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OSHA 1918.83

Stowed cargo safety procedures

Subpart H

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.83(a), when must an employer secure or block stowed cargo in a ship's hold?

Under 1918.83(a), an employer must secure or block stowed cargo that is likely to shift or roll whenever it is necessary to protect personnel working in a hold. Employers should not rely on chance—if cargo could move and endanger workers inside a hold, it must be blocked or otherwise secured before work continues.

  • Practical examples of securing include using chocks, wedges, blocking timbers, dunnage, or lashings where appropriate.
  • Always plan the work and inspect blocking before allowing personnel into the area.

See the requirement in 1918.83(a) for the full regulatory text.

Under 1918.83(b), what precautions must be taken when breaking down stowed cargo so remaining cargo does not fall?

Under 1918.83(b), the employer must take precautions during the breaking down of stowed cargo to prevent remaining cargo from falling. This means planning and controlling the removal sequence so that what is left behind is stable and cannot slide, topple, or roll onto workers.

  • Common precautions include removing cargo from the top down in a controlled way, using blocking or shoring to support tiers before adjacent material is moved, establishing exclusion zones below breaks, and using tag lines and guided pulls.
  • Train workers on the sequence to dismantle tiers and require a competent person to supervise hazardous breaks.

Refer to 1918.83(b) for the regulatory requirement.

Under 1918.83(c), what are an employer's responsibilities for employees trimming bulk cargo?

Under 1918.83(c), the employer must ensure employees trimming bulk cargo are checked in and out by the job boss, and that frequent checks are made to ensure the safety of any employee working alone in a tank or cargo compartment. Employers must also verify that no employee remains inside a reefer compartment before it is secured.

  • The job boss must maintain a check-in/check-out system (logs, radio confirmations, or visual checks) so the location and status of trimmers is known.
  • Implement frequent monitoring for lone workers and ensure an emergency/rescue plan is in place.

See 1918.83(c).

Under 1918.83(c), how should an employer ensure no one remains inside a reefer compartment before securing it?

Under 1918.83(c), the employer must check to ensure that no employee remains inside a reefer compartment before securing it. Simple verbal confirmation is not enough—use a reliable method such as a visual sweep, a buddy system, a written or radio check-out, or a physical walkthrough by the job boss.

  • Maintain a check-in/check-out log or use radio confirmation that is recorded.
  • If visibility is poor, have the job boss physically inspect the compartment or require personnel to exit and report to the job boss before the compartment is secured.

The duty to verify is set out in 1918.83(c).

What does 1918.83(c) require for employees who work alone in a tank or cargo compartment?

Under 1918.83(c), frequent checks must be made to ensure the safety of any employee working alone in a tank or cargo compartment. Employers must not leave lone workers unchecked for long periods and must have a system to monitor them and to summon help quickly if needed.

  • Use scheduled radio check-ins, visual checks by the job boss, electronic monitoring, or another reliable communication method at frequent intervals.
  • Have a written emergency plan and trained rescuers available in case the lone worker needs assistance.

See 1918.83(c). For guidance on first-aid and on-site trained personnel relevant to maritime and longshoring operations, see OSHA's interpretation on First aid and bleeding control.

Under 1918.83(a) and (b), is it acceptable to rely only on a worker's statement that cargo is stable before entering a hold or breaking it down?

No. Under 1918.83(a) and 1918.83(b), employers must secure or block cargo likely to shift or roll and take precautions when breaking down cargo to prevent falling material—relying solely on a worker's verbal assurance is not sufficient.

  • Employers must verify stability through blocking, inspections, and competent-person confirmation before allowing personnel into the hazard area.
  • Documented checks, visual inspections, and physical restraints (blocking, chocks) are preferred controls over informal assurances.

These obligations are found in the requirements at 1918.83(a) and (b).

Under 1918.83, who must perform the check-in and check-out of employees trimming bulk cargo and what should that process include?

Under 1918.83(c), the job boss is responsible for checking employees trimming bulk cargo in and out, and the process should include a reliable record or confirmation that shows who is in each compartment and when they left.

  • The check-in/out system can be a written log, electronic record, or radio confirmation recorded by the job boss.
  • The process should also include verification before sealing/resecuring any compartment (for example, the reefer check) and scheduled follow-up checks for lone workers.

See 1918.83(c).

What practical controls can an employer use to block or secure stowed cargo that might shift or roll in a hold?

Under 1918.83(a), employers must secure or block cargo likely to shift or roll; practical controls include chocks, wedges, blocking timbers, dunnage, lashings, and bracing designed for the load and hold geometry.

  • Use blocking and bracing sized and placed to prevent movement; dunnage can fill voids and stabilize tiers.
  • Ensure blocking materials are in good condition and installed under supervision of a competent person.
  • For repetitive or engineered solutions, consult manufacturer guidance or a qualified engineer if modifications are required.

The regulatory duty to secure cargo is in 1918.83(a).

How should employers prevent accidental disengagement of cargo attachments (brides, shackles) while breaking down stowed cargo?

Employers should use positive means to prevent accidental disengagement—such as shackles, safety latches, or other secure attachments—when cargo handling bridles or slings remain attached to hoisting gear during successive lifts, because inadvertent disengagement could cause falling cargo and injuries.

  • Use shackles or equivalent positive attachments and inspect them before use.
  • Where hooks are used, prefer latch-equipped hooks unless the application makes latches impractical; use industry-accepted safeguards to prevent slings or loads from slipping off hooks.

For related guidance, see OSHA's longshoring provisions referenced in the hook/sling interpretation and the discussion at 1918.83(b). OSHA's interpretation on safety latches on sling hooks discusses the use of latches and references longshoring requirements at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0.

Can a crane operator leave controls or walk away from a suspended load during cargo handling operations in a hold?

No. OSHA's enforcement guidance requires that the individual assigned to operate equipment such as a crane must be physically able to perform the task without unscheduled interruption; leaving the controls while a load is suspended is not acceptable because it can create an unsafe condition.

  • Ensure crane operators are fit for duty and able to complete lifts; have procedures for transferring control safely to another qualified operator without leaving a suspended load unattended.

See OSHA's crane operator interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13 for explanation of the employer's responsibility and apply that principle together with the hazard-control requirement of 1918.83(b).

Is it permissible to secure wire rope by tying knots when handling or blocking cargo?

No. Tying knots in wire rope to secure loads is a recognized hazard and is prohibited by OSHA guidance; wire rope should be spliced or connected with appropriate fittings, shackles, or hardware rather than knots.

  • Use correct end fittings, mechanical splices, or approved terminations designed for the rope and load.
  • If you believe an alternate method provides equivalent safety, follow the formal variance process rather than knotting rope.

See OSHA's interpretation on wire rope knot prohibition at https://www.osha.gov/laws-regs/standardinterpretations/1977-12-14 which references the maritime longshoring rule prohibitions among other standards.

What emergency planning and first-aid considerations are relevant when workers trim cargo inside holds or compartments?

Employers must ensure workers trimming cargo are monitored and that adequate first-aid measures and trained personnel are available, because injuries in confined compartments or holds can be serious and require rapid response.

  • Provide on-site first-aid trained personnel and equipment appropriate to the hazards; OSHA recognizes that maritime longshoring operations may require one or more on-site first aiders depending on hazards.
  • Maintain a clear communication and rescue plan for compartments, ensure check-in/out records are maintained, and make sure rescuers are trained and equipped for confined-space-style rescues if needed.

See 1918.83(c) for monitoring requirements and OSHA's interpretation on First aid and bleeding control for first-aid training considerations in maritime operations.

What should an employer do before sealing or securing a cargo compartment that has been worked in during a shift?

Before sealing or securing any cargo compartment that has been worked in, the employer must confirm that no employee remains inside and that the space is safe to secure, which can be accomplished by direct visual check, radio confirmation logged by the job boss, or a written check-out record.

  • Require employees to check out with the job boss and maintain a log showing who was in the compartment and when they left.
  • If the compartment has hazards like limited ventilation or refrigerated atmosphere, take additional steps (e.g., ventilation, atmospheric testing) before sealing.

This requirement is stated in 1918.83(c).

What does "breaking down stowed cargo" mean under 1918.83 and why does it require special precautions?

Under 1918.83(b), "breaking down stowed cargo" refers to the process of removing tiers, layers, or sections of cargo after it has been stowed, and it requires special precautions because removing material can change load support and allow remaining cargo to fall.

  • Precautions include planned sequence of removal, blocking/shoring before adjacent cargo is moved, exclusion zones beneath areas being worked on, and close supervision by the job boss.
  • Treat each removal as an operation that can create new hazards and reassess controls continuously.

See 1918.83(b) for the regulatory requirement.