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OSHA 1926.605

Marine operations requirements

Subpart O

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.605(a)(1), when must material handling (longshoring) operations follow the longshoring standards in part 1918?

Yes — under 1926.605(a)(1) any operation that fits the definition of “material handling” must be performed in conformance with the longshoring requirements in part 1918.

  • Material handling ("longshoring operations") includes loading, unloading, moving, or handling construction materials, equipment, and supplies into, in, on, or out of any vessel from a fixed structure or shore-to-vessel, vessel-to-shore, or vessel-to-vessel. See 1926.605(a)(1).
  • For the specific longshoring rules to apply, consult the longshoring standard at 29 CFR part 1918.

Practical tip: if your crew is moving materials on or off vessels from a wharf or between vessels, use the checklists and controls in part 1918 (equipment inspections, rigging, communications) as your minimum requirements.

Under 1926.605(b)(1), what are the minimum requirements for vehicle ramps used to access or move between barges?

Ramps used to access or move vehicles to or between barges must be strong enough for the load, have side boards, be well maintained, and be properly secured. See 1926.605(b)(1).

  • "Adequate strength" means the ramp is rated for the vehicle weight, including cargo and dynamic loads during movement.
  • Side boards (curbs) prevent wheels from slipping off the edge.
  • "Well maintained" includes keeping the surface free of oil, ice, excessive wear, and broken fasteners.
  • "Properly secured" means the ramp is lashed, pinned, or otherwise attached so it will not shift while in use.

Practical action: document ramp load capacity, perform a pre-use inspection, and tag out any ramp that shows structural damage.

Under 1926.605(b)(2), when is an employer required to provide a ramp or walkway for employees stepping to or from a wharf, float, barge, or river towboat?

You must provide either a compliant ramp or a safe walkway unless employees can step safely to or from the wharf, float, barge, or river towboat. See 1926.605(b)(2).

  • If a safe single-step transfer is not possible because of gaps, movement, or height differences, provide a ramp that meets 1926.605(b)(1) or a dedicated walkway.
  • Walkways should be properly secured, wide enough for the intended traffic, and free of obstructions.

Practical tip: measure the step gap and vertical difference before allowing employees to step; if unsure, use a ramp or walkway to control the hazard.

Under 1926.605(b)(3)–(4), what are the rules for Jacob’s ladders used as means of access to barges?

Jacob’s ladders must be the double-rung or flat-tread type, be well maintained, properly secured, and must either hang without slack from their lashings or be pulled up entirely. See 1926.605(b)(3) and 1926.605(b)(4).

  • Double-rung or flat-tread ladders provide better footing than single-rung types.
  • Regularly inspect lashings, rungs, and attachment points; remove from service if damaged.
  • Do not allow a ladder to hang with slack — it must be taut or not in place for use.

Practical checklist: inspect before each use, ensure lashings are intact, and secure the top and bottom to prevent movement.

Under 1926.605(b)(5), what are the requirements when the upper end of a means of access rests on or is flush with the top of the bulwark?

When the upper end of the means of access rests on or is flush with the top of the bulwark, you must provide substantial steps properly secured and at least one substantial handrail approximately 33 inches in height between the top of the bulwark and the deck. See 1926.605(b)(5).

  • "Substantial" means the steps and handrail are strong, well-fastened, and sized to allow safe ascent and descent.
  • The handrail at ~33 inches gives a reliable handhold when stepping over the bulwark.

Practical action: measure handrail height during installation and include the steps and handrail in your pre-use inspection program.

Under 1926.605(b)(6)–(8), what controls are required for gangways and means of access to prevent hazards?

Gangways and means of access must be kept free of obstructions, adequately illuminated for their full length, and located so loads will not pass over employees unless the structure makes that impossible. See 1926.605(b)(6), 1926.605(b)(7), and 1926.605(b)(8).

  • Keep gangways clear of materials, tools, and hoses; do not lay obstructions across.
  • Provide lighting that allows safe passage for the full gangway length during all work periods.
  • Position access so that loads moved on or across the structure do not travel over employees whenever possible.

Practical tip: include gangway checks in your site safety inspections and correct obstructions immediately to prevent tripping or struck-by hazards.

Under 1926.605(c)(1), when are employees allowed to walk along the sides of covered lighters or barges with coamings more than 5 feet high?

Employees may not walk along the sides of covered lighters or barges with coamings more than 5 feet high unless there is a 3-foot clear walkway, or a grab rail, or a taut handline provided. See 1926.605(c)(1).

  • A 3-foot clear walkway must be unobstructed and continuous for the length employees must travel.
  • A grab rail or taut handline must be secured so employees can maintain three points of contact while walking.

Practical example: if coamings are 6 feet high, install a 3-foot-wide walkway along the side or rig a continuous handline before allowing foot traffic.

Under 1926.605(c)(2)–(4), what are employer responsibilities regarding deck and working-surface safety on barges?

Employers must maintain decks and other working surfaces in a safe condition, ensure employees have safe passages around or over deckloads, and prevent employees from walking over deckloads unless a safe passage exists. See 1926.605(c)(2), 1926.605(c)(3), and 1926.605(c)(4).

  • "Maintained in a safe condition" includes removing hazards (holes, slippery substances), replacing broken planks, and ensuring secure fastenings.
  • If deckloads block normal passage, provide clearly identified, secure walkways or platforms to allow passage fore and aft.
  • Do not permit walking over unstable or uneven deckloads from rail to coaming unless a safe, secure passage is provided.

Practical action: before work begins, inspect deck surfaces and mark or build temporary walkways where loads obstruct normal paths.

Under 1926.605 (edge protection paragraph), when must employees standing at the edge of a deckload be provided fall protection?

If an employee must stand at the outboard or inboard edge of a deckload where less than 24 inches of bulwark, rail, coaming, or other protection exists, the employer must provide a suitable means of protection against falling from the deckload. See 1926.605.

  • "Suitable means of protection" can include guardrails, personal fall arrest systems, rescue plans, or other controls that effectively prevent a fall.
  • Evaluate each work task and select fall protection appropriate to the exposure and feasibility.

Practical tip: measure the protective height — anything under 24 inches of barrier requires you to put engineered or personal fall protection in place before employees work at that edge.

Under 1926.605(d)(1)–(2), what first-aid and lifesaving equipment must be near each barge in use?

Employers must provide first aid and medical assistance in accordance with Subpart D, and must ensure at least one U.S. Coast Guard–approved 30-inch lifering with not less than 90 feet of line and at least one ladder that reaches from the apron to the water surface is in the vicinity of each barge while in use. See 1926.605(d)(1) and 1926.605(d)(2).

  • If that equipment is not available at the pier, the employer must furnish it during the time they are working the barge.
  • Ensure liferings are visually inspected, lines are coiled and ready, and ladders are secured and free of defects.

Practical checklist: verify lifering size and line length, inspect ladder reach and condition, and document availability during barge operations.

Under 1926.605(d)(2), what are the specific requirements for liferings and lines near barges?

The lifering must be U.S. Coast Guard–approved, 30 inches in diameter, and have not less than 90 feet of line attached; a portable or permanent ladder that reaches from the top of the apron to the surface of the water must also be available. See 1926.605(d)(2).

  • Inspect the lifering for cracks, floats, and ensure the line is in serviceable condition and coiled for quick deployment.
  • Confirm the ladder will reach the water level from the apron at the expected tide or water level range.

Practical step: add lifering and ladder checks to your pre-start barge safety checklist and train crews on rapid deployment.

Under 1926.605(d)(3), what personal flotation devices are required for employees walking or working on unguarded barge decks?

Employees walking or working on unguarded barge decks must be protected with U.S. Coast Guard–approved work vests or buoyant vests. See 1926.605(d)(3).

  • Ensure the vest is U.S. Coast Guard–approved for the intended activity (work vest vs. a general-purpose life preserver).
  • Check vest condition, fit, and serviceability; replace defective vests.

Practical action: require donning of approved vests before allowing personnel onto unguarded decks and include vest checks in site safety briefings.

Under 1926.605(e), what OSHA requirements apply to commercial diving operations?

Commercial diving operations are subject to 29 CFR 1910 subpart T, specifically 1910.401–1910.441. See 1926.605(e) and the subpart at 1910.401 through 1910.441.

  • Employers conducting commercial diving must follow diving-specific requirements for equipment, medical exams, training, emergency procedures, and supervision found in subpart T.
  • Coordinate diving operations with shipboard and shore-side safety procedures to ensure compliance with both the diving standard and the marine operations requirements.

Practical step: maintain diving logs, ensure certified dive supervisors, and review subpart T before planning any commercial dive.

Under 1926.605(b)(4), when must a Jacob’s ladder be pulled up entirely rather than hung without slack?

A Jacob’s ladder must either hang taut without slack from its lashings or be pulled up entirely when not in safe, steady use. See 1926.605(b)(4).

  • Pull the ladder up entirely when you cannot maintain it in a secure, taut condition (for example, during heavy heaving or when it would interfere with operations).
  • Leaving a ladder with slack can create pinch, swing, and fall hazards; secure or stow it to prevent those risks.

Practical action: include ladder stowage procedures in your barge operations plan and train employees on when to stow versus secure ladders.

Under 1926.605(b)(7), what does "adequately illuminated for its full length" mean for means of access?

"Adequately illuminated for its full length" means the entire gangway or access route must have sufficient lighting so employees can see hazards and travel safely along it from end to end. See 1926.605(b)(7).

  • "Sufficient lighting" is job- and site-specific, but should eliminate dark spots, reveal changes in elevation, and expose obstructions.
  • Lighting should be maintained (replace bulbs, keep fixtures clean) and positioned to minimize glare and shadowing along the full walk surface.

Practical tip: during night operations or low-light conditions, perform a walk-through to confirm continuous visibility and add temporary lighting where necessary.

Under 1926.605(b)(8), how should employers position means of access so loads do not pass over employees?

Employers must locate means of access so that, unless the structure makes it impossible, loads will not pass over employees. See 1926.605(b)(8).

  • Plan routes so lifting and moving operations do not cross pedestrian traffic; if unavoidable, stop pedestrian traffic during lifts or use barriers.
  • If the structure makes it impossible to avoid passing loads over employees, use administrative controls (exclusion zones), tag lines, and communication protocols to reduce exposure.

Practical action: include load path review and pedestrian exclusion in your lift plan and enforce exclusion zones during all barge cargo moves.

Under 1926.605(c)(1), how should you measure and provide a 3-foot clear walkway when coamings exceed 5 feet in height?

Measure the clear walking width as 3 feet (36 inches) of unobstructed, continuous walkway alongside the coaming when employees must walk the sides of covered lighters or barges with coamings over 5 feet high. See 1926.605(c)(1).

  • The 3-foot measurement is the clear horizontal width available for walking; do not count ladders, protruding fittings, or stored materials as part of the clear width.
  • If a 3-foot walkway cannot be provided, install a grab rail or taut handline continuous along the route.

Practical advice: mark the walkway with paint or tape, keep it free of tools and loose materials, and inspect it before each shift.

Under 1926.605(d)(2), if lifering or ladder equipment is not available at a pier, what must the employer do while working a barge?

If lifering or ladder equipment is not available at the pier, the employer must furnish the required U.S. Coast Guard–approved lifering with at least 90 feet of line and a ladder reaching the water surface during the time they are working the barge. See 1926.605(d)(2).

  • Temporary equipment provided must meet the same approval and reach requirements as the permanent fixtures.
  • Document that temporary lifesaving equipment was provided and maintained while operations were ongoing.

Practical step: include an equipment checklist for each barge job and verify temporary liferings and ladders are in place before workers go on deck.