Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

September 2, 1993

Mr. Michael T. Bohlman Director,
Marine Services Sea-Land Service, Inc.
P.O. Box 2000
Elizabeth, New Jersey 07207

Dear Mr. Bohlman:

The following information is provided in response to your letter of August 3, 1993 to Mr. Joseph Nolan of this office regarding the lifting of two empty containers that are vertically coupled by twist locks. We have reviewed the proposed operation and determined that it would comply with OSHA Regulations as long as you comply with the following provisions:

1. The containers must be inspected for visible defects prior to hoisting and damaged containers shall not be hoisted in tandem. Ref.-29 CFR 1918.85(d).

2. You must ensure that both containers are empty. Ref.-29 CFR 1918.85(b)(1).

3. The weight of the containers when empty shall be permanently marked on the containers. Ref.-29 CFR 1918.85(a)(1).

4. The twist locks must all operate in the same manner (be uniform) and they must have a positive, verifiable locking system.

5. The load shall not exceed the capacity of the crane. Ref.-29 CFR 1918.85(c).

6. The top container must be hoisted by the top fittings and the lifting forces shall be applied vertically from at least (4) such fittings. Ref.-29 CFR 1917.71(f)(1)(i).

7. You must have available for inspection documentation from the manufacturer which verifies the capacities of the twist locks and corner castings.

8. You must direct employees to stay clear of the area beneath the suspended containers. Ref.-29 CFR 1917.71(d)(2).

Please do not hesitate to call us at (202) 219-8131 or write to us at the following address if you have any questions or require further assistance:

        Joseph Nolan, Chief
        Division of Maritime Compliance Assistance
        U.S. Department of Labor - OSHA
        Room N3610 
        200 Constitution Avenue, N.W.
        Washington, D.C.  20210

We appreciate your continued interest in safety and health matters.


Roy F. Gurnham, Esq., P.E. Director
Office of Construction and Maritime
Compliance Assistance