Hazard communication requirements

The requirement is that hazard communication for longshoring follows the applicability provisions referenced in 1918.1(b)(4). See 1918.90, which explicitly directs you to 1918.1(b)(4).

• Employers should consult 1918.1(b)(4) to determine how hazard communication requirements apply to their specific longshoring operations.

Cited authority: 1918.90 and 1918.1(b)(4).

Yes. Stevedores who work with sealed containers, including trailers with sealed cargo, must receive limited Hazard Communication training to the extent necessary to protect them in case of a leak or spill. OSHA clarified that trailers with sealed cargo are treated as sealed containers and therefore covered by the limited training provisions. See the OSHA Letter of Interpretation on HCS training for stevedores at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

• Training can be focused on employer-specific emergency actions (for example, evacuation) if the employer's procedures for sealed-container incidents are limited to those measures.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

Yes. If the employer’s written work practice is to evacuate the area for a sealed-container leak, it is acceptable to limit training to those evacuation and emergency procedures rather than detailed hazard information for every chemical. OSHA explained that employers may tailor training to the work performed and emergency actions in the Letter of Interpretation on HCS training for stevedores at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and the hazard communication direction in 1918.90.

• Make sure the training still gives employees the information they need to protect themselves in the event of a spill or leak.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

A stevedore must receive comprehensive Hazard Communication training when they open sealed containers or otherwise are expected to handle or be exposed to the container’s hazardous contents. OSHA stated that employees who open sealed containers are covered by the more comprehensive provisions of the HCS. See the OSHA Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

• If an employee’s job includes opening, unpacking, or directly handling the materials inside sealed containers, train them on the specific hazards, protective measures, and how to read labels and safety data sheets.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

No. For employees who only work around sealed containers and are not expected to open them, employers do not have to provide detailed information on every chemical inside those containers; training may be limited to general precautions and actions to take in a spill or leak. OSHA made this clear for stevedores in its Letter of Interpretation: specific training on each chemical is not required provided workers know general precautions and emergency procedures. See https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

Yes. Trailers with sealed cargo are treated as sealed containers and fall under the limited training provisions that apply to sealed containers. OSHA explicitly stated that trailers with sealed cargo would be considered sealed containers for HCS training purposes. See the Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

Yes. Employers may design training programs that reflect the actual work tasks and hazards employees face; training can be shorter and targeted so long as it gives workers the information they need to protect themselves. OSHA noted that employers can develop training tailored to their work practices, especially for workers who only deal with sealed containers. See the OSHA Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

• Keep documentation of what was covered so you can show that the training matches the job hazards.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

Yes. Written notifications and warranties that employers obtain from carriers when handling tobacco are considered employee exposure records and must be maintained as required by OSHA. The 1983 Letter of Interpretation explained that those documents are employee exposure records under 29 CFR 1910.1020 and must be retained for at least the period specified in the longshoring requirement. See https://www.osha.gov/laws-regs/standardinterpretations/1983-03-01 and 1918.90.

Cited authority: OSHA Letter of Interpretation, "Employee exposure record requirements" (March 1, 1983) at https://www.osha.gov/laws-regs/standardinterpretations/1983-03-01 and 1918.90.

The employer is responsible for determining and providing training that is sufficient to protect employees given the specific work tasks and hazards; OSHA enforces that obligation and has explained how to apply this in specific situations such as sealed-container work. See 1918.90 and the Letter of Interpretation on HCS training for stevedores at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17.

• If your operations include tasks that expose workers to chemical hazards (for example, opening containers), you must provide more comprehensive HCS training.

Cited authority: 1918.90 and OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17.

Yes. Employers in longshoring and related maritime operations are required to ensure that one or more on-site individuals are trained in first aid, and this requirement complements Hazard Communication by addressing medical readiness for injuries such as uncontrolled bleeding. OSHA discussed first-aid training expectations in its June 19, 2019 Letter of Interpretation and noted that maritime standards require on-site first-aid-trained personnel. See https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19 and 1918.90.

• First-aid preparedness does not replace HCS training; both are part of protecting employees from chemical and physical hazards.

Cited authority: OSHA Letter of Interpretation, "First aid and bleeding control" (June 19, 2019) at https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19 and 1918.90.

Employers should document what topics were covered and why the training scope was limited, for example by noting that employees only work with sealed containers and were trained on evacuation and emergency actions. OSHA’s Letter of Interpretation on HCS training for stevedores affirms that training programs may be tailored to work tasks, so keeping records showing the match between tasks and training is good practice. See https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.

• Suggested documentation: training date, attendees, topics covered (e.g., evacuation, spill notification), and employer rationale for limiting scope.

Cited authority: OSHA Letter of Interpretation, "HCS training for stevedores" (November 17, 1988) at https://www.osha.gov/laws-regs/standardinterpretations/1988-11-17 and 1918.90.