Temporary surfaces and safety nets

Under 1918.32(a), "of sufficient size and strength" means the temporary landing surface must be big enough and strong enough to support the weight and activity placed on it so employees can work without collapse or tipping.

• Inspect size and load: make sure the platform or landing area can accommodate the maximum load (cargo plus equipment and people) and the work space needed for safe handling.
• Verify strength: use engineering data, manufacturer ratings, or a qualified person to confirm the surface and supports (beams, shores, pallets, decking) will carry the expected loads with a margin of safety.
• Practical checks: confirm connections, fasteners, and bearing surfaces are secure; remove or repair any damaged members before landing loads.

See the 1918.32(a) requirement for the legal standard on this point.

Under 1918.32(b), a vertical safety net must be used when the edge of a hatch section or stowed cargo may create a fall hazard for an employee.

• If an exposed edge could let an employee fall, provide a vertical net or another method that gives equal protection to stop the fall.
• If vertical nets cannot be used because of the cargo type, stowage, or special circumstances, rig a trapeze net at the top edge or take other effective measures to prevent injury from a fall.
• Safety nets must be kept in good condition and be strong enough for their intended use, per 1918.32(b).

Under 1918.32(b), the employer must be able to demonstrate that vertical nets or other equally effective guarding cannot be used because of the type of cargo, cargo stowage, or other circumstances.

• You should document why vertical nets are impractical (for example, cargo geometry prevents attachment points, or stowage blocks access).
• Explain the alternative: rig a trapeze net at the top edge or describe other measures you will use to prevent injury from a fall.
• Keep evidence such as photos, written assessments, or a qualified person's statement to support the decision if OSHA requests it.

Under 1918.32(b), a trapeze net must be rigged at the top edge of the elevation when vertical nets cannot be used, and it must be installed to prevent an employee from striking dangerous objects or falling to a lower level.

• Rigging should place the trapeze net so it intercepts an employee who falls from the edge:
  • Secure rigging points at the top edge that can carry the dynamic load.
  • Keep the net taut and positioned to catch falls before the employee reaches hazards below.
• Maintain the net in good condition and ensure its strength is adequate for the intended use, per the maintenance and strength language in 1918.32(b).

Consult a qualified person when planning the rigging to confirm attachment strength, clearance, and net placement.

Under 1918.32(b), "other means providing equal protection" must prevent an employee from falling or prevent injury if a fall occurs to the same degree a vertical net would.

• Examples of acceptable alternatives could include: well-secured guardrails, barriers, fall-restraint systems, or a properly rigged trapeze net when vertical nets are impractical.
• The chosen method must be effective for the specific hazard (edge, cargo configuration) and maintained in good condition with adequate strength.
• Employers should document why the alternative provides equal protection and be prepared to show that documentation during inspections.

Always follow the performance requirement in 1918.32(b).

Under 1918.32(b) and 1918.32(c), safety nets must be maintained in good condition and be of adequate strength for the intended purpose.

• Inspect nets regularly for tears, worn fibers, broken seams, damaged or corroded hardware, and any other defects.
• Remove damaged nets from service and repair or replace them using the manufacturer's guidance or a qualified person's instructions.
• Ensure anchors, rigging hardware, and connections are rated for the dynamic and static loads expected and are secured by qualified personnel.

See the maintenance and strength requirement in 1918.32(b) and 1918.32(c).

Under 1918.32(c), a vertical safety net must be rigged and securely fastened when two gangs work in the same hatch on different levels to prevent employees or cargo from falling.

• The vertical net must be positioned to stop people or falling cargo from passing between the working levels.
• Secure fastening means the net and its anchors must be capable of resisting the forces of a fall and kept in good condition as required by 1918.32(c).
• Use a qualified person to design and inspect the net layout if the setup is complex or involves heavy cargo.

Under 1918.32(b), the employer is responsible for demonstrating that vertical nets or other equally effective guarding cannot be used due to cargo type, cargo stowage, or other circumstances.

• The employer should have written or photographic documentation, engineering assessments, or a qualified person's statement showing why vertical nets are impractical.
• This documentation should also describe the alternate protection chosen (e.g., trapeze net) and how it provides equivalent protection.
• Keep the documentation available for inspections and to inform workers of the safety plan.

Yes. Under 1918.32(b) and 1918.32(c), safety nets intended to prevent employees or cargo from falling must be maintained in good condition and be of adequate strength for the intended purpose.

• Design and select nets based on the expected loads: nets used to stop cargo may need higher load ratings and different construction than those designed primarily for personnel.
• Inspect hardware and netting before use, and keep records of inspections and repairs.
• When in doubt about required strength or inspection intervals, consult the net manufacturer or a qualified person.

Under 1918.32(b) and 1918.32(c), if a safety net is damaged it must be removed from service and repaired or replaced so it will provide adequate strength and protection.

• Stop using the damaged net immediately and secure the area to prevent reliance on it.
• Tag the net as defective and either repair it following the manufacturer's procedures or replace it.
• After repair or replacement, test and inspect the net and attachments before returning it to service.

Document the damage, corrective action, and inspections to show compliance with maintenance expectations in 1918.32(b).

Under 1918.32(b), guardrails or other means providing equal protection can be used instead of vertical nets if they prevent employees from falling or prevent injury if a fall occurs to the same degree as a net.

• Guardrails must be designed and installed so they effectively stop falls at the hatch edge and be strong enough for the expected loads.
• If guardrails cannot be used because of cargo or stowage configuration, nets or trapeze nets are required unless another equally protective measure is documented.
• Employers should document why a chosen method is equivalent and be prepared to demonstrate effectiveness during inspections.

The text of 1918.32 does not list detailed anchor specifications; it requires that nets be maintained in good condition and be of adequate strength for the purpose intended.

• Because the standard is performance-based, use manufacturer guidance, engineering design, or a qualified person to select and install anchors and hardware capable of the dynamic loads expected.
• Ensure anchors are inspected and rated, and that rigging is done by trained personnel.
• For complex or heavy-duty installations, document load calculations and attachment methods to show the attachment system meets the performance expectations of 1918.32.

Under 1918.32(c), the requirement specifically addresses gangs working on different levels; if two gangs are staggered horizontally and there's still a fall or cargo-drop hazard between them, employers must provide protection equivalent to preventing falls or falling cargo.

• If a horizontal offset creates a risk of someone or cargo falling from one gang to another, rig a vertical net, barrier, or other protective means that will stop people or cargo.
• Use the performance requirement in 1918.32(c) as the trigger: if a hazard exists, provide nets or equivalent protection and maintain them in good condition.
• Evaluate the specific layout and consult a qualified person to design the controls.

No—1918.32 does not specify exact inspection intervals; it requires that safety nets be maintained in good condition and be of adequate strength for the purpose intended.

• Employers should set inspection intervals based on the manufacturer's recommendations, frequency of use, environmental exposure, and the severity of possible failures.
• Typical practice: inspect nets before each use or shift for visible damage and perform periodic detailed inspections documented by a qualified person.
• Keep inspection records and remove defective nets from service until repaired or replaced to meet the maintenance expectations in 1918.32.

No. Under 1918.32(b), the employer must provide a vertical safety net or other means providing equal protection to prevent falls; tarps or canvas that do not provide reliable fall arrest or catch capability would not meet that performance requirement.

• If a tarp or canvas is engineered, anchored, and rated to catch a falling person or cargo and is demonstrated to provide equivalent protection, it could be considered—but that is uncommon and must be documented.
• Safer and more accepted controls are vertical nets, guardrails, trapeze nets (where vertical nets are impractical), or personal fall arrest/rescue systems designed and installed by qualified people.
• Employers should document why any nonstandard method is equivalent to the protections required in 1918.32(b).

Yes, safety nets may be moved and reused provided each installation meets the performance and maintenance requirements in 1918.32 for strength, condition, and proper rigging.

• Each time a net is installed it must be rigged and secured so it will stop falls or falling cargo for that specific location.
• Inspect the net, hardware, and anchors after each move and before use; repair or replace anything damaged.
• Keep records of inspections and ensure rigging is performed by trained personnel to maintain compliance with 1918.32.

Under 1918.32, employers must ensure nets and protections are used, but employers should also train workers on the hazards and safe work practices around hatch edges and nets.

• Train workers to recognize fall and falling-object hazards, the limitations of nets, and procedures for working near or over nets.
• Instruct workers not to rely on damaged nets and to report defects immediately.
• Train riggers and inspectors on proper installation, inspection, and removal procedures to keep nets in good condition as required by 1918.32(b) and (c).

While 1918.32 doesn't list training specifics, training is a best practice to ensure the protections are effective.

Under 1918.32(b), if vertical nets cannot be used because of cargo or stowage operations, employers must rig a trapeze net at the top edge or take other measures to prevent injury if an employee falls.

• Plan stowage so protection can be provided whenever workers are exposed to hatch edges.
• Use trapeze nets where vertical nets would obstruct cargo handling, or install temporary barriers, fall restraint, or other equally effective controls that do not interfere with operations.
• Document why vertical nets interfere with the operation and how the chosen alternative provides equivalent protection, as required by 1918.32(b).

Yes. Under the performance expectation of 1918.32(b) and (c), nets must be installed so they will prevent employees or cargo from falling onto hazards below; that requires appropriate clearance and placement.

• Ensure adequate clearance between the net and any structures, equipment, or the deck below so the net can deform and absorb energy without the falling object striking a hard surface.
• Consider the size and weight of cargo: heavier or larger objects need more clearance and possibly stronger or specially designed nets.
• Have a qualified person calculate required clearance and net capacity based on the anticipated drop heights and weights to meet the intent of 1918.32.

A personal fall arrest system can be used as an alternative if it provides protection equal to nets and the employer demonstrates its effectiveness for the task under 1918.32(b).

• Personal fall arrest systems must be selected, installed, inspected, and used according to applicable standards and manufacturer instructions and must be adequate for the particular work.
• Where personal fall arrest is used, employers must ensure rescue procedures are in place for timely retrieval of a suspended worker.
• Employers should document why a fall arrest system equals or exceeds the protection of a net for the specific hatch-edge hazard, per 1918.32(b).

While 1918.32 does not explicitly require manufacturer certification, nets must be "of adequate strength for the purpose intended," which commonly means using nets rated by the manufacturer or selected based on engineering calculations.

• Use nets that have manufacturer load ratings or documented engineering specifications appropriate to catch people or cargo.
• If a custom or improvised net is used, have a qualified person evaluate and certify its strength and suitability for the intended use.
• Maintain documentation of ratings, tests, or qualifications to demonstrate compliance with the performance requirements of 1918.32.

Under 1918.32, protections like nets or equivalent measures are required when the edge may constitute a fall hazard; if there is no potential for a fall hazard, a net may not be required.

• If the edge is not accessible to employees during work or the work is arranged so no employee is exposed to the fall hazard (for example, when operations are fully enclosed or barricaded), nets may not be necessary.
• Employers must assess the work activities and provide nets or equivalent protection when exposure to a falling hazard exists.
• Document hazard assessments and the rationale for not providing nets to show compliance with the performance requirement in 1918.32.