Recently, a client asked us if fall protection railings are required on a loading dock that is more than four feet high. Our answer may surprise you.
After a comprehensive review of several documents, including proposed OSHA rules and publications, we advised our client to install railings on loading docks that are six feet (1.8 meters) or higher. While we still recommend railings on loading docks that are shorter than six feet, the railing must be installed in such a way as not to impede workflow. Finally, personnel working on a loading dock must have adequate fall prevention training—and no one should be on the loading dock unless absolutely necessary. In other words, the loading dock is not an appropriate place to take a cigarette or coffee break.
Relevant OSHA Regulations
The OSHA General Duty Clause. Employers will furnish “a place of employment … free from recognized hazards that are causing or are likely to cause death or serious physical harm.” This is the duty of care required of all employers and is relied upon when an OSHA regulation lacks clarity or detail. It is also the reason we recommend that our clients consider installing chains or railings on any active loading dock.
OSHA 1910.178(m)(6) Powered Industrial Trucks. This regulation requires that “a safe distance shall be maintained from the edge of ramps or platforms while on any elevated dock.” However, it does not define that safe distance.
OSHA 1917.112 (b)(1), Marine Terminals, Guarding of Edges. “Guardrails shall be provided at locations ... which present a hazard of falling more than 4 feet or into the water.” However, it goes on to say, “Guardrails are not required at loading platforms and docks.”
Other Relevant Guidelines
OSHA Publication 3220-10N, 2004 Pocket Guide Worker Safety Series Warehousing. This publication comes closest to addressing the question directly: “areas that employees could fall 4 feet or more or walk off should be chained off, roped off or otherwise blocked.” However, the use of the term “should” indicates that this is a guideline, not a requirement.
OSHA Proposed Rulemaking on Walking and Working Surfaces: April 1990. Published but never fully adopted, this proposal was referenced in a December 1997 Standards Interpretation letter and states: “employers would not be required to install guardrail systems on the working side of platforms, such as loading docks, where the employer can demonstrate that the presence of guardrails would prevent the performance of work.”
OSHA Proposed Standard for Walking-Working Surfaces (May 2010). The proposed standard indicates that guarding is needed on loading docks for heights of 4 feet or more, unless people work an undefined distance away from the edge. But there is an exception. If guardrails are infeasible, work may be done without guardrails if the work is in process, only authorized employees have access, and authorized employees are trained.
ANSI Standard A12.1264.1 Safety Requirements for Workplace Floor, Wall Openings, Stairs + Railings. The American National Standards Institute states that loading docks are an exception for requiring fall protection.
THE BULLETIN: Fall Protection & Workplace Safety on Loading Docks. A one-page review of the rules, regulations and guidelines related to fall prevention and loading dock safety.