Container Safety Regulations

Ole
23 Mar 2001

Brother Soren from Copenhagen wrote:

We have recently among the collegues in the port discussed the safety - or lack of same - while working on top of the containers with the twistlocks.

I understand that in the US a law or regulation was passed in 1999 to partly forbid longshoremen to work on top of the containers and force the shipowners to use semi-automatick locks. Would someone please help me with more information on this, maybe a web-address, where I can find this law/regulation?


Soren,

I was the West Coast (ILWU) longshoreman on the Occupational Safety and Health Administration’s Maritime Advisory Committee (MACOSH) during the time this was being prepared. I have some ideas on the implementation of the regulations you mention. I would rather not air these ideas in a public forum since the ramifications have not been explored yet. I would be happy to share these with you, if you contact me personally.

In the mean time, regarding your research, here are a couple of things that will help you search for information.

The entire body of standards for Longshoring is [29 CFR 1918] The specific regulations to which you refer are in 1918. 85(j) (Requirements for employees working atop cargo containers being handled by container gantry cranes)

Since that standard makes reference to the following one you should also read 1918. 85(k).

You will find both of these sections at this page

http://www.osha-slc.gov/OshStd_data/1918_0085.html#1918.85(j)

you will also find links to related information there. Any thing I can help with – don’t hesitate to write.

Since the subject IS Federal Law in this country now and since many of the readers here might not be familiar with it, I’ll post a copy of the text of the regulations here too.

frats,

ole


1918. 85(j) Fall protection.

1918. 85(j)(1) Containers being handled by container gantry cranes.

1918. 85(j)(1)(i)

* After July 26, 1999, where a container gantry crane is being used to handle containers, the employer shall ensure that no employee is on top of a container. Exception: An employee may be on top of a container only to perform a necessary function that cannot be eliminated by the use of positive container securing devices. (footnote 6)

1918. 85(j)(1)(ii)

* After July 26, 1999, the employer shall ensure that positive container securing devices, such as semi-automatic twist locks and above deck cell guides, are used wherever container gantry cranes are used to hoist containers.

1918. 85(j)(1)(iii)

The employer shall ensure that each employee on top of a container is protected from fall hazards by a fall protection system meeting the requirements of paragraph (k) of this section.

1918. 85(J)(2)

* Containers being handled by other hoisting devices. Where containers are being handled by hoisting devices other than container gantry cranes, the employer shall ensure that each employee on top of a container is protected by a fall protection system meeting the requirements of paragraph (k) of this section.

1918. 85(J)(3)

Other exposure to fall hazards. The employer shall ensure that each employee exposed to a fall hazard is protected by a fall protection system meeting the requirements of paragraph (k) of this section. Exception: Where the employer can demonstrate that fall protection for an employee would be infeasible or create a greater hazard due to vessel design, container design, container storage, other cargo stowage, container handling equipment, lifting gear, or port conditions, the employer shall alert the affected employee about the fall hazard and instruct the employee in ways to minimize exposure to that hazard.


Footnote(6)

Examples of work that may not be eliminated by positive container securing devices and that may require employees to work on top of containers include, but are not limited to: installing or removing bridge clamps; hooking up or detaching over-height containers; or freeing a jammed semi-automatic twist lock.