This OSHA guidance document is designed to help improve traffic
safety in marine terminals. Traffic accidents 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, is conducted at any
time of the day or year, and is often performed in bad weather.
Anyone walking in a marine terminal is also endangered by vehicular
traffic.
In addition to complying with OSHA standards for powered industrial
trucks (PITs) (29 CFR 1910.178(l) and 1917.43) 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
employees to operate vehicles safely.
Traffic safety controls can help individuals avoid traffic
accidents and prevent or reduce work-related fatalities and
injuries. Reducing traffic accidents can also increase the
productivity of the marine terminal.
These guidelines are intended for use by marine terminal operators
and stevedoring firms. However, other employers in the maritime
or transportation industries that have similar operations may
find the information useful.
Edwin G. Foulke, Jr.
Assistant Secretary of Labor for
Occupational Safety and Health
Traffic accidents 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 are caused by traffic accidents. The Bureau of Labor
Statistics reported 15 fatalities in the marine cargo handling
industry in 2005, and eight of those were the result of transportation
incidents. The following examples describe several marine terminal
traffic accidents that resulted in fatalities:
A clerk was struck and killed by a forklift as he exited a warehouse and walked around a large container. The forklift operator was transporting a load of paper rolls that obstructed his view.
A forklift struck two employees, killing one, when the operator was backing away from a flatbed trailer. The operator did not see the employees standing with their backs to the rear of the forklift. The survivor said that although he heard the forklift’s backup alarm, he did not heed it because he had been hearing those alarms all day.
A forklift operator was killed when he fell out of a tipping forklift and was crushed by the rollover bar. The operator, who was not wearing a seatbelt at the time of the accident, apparently made a sharp turn at excessive speed, causing the forklift to tip over.
A longshoreman was struck and killed by a forklift after handing paperwork to the operator. As the employee walked away from the forklift, the operator made a u-turn and struck the employee with the right front wheel of the forklift.
A straddle carrier operator was killed when the vehicle tipped over and crushed him. The operator, who was using the carrier to transfer containers, was traveling at a high rate of speed with a loaded container raised at or near the top position. When the carrier started crossing railroad tracks, which were located in the middle of a curve in the road, the vehicle rolled over.
A truck driver was killed when pipe being lifted from a truck fell off the forklift and hit him. Just prior to the accident, the truck driver had removed the safety straps from the load of 40-foot pipe and put them on the ground opposite the side where the forklift would be unloading the pipe. Once the forklift operator lifted the load off of the truck and backed away, the truck driver moved in to pick up the straps. The load shifted and a piece of pipe rolled off of the forklift and hit the driver.
To help prevent these types of accidents 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 everyone 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 authorities, 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);
There are many factors that can contribute to traffic accidents
in marine terminals. Oftentimes, accidents are caused by a
combination of factors. The following points illustrate common
traffic safety problems:
Unsafe equipment. Broken, improperly maintained, or missing safety equipment, such as lights, seat belts, brakes, and horns, can lead to accidents and injuries.
Inadequate traffic controls. Inadequate traffic controls (e.g., lack of proper signage, marking) may lead to accidents.
Condition of terminal driving surfaces. Many marine terminals, particularly larger ones, have paved terminal driving surfaces. Paved surfaces, which are smoother, are desirable because they reduce the potential for vehicle tipovers, cargo and equipment shifting, and operator bouncing and allow for improved road markings (e.g., lane markings). However, smoother driving surfaces also require heightened awareness because they can become slippery when wet and contribute to excessive vehicle speed. Road surfaces need to be maintained properly because, over time, paving material can settle and result in uneven surfaces, potholes and sinkholes that can lead to tipovers or other vehicle accidents.
Driving obstacles. Vessel equipment, stacked materials, containers, and repair crews are some of the driving obstacles that increase the risk of traffic accidents at marine terminals.
Weather. 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.
Inadequate illumination. Poor lighting, particularly at night, and shadows can make it difficult for drivers to see and avoid pedestrians, hazardous driving surfaces, and other obstacles.
Welding. Welding flashes can distract vehicle and crane operators.
Unsafe vehicle operation. Factors such as improperly loaded equipment, speed, and distractions (e.g., cell phones) can contribute to traffic accidents .
Improper parking. Hazards can be created by improper parking of personal or company-provided vehicles and PITs in areas where cargo is being worked on, or heavy machinery is being used.
Lack of communication. Accidents often occur because of poor communication. Technicians, mechanics, and other employees fail to alert vehicle operators of their location, and employers fail to notify employees of changes to traffic routes. In addition, noisy terminal environments can hinder effective communications. In some cases there may be inadequate accommodations for persons with hearing impairment or language barriers.
Lack of training and awareness. Accidents 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 if they do not receive training on the potential for traffic accidents and how to avoid them.
Shift changes. Marine terminal employers report that accidents often occur just before the end of a work shift or while employees are parking equipment at the end of the work shift.
Fatigue. Marine terminal employees often work long and irregular hours, which can lead to fatigue and sleepiness. Fatigue and sleepiness can impair operator performance and contribute to workplace accidents and fatalities.
Substance abuse. Substance abuse may contribute to vehicle accidents in marine terminals.
Traffic safety programs can reduce the risk of traffic accidents
in marine terminals by eliminating or reducing potential hazards
and increasing awareness of traffic safety issues for everyone
working in marine terminals. Employers should develop a traffic
safety program that includes the following: 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 accidents,
fatalities, and injuries.
Safety checks. OSHA requires vehicles used to transport employees within marine terminals to be maintained in safe working order and that safety devices shall not be removed or made inoperative (§1917.44(n)). To ensure that vehicles are in safe working order, employers should check vehicles daily. In addition, employers should train employees to recognize and report vehicle damage and deficiencies to their supervisor. If a vehicle is not working properly, it should be taken out of service until repaired.
At a minimum, daily PIT safety checks should include the following items:
Vehicle selection and maintenance. Selecting safe vehicles and maintaining them in proper condition are critical components to effectively minimize traffic accidents in marine terminals. Employers should ensure that vehicle safety equipment such as horns, backup alarms, seatbelts, brakes, mirrors, and warning devices are maintained in good repair and utilized properly by the operator. Employers should also ensure that vehicle operators follow the manufacturer’s design and operation parameters. Employers must also ensure that the equipment is not modified 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.
Traffic controls. Employers must install traffic controls and remind drivers to operate at safe speeds and protect pedestrians. OSHA requires the following traffic controls in marine terminals:
Stop signs shall be posted at main entrances and exits of structures where visibility is impaired;
Stop signs shall be posted at blind intersections, unless direct traffic control or warning mirror systems or other systems of equivalent safety are provided;
Vehicular routes, parking areas, and traffic rules shall be established, identified, and used; and
Signs indicating pedestrian traffic shall be clearly posted at vehicular check-in and check-out lines and similar locations where employees may be working (§1917.44).
OSHA also requires that employers direct vehicle operators to comply with posted traffic controls signs (e.g., posted speed limits) or signals, and written traffic instructions (§1917.44). Other traffic controls that employers can implement include:
Speed limit signs at appropriate locations;
Stop lines and lane markings on pavement;
Rumble strips/surface indentations at intersections and other critical areas to remind drivers of speed;
Utility vans parked to guard terminal mechanics working in a container yard, traffic cones to alert vehicle operators of the location of employees, and alerts to warn drivers about the work;
K-rails ( Jersey barriers) or other barriers used for directional traffic controls and to separate pedestrians from motor vehicle traffic;
Sign(s) and barriers to alert drivers of construction projects and other changes to traffic routes;
Traffic control information for OTR trucks entering terminals, including terminal maps and driving rules; and
Supervisors or traffic guards to direct traffic in the terminal at busy intersections and work areas.
Safe operation of vehicles. Employers must ensure that employees know and follow applicable OSHA vehicle requirements (e.g., §§1917.43, 1917.44 and 1910.178(l)). Employers must ensure that only trained and authorized employees are permitted to operate vehicles in marine terminals as required in §1917.27(a). They must also train employees on any vehicle operation procedures the terminal has developed, including proper loading of vehicles and safe driving techniques (discussed below). For example, employers should ensure that employees know that vehicles must be stopped a safe distance apart to prevent employees from being struck by or crushed between vehicles. OSHA’s Marine Terminal standards require that a distance of at least 20 feet be maintained between the first two vehicles in a line (i.e., vessel loading/unloading, check-in, check-out, roadability). Subsequent vehicles also must maintain a 20-foot distance if employees are required to work behind the vehicle in front of them (§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; utilize 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 are examples of safe driving techniques that vehicle operators should be trained to recognize:
Keep intersections clear;
Do not take shortcuts against the flow of traffic;
Be aware of activities in the terminal and possible changes of traffic routes;
Be aware of everyone walking and working in the area;
Avoid distractions such as cell phones, two-way radios, eating, or other non-driving activities while operating equipment;
Designated fueling areas. Mobile fuel trucks used to refuel vehicles can create roadway obstacles and fire hazards. OSHA requires that vehicles be fueled in designated, well marked, no-smoking areas located a safe distance from possible ignition sources.
Parking. Employers shall allow private vehicle parking only in designated areas in marine terminals (§1917.44(b)). In addition, employers should ensure that:
Vehicles are not parked in traffic lanes,
Vehicles are not parked in an equipment operator’s “blind spot,” and
Vehicles should not be parked in the path of cranes or other equipment,
Chassis are not parked where the chassis tongue will protrude into traffic lanes.
Repair work and welding. Welding flashes should be controlled so that the rays and sparks of the arc do not distract or blind vehicle operators driving in the vicinity². Employers should communicate with site personnel about the location of welding and repair operations so that employees do not enter the area unprotected . OSHA standards also require that cargo-handling operations are not performed when noise-producing maintenance, construction, or repair work interferes with the communication of warnings or instructions (§1917.20).
Fatigue. Employers should learn about the hazards of driving when fatigued or drowsy and how to detect those conditions. Employers should also help employees learn how to deal with fatigue and how to know if they are too fatigued to operate a vehicle. In addition, employers should learn about alternative methods to transport dangerously fatigued or drowsy employees home at the end of their shift. The following are some useful resources on fatigue and managing it.
Substance abuse programs. To help create a safer work environment, employers should implement and employees should support measures that contribute to a drug- and alcohol-free work environment. In addition, employers should establish drug-free workplace programs for employees. A drug-free workplace program generally includes five components: a drug-free workplace policy, supervisor training, employee education, employee assistance and drug testing. More information on substance abuse programs can be found on the OSHA home page at www.osha.gov (click on “substance abuse” in the alphabetized index).
Walking safely in marine terminals. The employer should inform anyone walking and/or working in marine terminals about traffic hazards and how to protect themselves from injury. Employers should point out the following to pedestrians in marine terminals:
The OSHA requirement that designated walkways must be provided and used. Marked or designated areas shall be set aside within a container or roll-on/roll-off terminal for passage of employees to and from active cargo transfer points, except where the employer provides transportation to and from these points (§1917.71(d)(1));
Pedestrians should be aware that drivers cannot see them when they are in a vehicle’s “blind spot.” Pedestrians should avoid these blind spots whenever possible. When approaching or walking near vehicles, it is essential that they make eye contact with the operator and be sure that the operator acknowledges them;
The OSHA requirement that each employee working in the immediate area of container handling equipment or in the terminal’s traffic lanes wear a high visibility vest (or equivalent protection) (§1917.71(e));
Pedestrians should make sure that their movements are predictable (not darting out suddenly from behind or between containers and not suddenly changing directions);
Avoid placing items on rolling or moving equipment. Loose items can fall off the equipment and strike someone; and
Be aware of the swing radius on forklifts and other similar vehicles. The rear wheels of forklifts enable these machines to turn sharply and quickly.
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:
Cargo operations;
Safe vehicle operation;
Activities that may affect traffic or change traffic routes in the terminal;
Oil transfers;
Ship’s stores transfers;
High-hazard cargo operations (e.g., explosives, radioactives); and
Location of repair crews, construction work and mechanics.
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 are oftentimes not supervised by marine terminal employers. 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 are allowed to get in 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 or equipment handling at a marine terminal are contained in §§1917.43 and 1910.178(l). The rules apply to every type of PIT used for material or equipment handling within a marine terminal (e.g., straddle carriers, hustlers, top loaders, and container reachstackers)³. The following are some of the provisions in §1917.43 that pertain to safe operation of PITs:
Modifications 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;
Unauthorized personnel shall not ride on PITs. A safe place to ride shall be provided when riding is authorized;
When a PIT is left unattended, load-engaging means shall be fully lowered; controls neutralized; and brakes set. Unless the PIT is in view and within 25 feet (7.62 m) of the operator, power shall be shut off. Wheels shall be blocked or curbed if the PIT is on an incline;
PITs shall not be operated inside damaged highway vehicles or railcars if the vehicle or railcar could affect operational safety;
PITs shall be marked with their rated capacities, which shall be visible to the operator;
Only stable and safely arranged loads that are within the rated capacity of the PIT shall be handled;
The employer shall direct PIT drivers to ascend and descend grades slowly;
The employer shall direct PIT drivers to slow down and sound the horn at cross-aisles and other locations where visibility is obstructed;
If the load obstructs the forward view, the employer shall direct PIT drivers to travel with the load trailing;
Steering knobs shall not be used unless the PIT is equipped with power steering;
When cargo is being towed on trucks or similar equipment, a safe means shall be provided to protect the PIT driver from sliding loads;
Only designated persons shall perform maintenance and repair;
Replacement parts whose function might affect operational safety shall be equivalent in strength and performance capability to the original parts they replace;
Braking systems or other mechanisms used for braking shall be in safe and operable condition; and
PITs shall be maintained in safe working order. Safety devices shall not be removed or made inoperative except as otherwise provided in §1917.43. PITs with a fuel system leak or any other safety defect shall be taken out of service until properly repaired.
Section 1910.178(l) establishes training requirements for
PIT operators, including those working at marine terminals.
The type of training required will be based on the type and
amount of the operator’s prior training; the operator’s
knowledge and demonstrated ability to operate PITs safely;
the types of PITs the operator will be using at the terminal;
and the conditions present in the workplace. For example, if
an operator has received prior training in the topics below
and been evaluated as competent to operate a PIT safely in
the working conditions to be encountered, then initial training
need not be repeated. Where initial training is necessary,
it must cover the following truck and work-related topics that
are applicable to safe operation of the PIT in the terminal:
PIT-related topics:
Operating instructions, warnings, precautions, and limitations, including those listed in the operator’s manual;
Differences between PITs and automobiles;
PIT controls and instrumentation;
Engine or motor operation;
Steering and maneuvering;
Visibility;
Fork and attachment operation and limitations;
Vehicle capacity and stability;
Vehicle inspection and maintenance the operator will perform; and
Refueling or recharging.
Work–related topics:
Surface conditions where the PIT will be operated;
Load composition, stability, manipulation, stacking, and unstacking;
Pedestrian traffic in areas where the PIT will be operated;
Narrow aisles and other restricted places where the PIT will be operated;
Hazardous (classified) conditions and closed environments where the PIT will be operated;
Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation; and
Ramps and other sloped surfaces that could affect the vehicle’s stability.
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.
Operators must also receive refresher training when they have
been observed operating the vehicle in an unsafe manner, been
involved in an accident or near-miss incident, received an
evaluation of unsafe operation, are assigned to operate a different
type of PIT, or when changes in workplace conditions could
affect safe operation. In addition, every operator’s
performance must be evaluated at least once every three years.
OSHA has entered into a settlement agreement concerning operator
training for PITs used in marine terminals. This agreement
is reflected in OSHA Directive CPL 02-02-128 at www.osha.gov (click
on the “Directives” link).
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/
The Network of Employers for Traffic Safety (NETS) is a public/private
partnership that engages employers of all sizes and industries
in seeking, developing, and expanding best practices in traffic
safety. The NETS Internet site includes a training center with
training materials 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/issues/drivsafe.htm
The National Sleep Foundation offers information to improve
public health and safety by achieving 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 (DFAS),
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. Consultation Program services are administered by
state agencies and are 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. Scheduling
priority for consultation visits are given to small and medium-sized
businesses in high-hazard industries or involved in hazardous
operations. 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 can be found
at http://www.osha.gov/consultation or
by requesting the Consultation Kit (OSHA 3184) from
OSHA’s Publications Office at (202) 693-1888.
This is one in a series of informational fact sheets highlighting OSHA programs, policies or
standards. It does not impose any new compliance requirements. For a comprehensive list of
compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal
Regulations. This information will be made available to sensory impaired individuals upon request.
The voice phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.
For more complete information:
Occupational
Safety and Health
Administration
U.S. Department of Labor www.osha.gov (800) 321-OSHA
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