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OSHA 1918.34

Deck load requirements

Subpart D

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.34(a), can I work cargo on any deck if I think it can hold the load?

No. Under 1918.34(a), cargo must not be worked on decks that were not designed to support the load being worked. Employers must verify that the deck was specifically designed or rated for the intended cargo and operations before allowing work there.

  • Employers should confirm design load capacity with ship plans, the vessel owner, or a qualified engineer.
  • Do not rely only on visual inspection or informal judgment when lives are at risk.

Cited standard: 1918.34(a).

Under 1918.34(a), who is responsible for ensuring a deck can support the load being worked?

Under 1918.34(a), the employer is responsible for ensuring cargo is not worked on decks that were not designed to support the load being worked. This means the employer must check and document that the deck is suitable before operations begin.

  • Practical steps employers should take: confirm deck design load from vessel documentation, consult a qualified engineer when unsure, and communicate limits to workers.

Cited standard: 1918.34(a).

Under 1918.34(a), is it acceptable to place heavy cargo on a deck temporarily if I use additional blocking or dunnage?

Not automatically. Under 1918.34(a), cargo must not be worked on decks that were not designed to support the load. Adding blocking or dunnage does not substitute for a deck that is structurally insufficient unless an engineer or other qualified person determines and documents that the measures make the deck safe for the intended load.

  • If you plan temporary reinforcement, get written approval or calculations from a qualified engineer or the vessel owner.
  • Keep records of the engineering determination and communicate limits to the crew.

Cited standard: 1918.34(a).

Under 1918.34(b), what are the employer’s duties regarding grated decks used by employees?

Under 1918.34(b), grated decks must be properly placed, supported, maintained and designed to support employees. Employers must ensure grated decking is installed and kept in a condition that safely supports the people who must walk or work on it.

  • "Properly placed" means grating is located where workers need to access work areas without creating trip or fall hazards.
  • "Supported" means grating is installed on adequate framing and fastened so it cannot shift under load.
  • "Maintained" means damaged, corroded, or loose grating is repaired or replaced promptly.
  • "Designed to support employees" means the grating’s load rating and spacing must be appropriate for foot traffic and any tools or small equipment used on it.

Cited standard: 1918.34(b).

Under 1918.34(b), can grated deck panels be used as a makeshift walkway without checks?

No. Under 1918.34(b), grated decks must be designed and supported to support employees, so you cannot simply use random panels as walkways without verifying they are appropriate and safe.

  • Verify grating load rating, secure fastening, and that openings or corrosion do not create hazards.
  • If in doubt, have a qualified person inspect and approve the grating before use.

Cited standard: 1918.34(b).

Under 1918.34, what should I do if I find a cracked or badly corroded grated deck?

You must repair or remove it from service so employees are not exposed to the hazard, because 1918.34(b) requires grated decks to be maintained and designed to support employees.

  • Immediately restrict access to the damaged area (barriers, signs) until corrected.
  • Replace or repair the grating per manufacturer or engineer guidance.
  • Document the inspection, action taken, and date of repair.

Cited standard: 1918.34(b).

Under 1918.34(a), do we need written engineering calculations to prove a deck can support a specific cargo load?

Not always, but you need reliable evidence that the deck was designed to support the load; when the deck’s capacity is unclear or the load is heavy/unusual, obtain written confirmation or calculations from a qualified engineer or the vessel owner. This follows the rule in 1918.34(a) that cargo shall not be worked on decks not designed to support the load.

  • When in doubt, get a documented determination to protect workers and meet compliance.
  • Keep that documentation on file and available to inspectors and employees.

Cited standard: 1918.34(a).

Under 1918.34, can employees walk on grating that has gaps large enough for small tools to fall through?

No. Under 1918.34(b), grated decks must be designed to support employees, which includes having openings sized appropriately to prevent foot or tool entrapment and to reduce fall/trip hazards.

  • If grating openings are large enough to create a hazard, provide covers, secondary decking, or replace with appropriately sized grating.
  • Use toe boards or tool lanyards for small tools where necessary.

Cited standard: 1918.34(b).

Under 1918.34, are employers required to inspect grated decks regularly?

Yes—while 1918.34(b) does not prescribe a specific interval, it requires grated decks to be properly placed, supported, maintained and designed to support employees, which implies routine inspection and maintenance to ensure safety.

  • Establish inspection frequency based on use, environment (corrosive conditions need more frequent checks), and manufacturer recommendations.
  • Document inspections and corrective actions.

Cited standard: 1918.34(b).

Under 1918.34(a), can stacking cargo higher than usual be allowed if the deck was designed for the base load but not for the stacked height?

No. Under 1918.34(a), you must ensure the deck is designed to support the actual load being worked, which includes effects of stacking (concentrated loads, pallet loads, and dynamic forces). If stacking increases the load beyond the deck’s design, it is not permitted without an engineered determination that the deck can handle it.

  • Consider load distribution, point loads, and dynamic forces when evaluating stacked cargo.
  • Obtain engineering confirmation before exceeding known limits.

Cited standard: 1918.34(a).

Under 1918.34, do grated decks used for both cargo and pedestrian traffic need different design considerations?

Yes. Under 1918.34(b), grated decks must be designed to support employees, so grating and supports chosen for cargo handling may not be adequate for pedestrian safety and vice versa. Each intended use should be accounted for in the design and maintenance.

  • Check grating load ratings for both pedestrian loads and any equipment or cargo that will be placed on the grating.
  • Avoid using grating with openings that create trip or foot hazards for pedestrians even if it can carry cargo.

Cited standard: 1918.34(b).

Under 1918.34, is temporary bridging allowed over damaged decks so work can continue?

Only if the temporary bridging is designed and installed to safely support employees and the loads, and it does not leave employees exposed to hazards; this is consistent with 1918.34(b) requiring grated decks to be properly placed, supported, maintained and designed to support employees. Temporary measures should be engineered or approved by a qualified person.

  • Use rated, tested bridging materials and secure them to prevent movement.
  • Restrict access until bridging is installed and verified safe.
  • Document approvals and inspections.

Cited standard: 1918.34(b).

Under 1918.34, what should I do before using a deck that has not been used for cargo operations in a long time?

You should verify that the deck was designed to support the intended load and inspect it for deterioration before use, because 1918.34(a) prohibits working cargo on decks not designed for the load and 1918.34(b) requires grated decks to be properly maintained and able to support employees.

  • Review vessel plans or consult the owner for deck load rating.
  • Perform a physical inspection for corrosion, damage, or loose fittings.
  • Obtain engineering confirmation if capacity or condition is uncertain.

Cited standards: 1918.34(a) and 1918.34(b).

Under 1918.34, can contractors bring their own temporary grating to create walkways on a vessel?

Yes, but only if the temporary grating is properly placed, supported, maintained and designed to support employees as required by 1918.34(b). The employer (or contractor acting as employer) must ensure the grating is safe for its intended use.

  • Verify the grating’s load rating and compatibility with vessel supports.
  • Secure and inspect the grating after installation and periodically while in use.
  • Keep documentation of the grating specifications and inspection records.

Cited standard: 1918.34(b).