Housekeeping and work area safety

Yes — active work areas must be kept clear of equipment, materials, and debris that are not needed for the work being performed. Employers must remove or stow lashing gear, loose materials, projecting nails, strapping, and other objects not necessary to current operations to prevent trips, falls, punctures, and other hazards. This requirement is found in 1918.91(a) and employers should treat it as a routine housekeeping obligation to reduce recognized hazards.

The employer must eliminate conditions that make walking and working surfaces slippery in areas where employees work or walk. That means fixing spills, securing loose decking, removing ice or grease, and using non-slip treatments or mats so employees have safe footing. See 1918.91(b) for the performance requirement; employers should also document corrective steps and train workers to report slippery conditions.

Dunnage must not be stacked in locations that interfere with the free movement of drafts (airflow) in the hold or work area. Keeping air flow clear prevents accumulation of harmful vapors and ensures proper ventilation during cargo operations. This obligation is stated in 1918.91(c); employers should plan stowage so dunnage does not block vents, scuppers, or natural air paths.

You may not use dunnage racked against sweat battens or bulkheads when the levels of those racks are above the safe reach of employees. In practice, if workers cannot safely reach a rack level without overextending or using unsafe methods, that level must not be used for racked dunnage. This requirement appears in 1918.91(d). Employers should evaluate reach distances and provide access equipment or rearrange storage so employees can handle dunnage safely.

Unused dunnage, hatch beams, tarpaulins, or gear must be stowed at least three feet (0.91 m) away from both the port and starboard sides of the weather deck hatch coaming. This creates a safety clearance to prevent obstructions around hatch openings and protect workers moving about the hatch. The specific distance requirement is in 1918.91(e). Employers should mark and enforce that clearance when stowing gear.

Protruding nails in shoring or fencing must be rendered harmless. That means you must remove, hammer down, cut off, or otherwise neutralize nails so they cannot puncture or snag clothing or skin. This requirement is in 1918.91(f)(1); employers should inspect shoring and fencing and correct protruding nails promptly.

Yes — but only if the nails are rendered harmless; otherwise the material must be removed from the work area. If dunnage, lumber, or shoring has visibly protruding nails, you must either remove those items or neutralize the nails (for example, by pulling, cutting off, or pounding them flush). This is required by 1918.91(f)(2). Employers should include inspection for protruding nails in routine housekeeping checks.

Employers must protect employees from falling ice coming from above. Protection can include removing the ice, erecting barriers, roping off danger zones, moving workers out of hazardous areas during icing conditions, or providing hard hats and other controls as appropriate. The duty is stated in 1918.91(g). Employers should evaluate where ice can fall and implement controls to prevent injuries.

No — even when gear is in use, dunnage, hatch beams, tarpaulins, or gear not in use must be stowed at least three feet from the weather deck hatch coaming; items in active use should be managed so they do not block the required clearance. The clearance requirement for unused items is in 1918.91(e); employers should plan workflows to keep coaming areas clear of obstructions.

"Rendered harmless" does not always require complete removal of the nail; it means the nail must be made safe so it cannot cause injury — for example, driving it flush, cutting it off, or otherwise neutralizing the hazard. The standard language is in 1918.91(f)(1). Employers should use the method that reliably prevents puncture, snagging, or laceration and document the corrective action.

The employer is responsible for ensuring work areas meet the housekeeping rules in 1918.91, which means the employer must establish inspection and correction procedures and assign competent persons to carry them out. The general duties in 1918.91 impose the obligation on the employer to keep active work areas safe; regular inspections and prompt corrective actions are good practice to meet that obligation.

Employers must remove or reposition dunnage that interferes with free movement of drafts so ventilation is not impeded. The requirement to avoid blocking drafts is in 1918.91(c). Practical steps include re-stowing dunnage, marking prohibited stacking zones, and training personnel to keep ventilation paths clear.

Yes — provided employees can access those rack levels safely using appropriate equipment and procedures; but you may not use racked dunnage at levels that are above the safe reach of employees without providing safe means to work at that height. The prohibition on using racked dunnage above safe reach is in 1918.91(d). Employers should supply proper access (e.g., fixed platforms, ladders, fall protection as needed) and training before allowing use of elevated racks.

Yes — if ice overhead presents a falling hazard, employers must take controls that can include stopping work in the affected area or moving employees out of danger zones until the hazard is removed or protected against. The protective duty is stated in 1918.91(g). Employers should assess the risk and implement the most effective combination of controls (removal of ice, barriers, exclusion zones) to keep workers safe.

While 1918.91 does not explicitly mandate written documentation, employers must ensure compliance by inspecting and correcting unsafe housekeeping conditions; maintaining records of inspections and corrective actions is a best practice to demonstrate compliance with 1918.91. Documentation helps show the employer met its duty to keep active work areas safe and can be useful during audits or incident investigations.

An "active work area" is any location where employees are actively performing tasks — holds, weather decks, staging areas, or near hatches — and those locations must be kept free of unnecessary equipment, materials, and debris while work is ongoing. The general requirement appears in 1918.91(a). Employers should identify active work zones during planning and maintain housekeeping while operations continue.

If immediate removal is not feasible, interim measures must render the nails harmless (for example, hammering or cutting nails flush, capping sharp ends, or erecting barriers/coverings) and the items should be removed from active work areas as soon as possible. This approach follows 1918.91(f)(2). Employers should log temporary controls and schedule prompt removal or repair.

No — relying solely on personal protective equipment is not sufficient in place of removing or rendering protruding nails harmless; the standard requires removing the hazard or making the nails harmless in the work area. See 1918.91(f)(1) and 1918.91(f)(2). PPE can be an additional layer of protection, but hazard elimination or control at the source is required.

OSHA's First Aid and Bleeding Control interpretation clarifies that employers must ensure adequate first aid resources and trained personnel when hazards can cause serious injuries like uncontrolled bleeding; for hazards such as protruding nails or falling ice that can cause cuts or traumatic injuries, employers should both prevent the hazard under 1918.91 and provide appropriate first aid readiness as discussed in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19. Employer measures include hazard elimination, prompt medical/first-aid response planning, and training one or more on-site persons in first aid where required.