Deck load safety requirements

No. Under 1918.33(a) employees are not permitted to pass over or around deck loads unless there is a safe route of passage, so employers must provide or designate a safe route before allowing passage (1918.33(a).

• Make sure the route is free of tripping hazards, adequately lit, and strong enough for foot traffic.
• If a safe route cannot be provided, do not allow employees to traverse the deck load; use alternative access such as gangways, ladders, or other protected walkways.

No. Under 1918.33(b) employees giving signals to crane operators may not walk over deck loads from rail to coaming unless there is a safe route of passage (1918.33(b).

• If the signaling task requires crossing a deck load, the employer must provide a safe route or an alternative method of signaling (e.g., radio, tag lines or designated spotting positions).
• Employers should assess the route and provide fall protection or guarding when appropriate.

Employers must provide fall protection whenever employees stand or walk at the outboard or inboard edge of a deck load that has less than 24 inches (0.61 m) of bulwark, rail, coaming, or other protection, per 1918.33(b) (1918.33(b).

• Fall protection can include guardrails, personal fall-arrest systems, safety nets, or other effective means appropriate to the task and conditions.
• Evaluate the specific hazard and provide training and equipment that fit the work (anchor points, harness inspection, etc.).

You must provide protection when the bulwark, rail, coaming, or other protection measures less than 24 inches (0.61 m) exist at the outboard or inboard edge of the deck load; the 24 inches is the threshold in 1918.33(b) that triggers the employer's duty to protect against falling (1918.33(b).

• Measure the horizontal distance from the edge where an employee would stand or walk to the top of the bulwark/rail/coaming or other barrier.
• If that protective feature provides less than 24 inches of effective protection, then provide fall protection for employees working on or near that edge.

The employer is responsible for ensuring and determining that a route over a deck load is safe before permitting employees to use it, because 1918.33(a) and (b) prohibit passage unless a safe route exists (1918.33(a), 1918.33(b).

• Employers should inspect routes for stability, clearances, tripping hazards, lighting, and proximity to fall hazards.
• Document the inspection and corrective actions; train employees to use only designated safe routes.

Temporary or partial walkways can be acceptable only if the employer ensures they meet the same safety criteria as permanent routes and that employees are only permitted to use them when they are safe, because 1918.33 requires a safe route of passage before permitting access (1918.33(a).

• Temporary walkways should be structurally sound, securely fastened, non-slip, and free of debris.
• Use guardrails or fall protection where required, and clearly mark and maintain temporary routes.
• If the temporary route cannot be made safe, do not permit employees to cross the deck load.

Yes. Employers must train employees so they understand the hazards and safe procedures for walking over deck loads or acting as signalers, because 1918.33 prohibits passage unless a safe route exists and requires protection when needed (1918.33(a), 1918.33(b).

• Training should cover how to use designated routes, required fall protection, hazard recognition, and safe signaling practices.
• Keep records of training and periodically refresh training when conditions or procedures change.

If a guardrail (or equivalent) providing at least 24 inches is not feasible, employers must provide other effective protection such as personal fall-arrest systems or safety nets for employees who must stand or walk at edges with less than 24 inches of protection, consistent with 1918.33(b) (1918.33(b).

• Personal fall-arrest systems must be properly selected, fitted, and anchored with appropriate training for use.
• Safety nets can be used if installed according to applicable standards and inspected regularly.
• Document why guardrails are infeasible and what alternative protection is provided.

Employers should not require signalers to cross deck loads unless a safe route of passage exists; 1918.33(b) explicitly prohibits signalers from walking over deck loads from rail to coaming unless a safe route is present (1918.33(b).

• Use alternative signaling methods (e.g., radio communications, designated signaling positions) when safe passage is not available.
• If crossing is necessary, ensure fall protection and a safe route are in place and signalers are trained.

The standard does not provide a detailed checklist but 1918.33 requires that employees not be permitted to pass over or around deck loads unless there is a safe route of passage, which means the employer must ensure the route is safe in practice (1918.33(a).

• A practical safe route should be stable, free of hazards, provide adequate footing and clearance, and include fall protection when needed.
• Employers should document inspections and corrective actions that demonstrate the route was evaluated and made safe.

Yes. The prohibition on passing over deck loads without a safe route applies at all times, including night or low-light operations; employers must ensure the route is safe under the actual conditions when employees will use it (1918.33(a).

• Provide adequate lighting for any designated route and for signaling positions.
• Reassess temporary routes at the start of each shift or when lighting or conditions change.

The standard does not prescribe a specific method, but 1918.33(b) requires that employees be provided with protection against falling when standing or walking at edges with less than 24 inches of protection, so lifelines and harnesses are acceptable options if they effectively prevent falls (1918.33(b).

• Select fall protection systems that fit the task, are compatible with anchor points, and meet relevant OSHA fall-protection requirements for inspection and use.
• Train employees on proper harness use, inspection, and rescue procedures.

Not inherently greater, but 1918.33(b) specifically addresses signalers and requires that they not walk over deck loads from rail to coaming unless a safe route exists and that they be protected against falling when working at edges with less than 24 inches of protection (1918.33(b).

• Because signalers often need to be nearer the operation and the edge, employers should evaluate their exposure carefully and provide appropriate fall protection and training.
• Use alternative signaling methods to reduce exposure where possible.

No. The standard requires the employer to ensure a safe route of passage before permitting employees to pass over deck loads; employee judgment alone is not sufficient to meet the employer's duty under 1918.33(a) (1918.33(a).

• Employers must inspect and control the route, correct hazards, and communicate when and how the route is safe to use.
• Prohibit informal workarounds and enforce use of designated safe routes.

While 1918.33 does not prescribe a specific documentation format, employers should keep inspection records, hazard correction logs, and training records showing the route was evaluated and made safe before permitting passage, which demonstrates compliance with the requirement in 1918.33(a) (1918.33(a).

• Include date/time of inspection, inspector name, observed hazards, corrective actions taken, and any temporary controls or fall protection provided.
• Maintain training records for employees authorized to use the route.

Yes. If a deck load shifts and creates an unsafe condition, the employer must stop passage and re-establish a safe route before permitting employees to pass over or around the deck load, consistent with 1918.33(a)'s prohibition on passage without a safe route (1918.33(a).

• Secure or re-stow the load, reassess footing and edge protections, and only allow passage after corrective actions.
• Communicate the hazard to all affected workers and supervisors.

Yes. OSHA's interpretation about a crane operator's responsibility to remain capable at the controls is relevant when signalers are crossing deck loads or working near suspended loads; the agency stated that an operator must be physically able to complete load handling without unscheduled interruption, which underscores coordinating safe signaling and routing for signalers (Crane operator medical condition scenario, Sept. 13, 2013).

• Ensure signalers are not placed in positions that require operators to leave controls or that create unsafe interruptions to crane operation.
• Coordinate procedures so both signalers and operators have safe routes and responsibilities before handling suspended loads.

No. PPE such as steel-toe boots may help with footing but cannot be the sole means to make a route safe; 1918.33 requires a safe route of passage and fall protection where applicable, which typically requires engineering or administrative controls in addition to PPE (1918.33(a), 1918.33(b).

• Combine PPE with hazards controls: stable walkways, good lighting, guardrails, or fall-arrest systems.
• Train workers on limitations of PPE and proper use as part of an overall hazard control plan.

The standard does not explicitly require a written plan in 1918.33, but when fall protection systems such as personal fall-arrest systems are used, employers should follow applicable OSHA fall protection requirements and maintain documentation of system selection, training, inspections, and any rescue plan; 1918.33(b) requires protection where less than 24 inches of barrier exists (1918.33(b).

• Document chosen fall protection measures, training records, and rescue procedures.
• A written rescue plan is particularly important if personal fall-arrest equipment is used and employees could be suspended after a fall.