Container Terminal and Shipyard Vehicle Safety Under OSHA (29 CFR 1917 and 1915)
Which OSHA rules apply where?
Marine terminals: 29 CFR Part 1917. Its scope covers "the loading, unloading, movement or
other handling of cargo, ship's stores or gear within the terminal or into or out of any land
carrier, holding or consolidation area" (§ 1917.1(a)).
Longshoring (work aboard vessels): 29 CFR Part 1918.
Shipyard employment: 29 CFR Part 1915.
Lift truck operator training: Part 1917 applies the general industry training rule,
§ 1910.178(l), to marine terminals (§ 1917.1(a)(2)(xiv)), and for shipyards § 1915.120 says its
requirements "are identical to those set forth at § 1910.178(l)". Our guide to OSHA's forklift
rule covers that training in detail.
The rest of this guide covers the parts of Part 1917 about vehicles and people on foot, then the
shipyard points.
Vehicle routes and traffic rules
Section 1917.44 sets the general rules for vehicles in a marine terminal. The core of it is short:
"Vehicular routes, traffic rules, and parking areas shall be established, identified, and used."
(§ 1917.44(f))
Three words carry the duty: established, identified, used. A traffic plan in a binder covers the
first; painted lanes and signs cover the second. The third is about what happens on the ground,
shift after shift.
The section also says:
"The employer shall direct motor vehicle operators to comply with any posted speed limits and
other traffic control signs or signals, and written traffic instructions." (§ 1917.44(d))
"Stop signs shall be posted at main entrances and exits of structures where visibility is
impaired, and at blind intersections, unless direct traffic control or warning mirror systems or
other systems of equivalent safety are provided." (§ 1917.44(e))
"The employer shall direct vehicle drivers to warn employees in traffic lanes of the vehicle's
approach." (§ 1917.44(g))
"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(h))
A distance of "not less than 20 feet (6.1 m)" between the first two vehicles in a check-in,
check-out, roadability, or vessel loading/discharging line (§ 1917.44(i)).
People on foot in a container or ro-ro terminal
Section 1917.71 covers terminals handling intermodal containers or roll-on roll-off operations.
Two paragraphs matter most for people on foot:
"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 transportation to and
from those points is provided by the employer." (§ 1917.71(d)(1))
"The employer shall direct employees to stay clear of the area beneath a suspended container."
(§ 1917.71(d)(2))
The first is about routes: lashers, checkers and other people on foot need a marked way to the
ship and the stack, or a ride. The second is about behavior: knowing where the suspended load is,
and staying out from under it.
High-visibility vests and hard hats
"Each employee working in the immediate area of container handling equipment or in the
terminal's traffic lanes shall wear a high visibility vest (or equivalent protection)."
(§ 1917.71(e))
A footnote adds: "Decals on hard hats will not be considered equivalent protection for the
purposes of this paragraph." The note to the paragraph explains that the material should make the
wearer visible by day (fluorescent) and at night in vehicle headlights (retro-reflective).
For head protection, § 1917.93(a) says: "The employer shall ensure that each affected employee
wears a protective helmet when working in areas where there is a potential for injury to the head
from falling objects." Section 1915.155(a)(1) uses the same words for shipyards.
Lift trucks at a terminal
Section 1917.43 covers powered industrial trucks in a marine terminal. Among its rules:
"The employer shall direct drivers to slow down and sound the horn at crossaisles and other
locations where visibility is obstructed." (§ 1917.43(b)(8))
"If the load obstructs the forward view, the employer shall direct drivers to travel with the
load trailing." (§ 1917.43(b)(9))
"Unauthorized personnel shall not ride on powered industrial trucks." (§ 1917.43(b)(2))
Shipyards
Shipyards have transporters, lift trucks and cranes moving around people on foot, and the same
practical questions apply as at a terminal: are routes marked, are people kept apart from moving equipment, is PPE worn where
it is required, and does anyone know where the near misses happen? Operator training follows
§ 1910.178(l) through § 1915.120, and head protection is § 1915.155.
Showing the rules hold on every shift
Most terminals have the rules written down. The hard part is knowing whether they are followed at
3 a.m., during a vessel change, or when the yard is full.
Ways to find out:
Walks and audits at different times, including nights and weekends. Good for culture,
limited by how much of the yard one person can see.
Near-miss reporting. Valuable, but many near misses are never written down.
Camera review. Many terminals already have cameras over the lanes and the quay. Watching them
for safety by hand is rarely practical.
Where RoboK SiteLens fits
RoboK SiteLens is AI safety monitoring that runs on the cameras a site already has. At a terminal
or shipyard it records:
people close to moving yard tractors, reach stackers, straddle carriers and lift trucks;
people in vehicle lanes and outside marked walkways;
entries to restricted zones you define, for example around crane working areas or the quay edge;
high-visibility vests and hard hats where the site requires them.
Speed monitoring is also available.
Each event comes with the time, the zone and the clip, and reports show where and when risk builds
up. It does not detect crane lifts or suspended loads, and it does not warn drivers in the cab.
It is a record for your safety program, not a substitute for it. RoboK SiteLens is available in the
US, with remote or on-site setup and support in US hours. The free trial,
Safety Mapping, runs on one of your own cameras for two weeks and ends with a
written report.
29 CFR Part 1917, Marine Terminals. Section 1917.71 covers terminals handling intermodal containers
or roll-on roll-off operations, and § 1917.44 sets general rules for vehicles in marine terminals.
Does OSHA require high-visibility vests at container terminals?
Yes, for employees "working in the immediate area of container handling equipment or in the
terminal's traffic lanes" (§ 1917.71(e)). Decals on hard hats do not count as equivalent
protection.
Does OSHA require marked walkways in a container terminal?
Section 1917.71(d)(1) requires marked or designated areas for employees to pass to and from active
cargo transfer points, unless the employer provides transportation to and from those points.
Which OSHA standard covers forklift training at a terminal or shipyard?
29 CFR 1910.178(l). Part 1917 applies it to marine terminals (§ 1917.1(a)(2)(xiv)), and § 1915.120
applies the same requirements to shipyard employment.
Is OSHA 1918 the same as 1917?
No. Part 1917 covers marine terminals (shore-side work). Part 1918 covers longshoring, which is
work aboard vessels.
The rules say where people and vehicles should be. Two weeks on one of your own cameras shows where they actually are. Safety Mapping: a free two-week trial on one camera.