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OSHA 1918.88

Log handling safety requirements

1918 Subpart H

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.88(a), what must employees do when logs are being dumped into vessel holds with dumper devices?

Employees must remain out of any area where dumped logs could strike, roll upon, or pin them. This is required under 1918.88(a).

  • Keep clear of the path of falling or rolling logs at all times while dumper devices are used.
  • Use established exclusion zones and communicate with equipment operators so everyone knows where it is safe to stand.

Cited: 1918.88(a).

Under 1918.88(b), what kind of personal flotation device (PFD) must employees working on a log boom wear?

Employees must wear a personal flotation device that meets the specifications set out in 1918.105(b)(2).

  • The employer must provide and ensure use of PFDs that comply with the requirements in 1918.105(b) and specifically 1918.105(b)(2).

Cited: 1918.88(b) and 1918.105(b)(2).

Under 1918.88(c), who must provide spiked shoes or caulked sandals for employees working on logs, and can the employer require employees to pay for them?

The employer must provide appropriate footwear such as spiked shoes or caulked sandals, and the employer generally must pay for required PPE rather than require the employee to bear the cost. This is required by 1918.88(c), and OSHA’s interpretation on employer payment for PPE explains that employers must pay for required PPE and may only use limited deposit/return systems consistent with the payment rule (Employee PPE payment methods, 2014-11-13).

  • Provide and ensure employees wear appropriate footwear to walk or climb on logs.
  • If the employer retains ownership of the footwear, a deposit/return system may be used only if it does not result in the employee bearing the cost in violation of the PPE payment rule.

Cited: 1918.88(c) and Employee PPE payment methods (2014-11-13).

Under 1918.88(d), what is required for lifelines when employees work on log booms or cribs?

Lifelines must be furnished and hung overside to the water's edge when employees are working on log booms or cribs. This requirement appears in 1918.88(d).

  • Install lifelines along the working side so employees have a secure line to reach to the water’s edge in case of a fall.
  • Inspect lifelines regularly for damage and secure attachment points before each shift.

Cited: 1918.88(d).

Under 1918.88(e), when must a Jacob's ladder be provided and how many are required per log boom?

A Jacob's ladder that meets 1918.23 must be provided for each gang working alongside a log boom unless another safe means of access (for example, the vessel's gangway) is provided, and no more than two Jacob's ladders are required for any single log boom being worked. The full requirement is in 1918.88(e).

  • Provide one Jacob’s ladder per working gang if no other safe access is available.
  • Employers may limit ladders to two per boom even if multiple gangs are working, provided safe access is maintained.

Cited: 1918.88(e) and 1918.23.

Under 1918.88(f), what life-ring must be provided when working a log boom alongside a ship, and where must it be located?

A U.S. Coast Guard–approved 30-inch (76.2 cm) life-ring with no less than 90 feet (27.4 m) of line must be provided either on the floating unit itself or aboard the ship close to each floating unit being worked, as required by 1918.88(f).

  • Ensure the life-ring is Coast Guard approved, 30 inches in diameter, and has at least 90 feet of line attached.
  • Position it where it can be quickly thrown to a person who falls into the water from the floating unit being worked.

Cited: 1918.88(f).

Under 1918.88(g), when is a powered rescue boat required when employees work on rafts or booms?

A rescue boat capable of effecting an immediate rescue must be available when employees work on rafts or booms, and a powered rescue boat is specifically required when the current exceeds one knot, under 1918.88(g).

  • Have a rescue boat on site and ready for immediate use whenever employees are on rafts or booms.
  • Switch to a powered rescue boat if water current in the work area exceeds one knot to ensure timely rescues.

Cited: 1918.88(g).

Under 1918.88(h), what are the dimensional and buoyancy requirements for walking sticks (safety sticks) used on log rafts?

Walking sticks must be planked and at least 24 inches (0.61 m) wide, must extend along the entire length of all rafts on the side(s) of the vessel being worked and to the means of access, and must be buoyant enough to keep the walking surface above the waterline when employees walk on them, as specified in 1918.88(h)(1)–(3).

  • Minimum width: 24 inches planked surface (1918.88(h)(1)).
  • Coverage: must run the full length of the raft along sides being worked and to access points (1918.88(h)(2)).
  • Buoyancy: must keep the walking surface above the waterline under load (1918.88(h)(3)).

Cited: 1918.88(h) and subsections (1)–(3).

Under 1918.88(h), what is the OSHA definition of a "walking stick" (safety stick) used in loading logs?

A walking stick (safety stick) is two logs bolted or otherwise secured together with two or three planks firmly attached on top to serve as a floating walking and working surface used in loading logs onto vessels from the water, as explained in the footnote to 1918.88(h).

  • It is a floating structure formed from logs and planks that provides a walking surface for employees moving logs from the water to a vessel.

Cited: 1918.88(h) (footnote).

Under 1918.88(e), when is a vessel's gangway an acceptable substitute for a Jacob's ladder?

A vessel's gangway or another safe means of access is an acceptable substitute for a Jacob's ladder if it provides safe access for the gang working alongside the log boom; the ladder requirement applies only when no other safe means of access is provided, per 1918.88(e).

  • If the vessel’s gangway gives safe access to the area being worked, you do not need to provide a separate Jacob’s ladder.
  • Ensure the alternative access complies with the safety standards in 1918.23 where applicable.

Cited: 1918.88(e) and 1918.23.

Under 1918.88(c) and OSHA policy, can an employer require a deposit or payroll deduction for work footwear that is required for log handling?

The employer must provide the required footwear, and while a deposit/return system can be used when the employer retains ownership, the employer generally may not shift the cost of required PPE to employees; deposits must not result in an employee effectively paying for the PPE, according to 1918.88(c) and OSHA’s interpretation on employer payment for PPE (Employee PPE payment methods, 2014-11-13).

  • If the employer keeps ownership and requires return at termination, a deposit system that incentivizes return may be used, but it must not circumvent the employer’s obligation to provide PPE at no cost.
  • Payroll deductions or charging the employee for normal wear-and-tear are restricted by the PPE payment requirements discussed in the interpretation.

Cited: 1918.88(c) and Employee PPE payment methods (2014-11-13).

Under the maritime first-aid interpretations, are employers working with log handling required to have on-site first-aid trained personnel or bleeding-control measures?

Yes — employers in maritime operations like longshoring must ensure that one or more on-site individuals are trained in first aid, and employers should consider appropriate first-aid and bleeding-control readiness based on the hazards, as explained in OSHA's interpretation on first aid and bleeding control (First aid and bleeding control, 2019-06-19).

  • OSHA standards for maritime operations require adequate first-aid training for required first aiders; OSHA does not itself certify specific training programs but expects employers to ensure adequate training for their hazards.
  • Employers should assess workplace hazards (including potential for severe bleeding) and provide appropriate first-aid supplies and training consistent with OSHA guidance.

Cited: First aid and bleeding control (2019-06-19) and general maritime requirements in 1918.

Under 1918.88(a) and crane/operator guidance, can an operator of equipment used in handling logs leave the controls while a load is suspended?

No — an operator who becomes incapacitated or leaves the controls while a suspended load is in use must not abandon the load, because the employer must ensure the person assigned to operate the equipment is physically able to complete the operation without leaving the controls, as explained in OSHA’s crane operator interpretation (Crane operator medical condition scenario, 2013-09-13).

  • Employers must ensure operators are fit for duty and that procedures exist to prevent an operator from leaving controls while a load is suspended.
  • If an operator cannot safely complete the operation, the employer must have procedures to safely secure or lower the load without leaving it suspended unattended.

Cited: Crane operator medical condition scenario (2013-09-13) and 1918.88(a).

When hoisting logs with hooks, are safety latches required under OSHA guidance applicable to longshoring and log handling?

Whether a safety latch is required on a sling or hoist hook depends on the activity and the equipment, but OSHA guidance emphasizes using latched or otherwise secured hooks to prevent accidental load disengagement in maritime and longshoring contexts, as explained in OSHA’s interpretation on safety latches (Safety latches on sling hooks, 2006-01-10).

  • Use hooks with safety latches where they prevent accidental disengagement unless the application makes the latch impractical.
  • OSHA cites related maritime provisions requiring latched or otherwise secured hooks to prevent accidental disengagement and recommends consulting manufacturers’ guidance and consensus standards.

Cited: Safety latches on sling hooks (2006-01-10) and general longshoring/marine requirements in 1918.

If powered industrial trucks are used inside vessel holds during log handling, can an employer install strobe lights in place of noisy backup alarms?

Installing strobe lights in addition to existing audible alarms is allowed in marine terminal and longshoring industries if the modification has the manufacturer’s prior written approval or the written approval of a qualified professional engineer, and operators may need refresher training — see OSHA’s guidance on strobe lights (Strobe lights on industrial trucks, 2004-12-21).

  • Do not remove or make inoperative required safety devices unless permitted by the applicable standards and approvals.
  • Obtain manufacturer approval or a qualified engineer’s written approval before modifying vehicles in ways that might affect safety or capacity; provide operator retraining if needed.

Cited: Strobe lights on industrial trucks (2004-12-21) and general maritime rules in 1918.

Under 1918.88(f) and (g), what rescue equipment should be positioned when working a log boom alongside a ship and when working on rafts or booms?

When working a log boom alongside a ship, provide a U.S. Coast Guard–approved 30-inch life-ring with at least 90 feet of line close to each floating unit being worked; when employees work on rafts or booms, have a rescue boat capable of effecting immediate rescue available and use powered boats if the current exceeds one knot, as required by 1918.88(f) and 1918.88(g).

  • Life-ring: 30-inch USCG-approved ring with ≥90 feet of line, located on the floating unit or ship near each unit.
  • Rescue boat: immediately available for worker rescue; powered rescue boat required when current > 1 knot.

Cited: 1918.88(f) and 1918.88(g).

Under 1918.88(h)(2), how far must walking sticks extend on a raft being worked alongside a vessel?

Walking sticks must extend along the entire length of all rafts on the side(s) of the vessel being worked and must extend to the means of access to the log raft(s), as required by 1918.88(h)(2).

  • Ensure the walking stick runs the full length of the raft on the sides where crew work and connects to the access points so employees do not need to step into the water to move along the raft.

Cited: 1918.88(h)(2).

Under 1918.88(h)(3), how buoyant must walking sticks be when employees use them?

Walking sticks must be buoyant enough to keep the walking surface above the waterline when employees are walking on them, according to 1918.88(h)(3).

  • Design and maintain walking sticks so that the planked surface does not submerge under the expected worker load.
  • Regularly inspect buoyancy elements and repair or replace components that reduce flotation.

Cited: 1918.88(h)(3).