Bulling cargo requirements

The bull line must be led directly from the heel block unless an exception applies. This requirement is stated in 1918.84(a).

• Follow the direct heel-block lead to avoid side pulls that can damage gear or create unsafe dragging over coamings or obstructions.
• If you believe an exception applies (see next questions), document the reason and ensure safe alternative rigging is used.

Bulling may be done from the head of the boom only when the cargo and the surface over which it is dragged make stalling unlikely, or when the winch plus purchase cannot overload the boom. This allowance is specified in 1918.84(a).

• Before using the head of the boom, verify the load will not stall and the winch/purchase combination cannot create a boom overload.
• If in doubt, lead the bull line from the heel block per the standard to reduce risk.

Snatch blocks must be used to provide a fair lead so the bull line does not drag unnecessarily against coamings and obstructions, per 1918.84(b).

• Use snatch blocks to change the angle of pull and protect the line from chafing and excessive wear.
• Place blocks so the line runs freely and avoids snag points that could cause sudden load shifts.

No; snatch blocks must not be used with the hook point resting on a beam flange — they must be hung from padeyes, straps, or beam clamps as required by 1918.84(c).

• Resting the hook on a flange is unstable and can let the block shift or the hook slip off.
• Use properly rated padeyes, straps, or beam clamps to hang snatch blocks securely.

No; the standard specifically prohibits making snatch blocks or straps fast to batten cleats or other insecure fittings, per 1918.84(c).

• Always pick a secure, rated attachment point to prevent sudden release.
• If a suitable fixture is not available, stop and install an appropriate padeye, strap, or beam clamp before bulling.

Beam frame clamps must be secured to prevent slipping, falling, or being pulled from their stationary attachment, as required by 1918.84(d).

• Use clamps rated for the load and inspect mounting hardware (bolts, pins, locks) for tightness and integrity.
• Where practicable, add secondary restraints (safety chains, wire rope lanyards) to prevent loss if the primary clamp begins to slip.

No; falls led from cargo booms must not be used to move scows, lighters, or railcars, as stated in 1918.84(e).

• Use appropriately rated towing gear or tugs designed for moving watercraft and rail equipment rather than cargo-boom falls.
• This restriction prevents unsafe loads and unintended vehicle movement that cargo booms are not designed to control.

If the winch plus purchase cannot overload the boom, bulling from the head of the boom is allowed under 1918.84(a).

• Confirm through calculation or manufacturer's data that the winch/purchase combination cannot reach boom limits.
• Even when allowed, rig and monitor the operation carefully to avoid unintended stresses on the boom or rigging.

Snatch blocks should be positioned to provide a fair lead so the bull line avoids dragging against coamings and obstructions, per 1918.84(b).

• Select attachment points that give a straight, controlled run for the line.
• If you must run near deck edges or obstructions, add protective chafe gear (pads or sleeves) and use additional blocks to change direction smoothly.

Acceptable hang points for snatch blocks are padeyes, straps, or beam clamps, as specified in 1918.84(c).

• Use only attachment points rated for the expected load.
• Inspect padeyes, straps, and beam clamps before use and ensure they are securely installed and not damaged.

Where practicable, hooks should have safety latches to prevent accidental disengagement, but the immediate 1918.84(c) rule focuses on proper hanging points rather than latches; guidance about using latch-equipped hooks where feasible is explained in the OSHA letter on safety latches at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0 and in practice you should use latched hooks when they improve safety.

• 1918.84(c) requires secure hanger points (padeyes, straps, beam clamps).
• OSHA's interpretation on hook latches (https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0) explains that latches are recommended where they make hooked connections safer and are used in related maritime standards.

Before use, check beam frame clamps to ensure they are tight, undamaged, and cannot slip or be pulled from their attachment, in line with 1918.84(d).

• Inspect for cracks, corrosion, missing bolts or locking devices.
• Verify the clamp is rated for the load and that locking mechanisms (pins, bolts) are properly engaged.
• If any doubt exists about the clamp's security, do not use it until repaired or replaced.

Making snatch blocks fast to insecure fittings like batten cleats risks sudden disengagement or failure of the fitting and is prohibited by 1918.84(c); snatch blocks must be used to provide a fair lead as required by 1918.84(b).

• Insecure fittings can pull out or break under side-loads, causing dropped loads or whip-back of lines.
• Use rated padeyes, straps, or beam clamps instead of temporary or nonrated fittings.

You must evaluate the cargo weight, friction characteristics of the surface, and run length to determine if the load can stall; if stalling is unlikely, bulling from the boom head is allowed under 1918.84(a).

• Check cargo skid/slide properties (rollers, dunnage), deck coatings, and any obstructions.
• If calculations or experience indicate the load may bind or stall, lead from the heel block per the standard.

The employer is responsible for ensuring bulling operations are rigged and conducted safely in accordance with 1918.84 and the broader longshoring rules at 1918. Employers must provide proper equipment, training, and supervision.

• Supervisors should verify all gear, hang points, and clamps are rated and inspected.
• Workers must be trained to recognize unsafe rigging and stop operations that violate the standard.

If padeyes are not available, the standard allows hanging snatch blocks from straps or beam clamps provided they are secure and appropriate for the load, per 1918.84(c).

• Use rated lifting straps or beam clamps designed for the load and ensure they are installed and secured correctly.
• Do not improvise with nonrated fittings (batten cleats, loose shackles) — the standard expressly forbids insecure attachments.

To reduce the risk of beam clamp failure, secure clamps with rated fasteners, use redundant attachments (safety chains or secondary slings), and perform regular inspections as required by 1918.84(d).

• Engineering: use clamps sized for the load, add backup attachment points, and apply load-limiting devices where appropriate.
• Administrative: require pre-use checklists, qualified personnel to install clamps, and periodic competency training.

You must not secure wire rope by knots; this practice is prohibited and considered a hazard, as explained in the OSHA wire rope knot prohibition letter at https://www.osha.gov/laws-regs/standardinterpretations/1977-12-14 and in maritime standards referenced therein. Use proper end fittings (thimbles, shackles, swages) instead.

• Knots reduce rope strength and can slip under load — do not use them except where a standard expressly allows (rare exceptions).
• Use appropriate terminations (swaged fittings, shackles) and follow manufacturer and industry guidance.

Stop the operation immediately and use appropriate equipment or procedures because 1918.84(e) prohibits using falls from cargo booms to move scows, lighters, or railcars.

• Notify a supervisor and switch to approved towing or positioning methods (tug, shore-based winch, or rail-yard equipment).
• Record the unsafe practice and retrain personnel to prevent recurrence.

Rigging and clamps should be marked or documented with rated capacity and manufacturer identification where practicable, and be inspected to meet the secure-attachment requirements of 1918.84(b)-(d).

• Keep records of inspections and ensure visible capacity markings on slings, blocks, and clamps.
• If equipment lacks markings, treat it as unfit until its capacity and suitability can be verified.

Training should teach workers to lead bull lines from the heel block unless an authorized exception exists, to use snatch blocks for fair leads, to hang blocks only from padeyes/straps/beam clamps, to secure beam clamps against slipping, and to never move scows, lighters, or railcars with cargo-boom falls, consistent with 1918.84.

• Include hands-on rigging demonstrations, inspection checklists, and clear stop-work authority for unsafe rigging.
• Document training and re-evaluate competence periodically or when procedures change.