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Access and Guarding of Work Surfaces » Access to Cargo Spaces and Confined Spaces


Confined space with small, inadequately guarded opening for access
Figure 1: Confined space with small, inadequately guarded opening for access.

Typical access into cargo spaces is provided by the ship's ladders. A ship's ladders may be continuous straight ladders reaching up to 90 feet and may be without climbing devices, platforms, or protective cages. Confined spaces often have only one small means of entry. Portable ladders may be used to gain access to these spaces. [29 CFR 1915.72]











Cargo Spaces
Figure 2: Improper practice - Ships ladder blocked by hoses and equipment
Figure 2: Improper practice - Ships ladder blocked by hoses and equipment.
  Figure 3: Improper practice - Worker on ladder that may shift or slip
Figure 3: Improper practice - Worker on ladder that may shift or slip.
  Figure 4: Improper practice - Fixed ladder extending out of an enclosed space with less than 4-inch clearance behind the ladder rung
Figure 4: Improper practice - Fixed ladder extending out of an enclosed space with less than 4-inch clearance behind the ladder rung.
Potential Hazards:
  • Ship's ladders are often damaged or slippery.
  • Ship's ladders are often blocked by cargo or materials.
  • Cargo or materials are being moved while workers are using the ladder.
  • Portables ladders may shift or slip.

Requirements and Example Solutions:

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Confined Spaces
Figure 5: Ventilation duct passing through access opening
Figure 5: Ventilation duct passing through access opening.

Figure 6: Access to confined space blocked by ventilation hoses. (Improper practice if only access.)
Figure 6: Access to confined space blocked by ventilation hoses. (Improper practice if only access.)
Potential Hazards:
  • Limited egress from the space may be blocked.
  • There may be only one means of egress from the space.

Requirements and Example Solutions:

  • More than one means of access must be provided to a confined space unless the structure of the vessel makes it impractical. [29 CFR 1915.76(b)(1)]
  • When the ventilation ducts must pass through the means of access, ducts must allow for free passage. [29 CFR 1915.76(b)(2)] See Figure 2.
    • Note: When there is only one means of access, collapsible ducts may be used to provide access.
  • If ventilation equipment blocks access to the space, airline respirators as well as a stand-by employee must be used. [29 CFR 1915.51(c)(3)]
  • Frequent checks must be conducted to ensure the safety of employees working alone in a confined space. [29 CFR 1915.94]
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