Definitions for marine operations

Under 1926.606(a) an "apron" is the area along the waterfront edge of the pier or wharf.

• This definition is used to identify where workers are at the immediate edge of a pier or wharf so appropriate fall protection and edge controls under related rules (for example, 1926.605) can be applied.

Under 1926.606(b) a "bulwark" is the side of a ship above the upper deck.

• A bulwark is a structural part of a vessel (usually a solid or substantial vertical structure) and is different from a "rail," which the rule defines as a lighter guard structure used for protection (1926.606(e)). Employers should verify whether a bulwark provides the required protection in practice and, if not, install compliant guarding per 1926.605.

Under 1926.606(c) a "coaming" is the raised frame, such as around a hatchway in the deck, intended to keep out water.

• A coaming is primarily a water-control feature, but because it is raised, it can affect trip and fall exposure at hatch openings. If workers are exposed to fall hazards at or through hatchways, employers must provide protection that meets the relevant requirements, for example 1926.605.

Under 1926.606(d) a "Jacob's ladder" is a marine ladder made of rope or chain with wooden or metal rungs.

• This is a specific type of flexible ladder used in marine settings; employers should recognize it by this definition when performing hazard assessments for access and egress on vessels and waterfront work areas.

Under 1926.606(e), for the purpose of 1926.605, a "rail" means a light structure serving as a guard at the outer edge of a ship's deck.

• In practice, this means the term covers lighter guard structures (for example, pipe rails or removable guardrails) used to protect the deck edge; heavier structural elements (such as a bulwark) are defined separately.

Under 1926.606(b) a bulwark is the side of a ship above the upper deck, but it is not automatically deemed compliant fall protection under 1926.605.

• Employers must evaluate whether the bulwark provides effective edge protection equivalent to the guarding required by 1926.605 (for example, height and strength). If it does not, additional guarding or fall protection must be provided.

Under 1926.606(c) a coaming is a raised frame around a hatchway, but being a coaming alone does not necessarily meet the guarding requirements of 1926.605.

• Employers should inspect coamings to determine if they prevent falls (for example, sufficient height and coverage). If the coaming does not provide adequate protection, add compliant guards or other fall protection measures as required by 1926.605.

Under 1926.606(e) the term "rail" means a light structure serving as a guard at the outer edge of a ship's deck, so temporary guardrails that are light structures and serve as guards would fall under that definition.

• Employers must ensure temporary rails meet the protective intent of 1926.605 (strength, height, and placement) when used to protect workers from falling over the deck edge.

Under 1926.606 you should specifically identify the apron (pier edge), bulwark, coamings (hatch frames), Jacob's ladders (rope/chain ladders), and rails (light guard structures) when performing a waterfront hazard assessment.

• Identifying these features helps determine where to apply fall protection and guarding per 1926.605.
• For guidance on employer hazard assessments and selecting controls (including PPE), see OSHA's interpretation on PPE hazard assessment at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28.

Under 1926.606(d) a Jacob's ladder is defined as a rope- or chain-based ladder with rungs, but the definition alone does not make it a permanent or acceptable primary means of access for every situation.

• Whether a Jacob's ladder may be used as an access means depends on the task, employer assessment of hazards, and any applicable access standards; employers should evaluate stability, condition, and safe use during their hazard assessment consistent with general duties under 1926.

Under 1926.606(a) the apron is the area along the waterfront edge of the pier or wharf, and employers must protect workers there from falling by applying the appropriate guarding or fall protection methods in 1926.605.

• Typical protections include guardrails (rails as defined in 1926.606(e)), personal fall protection where necessary, and ensuring safe access/egress.
• For broader fall protection application in similar contexts, see OSHA's interpretation on fall protection and suspended conveyances at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

Under 1926.606(e) the word "rail" refers to a light structure serving as a guard at the outer edge of a ship's deck, so temporary fall protection systems that function as light guard structures can be treated as "rails."

• Employers must ensure any temporary rail meets the protective requirements and performance expectations of 1926.605 (for example, proper height, strength, and completeness).

Under 1926.606(c) a coaming is a raised frame around a hatch, while under 1926.606(e) a rail is a light guard at the deck edge.

• Coaming: primarily a structural/watertight feature; may reduce but not necessarily eliminate fall risk at a hatch opening.
• Rail: specifically intended as a guard to prevent falls.
• If the coaming does not provide adequate fall protection, add rails or other compliant fall protection per 1926.605.

Under 1926.606 employers must recognize defined shipboard features during hazard assessments, and it is a good compliance practice to inspect and document the condition of rails, coamings, bulwarks, Jacob's ladders, and apron areas as part of that assessment.

• Documented inspections and hazard assessments help determine whether the existing features meet the protective requirements in 1926.605.
• OSHA’s interpretation on PPE and hazard assessment emphasizes the employer’s responsibility to assess hazards and maintain written certification when PPE is required; see https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28 for related guidance.