Reader Mark Spohn asks the following question:
“Is there a directive from CAL/OSHA stating that delivery docks (for trucks) be secured with a safety chain (when not in use) across the opening (possibly at waist level) to prevent potential falls from personnel?
“I should clarify that I’m not a manager. I’m an hourly employee in a warehouse. My concern with this particular safety issue is valid. We have individuals here who continuously refuse to replace our safety chain which cordons off the edge of the loading/unloading dock (the drop is over three feet). I just thought this was a ‘pet peeve’ with my supervisor, but a co-worker informed me it was actually a CAL/OSHA infraction not to replace the chain when the dock is not being used.”
Patrick Bell, senior safety engineer for the Division of Occupational Safety and Health, gives the following answer:
“If the question is as simply stated, the answer is ‘No, a guardrail is not required at the open edge of a loading dock.’ See General Industry Safety Orders §3210(a) - exception No. 3 (copied below). This exception does not apply to open sides of mezzanine storage areas such as may be used for loading and unloading of industrial lift trucks.
“If you have a doorway that opens immediately onto an unguarded edge, as sometimes is the case, it is advisable to provide some kind of warning to alert workers to the hazard and prevent one from inadvertently walking off the edge. In these situations employers frequently use warning signs [Ref: GISO §3340(c)] and beacons to indicate the hazard when a door is open. This type of situation often occurs at roll-up doors in sides of buildings (weather enclosed docks) adjacent to private rail sidings.
Editor’s Note: Although Title 8 doesn’t require loading docks to be secured when not in use, there is nothing to prevent Mr. Spohn’s employer from going above and beyond Cal/OSHA regulations, which are minimum requirements. Bell points out, “The regulations are thresholds, not ceilings, and a well-devised safety program will take into account hazards unique to the industry in which it is intended to operate.”
Bell also points out that loading docks sometimes are used by workers as break areas, for smokers and warehouse workers “looking for a little sunshine and fresh air.” Therefore, it is important from a safety standpoint to limit dock activities to authorized personnel.
Bell adds, “In addition to the fall hazard at the open side of the dock when trucks are not present, workers and other persons may be needlessly exposed to the hazards of moving lift trucks on the dock, and moving trucks or railcars immediately adjacent to the dock. Workers on foot in loading dock areas are frequently victims of serious injuries and fatalities from falls, struck-by, and caught-between types of incidents.”
Subchapter 7. General Industry Safety OrdersGroup 1. General Physical Conditions and Structures OrdersArticle 2. Standard Specifications
§3210. Guardrails at Elevated Locations.
(a) Buildings. Guardrails shall be provided on all open sides of unenclosed elevated work locations, such as: roof openings, open and glazed sides of landings, balconies or porches, platforms, runways, ramps, or working levels more than 30 inches above the floor, ground, or other working areas of a building as defined in Section 3207 of the General Industry Safety Orders. Where overhead clearance prohibits installation of a 42-inch guardrail, a lower rail or rails shall be installed. The railing shall be provided with a toeboard where the platform, runway, or ramp is 6 feet or more above places where employees normally work or pass and the lack of a toeboard could create a hazard from falling tools, material, or equipment.
3. Portions of loading or storage platforms which are used primarily for loading or unloading railroad cars or trucks, or at waterside edges used for cargo handling.