Containerized cargo operations

Every intermodal container must be clearly marked with its empty weight, maximum cargo weight, and the combined total weight of the container plus its maximum cargo. See the marking requirements in 1918.85(a).

• Markings must be legible and permanent.
• The required items are listed in 1918.85(a)(1), 1918.85(a)(2), and 1918.85(a)(3).

Employers must determine from the carrier whether a container is empty or loaded and identify empty containers so supervisors, crane operators, and signalmen are informed before hoisting. See the identification duty in 1918.85(b)(1).

• Acceptable identification methods include cargo plans, manifests, or markings on the container.
• The identification must be adequate to inform every supervisor, job boss, crane operator, and signalman involved in the operation.

For a loaded container, the actual gross weight must either be plainly marked on the container or provided on a cargo stowage plan or permanently recorded display that includes the container's serial number or other positive identification. See 1918.85(b)(2).

• The two options are described in 1918.85(b)(2)(i) and 1918.85(b)(2)(ii).
• The information must be visible to the crane or hoisting equipment operator, signalman, and site supervisors.

Every outbound container that is received at a marine terminal ready to load without further consolidation or loading must be weighed to obtain the actual gross weight before hoisting. See 1918.85(b)(3).

• If the terminal has scales and the load was consolidated at that terminal, the container must be weighed as required in 1918.85(b)(4)(i).
• If the terminal has no scales, the actual gross weight may be calculated from the container contents plus the empty weight and those weights plus the person and date must be posted on the container as required by 1918.85(b)(4)(ii).

When a terminal calculates a container's actual gross weight (because it has no scales), the weights used in the calculation, the name of the person who made the calculation, and the date must be posted conspicuously on the container. See 1918.85(b)(4)(ii).

• The calculation must use the container's empty weight plus the weight of the contents.
• The posted information must be visible to crane operators, signalmen, and supervisors.

Open-top vehicle-carrying containers and containers used solely for compressed gases are excepted from the weighing requirements in 1918.85(b)(3) and 1918.85(b)(4). Closed dry-van containers carrying only completely assembled vehicles, marked to indicate they carry vehicles, and loaded at the marine terminal are also exempt from [1918.85(b)(4)]. See 1918.85(b)(5) and 1918.85(b)(6).

• For the vehicle exemption the container must carry only fully assembled vehicles, be marked so employees can readily see it contains vehicles, and the vehicles must have been loaded at the terminal per 1918.85(b)(6)(i)–(iii).

Loaded inbound containers from foreign ports may have their weight determined by actual weighing, by calculation as described in 1918.85(b)(4)(ii), or by shipping documents as allowed in 1918.85(b)(7). Any scale used within the United States for these requirements must meet the accuracy standards of the state or local public authority where the scale is located per 1918.85(b)(8).

• Employers should verify local weights and scale accuracy requirements before relying on scale readings.

No; a container must not be hoisted if its actual gross weight exceeds the combined weight marked on the container or the capacity of the lifting appliance. See the prohibition in 1918.85(c).

• Employers must confirm weights and lifting equipment capacity before hoisting to prevent overloaded lifts.

Before hoisting, each container must be inspected for visible defects in structural members and fittings that would make handling unsafe, and any container with such defects must either be handled by a special safe means or emptied before handling. See 1918.85(d)(1) and 1918.85(d)(2).

• ‘‘Special means’’ could include rigging modifications or repair procedures that ensure safe handling.
• Do not hoist containers with known unsafe defects unless an approved special handling method is used.

No, employers must prohibit employees from working beneath a suspended container. This is required by 1918.85(e).

• Employers should establish exclusion zones and communicate them to crane operators and ground personnel.

Loaded intermodal containers 20 feet or longer must be hoisted by applying lifting forces vertically from at least four top fittings, as required in 1918.85(f)(1) and 1918.85(f)(1)(i).

• Less-than-vertical lifts are allowed only when all conditions in 1918.85(f)(1)(i)(A)–(F) are met (ISO closed box, sound condition, moderated speed for heavy loads, lift angle 80–90°, specified distance to lifting beam, and minimum spreader beam length).
• Bottom-fitting lifts and fork/grappling lifts have separate requirements in 1918.85(f)(1)(ii)–(iv).

When hoisting containers from bottom fittings, the angles of the four bridle legs must not be less than 45 degrees to the horizontal for 20-foot containers, 37 degrees for 30-foot containers, and 30 degrees for 40-foot containers, as specified in 1918.85(f)(1)(ii).

• Ensure rigging geometry meets these minimum angles to avoid overstressing fittings and spreader gear.

Spreaders that use lanyards for activation and load disengagement must have all possible precautions taken to prevent accidental load release, and spreaders with automatic twist-lock systems must be designed and used so a suspended load cannot accidentally be released, per 1918.85(f)(2)(i) and 1918.85(f)(2)(ii).

• Employ redundant safety measures (mechanical or procedural) to prevent accidental disengagement.

Employers must provide a safe means of access for any employee required to work on top of an intermodal container; if ladders are not used, the access must meet the requirements of 1917.45(j). See 1918.85(g).

• Where ladders are used, 1918.85(i) limits their use for stacks greater than two containers high when safer means are available.
• Make sure access methods are stable, have handholds, and are appropriate for the work environment.

Employees must not be hoisted on intermodal container spreaders while a load is engaged, and after July 26, 1999, no employee is allowed on top of a container being handled by a container gantry crane except in limited circumstances. See 1918.85(h) and 1918.85(j)(1).

• An employee may be on top only to perform a necessary function that cannot be eliminated by using positive securing devices, per the exception in 1918.85(j)(1).
• Positive securing devices such as semi-automatic twist locks must be used where gantry cranes are used as required in 1918.85(j)(1)(ii).

Employees on top of containers must be protected from fall hazards by a fall protection system that meets the requirements of 1918.85(k), as stated in 1918.85(j)(1)(iii).

• Fall protection components must prevent accidental disengagement and include a full body harness per 1918.85(k)(9).
• Energy-absorbing mechanisms must limit arresting force to not greater than 1800 pounds per 1918.85(k)(4).
• Fixed anchorages must sustain 5,000 pounds or be certified by a qualified person per 1918.85(k)(6).

If a live (activated) container gantry crane lifting beam or attached device is used as an anchorage point, the crane must be placed in slow speed mode, equipped with a remote shut-off switch controlled by the attached employees, and include a visible or audible indicator that the remote shut-off is operational, as required in 1918.85(k)(7).

• These controls help employees attached to live equipment stop movement in an emergency.

Fall protection systems must be inspected before each day’s use by a designated person and defective components removed from service; employees must be trained in equipment use and inspection before use; and the employer must establish a procedure to retrieve personnel safely in case of a fall, as required in 1918.85(k)(11)–(13).

• Training must cover application limits, proper hookup, anchoring, tie-off techniques, inspection, and storage per 1918.85(k)(12).
• Have a written rescue/retrieval procedure and ensure personnel are trained and equipped to perform it per 1918.85(k)(13).

Employers must provide and ensure the use of fall protection meeting 1918.85(k) whenever an employee works along an unguarded edge where a fall hazard exists, as stated in 1918.85(l).

• Section 1918.2 helps define when an edge presents a fall hazard that triggers protection requirements.

Vertical tandem lifts involving the lifting of two or more intermodal containers by the top container must be performed in accordance with 1917.71(i) and 1917.71(k)(1), as required by 1918.85(m).

• Refer to the detailed rigging, load control, and equipment requirements in 1917.71 before attempting vertical tandem lifts.

An operator who becomes incapacitated and cannot complete a lift must not leave the controls while a load is suspended; employers must ensure the person assigned to operate equipment can perform without unscheduled interruption, as stated in OSHA's crane operator medical-condition interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13.

• This interpretation reinforces the requirement that an operator must remain at controls unless a safe transfer to a qualified operator is made and the suspended load is secured (see https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13).
• Employers should assess operators’ medical fitness and provide procedures to safely stop or secure suspended loads if an operator becomes unable to control the equipment.

OSHA expects hooks and attachments to be latched or otherwise secured to prevent accidental load disengagement; if a latch is impractical, other positive means must be used as discussed in OSHA's hook-safety interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0 and in 1918.85(f)(2).

• Use latch-equipped hooks where practical, or alternative positive securing methods consistent with industry practice.
• The 2006 LOI explains that latch requirements depend on the activity and that where latches are infeasible, other secure attachments should be used (see https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0).

Modifications that might affect a vehicle's capacity or safety should not be performed without the manufacturer's written approval or written approval of a professional engineer who has consulted with the manufacturer, as discussed in OSHA's strobe-light interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0 and in related powered truck standards.

• Obtain written manufacturer approval or a qualified engineer's approval before modifying equipment; provide refresher training for operators if the modification affects safe operation (see https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0).
• Remember powered industrial trucks in marine terminals are subject to 29 CFR 1917 requirements and operator training per 1910.178(l).

If a container has visible defects that make handling unsafe, it must either be emptied before handling or handled by special means that ensure safe handling, per 1918.85(d)(2).

• ‘‘Special means’’ may include using alternate rigging, repair, or stabilization approved by a qualified person.
• Do not hoist a structurally unsound container unless the special handling method renders the lift safe and documented.

Positive container securing devices such as semi-automatic twist locks and above-deck cell guides must be used where container gantry cranes are used to hoist containers; their purpose is to secure containers so employees are not required to be on top of containers to secure them, as required in 1918.85(j)(1)(ii).

• The rule reduces the need for personnel to go on top of containers and lowers fall hazard exposure.