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OSHA loading dock requirements

When is a guardrail required on a loading dock, and when will a visual barrier suffice?

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Responding is Maree Mulvoy, president, M R Products Inc., home of Mr. Chain, Copemish, MI.

Answer: Loading docks can be dangerous. About 25 percent of all reported warehouse injuries occur on loading docks, and for each incident hundreds of near misses occur.1 Causes of dock injury include truck separation from the dock and falls from the dock – particularly when a forklift backs off the platform and falls on the operator. Because these incidents may result in serious injuries and fatalities, effective safety measures around loading docks are critical.

Some employers simply require dock doors to be closed at all times when a truck is not at the dock. But most factories aren’t climate-controlled, so open dock doors provide ventilation. And on a busy dock, it’s easier to see trucks arriving with the door open, and easier to use the dock without having to repeatedly open and close the door.

So, if the dock door is open, when is it necessary to install a guardrail or actual fall protection barrier, and when will a visual barrier suffice? The answer depends on the height of the platform. The current OSHA standard 26 CFR 1910.23(b) relating to Protection for Wall Openings and Holes states that every wall opening from which there is a drop of more than 4 feet shall be guarded by an actual fall protection barrier. It’s important to note that OSHA covers only federal baseline requirements; states may have their own, stricter requirements.

Semitrailers, flatbeds and straight trucks all have bed heights that closely align with 48-inch-high platforms, so loading dock platforms most commonly are 44 to 48 inches high. Refrigerated trucks are 50 to 60 inches in bed height, so they always will require a guardrail.

In addition, OSHA also issued an interpretation (55 FR 13407; April 10, 1990) that 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.” However, the interpretation refers to a proposed OSHA standard that has not been promulgated, so it’s safer to simply require any dock higher than 48 inches to have a fall protection barrier.

For the clear majority of docks, a visual barrier is sufficient. To be as safe as possible, the visual barrier needs to be prominent. The barrier should be a bright color. Yellow is preferred because it’s the international safety color indicating “warning.” To be productive around busy docks, the visual barrier should be able to be installed and removed as quickly as possible. Because most docks have metal trim around the doors, a strong magnet is a quick, easy way to install and remove a visual barrier.

Knowing the risks, as well as OSHA and state requirements, and maintaining a safe zone around loading docks is an important first step in preventing injuries and fatalities. Also important is convenient use of safety measures – especially on busy docks.

Reference
1. LoadDelivered, August 2017.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.

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