Loading dock safety: Part 2

EDITOR’S NOTE: In January, Safety+Health published a “Workplace Solutions” column titled, “OSHA loading dock requirements: When is a guardrail required on a loading dock, and when will a visual barrier suffice?” (Read it at sh-m.ag/2QuAWQj.) It generated many follow-up questions from readers, so we brought back the column’s author – Maree Mulvoy, president of Copemish, MI-based M R Products Inc., home of Mr. Chain – to respond.

Question: Do you know if protection as stated by 1910.23 is required by these dock door openings of 48 inches in height or greater? Many people use a plastic chain barrier or rope, but according to the regulation, the protection should be something more rigid, such as a bar with a midrail that can withstand 200 pounds of force.

Maree Mulvoy: If your dock is higher than 48 inches, you need a barrier that meets OSHA fall protection standards. I don’t know of any chain that would meet those standards.

Question: If the dock door is closed, do I have to put the chain across the door?

Mulvoy: If the dock door is closed, that is an actual barrier, so you do not need the chain across the door until it is open. Because so many dock doors open and close many times a day, a simple chain with magnets is a quick and easy way to create a visual barrier.

Question: If a loading dock is in the middle of a lot, not adjacent to a building, is it required to be marked?

Mulvoy: I did research this and found no requirement for any floor markings around docks, whether they are attached to a building or not.

Question: Is there a recommendation or standard for the mounting height of a loading dock light to illuminate the trailer interior?

Mulvoy: OSHA just requires that illumination be safe and adequate, but I couldn’t find a regulation specifically addressing this question. However, the American National Standards Institute [standards] have been accepted by OSHA in other instances. See ANSI/IES-RP-7-1991 Standards.

Question: Are dock door seals an OSHA requirement?

Mulvoy: There is no OSHA requirement for dock door seals.

Question: Is this applied to new construction or modified docks doors vs. existing use docks?

Mulvoy: The OSHA requirements for visual barriers or fall protection on loading docks apply to all docks. There is no distinction between existing docks and new construction.

Question: Does the rule for the loading dock openings read “4 feet and higher” or “over 4 feet”? Our openings are 48 inches from the ground to the opening. Also, if we are allowed to use the bright-colored straps/chains, is there a required height that they should be hung?

Mulvoy: There actually is a conflict here. One ruling mentions 48 inches; another section says less than 4 feet. So, to be safe, we recommend the height of the platform be 48 inches or less. Over that height, OSHA requires fall protection, not just a visual barrier.

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