Building drafts requirements

It means the employer must construct the draft (the load assembly) or provide other measures so cargo cannot accidentally fall from the draft while it is being handled. Employers satisfy this duty by designing drafts and using equipment or procedures that reliably keep the cargo secured during lifts and moves.

• See the plain requirement in 1918.82(a).
• Practical examples of “means” include properly sized pallet bridles, secure lashings, nets, covers, or other positive attachments so cargo cannot fall; OSHA has discussed use of positive attachments for bridles and hooks in interpretations such as Safety latches on sling hooks.

Always choose methods appropriate to the cargo, its condition, and the lifting equipment.

The employer is responsible for ensuring drafts are built or that other means are used to prevent cargo from falling from them. Employers must provide safe systems and equipment, and supervise operations to make sure the requirement is met.

• See the employer obligation in 1918.82(a).
• Practical compliance often includes training crew members, issuing appropriate lifting gear, and enforcing safe loading procedures.

Acceptable means include any reliable method or equipment that keeps the cargo from slipping or falling out of the draft—examples are properly sized pallet bridles, lashings, cargo nets, tarpaulins or covers, secure slings, and hooks or shackles that prevent accidental disengagement.

• The general duty is stated in 1918.82(a).
• OSHA interpretation letters note the need for positive securing methods for bridles and hooks; see Safety latches on sling hooks which discusses latches and other positive means to prevent accidental load disengagement.

Choose the method based on cargo type (e.g., loose, palletized, frozen) and handling equipment.

If bridles are intended to remain attached to hoisting gear while hoisting successive drafts, they must be attached by shackles or other positive means to prevent them from accidentally disengaging. This practice supports the 1918.82(a) requirement to prevent cargo from falling.

• See the general requirement in 1918.82(a).
• OSHA has specifically addressed bridles remaining attached in the interpretation noting that such bridles "shall be attached by shackles, or other positive means" in Safety latches on sling hooks (which cites related longshoring provisions).

Using positive attachments reduces the chance of accidental disengagement and falling cargo.

No—relying solely on operator skill is not sufficient; employers must build drafts or put physical means in place to prevent cargo from falling. While trained operators are essential, the standard requires constructed drafts or other measures that physically prevent cargo loss.

• The requirement is stated in 1918.82(a).

Combine competent operators with properly built drafts and positive securing methods to meet the standard's intent.

No. Buckets and tubs used for handling bulk or frozen cargo must not be loaded above their rims. Loading above the rim is prohibited because it increases the chance that cargo will fall during handling.

• The requirement is explicit in 1918.82(b).

Ensure loading practices and equipment capacity prevent overfilling of buckets and tubs.

Frozen cargo that forms a dome above the rim must be trimmed or otherwise reduced so the material does not extend above the rim when the bucket or tub is being handled; employers must prevent any load from being carried above the rim.

• The prohibition is in 1918.82(b).

Practical steps include breaking or shaving domed frozen material, using properly sized containers, or using alternative handling methods to avoid any over‑rim loading.

No—1918.82 itself does not impose specific recordkeeping or paperwork requirements; it requires that drafts be built or other means used to prevent cargo from falling and that buckets/tubs not be loaded above rims. However, employers may choose to document procedures, inspections, or training as part of their safety program.

• See the regulatory text at 1918.82.

While the standard does not mandate records, keeping written procedures and inspection logs is a good compliance practice and helps demonstrate due diligence during inspections.

Using a hook without a safety latch can satisfy 1918.82(a) only if the employer uses other reliable, positive means to prevent the load from slipping off the hook. OSHA expects that loads be secured against accidental disengagement; where latches are practicable they are recommended.

• The basic obligation appears in 1918.82(a).
• OSHA's interpretation Safety latches on sling hooks explains that latches are preferred where practical and that other positive securing measures may be required by the situation.

If a hook lacks a latch, document and use alternative positive methods (shackles, properly seated slings, redundant attachments) and consult equipment manufacturer guidance where appropriate.

No—employers may not overload buckets or tubs above their rims for bulk or frozen cargo; 1918.82(b) prohibits loading above the rim regardless of perceived efficiency. Overloading increases the risk of falling cargo and violates the standard.

• The prohibition is clear in 1918.82(b).

Plan lifts so that each bucket or tub carries only up to the rim and use more lifts or larger containers if needed to maintain productivity safely.

The requirement to build drafts or take means to prevent cargo from falling applies to the handling operation as a whole, including assembling drafts, moving them on deck, and lifting or lowering—they must be built or secured so cargo will not fall at any point in the handling process.

• See the governing language in 1918.82(a).

Employers should ensure securing measures are in place during assembly, transport, and hoisting to prevent falling cargo.

No—1918.82 sets performance requirements (prevent cargo from falling; do not load buckets/tubs above rims) but does not prescribe specific hardware sizes or dimensions. Employers must select effective equipment and methods appropriate to the cargo, conditions, and lifting equipment.

• See the text of 1918.82.

When choosing equipment, follow manufacturers’ guidance and recognized industry practices; where helpful, consult OSHA interpretations such as Safety latches on sling hooks that discuss acceptable securing methods.

Loose bulk cargo must be contained or secured so it cannot fall out of the draft during handling—use appropriate buckets/tubs sized to avoid overfill, nets or covers, properly seated slings, or other measures that keep the material contained.

• The containment duty is in 1918.82(a), and bucket fill limits are in 1918.82(b).

Do not rely on temporary balancing or doming of loose material above the rim—use proper containers and securing methods to prevent spillage and falling cargo.

If a bucket or tub is found loaded above its rim, the employer should immediately stop using that container for lifting, remove or trim the excess so the cargo is at or below the rim, and inspect related procedures and training to prevent recurrence. Continued use while overfilled would violate 1918.82(b).

• See the direct prohibition at 1918.82(b).

Document corrective actions and retrain crew members as needed to show steps taken to comply.

Yes—1918.82(a) permits employers to “build drafts or take means” to prevent cargo from falling, so using mechanical devices or alternative systems is acceptable provided those means reliably prevent cargo from falling during handling.

• The acceptance of alternative methods is reflected in 1918.82(a).

Ensure any mechanical system is maintained, used per manufacturer guidance, and evaluated to confirm it prevents falling cargo as effectively as a built draft would.