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OSHA 1918.35

Open hatch guarding requirements

Subpart D

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.35, when do open weather-deck hatches need additional guarding?

Open weather-deck hatches need additional guarding when the hatch coamings do not protect employees to a height of 24 inches (0.61 m). 1918.35 requires that hatches that lack a 24-inch coaming must be guarded by taut lines or barricades at a height of 36 to 42 inches (0.91 to 1.07 m) above the deck, except on the side where cargo is being worked.

Under 1918.35, what height must coamings reach to be considered adequate guarding for open hatches?

A coaming is considered adequate guarding if it protects employees to a height of at least 24 inches (0.61 m). The standard states that open weather deck hatches protected to a height of 24 inches by coamings do not require the additional taut-line or barricade at 36–42 inches. See 1918.35.

Under 1918.35, what are the required heights for taut lines or barricades used to guard open hatches?

Taut lines or barricades used to guard open hatches must be placed at a height between 36 and 42 inches (0.91 to 1.07 m) above the deck. That is the explicit range required by 1918.35.

Under 1918.35, is there an exception to placing taut lines or barricades on all sides of a hatch?

Yes. You do not have to place the taut lines or barricades on the side of the hatch where cargo is being worked. 1918.35 explicitly excepts the side on which cargo operations are taking place from this guarding requirement.

Under 1918.35, what types of barriers satisfy the guarding requirement for open hatches?

The standard allows either taut lines or barricades to guard open hatches that are not protected by a 24-inch coaming. 1918.35 does not limit the barricade material, but it does specify the required height of 36–42 inches above the deck for the barrier.

Under 1918.35, what does the standard say about portable stanchions used around open hatches?

Portable stanchions or uprights used to support taut lines or barricades must be supported or secured so they cannot be accidentally dislodged. 1918.35 requires employers to prevent accidental dislodgement of portable stanchions.

Under 1918.35, how should employers ensure portable stanchions are not accidentally dislodged?

Employers must support or secure portable stanchions so they will not be accidentally dislodged; the standard does not mandate a specific securing method. 1918.35 requires that any portable uprights used to guard hatches be supported or secured to prevent accidental dislodgement, so choose a reliable method (weighting, fasteners, base plates, or other positive means) appropriate to the vessel and conditions.

Under 1918.35, does the standard specify how many taut lines or barricades are needed around a hatch?

No. 1918.35 requires that hatches without a 24-inch coaming be guarded by taut lines or barricades at 36–42 inches above the deck but does not specify the number or spacing of lines or barricade segments. Employers should provide sufficient coverage to prevent accidental falls around the hatch.

Under 1918.35, how should the guarded height be measured when complying with the 36–42 inch requirement?

Measure from the deck surface up to the top edge of the taut line or the top of the barricade; it must fall between 36 and 42 inches (0.91 to 1.07 m). 1918.35 sets that height range as the compliance requirement.

Under 1918.35, if cargo operations require placing workers on the 'excepted' side of the hatch, are other sides still required to be guarded?

Yes. The standard's exception applies only to the side on which cargo is being worked; the other sides of the hatch that are not being used for cargo handling must still be guarded by taut lines or barricades at 36–42 inches if the coaming is less than 24 inches high. See 1918.35.

Under 1918.35, does the type of cargo or cargo handling method change the guarding requirement for open hatches?

No. The requirement in 1918.35 is based on the presence or absence of a coaming of at least 24 inches and whether cargo is being worked on a particular side; it does not vary by cargo type or specific handling method. If coamings are under 24 inches, you must guard the hatch sides (except the side in use) with taut lines or barricades at 36–42 inches.

Under 1918.35, are fixed railings an acceptable alternative to taut lines or portable barricades?

Yes—fixed railings that provide equivalent protection to what the standard requires would be acceptable, provided they keep the same protective effect as a 24-inch coaming or a 36–42 inch barricade. While 1918.35 specifies taut lines or barricades for hatches lacking a 24-inch coaming, employers may use fixed guarding that meets or exceeds the protective intent of the regulation.

Under 1918.35, does the standard apply to hatches below weather deck level or only to weather deck hatches?

The text of 1918.35 specifically addresses open weather-deck hatches. The requirement to guard hatches with taut lines or barricades when coamings are under 24 inches applies to weather-deck hatches around which employees must work.

Under 1918.35, who is responsible for ensuring stanchions and barricades are in place and secure?

The employer is responsible for ensuring that required guards, including taut lines, barricades, and portable stanchions, are in place and that portable stanchions are supported or secured to prevent accidental dislodgement. This is the duty implied by the standard's mandatory language in 1918.35.

Under 1918.35, what should be done when cargo operations move from one side of a hatch to another side?

When cargo operations move, employers should re-establish guarding consistent with 1918.35: the side where cargo is being worked can be left without the taut line or barricade, but the other sides must be guarded by taut lines or barricades at 36–42 inches if the coaming is under 24 inches. Shift guarding as needed so the non-working sides remain protected.

Under 1918.35, can a temporary work platform used over a hatch replace the need for taut lines or barricades?

A temporary work platform can reduce the fall hazard, but 1918.35 specifically requires guarding by a 24-inch coaming or, if absent, taut lines or barricades at 36–42 inches on the non-working sides. If a temporary platform provides equivalent protection, employers should document how it meets the protective intent of the standard; the employer remains responsible for ensuring protection equivalent to what the standard requires.

Under 1918.35, does the standard tell you how to secure stanchions in heavy weather or on rolling ships?

No. 1918.35 requires that portable stanchions be supported or secured to prevent accidental dislodgement but does not prescribe specific methods for heavy weather or ship motion. Employers must select securing methods suitable to the vessel and conditions to ensure stanchions remain effective under anticipated weather and motion.

Under 1918.35, what documentation or training should employers provide about hatch guarding?

While 1918.35 itself does not specify training documentation, employers must ensure workers know where hatches are, what sides are guarded, and that portable stanchions will be secured. Employers should train crew and longshore personnel on the hatch-guarding practice on each vessel and keep reasonable documentation of training to show compliance with the standard's protective intent.

Under 1918.35, may employers leave a hatch entirely unguarded during active cargo operations on one side if that side is the only access?

No. The standard allows the side where cargo is being worked to be unguarded, but all other sides of a hatch that do not have a 24-inch coaming must be guarded by taut lines or barricades at 36–42 inches. 1918.35 does not permit leaving the entire hatch unguarded.

Under 1918.35, how does this hatch guarding rule fit within the broader maritime longshoring standards?

The open-hatches rule in 1918.35 is part of 29 CFR Part 1918, which governs safety and health regulations for longshoring. You can review the broader Part at 1918. Employers must apply 1918.35's hatch-guarding requirements along with other applicable longshoring provisions to provide a safe workplace.