Employees performing Ro-Ro operations during the night shift were exposed to the hazard of being struck by a container on a chassis.


Containers of various lengths are loaded onto a barge during a Ro-Ro operation.

Activity at time of incident:

An employee was working in a lane where vehicles were backing up.

Incident Description


Longshoremen are performing a Ro-Ro operation aboard a barge at night. The barge has three decks, with vehicle lanes divided by concrete rub rails. During a regular night shift, the crew consists of 19 drivers, about 30 longshoreman, three supervisors (one per deck), and one maintenance supervisor. Containers of varying sizes are loaded during the operation, ranging in length from 20 to 53 feet. Additionally, some of the trucks' tires blocked some of the lights that were placed along the side of the barge affecting the actual intensity of the illumination. The longshoreman on deck use their hands, whistle, hard hat and/or flashlights to notify the truck drivers of their position.


At the time of the incident, a longshoreman assisting with Ro-Ro operations was working in the lane on the third deck as a truck driver hauling a 53-foot-long container started backing up. At one point, while backing up, the driver noticed a hard hat on the ground, and believed it had been placed there by the hook-up man to indicate where the truck driver should stop. The driver continued to back up but stopped after feeling a bump. While backing up, the truck struck and killed the longshoreman working in the lane.

Relevant Factors:

The victim was not wearing a high visibility vest at the time of the incident. Although employees were provided with high visibility vests, they were not required to wear them. The lighting was so poor in the area where the victim was struck that the supervisor had to use a flashlight to identify the victim. Although employees were provided with strobe lights to put on their shirt sleeves, it did not solve the visibility problem at the terminal and its use was optional. The truck's back-up alarm was working but may not have been heard due to the noise generated by the Ro-Ro operations.

Truck drivers had not received initial or refresher training.

Applicable Standards and Control Measures

  • 29 CFR 1918.86(m): Roll-on roll-off (Ro-Ro) operations - Authorized personnel. "Only authorized persons shall be permitted on any deck while loading or discharging operations are being conducted. Such authorized persons shall be equipped with high visibility vests (or equivalent protection)."
  • 29 CFR 1918.86(n): Roll-on roll-off (Ro-Ro) operations - Vehicle stowage positioning. "Drivers shall not drive vehicles, either forward or backward, while any personnel are in positions where they could be struck."
  • 29 CFR 1918.92(a): Illumination - Walking, working, and climbing areas. "Walking, working, and climbing areas shall be illuminated. . . . illumination for cargo transfer operations shall be of a minimum light intensity of five foot-candles (54 lux). Where work tasks require more light to be performed safely, supplemental lighting shall be used."

This hazard could have been prevented if the employer had ensured that employees working on decks during Ro-Ro operations were clearly visible to the driver. The employer could have ensured this visibility by providing and requiring the use of high visibility vests with retro reflective material, strobe lights, or equivalent protection, and by requiring adequate illumination of the deck areas. Additionally, the employer should have ensured that there were clear communication signals between the truck driver and the employees on the deck, and that pedestrians remained out of the truck lanes at all times during Ro-Ro operations.

Other Relevant Standards and/or Control Measures

  • 29 CFR 1910.178(l)(4)(i): Powered Industrial Trucks - Refresher training and evaluation. "Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely."

Truck drivers should be trained in the operation of vehicles used in Ro-Ro operations to prevent unsafe practices.