Keeping People Clear of Straddle Carriers, Reach Stackers and Terminal Tractors
This guide is for terminal operations and safety managers at container and multi-purpose terminals.
It sets out the controls in the order they work, the situations where they tend to break down, and
what the UK and US rules say, quoted directly. It is not legal advice.
Why are these machines different?
Most of the plant on a terminal is bigger and faster than anything on a typical warehouse floor, and
the people around it often have a good reason to be there.
Height and blind spots. A straddle carrier driver sits high above the stack and looks down
through a frame. A reach stacker with a container on the boom can block much of the forward view.
HSE lists the "use of vehicles with limited visibility, including straddle carriers and reach
stackers" among the typical transport hazards in docks (L148, para 56).
Speed and stopping distance. Heavy plant moving across an open yard takes longer to stop than
a person expects.
Mixed traffic. Terminal tractors, internal plant and visiting HGVs share the same lanes. HSE
notes that "Many different people drive in docks" and that "Not all of these drivers will be
familiar with the dock environment" (L148, para 55).
Work that moves. Stacks grow and shrink through a shift, so a clear sight line at the start
can be a blind corner by the end.
Every one of these machines has a blind spot. The plan is to make sure nobody needs to stand in it.
Which controls work, in order?
The hierarchy of controls applies well to a terminal. The first
controls change the yard; the later ones help people work safely inside it.
Keep people out of the operating areas. Make the stack, the straddle carrier grid and the
quay apron vehicle-only wherever possible. L148's Approved Code of Practice says vehicles and
pedestrians "should be separated where they share the same workspace", which "may involve
excluding pedestrians from certain areas or providing separate pedestrian routes" (para 69).
Separate the routes people do need. Walkways that don't cross cargo handling areas where
possible, and carefully designed ones where they must: walkways "should if possible be so laid
out that they do not cross cargo handling areas" (para 58). Marked crossing points: "Appropriate
crossing points should be provided where pedestrians and vehicles meet" (para 71). Add refuges at
transfer points, and fixed places where people board or leave plant.
Control the few who must go in. Where people "are required to enter a high-risk area (eg
cargo handling area for a particular task) then additional control measures (eg a safe system of
work) may be required" (para 70). In practice: a permit or call-in to enter, radio contact with the
plant drivers, an agreed signal to stop plant in that block, and escorts for visitors.
Make people and plant easier to see. Lighting that suits a 24-hour operation (L148 says each
part of the dock in use "should be suitably and adequately lit", para 233), speed limits set for
the layout, and high-visibility clothing.
PPE last. HSE's guidance in L148 is plain: "PPE must only be used as a last resort" (para
267). Hi-vis matters, but it doesn't make a person visible from a cab that can't see them.
Where do the controls tend to break down?
Lashing and quay work near plant. Lashers, checkers and engineers work close to moving plant by
the nature of the job. Agree how plant movements stop or slow when people are working in a block,
and who confirms it is clear before they restart.
HGV drivers leaving their cabs. L148 asks for haulage drivers to "remain in a safe area while
their vehicles are being loaded and unloaded" (para 72). On a straddle carrier grid, "no person
should remain in the cab of a haulage vehicle while it is on the grid" other than to drive on or
off, and people "should have safe access to and from all haulage vehicles on a straddle carrier grid
to a safe place" (para 67). Our guide to visiting HGV drivers in ports
covers this in detail.
Maintenance in the stack. Engineers attending a broken-down machine or a reefer are on foot in a
vehicle-only area. Treat each entry as a planned task: block isolated or plant stopped, and the
drivers told.
Nights and bad weather. Glare off wet surfaces, rain on windows and short days reduce what a
driver can see. Our piece on dark yards after the clocks change
covers the weeks when this catches people out.
What do the UK and US rules say?
UK. HSE's Safety in docks (L148) is the Approved Code of Practice for docks; the paragraphs
quoted above are from its workplace transport section. HSE's page on
workplace transport in ports and docks lists the
same typical hazards and points to the Workplace (Health, Safety and Welfare) Regulations 1992 and
PUWER 1998, and to Port Skills and Safety's guidance, including SIP001 on workplace transport.
US. At a marine terminal, 29 CFR Part 1917 applies:
§ 1917.44 (general rules for vehicles): "Vehicular routes, traffic rules, and parking areas
shall be established, identified, and used" (§ 1917.44(f)), and "The employer shall direct vehicle
drivers to warn employees in traffic lanes of the vehicle's approach" (§ 1917.44(g)).
§ 1917.71 (terminals handling intermodal containers or roll-on roll-off operations): "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)); and "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)).
§ 1917.43 (powered industrial trucks used for material or equipment handling within a marine
terminal): "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)), and "If the load obstructs the
forward view, the employer shall direct drivers to travel with the load trailing" (§ 1917.43(b)(9)).
Fixed cameras can't stop a machine, but they can show what happens across every shift, including the
ones nobody walks. RoboK SiteLens runs on a site's existing CCTV and records:
people close to moving vehicles;
people in vehicle routes and outside marked walkways;
entries to restricted or exclusion zones that you define, such as a lashing area;
high-visibility clothing;
vehicles over a set speed limit in an area.
Each event comes with the time, the zone and the clip, so a team can see where risk builds up and
whether a change held.
What it doesn't do: it doesn't warn drivers in the cab, and it doesn't detect crane lifts or
suspended loads. It only sees what the cameras see, so areas with no coverage, poor light or a
blocked view need other checks. To try it on one terminal area, see Safety Mapping:
a free two-week trial on one camera, ending in a written report and a review call. More on our work
with ports and terminals.
How do you keep people safe around straddle carriers?
Keep people out of the areas where straddle carriers work, make the grid and stack vehicle-only
where possible, and give the few people who must enter a controlled way in: a permit or call-in,
radio contact and an agreed way to stop plant. HSE's docks code (L148) says vehicles and pedestrians
should be separated where they share the same workspace, and that people entering a high-risk area
may need additional controls such as a safe system of work.
Can an HGV driver get out of the cab on a straddle carrier grid?
Under HSE's docks code (L148, para 67), no one should remain in the cab of a haulage vehicle on a
straddle carrier grid other than to drive on or off, and people should have safe access to and from
the vehicles to a safe place. Drivers should wait in a safe area while their vehicles are loaded or
unloaded (para 72).
What OSHA standard covers container terminals in the US?
29 CFR Part 1917, Marine Terminals. Section 1917.71 covers terminals handling intermodal containers
or roll-on roll-off operations, including marked or designated areas for employees passing to and
from active cargo transfer points, and high-visibility vests near container handling equipment. Section 1917.44 sets the general
rules for vehicles, and § 1917.43 covers powered industrial trucks.
Is hi-vis enough around reach stackers?
No. High-visibility clothing helps a driver who is looking, but it can't help a driver who can't see
that spot. HSE's guidance is that PPE is the last resort, after keeping people and vehicles apart
and controlling who enters operating areas.
References
Health and Safety Executive (2014). Safety in docks: Approved Code of Practice and guidance (L148), 1st edition, paragraphs 55–56, 58, 67, 69–72, 233 and 267. https://www.hse.gov.uk/pubns/books/l148.htm
The rules say where people should be around the plant. Two weeks on one camera over your busiest stack end shows where they actually are. Safety Mapping: a free two-week trial on one camera.