This guidance document is not a standard or regulation, and it creates no new legal obligations. It contains recommendations as well as descriptions of mandatory safety and health standards. The recommendations are advisory in nature, informational in content, and are intended to assist employers in providing a safe and healthful workplace. The Occupational Safety and Health Act requires employers to comply with safety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, the Act's General Duty Clause, Section 5(a)(1), requires employers to provide their workers with a workplace free from recognized hazards likely to cause death or serious physical harm.
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This OSHA guidance document will help improve traffic safety in marine terminals. Traffic incidents are a serious problem at marine terminals, where heavy equipment is used to load and unload ships and move freight from place to place in the terminal. The work is fast-paced, conducted at any time of the day or year, and often performed in inclement weather. Vehicular traffic endangers any worker walking in a marine terminal.
In addition to complying with OSHA standards for powered industrial trucks (PITs) (29 CFR 1910.178(l) and 1917.43 1 ), and vehicle operation in marine terminals (29 CFR 1917.44), OSHA recommends that marine terminal employers design and implement a traffic-safety program for vehicle and pedestrian safety. Vehicle and pedestrian safety includes providing safe equipment, establishing safe traffic controls in all areas of the terminal, and training workers to operate vehicles safely.
Traffic-safety controls can help individuals avoid traffic incidents and prevent or reduce work-related fatalities and injuries. Reducing traffic incidents can also increase the productivity of the marine terminal.
These guidelines are for use by marine-terminal operators and stevedoring firms and their workers. However, other employers and workers in the maritime or transportation industries involved in similar operations may find the information useful.
This publication provides a general overview of a particular standards-related topic. This publication does not alter or determine compliance responsibilities set forth in OSHA standards, and the Occupational Safety and Health Act of 1970. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission. OSHA requests, but does not require, source credit.
Traffic incidents are a serious problem in marine terminals, with their fast-paced operations and large, heavy equipment. This "Traffic Safety in Marine Terminals" guidance document provides practical recommendations to help marine terminal employers reduce the number and severity of traffic-related injuries in their workplaces.
Many work-related injuries and fatalities occurring in marine terminals result from traffic incidents. From 2005 through 2012 the Bureau of Labor Statistics reported 88 fatalities in the marine-cargo-handling industry; 52 of these fatalities were the result of transportation incidents. The following examples describe several marine-terminal traffic incidents that resulted in fatalities:
To help prevent these types of incidents and fatalities, OSHA recommends that employers design and implement a traffic-safety program for vehicle and pedestrian safety that raises awareness of traffic hazards. This program should address every worker at marine terminals who is at risk for traffic-related injuries and fatalities, including operators of vehicles and cargo-handling equipment, mechanics, repair crews, port-authority personnel, ship's crews, and over-the-road (OTR) truck drivers.
OSHA recommends that marine-terminal employers focus their traffic-safety programs on the vehicles and equipment that travel throughout marine terminals, including: container-handling equipment (e.g., forklifts, top picks, side picks, reach stackers, straddle carriers); forklifts used for non-containerized cargo; yard tractors, utility tractors, hustlers, "yard dogs," and semi-tractors; automobiles, vans, and pickup trucks that transport workers, equipment, and materials in marine terminals; and OTR trucks.
There are many factors that can contribute to traffic incidents in marine terminals. Often, these incidents result from a combination of factors. The following points illustrate common traffic-safety problems:
Condition of terminal driving surfaces: Many marine terminals, particularly larger ones, have paved terminal driving surfaces. Paved surfaces, which are smooth, are desirable because they reduce the potential for vehicle tip-overs, cargo and equipment shifting, and operator bouncing, and allow for improved road markings (e.g., lane markings). However, smooth driving surfaces also require heightened awareness because they can become slippery when wet and contribute to excessive vehicle speed. Employers must ensure proper maintenance of road surfaces because, over time, paving material can settle and result in uneven surfaces, potholes, and sinkholes that can lead to tip-overs or other vehicle incidents which could result in injuries or fatalities.
Weather: Inclement weather such as snow, ice, fog, and rain can create hazardous conditions (e.g., slippery surfaces and poor visibility) in marine terminals. Also, the sun may cause glare on certain types of driving surfaces and vehicle windshields.
Distracted driving: Distractions, such as talking on cell phones, texting, using other electronic devices, or completing paperwork can contribute to traffic incidents. Employers should prohibit the use of electronic and audio/video devices such as radios (other than used for communication purposes), cell phones, video games, and laptops while workers are operating equipment or vehicles. Employers should allow workers to use hands-free communication devices only if such use is work-related.
Improper parking: Improperly parked personal or company-provided vehicles and PITs can create hazards. Employers should not allow workers to park vehicles in areas where cargo is being worked or heavy machinery operated.
Lack of communication: Traffic-related incidents often occur because of poor communication. Technicians, mechanics, and other workers may fail to alert vehicle operators of their location, and employers may fail to notify workers of changes to traffic routes. In addition, noisy terminal environments can hinder effective communications. In some cases, employers may not adequately address the needs of workers with hearing impairment or who communicate in a foreign language.
Lack of training and awareness: Traffic-related incidents can occur when drivers and equipment operators do not have adequate training in the safe operation and maintenance of equipment and vehicles. Likewise, pedestrians walking in marine terminals are at risk of injury or death if they do not receive training on the potential for traffic incidents and how to avoid them.
Fatigue 2: Marine-terminal workers often work long and irregular hours, which can lead to fatigue and sleepiness. Fatigue and sleepiness can impair operator performance and contribute to traffic-related injuries and fatalities. The Network of Employers for Traffic Safety Workers (NETS) offers an online driver fatigue quiz. The quiz is available online at: http://trafficsafety.org/safety/risk/driver-fatigue-quiz.
Traffic-safety programs can reduce the risk of traffic incidents in marine terminals by eliminating or reducing potential hazards and increasing awareness of traffic-safety issues among marine-terminal workers. Employers should develop a traffic-safety program that includes the following elements: safe operation of vehicles, PIT training, traffic controls, parking, and safety awareness for pedestrians in the terminal. The following traffic-safety controls can help prevent or reduce traffic-related fatalities and injuries.
Safety checks: Employers should train workers to recognize and report transport vehicle and PIT damage and deficiencies to their supervisor. Employers shall ensure that workers check vehicles before use. If a transport vehicle or PIT is not working properly, the employer shall take it out of service until the needed repairs are made.
Powered industrial trucks: OSHA requires employers to maintain PITs used within marine terminals in safe working order. In addition, employers shall ensure that safety devices shall remain on the PITs and are operative (29 CFR 1917.43(c)(5)). Before lifting workers with a fork lift truck (i.e., PIT), employers also must secure a platform to the lifting carriage or forks, and meet additional specific requirements found in 29 CFR 1917.43(e)(6).
Transport vehicles: OSHA requires that employers maintain vehicles used to transport workers within marine terminals in safe working order, and ensure that safety devices remain on the vehicles and are operative (29 CFR 1917.44(n)).
At a minimum, PIT and transport-vehicle safety checks should include the following items as applicable:
Many companies, as well as OSHA, have sample daily checklists for PITs. OSHA's checklist is available at: https://www.osha.gov/dte/library/pit/daily_pit_checklist.html.
Vehicle selection and maintenance: Selecting safe vehicles and maintaining them in proper condition are critical components to effectively minimize traffic-related incidents in marine terminals. Employers should ensure proper maintenance and operation of vehicle-safety equipment such as horns, backup alarms, seatbelts, brakes, mirrors, and warning devices. Employers should ensure that vehicle operators follow the manufacturer's operating instructions. Employers must modify equipment only in accordance with the manufacturer's prior written approval, or with the written approval of a professional engineer experienced with the equipment who consulted with the manufacturer, if available (29 CFR 1917.43(b)(1)). Employers must maintain vehicles used to transport workers in safe working order and ensure that safety devices remain on the vehicles and are operative (29 CFR 1917.44(n)).
OSHA also requires that employers direct vehicle operators to comply with posted speed limits or signals, and written traffic instructions (29 CFR 1917.44(d)). Other traffic controls that employers can implement include:
Controlling speed: Speeding is an issue that employers should address within marine terminals. A variety of haulage, lifting, and transportation equipment are present within marine terminals. Each piece of equipment has its own operational characteristics and speed limitations. Employers must ensure that equipment and vehicle operators comply with posted speed limit signs as required in 29 CFR 1917.44(d). Employers should provide equipment and vehicle operators with the proper tools and equipment to control their speed. Employers should incorporate some or all of the following elements into their traffic-safety plan to prevent speeding in the marine terminal:
Employers should check devices, policies, and procedures frequently to ensure they are effective and suited to the terminal layout and operations. Enforcement of speed restrictions should be continuous and consistent. Employers must ensure that safety devices on PITs remain in place and are operational (29 CFR 1917.43(c)(5)).
Safe operation of vehicles: Employers must ensure that workers know and follow applicable OSHA vehicle requirements (e.g., 29 CFR 1917.43, 1917.44, and 1910.178(l)). Employers must ensure that only trained and authorized workers operate vehicles in marine terminals as required in 29 CFR 1917.27(a). They must also train workers on any vehicle operation procedures the terminal developed, including proper loading of vehicles and safe driving techniques (discussed below). For example, employers should ensure that workers know that vehicles must stop a safe distance apart to prevent striking or crushing workers between vehicles. OSHA's Marine Terminal standards require that a distance of at least 20 feet between the first two vehicles in a line (i.e., vessel loading/unloading, check-in, check-out); subsequent vehicles also must maintain a 20-foot distance if workers work behind the vehicle in front of them (29 CFR 1917.44(i)).
Safe driving techniques: Training in safe driving techniques should emphasize the need for operators to follow manufacturers' operating instructions, terminal traffic-control signs, and terminal driving procedures; use good judgment while operating vehicles; and remain alert to the presence of pedestrians and other operations in the area. Employers should observe operator performance on a random basis and set an example with their own driving. The following list provides examples of safe driving techniques that vehicle operators should recognize and adopt:
Designated fueling areas: Mobile fuel trucks used to refuel vehicles can create roadway obstacles and fire hazards. OSHA requires employers to fuel vehicles in designated, no-smoking areas located a safe distance from possible ignition sources (29 CFR 1917.156(a)(5); 1917.156(b)(1)(i); 1917.156(b)(5)(iii)).
Parking: Employers shall allow private vehicle parking only in designated areas in marine terminals (29 CFR 1917.44(b)). In addition, employers should ensure that workers:
Repair work and welding: Employers must separate arc-welding and cutting operations from other operations to protect workers in the vicinity of the arc's rays (arc flash) and sparks (29 CFR 1917.152(e)(8)(i)). In addition, employers should ensure that vehicle operators are not distracted while driving in the vicinity of welding operations. Employers should communicate with site personnel about the location of welding and repair operations so that workers do not enter the area unprotected. OSHA standards also require employers not to perform cargo-handling operations when noise-producing maintenance, construction, or repair work interferes with the communication of warnings or instructions (29 CFR 1917.20).3
Fatigue: Employers should learn about, and train workers about, the hazards of driving when fatigued or drowsy, and how to detect those conditions. Employers should also help workers learn how to deal with fatigue and how to know if they are too fatigued to operate a vehicle. The following are some useful resources on fatigue:
National Institute for Occupational Safety and Health
National Highway Transportation Safety Association (NHTSA)
Network of Employers for Traffic Safety (NETS)
National Sleep Foundation
Federal Motor Carrier Safety Administration
Substance abuse programs: To help create a safer work environment, employers should implement, and workers should support, measures that contribute to a drug- and alcohol-free work environment. In addition, employers should establish drug-free workplace programs for workers. A drug-free workplace program generally includes five components: a drug-free workplace policy, supervisor training, worker education, worker assistance and drug testing. More information on substance abuse programs is available on the OSHA home page at www.osha.gov (click on "substance abuse" in the alphabetized index).
Walking safely in marine terminals: Employers should inform pedestrians about traffic hazards and provide instructions and directions as how to protect themselves from injuries. Employers should point out the following safety recommendations to pedestrians in the marine terminal:
Working safely on the apron or highline: The following items apply when workers are on foot on the highline or apron (see Working Safely on the Apron or Highline during Marine Terminal Operations Quick Card)*:
Gangway safety meetings and toolbox talks: Frequent safety meetings (e.g., at the start of work shifts) help reinforce safety awareness and facilitate the communication that is critical for traffic safety in the terminal. Topics can include:
Commercial driver safety: Commercial drivers such as OTR drivers, messengers, and vendors account for much of the traffic in marine terminals. Commercial drivers may not be familiar with the terminal and its traffic patterns and rules, and marine-terminal employers may not supervise these drivers. Marine-terminal employers can help these drivers operate safely by providing them with information about terminal driving rules and traffic patterns, providing clear traffic lane designations and signs, establishing rules for when drivers and passengers can get into and out of their vehicles, and by reminding all drivers about driving hazards at the facility.
As mentioned, OSHA standards for PITs used for material handling or equipment handling at a marine terminal are at 29 CFR 1917.43 and 1910.178(l). These rules apply to every type of PIT used for material handling or equipment handling within a marine terminal (e.g., straddle carriers, hustlers, top loaders, and container reachstackers). The following are some of the provisions in 29 CFR 1917.43 that pertain to safe operation of PITs:
Paragraph (b)(1) of 29 CFR 1917.43 states, "[M]odifications...that might affect the vehicle's capacity or safety shall not be performed without either the manufacturer's prior written approval or the written approval of a professional engineer experienced with the equipment who has consulted with the manufacturer, if available," while paragraph (b)(2) of that section specifies:
"Unauthorized personnel shall not ride on PITs. A safe place to ride shall be provided when riding is authorized." Other provisions of 29 CFR 1917.43(b) and (c), notably 29 CFR 1917.43(b)(3)-(b)(10), (b)(12), (c)(1), and (c)(3)-(c)(5), respectively, specify that employers must ensure that:
29 CFR 1910.178(l) establishes training requirements for PIT operators,4 including those working at marine terminals. For example, if an operator received prior training in the topics listed below and an evaluation finds the operator to be competent to operate a PIT safely in the working conditions encountered, then the employer does not have to repeat initial training (see 29 CFR 1910.178(l)(5)). When initial training is necessary, it must cover the following PIT-related and work-related topics that are applicable to safe operation of the PIT:
Training must be a combination of formal instruction (e.g., lecture/discussion, interactive computer learning, videotape, written material), practical training (e.g., demonstrations performed by trainer, training exercises by trainee), and evaluation of the operator's performance in the workplace (see 29 CFR 1910.178(l)(2)(ii)).
Operators must also receive refresher training when they are observed to operate the vehicle in an unsafe manner, have a near-miss incident, receive an evaluation for unsafe operation, are assigned to operate a different type of PIT, or when changes in workplace conditions could affect safe PIT operation. In addition, the employer must evaluate every operator's performance at least once every three years (see 29 CFR 1910.178(l)(4).
OSHA entered into a settlement agreement concerning operator training for PITs used in marine terminals. OSHA Directive CPL 02-01-028 at www.osha.gov (click on the "Directives" link) addresses this agreement.
The following sources may be useful to those seeking further information about motor vehicle safety:
The National Highway Traffic Safety Administration (NHTSA) provides a number of resources on motor-vehicle safety, including a brochure to help employers establish a motor-vehicle safety program. http://www.nhtsa.dot.gov
nd work by preventing traffic crashes that occur both on-and off-the-job. The NETS Internet site includes resources and information on traffic safety. http://www.trafficsafety.org/index2.asp
The National Institute for Occupational Safety and Health (NIOSH) produces a number of fact sheets, hazard alerts, studies, and links to other Internet resources. http://www.cdc.gov/niosh/homepage.html
The National Safety Council offers a number of articles, studies, advice, and links to other Internet resources on its driver-safety Internet page. http://www.nsc.org
The National Sleep Foundation offers information to improve public health and safety by achieving an understanding of sleep and sleep disorders, and by supporting sleep-related education research, and advocacy. http://www.sleepfoundation.org
The Department of Transportation motor-carrier web page contains information on the Driver Fatigue and Alertness Study, a comprehensive over-the-road study on driver fatigue and alertness in North America. http://www.dot.gov/
The OSHA Consultation Program offers, at no cost, a confidential and comprehensive safety and health consultation service for employers. State agencies administer the Consultation Program, and the program is available in all 50 states, the District of Columbia, and U.S. territories. Using the expertise of highly qualified occupational safety and health professionals, the program offers employers a variety of services to help them establish and maintain a safe and healthful workplace. These services include: identification of workplace hazards, training and education, and assistance in the development and implementation of an effective safety and health management system. Small and medium-sized businesses in high-hazard industries or involved in hazardous operations receive scheduling priority for consultation visits. Consultants work in a non-enforcement capacity, and employers are not subject to enforcement penalties or citations upon proper abatement of workplace hazards. More information on the OSHA Consultation Program is available at http://www.osha.gov/consultation or by requesting the Consultation Kit (OSHA 3184) from OSHA's Publications Office at (202) 693-1888.
OSHA will make the information in this guidance document available to sensory-impaired individuals upon request. Voice phone: (202) 693-1999; teletypewriter (TTY) number: 1-877-889-5627.
For more information:
Occupational Safety and Health Administration
U.S. Department of Labor www.osha.gov or (800) 321-OSHA
2 Fatigue and sleepiness impair reaction time, judgment, and vision, cause problems with information processing and short term memory, and decrease performance, vigilance and motivation. Source: National Sleep Foundation http://www.sleepfoundation.org/article/white-papers/national-sleep-foundation-white-paper
3 Paragraph (e)(8)(i) of 29 CFR 1917.152 reads: "Arc welding and cutting operations shall be separated from other operations by shields, screens, or curtains to protect employees in the vicinity from the direct rays and sparks of the arc."
4 Under 29 CFR 1910.178(l)(3)(i)(M), PIT operator training programs must cover equipment manufacturers' instructions, warnings, or precautions ( including the use of seatbelts if applicable). Such programs may also address the hazards, if any, the training provider believes seat-belt use could cause in a particular work situation in the marine cargo-handling industry (OSHA Compliance Directive CPL 02-01-028).
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