators handle suspended loads so workers on or near hatches are not placed at risk.

Under 1918.31, can hatch covers with temporary repairs be used to land or handle cargo?

Only if the temporary repairs make the flooring safe for the prevailing conditions; otherwise, work must not be performed in the section or adjacent sections until proper repairs or replacement are completed. See 1918.31(c).

  • Any temporary flooring or repair must be strong enough for the expected loads and must be inspected and approved by the officer in charge before use.

Under 1918.31, are there specific markings or records required for which covers and beams belong to which hatch section?

1918.31(d) requires that non-uniform covers and beams be used only where they fit properly but does not prescribe markings or records; however, marking and keeping an inventory is a practical compliance step to ensure correct placement. See 1918.31(d).

  • Employers should adopt procedures (marking, tagging, or logs) so covers and beams are returned to the correct hatch and to prevent mismatches that create hazards.