Deck and hatch safety requirements

A taut handline must be provided when a deck load more than five feet high is stowed within three feet of the hatch coaming and workers handling hatch beams and covers are not protected by a coaming at least 24 inches high. This is stated in 1918.41(a).

• The rule applies to smooth-sided deck cargo (for example lumber) over 5 ft high placed within 3 ft (0.91 m) of the coaming.
• If the coaming is at least 24 inches (0.61 m) high and protects employees, the taut handline is not required.
• Note: the provision also says the requirements of 1918.35 are not intended to apply in this specific situation, so follow the handline/coaming rule in 1918.41(a).

You must provide a three-foot (0.91 m) working space between the stowed cargo and the coaming at both sides and at one end for hatches with athwartship hatch beams, and at both ends for hatches with fore-and-aft hatch beams before removing or replacing intermediate deck hatch covers and hatch beams. This requirement is in 1918.41(b)(1).

• The three-foot clearance must exist before work to remove or replace hatch beams or covers begins.
• Exceptions: the clearance is not required on the covered portion of a partially open hatch, nor when lower decks are filled to hatch beam height with cargo that provides a safe surface to work on, per the same paragraph.

Yes — fitted gratings in good condition, when properly placed within the three-foot area, are considered part of the decking for the purposes of the three-foot clearance requirement. This is specified in 1918.41(b)(2).

• "Good condition" and "properly placed" are the conditions required by the standard; employers should ensure gratings are intact, installed correctly, and stable before relying on them as a safe work surface.
• Use appropriate inspection and maintenance practices to confirm gratings meet those conditions before work begins.

Grab rails or taut handlines must be provided when bulkheads, lockers, reefer compartments, or large spare parts are within three feet (0.91 m) of the coaming and employees are handling hatch beams and covers. This requirement is in 1918.41(c).

• The intent is to give employees a secure handhold when nearby obstructions limit footing or clearance.
• Employers should position and secure grab rails or handlines so they are readily usable during the handling of hatch beams and covers.

No — the three-foot clearances do not apply to hatches opened or closed solely by hydraulic or other mechanical means; however, if the three-foot clearance does not exist, any cargo stowed within three feet of the hatch edge must be adequately secured to prevent cargo from falling into the hold. This is stated in 1918.41(d).

• Even when mechanical operation removes the clearance requirement, securing nearby cargo is mandatory to prevent falling hazards.
• "Adequately secured" is a performance requirement — employers must use methods that reliably prevent cargo movement or collapse into the hold.

A coaming at least 24 inches (0.61 m) high provides physical protection sufficient to remove the requirement for a taut handline when employees handle hatch beams and covers. This protection concept appears in 1918.41(a).

• The standard uses the 24-inch height as the threshold for a protective coaming; if the coaming reaches or exceeds that height and shields employees working at the hatch edge, a taut handline is not required under the circumstances described in 1918.41(a).
• Employers should ensure the coaming provides a usable barrier and is not compromised by cargo or temporary obstructions.

The difference is which ends require the three-foot clearance: for hatches with athwartship hatch beams you need a three-foot working space at both sides and at one end; for hatches with fore-and-aft hatch beams you need a three-foot working space at both ends. This is specified in 1918.41(b)(1).

• This reflects how hatch beams are oriented and how removal/replacement work is performed; follow the specific end/side clearance pattern the standard prescribes before starting work.

No — the three-foot clearance requirement does not apply to the covered portion of a partially open hatch. That exception is part of 1918.41(b)(1).

• Only the covered portion of a partially open hatch is exempted; other portions where employees work to remove or replace hatch beams and covers still must meet the clearance requirements unless another exception applies.

Cargo stowed within three feet (0.91 m) of the hatch edge must be adequately secured to prevent cargo from falling into the hold when the three-foot clearance does not exist for a mechanically operated hatch. This requirement is in 1918.41(d).

• "Adequately secured" is a performance requirement — securement methods should reliably prevent displacement or collapse of the cargo during hatch operation.
• Employers should document and implement effective blocking, lashing, chocking, or other appropriate measures to meet this requirement.

Yes — fitted gratings will be considered part of the decking only if they are in good condition and properly placed within the three-foot (0.91 m) area, as stated in 1918.41(b)(2).

• Employers should inspect gratings for structural damage, secure fit, and stability before relying on them to provide the required working surface.
• If gratings are damaged, loose, or improperly installed, they cannot legally be used to satisfy the three-foot clearance requirement.

You must ensure the required three-foot working space between stowed cargo and the coaming is provided (per hatch beam orientation rules in 1918.41(b)(1)), or otherwise take actions required by other paragraphs (such as providing handlines under 1918.41(a) or grab rails per 1918.41(c)).

• Verify whether exceptions apply (partially open hatch covered portions or lower decks filled to beam height with safe cargo surface).
• If using fitted gratings within the three-foot area, confirm they are in good condition and properly placed as allowed by 1918.41(b)(2).
• Ensure any required handlines or grab rails are installed and secure before employees handle beams or hatch covers.

The taut handline provision in 1918.41(a) specifically mentions deck loads such as lumber or other smooth-sided deck cargo; that language signals the rule is aimed at cargo that can slip or present smooth surfaces near the hatch coaming.

• While the standard calls out lumber and other smooth-sided cargo, the employer should assess other cargo types for similar hazards and apply the protection measures required by the standard where the conditions (height, proximity, lack of protective coaming) match.
• The 1918.35 requirements are not intended to apply in the specific situation described in 1918.41(a), so follow the handline/coaming rule there.

Employers cannot rely solely on mechanical hatch operation to avoid all protective measures: 1918.41(d) excludes the three-foot clearance requirement for hatches opened or closed solely by hydraulic or other mechanical means, but it still requires that cargo stowed within three feet of the hatch edge be adequately secured to prevent falling into the hold when the clearance does not exist.

• Mechanical operation removes the clearance requirement only; it does not remove the duty to secure nearby cargo or otherwise ensure employee safety during hatch operations.
• Employers should have written procedures and controls for securing cargo and for safe mechanical hatch operation.

The requirement is phrased as a performance obligation: 1918.41(d) states that cargo stowed within three feet (0.91 m) of the hatch edge shall be adequately secured to prevent cargo from falling into the hold when the three-foot clearance does not exist.

• The standard does not prescribe a specific tying, lashing, or blocking method — it requires that the securement be adequate to prevent falling.
• Employers should choose securement methods based on cargo type, weight, and stowage configuration, and document their procedures as part of their safe-work practices.

No — 1918.41(a) expressly states that the requirements of 1918.35 are not intended to apply in the situation described (deck load over 5 ft high within 3 ft of coaming when a taut handline is provided).

• Employers should follow the specific provisions of 1918.41(a) in that situation rather than attempting to apply 1918.35 requirements that the standard says are not intended to apply there.

Employers must provide grab rails or taut handlines for the protection of employees handling hatch beams and hatch covers when bulkheads, lockers, reefer compartments, or large spare parts are within three feet of the coaming, per 1918.41(c).

• Position the grab rails or handlines so workers can readily use them while removing or replacing hatch beams and covers.
• Inspect and maintain these protective devices to ensure they remain secure and effective.

Filling lower decks to hatch beam height with cargo of such a nature as to provide a safe surface upon which employees may work is an exception to the three-foot clearance requirement in 1918.41(b)(1). In other words, if the cargo on the lower deck creates a safe working surface at beam height, the three-foot clearance is not required.

• Employers must evaluate whether the cargo truly provides a safe surface (stable, level, and able to support workers and tasks) before relying on this exception.
• If the lower-deck cargo is unstable, irregular, or otherwise unsafe as a work surface, the three-foot clearance rules remain applicable.

Measure the three-foot (0.91 m) working space from the hatch coaming to the nearest stowed cargo item; that is the three-foot area referenced in 1918.41(b)(1) and related paragraphs.

• The standard uses the three-foot distance as the required clear working area to allow safe removal or replacement of hatch beams and covers.
• If cargo intrudes into that three-foot zone, employers must take the actions required by the applicable paragraph (e.g., provide handlines, secure cargo, use fittings gratings if in good condition).

No — 1918.41(d) requires that cargo within three feet of the hatch edge be "adequately secured," but it does not specify particular tools or methods.

• The standard sets a performance requirement rather than prescribing methods; employers must choose securement techniques (lashings, chocks, blocking, straps, etc.) that are appropriate to the cargo and that reliably prevent falling into the hold.
• Employers should document their securement procedures and verify their effectiveness by inspection before hatch operations begin.

When smooth-sided deck cargo over 5 feet high is stowed within 3 feet of a coaming that is less than 24 inches high, employers must provide a taut handline along the side of the deck load as required by 1918.41(a). Practical steps include: installing secure taut handlines at an appropriate height, positioning them so workers can use them while handling hatch beams and covers, and inspecting handlines for integrity before and during use.

• Consider moving cargo back to create the three-foot working space where feasible.
• Train workers on safe use of handlines and on procedures for handling hatch beams and covers when handlines are used as the protective measure.