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OSHA 1918.37

Barge safety requirements

Subpart D

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.37(a), when is walking along the sides of a covered lighter or barge prohibited?

Under 1918.37(a), walking along the sides of a covered lighter or barge is prohibited when the coamings or cargo are more than five feet (1.52 m) high unless a safe means of passage is provided. The standard requires either a three-foot (0.91 m) clear walkway, a grab rail, or a taut handline to be provided before walking is allowed on those sides; see 1918.37(a).

  • "More than five feet" is measured as stated in the rule (1.52 m).
  • A "three-foot clear walkway" means an unobstructed 3-foot width for walking.
  • If no walkway, grab rail, or taut handline is provided, workers must not walk along those sides.

Under 1918.37(a), what counts as an acceptable "three-foot clear walkway" on a barge?

Under 1918.37(a), an acceptable "three-foot clear walkway" is an unobstructed path at least three feet (0.91 m) wide that lets a person walk safely along the side of the barge where coamings or cargo exceed five feet in height. The rule explicitly requires that either this clear walkway, a grab rail, or a taut handline be provided before walking is allowed; see 1918.37(a).

  • "Clear" means free of obstructions that would impede safe walking (tools, loose cargo, slippery material, etc.).
  • The standard does not specify construction materials, but the walkway must be safe and structurally sound (see 1918.37(b)).

Under 1918.37(a), may a taut handline be used instead of a walkway or grab rail to allow walking along a barge side?

Yes. Under 1918.37(a), a taut handline may be used as an alternative to a three-foot clear walkway or a grab rail to permit walking along the sides of covered lighters or barges where coamings or cargo are more than five feet high; see 1918.37(a).

  • The handline must be taut and positioned so it can be effectively used by someone walking along the side.
  • The standard does not prescribe exact handline height or attachment details; however, the handline should be installed so it provides a safe means of handhold for workers using it.
  • Ensure the handline and its anchors are maintained and inspected as part of the barge’s safe-access checks (see 1918.37(b)).

Under 1918.37(b), when must the deck of a barge be visually inspected before walking or working on it?

Under 1918.37(b), the deck of a barge must be visually inspected and determined to be structurally sound and properly maintained before any walking or working on the deck of a barge to be loaded is allowed. See 1918.37(b).

  • The inspection is required before loading begins; it is a prerequisite to allow personnel on the deck.
  • Visual inspection should check for rot, soft spots, separated or missing planks, holes, corrosion, and other signs that the deck may fail under load.
  • If you are unsure, treat the surface as unsafe until verified safe.

Under 1918.37(b), what must be done if an unsound deck surface is discovered while discharging a barge?

Under 1918.37(b), work must be discontinued immediately if an unsound deck surface is discovered while discharging a barge, and work cannot resume until steps are taken to ensure a safe work surface. See 1918.37(b).

  • "Discontinued" means stop all walking and work in the affected area.
  • "Means...to ensure a safe work surface" can include making repairs, shoring up or replacing decking, restricting access to the unsafe area, or relocating work operations.
  • Supervisors or designated personnel should verify repairs and reinspect the surface visually before resuming operations.

Under 1918.37, who is responsible for ensuring the barge deck and walkways are safe?

Under 1918.37, the employer or the party in control of loading/discharging operations is responsible for ensuring that barge decks and walkways are inspected and safe for walking or working. The regulation requires that walking or working on decks be prohibited unless they have been determined by visual inspection to be structurally sound and properly maintained; see 1918.37(b).

  • Employers should designate qualified personnel to perform the visual inspection and to determine whether walkways or handholds are adequate.
  • Responsibility includes providing required walkways, grab rails, or taut handlines where coamings or cargo exceed five feet (see 1918.37(a)).

Under 1918.37, can temporary planks or gangways be used to meet the three-foot clear walkway requirement?

Yes. Under 1918.37(a) and (b), temporary planks or gangways can be used to meet the three-foot clear walkway requirement provided they are visually inspected and determined to be structurally sound and properly maintained before use. See 1918.37(a) and 1918.37(b).

  • Temporary walkways must provide a continuous clear 3-foot width and be free of trip hazards.
  • They must be secured so they do not shift under load and be rechecked if conditions change (e.g., after heavy weather or cargo shifts).
  • If in doubt about structural soundness, do not use the walkway until it is made safe.

Under 1918.37(a), does the rule require a handrail or handline along the entire length of the barge side where cargo exceeds five feet?

Under 1918.37(a), the rule requires that a three-foot clear walkway, a grab rail, or a taut handline be provided where walking along the sides of covered lighters or barges is needed because coamings or cargo exceed five feet, but it does not explicitly state that the handrail or handline must run the entire length. See 1918.37(a).

  • Practically, the handrail/handline should be provided where workers need it to move safely; gaps or short sections that force workers into exposed areas are not acceptable.
  • Employers should provide continuous or sufficiently spaced handholds so that workers can traverse the required walking route safely; verify by visual inspection and maintenance as required by 1918.37(b).

Under 1918.37(b), how thorough must the "visual inspection" be to determine whether a barge deck is structurally sound?

Under 1918.37(b), the visual inspection must be thorough enough to determine whether the walking or working surface is structurally sound and properly maintained before allowing walking or working on the deck. See 1918.37(b).

  • A proper visual inspection should look for obvious defects such as rot, missing or broken boards, corrosion, holes, soft spots, loose fastenings, or other signs the surface may fail under foot traffic or load.
  • If the inspector cannot confidently determine soundness by sight (for example, suspecting hidden rot), the surface should be treated as unsafe until further evaluation or repair is completed.
  • The standard does not prescribe specialized testing; visual inspection is the required minimum.

Under 1918.37, may work continue on other parts of the barge if an unsound deck surface is discovered in one area during discharging?

Under 1918.37(b), if an unsound deck surface is discovered while discharging a barge, work in the affected area must be discontinued and cannot resume until the surface is made safe; the standard does not prohibit work elsewhere on the barge that does not rely on the unsound area. See 1918.37(b).

  • Employers should assess whether continuing operations elsewhere creates hazards (e.g., loads that could shift and worsen the unsafe area).
  • Where there is any doubt about the potential for danger to workers moving between areas, suspend broader operations until the unsafe condition is abated.

Under 1918.37, does the regulation specify who must perform the visual inspection of the barge deck?

Under 1918.37(b), the regulation requires that the walking or working surfaces "have been determined by visual inspection to be structurally sound and maintained properly," but it does not specify a particular job title; the employer must ensure someone capable performs the inspection. See 1918.37(b).

  • Employers should designate a competent person—someone familiar with the hazards and able to recognize unsafe decking—because the employer is responsible for workplace safety.
  • Documentation of inspections is not required by 1918.37, but keeping inspection records can help demonstrate compliance and track recurring problems.

Under 1918.37, is personal protective equipment (PPE) a substitute for providing a three-foot walkway, grab rail, or taut handline?

No. Under 1918.37(a), PPE is not a substitute for the required three-foot clear walkway, grab rail, or taut handline when coamings or cargo exceed five feet; the regulation requires a physical means of safe passage or hold. See 1918.37(a).

  • PPE may be required in addition to these measures depending on other hazards, but the presence of PPE does not relieve the employer from providing the walkway, grab rail, or handline.
  • Employers must follow other applicable PPE payment and provision rules as found elsewhere in OSHA regulations (see general obligations under 1918).

Under 1918.37, can an employer allow workers on a barge deck that was inspected earlier in the day without re-checking it before a second shift?

Under 1918.37(b), walking or working is prohibited on barge decks unless the surfaces "have been determined by visual inspection to be structurally sound and maintained properly," so an employer should re-inspect or otherwise verify the surface is still safe before allowing a new shift to work, especially if conditions may have changed. See 1918.37(b).

  • Factors that warrant re-inspection include weather, cargo movements, machinery operations, or any events that could damage or change the deck condition.
  • When in doubt, conduct a quick visual check at the start of the shift to confirm continued soundness.

Under 1918.37, does the barge walkway requirement apply to uncovered barges or only "covered lighters or barges"?

Under 1918.37(a), the walkway, grab rail, or taut handline requirement is stated specifically for "covered lighters or barges" with coamings or cargo more than five feet high; the text focuses on covered barges. See 1918.37(a).

  • If you work with uncovered barges, other applicable standards or general safety obligations under 1918 and the OSH Act’s general duty clause may still require safe means of access and fall protection depending on conditions.
  • Employers should evaluate uncovered barge conditions and provide safe passage or handholds as needed even if not explicitly stated in 1918.37(a).

Under 1918.37, what are acceptable ways to "ensure a safe work surface" after finding an unsound deck?

Under 1918.37(b), acceptable ways to "ensure a safe work surface" after finding an unsound deck include repairing or replacing the damaged decking, shoring or reinforcing the area, barricading and rerouting workers away from the unsafe section, or taking other corrective actions that restore a structurally sound surface. The rule requires work to stop until such means are taken; see 1918.37(b).

  • Any repair or corrective action should be confirmed by visual inspection before work resumes.
  • If temporary repairs are used, ensure they are strong enough for the expected loads and that they are maintained and rechecked during continued operations.